ML20094A853
| ML20094A853 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/24/1984 |
| From: | Twana Ellis HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20094A854 | List: |
| References | |
| CON-#484-980 OL, NUDOCS 8411060580 | |
| Download: ML20094A853 (4) | |
Text
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October 24, 1984 REUJ:0 ;;,,,3,y; i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIgI93T 26 A10:01-Before the Atomic Safety and Licensina Board In'the Matter of
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LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322(OL)
)
(Shoreham Nuclear Power Station,)
Unit 1)
)
LILCO'S MOTION TO ADMIT SUPPLEMENTAL TESTIMONY OF DUANE P. JOHNSON AND LEE A.
LIGHTING COMPANY REGARDING AE PISTON SKIRTS AT S Long Island Lighting Company (LILCO), for good cause, j
moves the. Board for leave to file the attached Supplemental l
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Testimony of Donald O. Johnson, Duane P. Johnson and Lee A.
Swanger.
In support of such motion, LILCO states the following:
(1)
The attached testimony is relevant and material to the apparent conflict in the evidence (e.g.,
Tr. at 22299-302, 22312-318, 23781-811) presented in this proceeding on the subject of the polishing or non-polishing of the stud boss area in the AE piston skirts operated in the R-S prototype engine.
This issue was raised for the first time during cross-examination of LILCO's panel on the Shoreham AE pisto ns.
(2)
The attached testimony is necessary to clarify the record regarding interpretations by previous LILCO aitnesses of language in a memorandum dated February 3, 1984 in LILCO's Exhibit P-29.
Certain LILCO witnesses gave testimony on the 8411060580 841024 PDR ADOCK 05000322 O
PDR Sh 3
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assumption that the memorandum could be construed to mean th t a
the highly stressed area of the stud boss region on the R-5 pistons was polished.
Subsequently, Dr. David Harris testified and informed the Board and the parties that he Dr. Duane Johnson and Donald Johnson had recently inspected th e R-5 piston skirts and confirmed that there was no polishing of th highly stressed regions of the R-5 bosses and that th e
e February 3 memorandum had been misconstrued in this regard(Tr.
23,781-806)
Given the prior testimony concerning the memorandum, the Board indicated that the appropriate way to clarify the re, cord would be for LILCO to produce witnesse s with first hand knowledge.
(Tr. 23,810-811)
Through the attached.
testimony, LILCO produces the author of the February 3
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memorandum, Mr. Donald Johnson, to furnish first-hand evidence as to its meaning.
LILCO also produces Drs. Johnson and Swanger to clarify their earlier testimony in li ht g
of their recent inspections of the R-5 pistons and in light of a correct interpretation of the memorandum.
j (3) The attached testimony is not cumulative of evidence previously submitted and is necessary to mak e the record fully and accurately reflect the facts.
(4)
- Moreover, the attached testimony will not delay this proceeding or prejudice the other parties.
The parties cannot claim surprise by this testimony because they w ere O
i informed of its substance th rough Dr. Harris' testimony o October 1, 1984.
to review the testimony b fin addition, the parties will n
have ample time Counsel for Suffolk Counte ore 4.t is presented b'efo Board.
e the y
testimony, if presented y has advis-d LILCO that thi prior to the cross-examinatishould be offered and cross s
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-examined no objection to this.on of the County's piston p LILCO has
- anel, WHEREFORE, admit the Supplemental TestiLILCO respectfully reques s that the Board Johnson And Lee A. Swan mony Of Donald O.
Johnson, Duane P.
Company Regarding AE Pistger On Behalf of Long Island L i
ighting on Skirts At Shoreham Respectfully submitted LONG ISLAND LIGHTING COMPA By
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j, y E. Milton Earley, 2
HUNTON & WILLIAMS III Post Office Box 19230 Washington, D.C.
20036 T. S. Ellis, yy7 Darla B. Tarlet-HUNTON & wyttyggg Post Office Box 1535
- chm o nd,
Virginia 23212
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Odes L. Stroupe, Jr.
David Dreifus HUNTON & WILLIAMS Post Office Box 109 Raleigh, North Carolina 27602 DATED:
October 24, 1984 w
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