ML20100C152

Reply to Joint Proposed Findings of Fact Proposed by Suffolk County & State of Ny Re Compliance W/Rules of Classification Societies.Certificate of Svc Encl

ML20100C152
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	12/03/1984
From:	Dreifus D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
References
CON-#484-541 OL, NUDOCS 8412050323
Download: ML20100C152 (62)

Text

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UNITED STATES OF AMERICA M' q i .' ',5C. -

NUCLEAR REGULATORY COMMISSION u ' , c';l Betfore the Atomic Safety and Licensind Board ..ss, In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL

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(Shoreham Nuclear Power Station )

Unit 1) )

LILCO'S REPLY TO SUFFOLK COUNTY AND STATE OF NEW YORK PROPOSED FINDINGS OF FACT HUNTON & WILLIAMS P. O. Box 109 Raleigh, North Carol'ina 27602 8412050323 841203 gDRAEOCK 05000322 PDR I

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TABLE OF CONTENTS I. INTRODUCTION....................................... 1 II. DISCUSSION......................................... 2 A. Compliance wit the Rules of Classification Societies................................... 2

1. Relevance of Classification Societies' Rules.................................... 2

2. Compliance with the Rules of Classification Societies................................ 4 (a) Lloyd's............................. 4 (b) IACS................................ 9 (c) ABS Rules on Torsional Vibration... 12 (d) ABS web Dimensions................. 16 (e) The Crankshafts are Adequate under the Kritzer-Stahl Criteria............. 17 B. DEMA....................................... 20 1.- DEMA is an Appropriate Standard......... 20

2. The Crankshafts Comply with DEMA........ 27 C. FaAA's Fatigue Analysis.................... 33 D. Shot Peening............................... 38 1

I. INTRODUCTION

1. These reply findings address the findings proposed by Suffolk County and New York State (Joint Proposed Findings).

For convenience, this reply follows the format of the Joint Proposed Findings.1/ LILCO does not propose that the Board adopt these reply findings. Rather, the reply findings demon-strate-that the findings proposed by the Intervenors should be rejected. A surprising number of the findings are wholly unsupported by citations to the evidentiary record. (Sgg, e.a., Joint Proposed Findings 18, 28, 29, 34, 39, 42, 46, 50, 51, 55, 77, 86, 96, and 104-106). Others misrepresent or omit pertinent testimony. The Joint Proposed Findings also largely ignore the cross-examination of witnesses for the County and the Staff and the direct testimony of LILCO's witnesses.

2. Joint Proposed Findings 1-17 are not proposed find-ings of fact but rather are summary conclusions in the form of a proposed decision and are not supported by citations to the record. LILCO disagrees with the conclusions in Section I of 1/ LILCO disagrees with some of the findings proposed by the NRC Staff, although LILCO agrees with many of the Staff's Pro-posed Findings. To avoid repetition, LILCO does not separately discuss the Staff Proposed Findings with which it disagrees, except in certain isolated instances.

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-s l the Joint-Proposed Findings. However, because this Section

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merely contains unsupported conclusions, LILCO will not specif-ically address each paragraph of Section I of the Joint Pro-posed Findings.

4-II. DISCUSSION i-i A. Compliance with the Rules of classification Societies

1. Relevance of Classification Societies' Rules

3. Joint Proposed Findings 19-27 argue that the ruler

.of various marine classification societies (Lloyd's, ABS and IACS) are relevant in determining whether the replacement crankshafts in the Shoreham EDGs are adequate. These proposed i

findings are argumentative and conclusory and are often unsupported by any citation to the transcript. In addition, i

( they ignore the fact that current Nuclear Regulatory Guides

provide that standby emergency diesel generators need only com-ply with DEMA. (LILCO Proposed Finding 9; Staff Proposed Find-ing 17).

4. Joint Proposed Finding 23 concludes that if a crankshaft in a diesel generator at a nuclear plant does not 4

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comply with the rules of the classification societies, the crankshaft does not satisfy NRC regulations. There is no tran-script citation for this conclusion nor is there any indication which NRC regulations the Intervenors claim the crankshafts fail to meet.

5. Joint Proposed Findings 24-27 discuss the alleged similarities between marine diesels and diesels in nuclear standby service. These proposed findings are misleading for several reasons. First, the findings ignore testimony by LILCO and the Staff that operating conditions for marine diesels are more severe than operating conditions for nuclear standby die-sels. (LILCO Proposed Finding 15). Second, even if marine diesel generators (as opposed to main propulsion diesel en '

gines) are not subjected to more severe operating conditions than land based diesels, the rules of the classification soci-eties for designing crankshafts make no distinction between main propulsion diesel engines and diesel engines used for electrical generation. (Joint Proposed Finding 27). While the service seen by a marine diesel generator may be similar to the service seen by a land based diesel, marine diesel genera-l tors are designed to the same standards au main propulsion die-l sel engines. The County's witnesses concede that main propul-sion engines are subject to more severe stresses than land L

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based diesels. (Joint Proposed Finding 26, Tr. 23,984-85 Eley). It is clear that the design standards of the classifi-cation societies are intended to apply to engines subject to more severe operating conditions than the Shoreham EDGs.

It is not appropriate to evaluate a land based diesel according to these standards. The fact that marine generators may be sub-ject to similar operating conditions as land based diesels is irrelevant.

2. Compliance with the Rules of Classification Societies (a) Lloyd's

6. Joint Proposed Findings 29-33 discuss the County's horsepower calculations under Lloyd's rules. These proposed findings completely ignore the extensive cross-examination of the county's witnesses. Proposed Finding 29, which is unsupported by any transcript citation, states that LILCO did not contest the accuracy or validity of the County's Lloyd's calculations. Contrary to this assertion, LILCO extensively cross-examined the County concerning the Lloyd's calculations.

(Tr. 23,976-24,056). Furthermore, there is no requirement in Lloyd's for an overload calculation. (Lilco Reply Finding 10).

7. Little if any weight should be given to the Coun-ty's Lloyd's calculations. Professor Christensen described the f

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Lloyd's horsepower calculations as a~very, very simple " chug and' plug' formula.- (Tr. 24,011 Christensen). This type of formula is commonly used in the initial' design of a crankshaft.

(Id.) It is not appropriate to conclude, however, that an ex-isting crankshaft is_ inadequate because it does not comply with this simple horsepower formula. As Dr. Pischinger noted, de-sign formulas (such as-Lloyd's), which do r.ot require any thought during the design process, have been criticized for not being in complete accord with physical laws. (Tr. 22,789

-Pischinger).

8. Notwithstanding that the County's witnesses de-scribed the Lloyd's formula as very simple, they were unable to state whether.their calculated horsepower rating at full load was approximately 5% less than the actual horsepower-of the EDGs. (Tr. 23,977-79 Christensen). They were also unable to state what effect an increase of 25% in the Zed factor in the calculation would have on the allowable horsepower. (Tr.

24,040-49 Christensen, Eley).

9. In. addition, when asked if the allowable horsepower at 3300 kW could be obtained by ratioing the calculation that was made at 3500 kW, Professor Christensen stated that the

" chug and plug" horsepower formula was " complicated." He was unable'to say whether the a).lowable horsepower at 3300 kW could i

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be obtained by ratioing without " spending a lotfof time thinking about it." (Tr. 24,054-56 Christensen,.Eley).

10. Joint Proposed Finding 31 discusses the. County's horsepower calculation at 3900 kW. There is no requirement in Lloyd's for an overload calculation. (Tr.-24,005-06 Chris-tensen, Eley). According to the County's calculations, the re-

-placement crankshafts.would have to be capable of operation at 1

4290 kW in order to-meet Lloyd's requirements. (Tr. 24,016-20 Christensen, Eley).

11. Joint Proposed Finding 31 also incorrectly states that the acutal measured peak firing pressure in the "DGs is 1720 psi at full load. This representation is misleading be-l cause 1720 psi is the single highest peak firing pressure ever measured in any cylinder on the Shoreham EDGs at full load.

(Tr. 22,081 Pischinger). It was measured from one cylinder at one point in time and is by no means a representative number.

l The peak value for one individual cycle is not the important.

value in performing a fatigue analysis. The significant value is the peak firing pressure that is representative of the mil-lions of fatigue cycles to be experienced by the engine, or in l other words, the average peak for a large number of cycles.

! (Tr. 22,075; 22,081-82 McCarthy). The significant value is neither the highest nor the lowest pressure measured at any one l

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time and, therefore, is certainly not the 1720 psi represented by the Intervenors.

, 12. In addition to the fact that the 1720 psi is the highest peak firing pressure ever recorded on the Shoreham 1 EDGs, this measurement was recorded by a Kiene guage, which, in l and of itself, is designed to record "the maximum of the maxi-mum values of different cycles." (Tr. 22,562-63 Pischinger).  ;

The Kiene guage overemphasizes the higher peak firing prescures and is not as accurate as other measurement devices that re-flect a more representative peak firing pressure. (Tr.

22,113-15, 22,562-63 Pischinger).

13. A more accurate measurement of the average or rep-resentative peak firing presure can be obtained from a quartz Piezo electric transducer. (Tr. 22,113 Pischinger). FaAA mea-sured the peak firing pressures from cylinder number seven in the Shoreham EDG 103 with a Piezo electric transducer. The In-tervenors totally fail to give these measurements the proper f credit. The measurements using the quartz Piezo electric tranducer gave the whole pressure trace (Tr. 22,113-15 '

l Pischinger), reporting pressures from 800 individual cycles of the engine as opposed to just the maximum pressure of 1720 psi from one cycle measured by the Kiene guage. (Tr. 22,537 i

l Swanger). The highest peak firing pressure obtained from the

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e measurements (adjusted for the turbocharger boost) for 250 sec-onds using the more accurate quartz Piezo electric transducer at 100% load was 1668 psi, and the average value was 1604 psi.

(Tr. 22,461-62; 22,534-35 McCarthy). The Piezo tranducer mea-surements are more accurate than the Kiene guage measurements and nothing in the record contradicts this. The County at-tempted to discredit the accuracy of the Piezo electric tranducer measurements, but the entire record, and rot just the portions extracted by the Intervenors, does not support their attempt

14. In sum, little weight should be given to the Coun-ty's Lloyd's calculations. These formulas are intended to be used as initial design guidelines. The fact that the crank-shafts may not comply with these formulas does not mean the crankshafts are inadequate. The horsepower calculations were developed at a time when engineers did not know how to calcu-late torsional stresses. (Tr. 24,203-04 Christensen).

Cross-examination established that the County's witnesses did not fully understand even the simple Lloyd's horsepower calcu-lations, one of the few they actually performed.

15. An additional reason cited by the County for their belief that compliance with Lloyd's is important is the fact that Lloyd's has a staff of experienced surveyors who inspect

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. . i and evaluate engines after they have been in operation. The purpose of these. inspections is to ensure continued safe op-eration. As an example of the type of-inspections Lloyd's sur-veyors are capable of performing, the County's witnesses cited the testing of bottom-end bolts. The testing procedure is to remove the bolts, hang them on a piece of string, give them a blow with a hammer and'see if they ring. If the ring is doubt-ful, the bolt-may be~ tested further. There is, however, no specific rule covering bolt ringing in Lloyd's. (Tr. 24,215-17 Christensen, Eley). Obviously, this type of testing procedure could provide no assurance of the adequacy of any component in the Shoreham EDGs and provides no support for the County's con-tention..

(b) IACS

16. Joint Propcsed Findings 34-38 discuss the crank-shafts' alleged non-compliance with the CIMAC rules. These

' findings should not be adopted because the. record damonstrates that the County's witnesses had little or no understanding of the CIMAC rules and their testimony should be entitled to lit-tle weight.

17. Joint Proposed Finding 35 correctly states at footnote 10 that the CIMAC rules are based on the conservative

! . assumption that the maximum bending and torsional stresses I

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occur simultaneously and at the same location. However, when asked if this is what the CIMAC rules said, Professor-Chris-tensen said iso. When he was shown a copy of the CIMAC rules (County Exhibit 38), he said the translation was poor. (Tr.

24,106-07 Christensen). Furthermore, Professor Christensen did not know "without thinking about it" whether the actual maximum bending and torsional stresses in the Shoreham crankshafts oc-cured simultaneously and at the same location. (Tr. 24,109 Christensen). The uncontradicted evidence showed that the max-imum bending and torsional stresses do not occur simultaneously or at tiae same location. (LILCO Proposed Finding 63).

18. Joint Proposed Finding 36 states that the County reviewed TDI's CIMAC calculations and determined that the re-placement crankshafts do not comply with the CIMAC rules. This statement is misleading. Cross-examination of the County's witnesses established that they did little more than check TDI's math. (Tr. 24,138-39 Eley). One of the important inputs to a CIMAC calculation is torsional stress. The County's wit-nesses made no attempt to check the accuracy of TDI's torsional calculation. (Tr. 24,137-39 Christensen, Eley). Indeed, Mr.

Eley freely admitted that he was incapable of calculating tor-sional vibratory stresses. (Tr. 23,968 Eley). Professor

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Christensen claimed to be capable of performing forced i - er --w r g- -

torsional vibratory calculations, but admitted he had not per-formed such calculations for this case. (Tr. 23,965-66 Chris-tensen). When questioned further, Professor Christensen re-vealed that he did not know how to sum orders or how to calculate the phase relationship between two orders. Indeed, all Professor Christensen knew how to do was a Holzer tabu-lation. (Tr. 23,965-70 Christensen). The opinion of these witnesses concerning the accuracy of TDI's CIMAC calculation should be given no weight.

19. Joint Proposed Finding 36 also states that the firing pressure of 1720 psi should have been used in the CIMAC calculation, rather than the 1650 psi used by TDI. There is no basis for th1s statement. For purposes of calculating tor-sional stress, a representative rather than a maximum peak fir-ing pressure is desired. (LILCO Proposed Finding 57). 1720 psi is not a representative peak firing pressure. (LILCO Reply Findings 11-13). The TDI test logs, which are part of County Exhibit 46, show average peak firing pressures at full load no higher than 1647 psi. The figure of 1650 psi used by TDI was a conservative average.

20. Joint Proposed Findings 37 and 38 discuss an ABS calculation that shows compliance with the CIMAC rules. The Intervenors assert this calculation is insufficient evidence to

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support LILCO Proposed Finding 11. The Intervenors' assertion in this regard is entitled to no weight. First, the calcula-tion in question was part of an exhibit offered into evidence l by the County. (County Exhibit 43 at 29). Second, the fact l that the County's witnesses had not previously reviewed the calculation does not support Joint Proposed Finding 38. In-stead, this fact supports a finding that the County's witnesses were ill-prepared, unfamiliar with even their own exhibits and generally uninformed about the areas in which they were offered as expert witnesses.

(c) ABS Rules on Torsional Vibration

21. Joint Proposed Findings 39-50 urge the Board to find that the crankshafts do not comply with the ABS rules on torsional vibration. The Intervenors essentially ask the Board to overrule ABS's approval of the crankshaft and to determine that-ABS is incapable of performing its own job. The fact re-mains, however, that ABS approved the torsional critical speed arrangement of the crankshafts (LILCO Exhibit C-13) and, de-

spite an invitation by counsel for Suffolk County to reconsider

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(County Exhibit 46), ABS has not withdrawn its approval of the.

crankshafts. ABS approval on this issue is dispositive.

22. Joint Proposed Finding 40 and 41 state that the Staff and the County both conclude that the torsional stresses I

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,s -, . x a - - ..a.s .nm, ea exceed ABS limits. There is no basis for a finding that the torsional stresses in the crankshafts exceed ABS limits.

First, the County's witnesses have no ability to calculate tor-sional stresses (LILCO Reply Finding 18) and were merely inap-propriately comparing FaAA's calculations to the ABS limits.

Second, both the Staff and County compared a calculation that summed 24 orders. There is no evidence whatsoever that ABS re-quires or even contemplates a 24 order calculation. Indeed,

, the only evidence in the record is that ABS sums two orders.

t (Joint Proposed Finding 41, n. 12). There is no basis for a finding that ABS' requires more information concerning torsional stress that was submitted by TDI. The statements by Professor Sarsten in footnote 12 of the Joint Proposed Findings are sheer speculation on his part. 4

23. Witnesses for both the Staff and County argued that the crankshafts should be evaluated by the rules of vari-ous clasification societies. The classification societies are in the best position to interpret their own rules. ABS inter-preted its rules to approve the torsional stress levels in the replacement crankshafts. Furthermore, the last sentence in footnote 12 is just plain wrong. The_ ABS calculations showed that the stresses, as determined by ABS, clearly met the allow-able limits of the 1984 rules. (County Exhibit 43 at 26-28).

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, The stresses.did not meet the limits of the 1983 rules. The limits were increased-by approximately 400 psi in 1984. The Intervenors' statement in footnote 12 is blatantly misleading.

24. Joint Proposed Findings 42-50 argue that the ABS approval is entitled to no weight because TDI submitted inaccu-

. rate information to ABS concerning shotpeening. The Interve--

nors again distort the record in an attempt to provide a com-pletely one-sided view of the ABS approval. The Intervenors suggest that ABS approved the crankshafts only because TDI attributed a 20% increase in the fatigue life to shotpeening.

(See, e.a. Joint Proposed Findings 44, 49). There is however, nothing.in the rec 6sd to support this assertion. The informa-tion TOI submitt ed to ABS 'is contained in County Exhibit 45.

The information includes a torsional analysis by TDI, data con-cerning the mass elastic system for a number of DSR-48 engines, results of the torsiograph tests on EDG 103 in January, 1984, information on the physical properties of the crankshafts, re-

.sults of the strain guage tests-on EDG 103 and a log of op-erating hours for other DSR-48 engines. The Intervenors would have the Board believe, incorrectly, that the sole factor that lead to-ABS approval was shotpeening. The record supports no

[ such finding.

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25. The Intervenors also suggest that ABS would not have attributed a 20% increase in fatigue lif*e to shotpeening were it not for TDI's representation. The'Intervenors again fail-to reveal facts that do not support their version of events. For example, County Exhibit 43 contains, among others, pages 93, 98 and 99 of the ABS deposition. Page 93 of the dep-

' osition contains the statement that ABS accepted TDI's repre-sentations concerning shotpeening. The County intentionally excluded pages 94-97'of the ABS deposition from County Exhibit

43. This is not surprising. On page 94 the ABS representa-tives stated that they had no reason to disagree with the 20%'

value because that value was established by.the literature and

! ABS had seen that value quoted most often. Indeed, they said some-people actually claimed credit for a much higher increase in the fatigue limit as a result of shot peening.

In addition, at page 97 the ABS representatives said they had reviewed lit-

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erature on shotpeening and for that reason did not question the 20% figure reported by TDI. Therefore, contrary to the Inter-senors:' mischaracterization, ABS gave credit for the shotpeening because ABS believed 20% was a reasonable figure, j not because ABS was mislead by TDI.2/

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2/ LILCO recognizes that pages 94-97 of the ABS deposition are not part of the record and could not be the basis of a (Continued)

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26. It would be entirely inappropriate for the Bcard to overrule the ABS approval of the replacement crankshafts.

The Intervenors argue they are in a better position to inter-pret and apply the ABS rules than ABS. The record is clear that according to ABS the crankshafts comply with the ABS rules. .No further inquiry is necessary or appropriate.

(d) ABS Spo Dimensions

27. Joint Proposed Findings 51-55 argue that the re-placement crankshafts do not comply with the ABS rules on web dimensions. The record does not support these proposed find-ing.

28. Joint Proposed Finding 52 discusses Professor Christensen's web calculations. Even his calculatien shows compliance with ABS rules at full load. Professor Chris-tensen's web calculations show that the maximum allowable fir-I ing pressure at full load is 1746 psi. Even assuming that the correct peak. firing pressure at full load is 1720 psi, the crankshafts pass.

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(Continued from Previous Page) l finding.by the Board. LILCO merely brings this information to the Board's attention to assist in fairly evaluating the Joint

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Proposed Findings relating to ABS.

29. Joint Proposed Finding 55 states that there is in- l sufficient evidence to support a finding that ABS has approved I the web dimensions of the replacement crankshafts. The fact remains, however, that the testimony of Mr. Montgomery was uncontradicted concerning ABS approval of the web dimensions.

(LILCO Proposed Finding 45). Despite the fact that Professor Christensen thinks the webs do not meet ABS rules, ABS has ap-proved the webs.

(e) The Crankshafts are Adequate Under the Kritzer-Stahl Criteria l l

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30. Joint Proposed Findings 56-63 attempt to discredit the analysis performed by Dr. Pischinger under the Kritzer-Stahl criteria. These proposed findings are based on a tortured reading of the record and distort Dr. Pischinger's testimony.

31. Joint Proposed Finding 58 states that the replace-ment crankshafts are "just on the boundary" of the Kritzer-Stahl criteria at full load. The support for this statement is a reference to Dr. Pischinger's deposition on June 21, 1984. This proposed finding completely ignores Dr.

Pischinger's testimony at the hearings. Dr. Pischinger per-formed. additional work after his deposition which allowed him to state. unequivocally that the replacement crankshafts have a l

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factor of safety at full load of 1.24. (Tr. 23,026). The In-  ;

tervenors simply ignore the further analyses Dr. Pischinger performed. There.is no basis for a finding that the crank-shafts are."just on the boundary" at full load.

32. Footnote 17 to Joint Proposed Finding 58 and Joint

, Proposed Finding 63 draw a totally unsupported conclusion con-cerning the significance of the ultimate tensile strength (U.T.S.) values used by Dr. Pischinger in his calculations.

Dr. Pischinger used a U.T.S. value of 700 Newtons per square millimeter in his calculations. The actual U.T.'S. for two of the replacement crankshafts is 695 Newtons per square millime-ter. Dr. Pischinger contacted Krupp, the manufacturer of the crankshafts, and asked them what U.T.S. value he should use.

Krupp supplied 700 Newtons as the appropriate figure. (Tr.

22,993 Pischinger). In addition, the difference between 700 Newtons and 695 Newtons is less than 1% and is not significant.

(Tr. 22,993 Pischinger). The Intervenors argue this is i unsettling because minor refinements to Dr. Pischinger's calcu-I lations can substantially change the results. Dr. Pischinger testified without contradiction, however, that the difference in U.T.S. values was of no significance.

33. Joint Proposed Findings 59 and 60 are merely con-clusions that are unsupported by the record.

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. 1 34.- Joint Proposed Finding 62 distorts the record in i

an attempt to discredit Dr. Pischinger's calculations. The In-tervenors argue that if failure is defined as the time a crack initiates, rather than the time a crankshaft severs, Dr.

Pischinger's calculations accurately predict the lifetime of the original crankshafts.

The results of any calculation may be altered if the assumptions on which the' calculation'is based  !

l are changed. It is clear, however, that all of Dr. I Pischinger's calculations, as well as the S-N curve he used, were based on hours of operation until the crankshafts actually severed. (Tr. 22,778, 23,007-08 Pischinger). Dr. Pischinger's calculation of the lifetime of the original crankshaft predicts 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of life at full load until severance. He did not predict 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of life until crack initiation. The original crankshaft on EDG 102 actually operated for 273' hours at full load before it severed, almost twice the life predicted by_ Dr.-

Pischinger. (LILCO Proposed Finding 84). The discussion of when failure occurs was totally theoretical. (Tr. 23,008-09 Pischinger). Only by ignoring what Dr.~Pischinger actually did and making an entirely unfounded comparison can the Intervenors argue that his calculations do not provide assurance of the ad-equacy of the replacement crankshafts.

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35. Footnote 20 to Joint Proposed Finding 63 com-pletely distorts Dr. Pischinger's testimony concerning the ade-quacy of the webs of the replacement crankshafts. While the statements attributed to Dr. Pischinger in footnote 20 are cor-rect, the Intervenors fail to mention one critical fact. Al-though Dr. Pischinger said he might make the webs 1/2 inch thicker if he were designing the crankshafts, this fact had nothing to do with his assessment of the crankshafts under the Kritzer-Stahl criteria or his conclusion thst the crankshafts have an adequate safety factor. (Tr. 23,024-25 Pischinger).

Web dimensions are merely an input to the Kritzer-Stahl calcu-lations. (Tr. 22,783 Pischinger).

B. DEMA

1. DEMA is an Appropriate Standard

36. Joint Proposed Findings 64-76 present the County's view that DEMA is an inadequate standard by which to judge the adequacy of the replacement crankshafts. For example, Joint Proposed Findings 64, 67, 68, 70 and 76 all conclude, without any transcript citation, that LILCO has failed to establish that DEMA constitutes an acceptable criteria to judge the ade-quacy of the replacement crankshafts. These proposed findings ignore one critical fact: the adequacy of DEMA as a standard

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is not within the scope of the admitted-contention. (See Joint Proposed Finding 3). The Intervenors were well aware that the purchase specifications required the diesels to comply with DEMA. (LILCO Proposed Finding 8). At'no point, however, did the'Intervenors propose a contention that. challenged the ade-l quacy of DEMA as a standard. Therefore, LILCO did not have the burden of proving that DEMA was an appropriate standard. LILCO merely had to prove the crankshaf ts met the DEDUL recommenda-tions. -The Joint Proposed Findings also ignore the fact that i

DEMA is the only standard referenced in NRC Reg. Guide 1.9,

Rev. 2, which addresses the design of standby diesel generators at nuclear power plants. -(See LILCO Proposed Finding 9; Staff a Proposed Findings 15-21).

37. Joint Proposed Finding 66 cites only_a portion of Dr. Chen's testimony and does not accurately reflect the

-record.2/ Dr. Chen specifically stated that while he thought.

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the DEMA rules were older rules and conservative, he did not

.think they were out-of-date or obsolete. (Tr.'23,015 Chen).

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l' In addition, Dr. Chen considers DEMA a valid and reasonable method for evaluating torsional stresses on a crankshaft. (Tr.

l 23,015-16 Chen).

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l jb/ The selective use of the record by the Intervenors is par-l ticularly inappropriate in this instance. While Dr. Chen's

! .early testimony after arriving late on September 17, 1984, was

!. somewhat unclear, he later corrected himself. The Intervenors have chosen to ignore Dr. Chen's corrections.

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38. Joint Proposed Finding 67 makes the unsupported leap from the fact that DEMA is not a design code, which LILCO

does not dispute (LILCO Proposed Finding-10), to the conclusion that DEMA does not provide standards to measure the_ adequacy of a crankshaft. Suffolk County, and to some extent the Staff, have lost sight of-the fact that the issue in this proceeding is not which organization or society provides the best rules for designing crankshafts. Rather, the issue is whether the existing replacement crankshafts are adequate for their intend-ed service. Therefore, the fact that DEMA cannot be used to-design a crankshaft is irrelevant. DEMA can plainly be used to evaluate a crankshaft. (Tr. 23,015 Chen).

39. Joint Proposed Findings 68-75 deal with the ques-tion of how the DEMA recommendations should be interpreted.

These findings urge, as do Staff Findings 25-28, that the DEMA allowable stresses should be calculated according to the most sophisticated computational techniques, which permit the summa-tion of 24 orders of vibration. These proposed findings are based exclusively on the testimony of Professor Sarsten. The County's witnesses were unable to perform torsional vibration calculations, had no prior experience with DEMA and were able to shed no light whatsoever on-this question. (LILCO Reply Finding 18; Tr. 23,975-76 Christensen, Eley).

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40. Both the County and the Staff urge the Board to adopt Professor Sarsten's interpretation of DEMA and reject Dr.

Chen's interpretation. Professor Sarsten's interpretation of DEMA is entitled to little, if any, weight. Professor Sarsten i freely admitted that he had no way of knowing what methodology DEMA intended to be used for the calculation of vibratory stresses. (Tr. 23,239 Sarsten). He had no knowledge of how American diesel manufacturers sum orders for purposes of DEMA compliance or how those firms interpret DEMA. (Tr. 23,246-47, 23,250 Sarsten). Professor Sarsten had no experience with DEMA prior to his invovlvement in this case (Tr. 23,255 Sarsten), he made no inquiry of DEMA members concerning the number of orders typically summed for a DEMA calculation (Tr. 23,254 Sarsten),

and he based his interpretation of DEMA solely on his own reading of DEMA. (Tr. 23,247 Sarsten).

41. Dr. Chen, on the other hand, has worked in the American diesel industry since 1952, worked for Fairbanks-Morse (which is a member of DEMA) from 1969-1973, and was chairman of the DEMA Technical Committee from 1971-1973. (Chen, ff Tr.

22,610 at 4, 30; Tr. 22,695). Dr. Chen's testimony was uncontradicted that it is standard practice in the American diesel engine industry to sum only the four or six largest or-ders of vibration for purposes of comparing stresses against the DEMA allowables. (LILCO Proposed Finding 21).

42.' Joint Proposed Finding 68 implies that DEMA is in-adequate because it does not specify any method to be used for calculating torsional vibratory stresses. However, it should be noted that of the three classification societies supported by the Intervenors (Lloyd's, ABS and IACS) only the IACS calcu-lation (CIMAC) specifies the number of orders to be used in calculating torsional stress. (Tr. 23,286 Sarsten). Neither ABS nor Lloyd's specifies the number of orders to be used in calculating torsional stress, but rely on the calculations sub-mitted by the manufacturer. (Tr. 23,286 Sarsten).

43. Joint Proposed Finding 69 is riddled with internal inconsistencies. The Intervenors first criticize LILCO for not seeking an interpretation from DEMA. They then criticize DEMA for having no procedure for obtaining an interpretation of the recommendations. If no procedure exists for obtaining an in-terpretation of DEMA, LILCO can hardly be criticized for failing to seek such an interpretation. Finally, they recog-nize that Dr. Chen did contact several members of DEMA in for-mulating his opinions.

44. Joint Proposed Finding 71 and 72 state that calcu-lational methods such as modal superposition have been conven-tionally used since 1972. This is only partially accurate.

Both Professor Sarsten and Dr. Pischinger testified that such

- .- . -. .- - _ . - - - . - - - - . . ~ . - . . . - .,_ - .-.-.-

)

. l 9

I i

methods were conventional in Europe. (Tr. 23,283-84 Sarsten; i Tr. 22,989-90 Pischinger). There was no evidence that such methods were or are conventionally used in the United States.

45. Joint Proposed Finding 72 concludes, totally with-out support from the record, that DEMA would not continue to publish its recommendations if it did not believe current ana-lytical techniques should be used. There is no basis for this conclusion. Indeed, the only fair conclusion that may be drawn from the record is that analytical techniques similar to those available at the time the DEMA recommendations were adopted should be used for comparison with the DEMA allowables. Wit-nesses for LILCO, the Staff and the County all testified that prior to the development of digital computers in the mid-1960s it was very difficult to sum more than two er three orders.

(Tr. 22,742 Pischinger; Tr. 23,282 Sarsten; Tr. 24,200-04 Christensen). It is uncontradicted that at the time the DEMA torsional vibration limits were established in 1958, the summa-tion of 24 orders was not possible. It is further j uncontradicted that DEMA only calls for the summation of

" major" orders and that the DEMA stress levels have not changed since 1958. (LILCO Proposed Finding 19). Professor Sarsten's testimony on this matter is entitled to little weight because l

has has no experience with DEMA. (LILCO Reply Finding 40).

I l

! l i

l l

.l l

46. Joint Proposed Findings 73-74, and Staff Findings 27-28, state that Professor Sarsten's interpretation of DEMA g should be accepted because Dr. Pischinger and FaAA also sum-24 orders. These proposed findings misinterpret the significance of FEV's and FaAA's calculations. First, Joint Proposed Find-ing 74 distorts Dr. Pischinger's testimony. Dr. Pischinger's statement concerning the number of orders he would sum was made i.

specifically in the context of the calculations he would per-

, form for the Kritzer-Stahl criteria. It was not a general statement concerning all calculations of torsional stress.

(Tr. 22,798 Pischinger). Second, both FEV and FaAA calculated torsional stresses using 24 orders to determine an input to a fatigue cale.ulat.sn. Neither FEV nor FaAA were calculating nominal torsional stresses for purposes of comparison to the

, DEMA limits. Indeed, both Dr. Pischinger and Dr. Johnston

-stated that they did not believe their 24 order torsional stress calculations should be compared to DEMA. (Tr. 22,801, 22,809 Pischinger; 22,851-53 Johnston). Only Professor Sarsten summed 24. orders solely for the purpose of comparing his re-l' i-

.sults to the DEMA allowables, and even he recognized that his

. calculation of nominal stresses should more appropriately be r

used as an input to a factor of safety calculation. (Tr.

!' 23,384 Sarsten).

i b

-_ _ _ . . _ . , _ , . - _ _.-~.__ _ _ _ - . __ _ _ _ ..---. .- _ _ ,,. _ ...._.__ _ _ -.. _ _ _ _ _ _

47. Joint Proposed Finding 75 incorrectly asserts that Dr. Chen stated experts could reasonably disagree over which orders were major. Nowhere on the page of the transcript cited by the Intervenors is there a statement resembling the one attributed to Dr. Chen. In fact, the record reflected that there was remarkable agreement among the experts about what the term major orders meant. (Tr. 23,085-87 Chen, Johnston, Pischinger; Tr. 22,747-50 Chen, Johnston). ,

2. The Crankshafts Comply with DEMA

48. Joint Proposed Findings 77-85 discuss the tor-sional calculations performed by various witnesses. The entire discussion in this section is based on the incorrect assumption that the appropriate torsional stress calculation for purposes of comparison with DEMA is one that sums 24 orders.

49. Joint Proposed Finding 77 is'a conclusion that is unsupported by any transcript citation.

50. Joint Proposed Finding 79 incorrectly states that t.he analyses by FaAA and Dr. Pischinger show noncompliance with DEMA. Both Dr. Johnston and Dr. Pischinger specifically stated that it was not appropriate to compare the results of their analyses with DEMA. (Tr. 22,801, 22,809 Pischinger; 22,851-53 Johnston). Nominal torsional stresses exist only hypothetical-ly. The stresses may be computed in different ways for

different purposes. It is appropriate to use a 24 order summa-l tion as an input to a fatigue calculation to calculate a safety l margin or a true stress, rather than a nominal stress. It is not appropriate to use a 24 order summation to make a compari-son with DEMA. The appropriate calculation for a DEMA compari- J son is a four or six order summation or a reduction of torsiograph test data. (Tr. 22,851 Johnston).

51. Joint Proposed Findings 80 and 81 state that Pro-fessor Sarsten's calculations are "the most accurate of the methods used by the expert witnesses in this case." Although

~

the record supports a finding that there are some slight dif-ferences in the computational methods and results obtained by the different experts, the record does not support a finding-that Professor Sarsten's calculations are "more accurate."

(Tr. 23,050-54 Johnston, Pischinger). The Intervenors empha-size the fact that Professor Sarsten's prediction of free end amplitude was in closer agreement with the free end amplitude measured by Stone & Webster than the values calculated by FaAA and Dr. Pischinger. There is no significance to this fact.

The test measurements are only accurate to within + 5%. (LILCO Exhibit C-16 at 7-3; County Exhibit 49). Professor Sarsten's, L

FaAA's and Dr. Pischinger's predicted free end values are all within 5% of each other. This fact shows a rather remarkable

agreement among the results and in no manner establishes that one calculation is more accurate than another.

52. The primary basis for the proposed finding that Professor Sarsten's calculations are "more accurate" is that Professor Sarsten used a larger dynamic magnifier in his calcu-lations than did FaAA. However,-under cross-examination by the Board, Professor Sarsten was unable to explain why the dynamic magnifier he used (40) more accurately represented the real world condition of the engines than the dynamic magnifier used by FaAA (20). (Tr. 23,437-40 Sarsten). Professor Sarsten also admitted that it the engine speeds in question, the stresses were not very much influenced by the damping. (Tr. 23,440 Sarsten). The question of which method is "more accurate" is largely theoretical. (Tr. 23,441 Sarsten). Professor Sarsten's assertions that in theory his method is more accurate do not support Joint Proposed Findings 80 and 81. Inter-estingly, the Staff makes no such claims for Professor Sarsten's calculations. (See Staff Proposed Findings 31-33).

53. Footnote 35 in Joint Proposed Finding 81 incor-rectly states that FaAA used a one node vibratory form as the basis for calculating stresses. The record is clear that in its modal superposition analysis, which is the calculation being discussed by the Intervenors in Joint Proposed Finding r

81, FaAA calculated the multi-modal response of the crankshaft.

(Tr. 23,050-53 Johnston). FaAA did assume a one node vibratory form when it converted the torsiograph data into stresses.

(LILCO Proposed Findings 38-41). FaAA's torsiograph conversion is not, however, discussed in Joint Proposed Finding 81.

54. Joint Proposed Findings 83-85 state that the stresses calculated by Professor Sarsten, Dr. Pischinger and FaAA are too low, because FaAA's Tn values are too low, because the pressure measurements taken from cylinder No. 7 on EDG 103 are too low. The record supports none of these proposed find-ings. First, nowhere in the record is there testimony that the stresses should be higher, which is evident from the fact that there is no transcript reference in support of the statement.

Second, Professor Sarsten's testimony about alleged inaccuracies in FaAA's Tn values was, like his discussion of damping, largely theoretical. Professor Sarsten could not say with certainty that there was any error in the Tn values, and to the extent there was any error, it was not large and was not significant enough for him to address in his direct testimony.

(Tr. 23,412 Sarsten). Further, it was not even possible to calculate what error might exist. (Tr. 23,415 Sarsten). Final-ly, to the extent there was any error, it was not unacceptable and the Tn values were more accurate than tabulated Tn values.

I 8

- - - . - ~ , - . . , . . . . , _ . .- . , - . . . - _ , , , ~ _ ...,,..,_.-,,,.y _._.._y. __y-, ....-_,._s__

(Tr. 23,418-19 Sarsten). In sum, there is no evidence to sup-port a finding that FaAA's Tn values are too low. Dr.

> Pischinger also calculated Tn values from the pressure measure-ments taken on EDG 103. There was good agreement between Dr.

Pischinger's Tn values and FaAA's Tn values. (Tr. 22,811-16 Pischinger).

55. Joint Proposed Finding 85 and footnote 36 assert that the pressure measurements are too low. The accuracy of pressure measurements is a theme. repeated' frequently by the In-tervenors. (See e.a., Joint Proposed Findings 31 n. 8, 36, 49

n. 15 and 52). However, as before, the Intervenors have no ev-

idence to support their assertions. The Intervenors represent that the transducer pressure measurements are too low because the indicated mean effective pressure (IMEP) calculated from the pressures does not correspond to the break mean effective presure (BMEP) of the Shoreham EDGs. The Intervenors cite tes-1 timony by Mr. Henriksen to support this idea. Contrary to this implication, however, Dr. Sarsten stated unequivocally just two pages before those cited by the Intervenors that the difference need not be attributed to an error in the maximum firing pres-sures, but probably was due to the shift in the top dead cen-ter, which changes the mechanical efficiency. Moreover, at an-other point in his testimony, Mr. Henriksen agreed with Dr.

J Sarsten that the difference between the IMEP and BMEP was more likely attributable to.the top dead center location. (Tr.

23,727-728 Henriksen). The Intervenors, however, do not quote

~

this portion of Mr. Henriksen's testimony and attempt to convey the impression'that he attributed the difference in IMEP and BMEP to the fact that the peak firing measurements should be higher. Mr. Henriksen, in fact, made it very clear by his en-tire testimony that this was not the case. In addition, LILCO Exhibit C-16 (the results of the field test on EDG 103 in January, 1984) contains a detailed discussion of the pressure measurements taken by the Piezo electric transducers.and the procedures used to calibrate the transducers. The Intervenors presented absolutely no evidence to show that the transducers were improperly calibrated or that the pressure measurements 4

were too low. Indeed, the County's witnesses did not even know how to calibrate the transducers. (Tr. 24,220-24 Christensen, Eley).

56. The Intervenors state as a fact in footnote 36 that cylinder number 7 was not developing full power when the measurements were taken. There is absolutely no evidence to j support this finding. All of Mr. Eley's calculations, which are discussed in footnote 36, were based on the asumption that cylinder number 7 was not developing full power. The 1 l l

i, t

_v--.,,-----+v-v--r-,--e- rw,~%.--n-em-e,-.------,-,--#m..,---,...,--m----~--www- .m e

Intervenors attempt to parly Mr. Eley's assumption into a fact.

There is, however, no evi,dence to support Mr. Eley's assump-tion.

C. FaAA's Fatique Analysis

57. Joint Proposed Findings 86-95 argue that the 1.48 factor of safety calculated by FaAA is insufficient proof that the replacement crankshafts are adequate. There is, however, no evidence in the record that challenges the methods used or the conclusions reached by FaAA in its fatigue analysis. Nei-ther the County nor the Staff presented any evidence challenging the validity of FaAA's fatigue analysis, nor was FaAA's analysis successfully challenged on cross-examination.

The Staff agrees that FaAA's analysis is proper and that the factor of safety is accurate. (Staff Proposed Finding 61).

FaAA's actual factor of safety for the replacement crarkshafts of 1.48 stands uncontradicted.

58. The Intervenors rely almost exclusively on the testimony of Professor Sarsten to support Joint Proposed Fi'd-ings 86-95. This is not surprising due to the inability of the County's witnesses to ev.2 uate the adequacy of a crankshaft based on a fatigue analysis. For example, Mr. Eley admitted that he was incapable of calculating the actual stresses in the crankshaft fillets. (Tr. 23,847-48 Eley). Professor

Christensen stated that he could calculate the stresses in the fillets. He then described his method, which was a simplifica-tion that actually eliminated the fillets. (Tr. 23,848-49 Christensen). In addition, the County's witnesses did not have sufficient training or experience to evaluate the test data taken from EDG 103. Neither of the County's witnesses knew the degree of accuracy of pressure measurements taken by Piezo l

electric transducers. (Tr. 24,220-24 Christensen, Eley). Pro-fessor Christensen believed that a crack of several microns in the replacement crankshafts would propagate. However, he was unable to describe the stress field such a crack would need in order to propagate nor had he performed any calculations to show that such a crack would propagate. (Tr. 24,224-25 Chris-tensen).

59. Notwithstanding Professor Sarsten's v_.ious abili-ty to evaluate FaAA's fatigue analysis, he did not do so. Pro-fessor Sarsten had no opinion about the adequacy of the re-placement crankshafts because he made no attempt to determine whether the crankshafts were adequate. (Tr. 23,352-53, 23,383-84 Sarsten). Indeed, Professor Sarsten stated that his only concern was whether the nominal torsional stresses ex-ceeded 7000 psi. (Tr. 23,352-53 Sarsten). He did not review the results of the tests on EDG 103 and he made no calculations

4-of'the stresses in the original 13 inch x 11 inch crankshafts for purposes of comparison with the replacement crankshafts.

(Tr. 23,385, 23,389 Sarsten).

Professor Sarsten admitted that the' calculation of torsional stress was merely one of the in-puts required to evaluate the adequacy of the crankshafts.

(Tr. 23,384 Sarsten).

60. Joint Proposed Finding 89 states that FaAA's fac-

-tor of safety is not sufficient proof that the replacement crankshafts are adequate. The record does not support this proposed finding. Professor Sarsten's opinion (upon which this proposed fining is premised) is not based upon any criticism of FaAA's methods or conclusions. (See Staff Proposed Finding 61). Rather, it is simply based on the fact that Professor Sarsten wants to see the crankshafts tested for 107 cycles, and feels more comfortable with classification societies' guidelines. (Tr. 23,528-29 Sarsten).

61. The record is uncontradicted, however, that the degree of knowledge about the replacement crankshafts is more i

than sufficient to provide' confidence in FaAA's fatigue analy-sis. Dr. McCarthy testified that FaAA had more knowledge about

- the design of the replacement crankshafts than any other part he had ever confronted in his entire professional experience, and he did not expect to have this kind of information again for a long, long time. (Tr. 23,027 McCarthy).

t

.-..,v. - - - ,_.m, , , . - . - . _ . , -.mes,,. - . _ , . . . , . . ~ , , ,, , . _ , -,-_,.,r.,m,.,

, , , - . . - ,y n-- y .~ y,- - -. .

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62. Furthermore, Joint Proposed Finding 89 incorrectly suggests that FaAA's approach to analyzing the crankshaft was '

solely to compare a calculated endurance limit with the mea-sured stresses. First, FaAA did not calculate the endurance limit of the replacement crankshafts in the sense suggested by the Intervenors.- The actual endurance limit was established by tests and analyses of the original and replacement crankshafts.

(LILCO Proposed Findings 69-71). Second, FaAA's assessment of the crankshaft was based upon a three-tiered approach of

' testing, inspections and analyses, all of which confirmed that the replacement crankshafts were adequate. (See LILCO Proposed Findings 49-81).

63. Joint Proposed Finding 91 incorrectly attempts to

' compare the actual endurance limit determined by FaAA with the endurance limit calculated by Dr. Pischinger. The Intervenors s imply that FaAA should have used Dr. Pischinger's endurance limit in its fatigue analysis. It would be totally improper, however, to use an endurance limit that was calculated ac-cording to a specific criteria (Kritzer-Stahl) in a fatigue analysis that is based upon actual tests and measurements. Dr.

Pischinger specifically noted that the Kritzer-Stahl criteria was extremely accurate at predicting stresses because the pre-dicted stresses were very close to the actual measured

'l s

stresses. (Tr. 23,006 Pischinger). Dr. Pischinger believed,

+

however, that the endurance limit calculated by the Kritzer-Stahl criteria was extremely conservative and was too low. (Tr. 23,005-07, 23,045-46 Pischinger). There is no evi-dence to indicate that the actual endurance limit determined by FaAA is inaccurate.

64. Joint Proposed Findings 92 and 93 discuss the forging process of the crankshafts. There is no evidence that the factor of safety determined by FaAA is effected in any man-ner by the facts discussed in Joint Proposed Findings 92 and 93.

65. Joint Proposed Finding 94 discusses the various safety factors that have been calculated for the replacement crankshafts. It is significant to note that of the ten safety factor calculations made for these crankshafts (seven by ABS, one by TDI, one by Dr. Pischinger and one by FaAA), none yield a factor of safety of less than 1.0. (County Exhibit 39 at 6; County Exhibit 43 at 29, 32; LILCO Proposed Findings 72 and 87). Of tnese ten, only two are below 1.1, and only three are below 1.15. (County Exhibit 39 at 6; County Exhibit 43 and 32). Six of the safety factors exceed 1.22 and four exceed 1.3. (County Exhibit 43 at 32; LILCO Proposed Findings 72 and 87). Dr. Pischinger testified that an accepted range of safety

i_

i l

factors was between 1.15 and 1.3. (LILCO Proposed Finding 89).

Professor Sarsten testified that a factor of safety of 1.1 was adequate under certain circumstances. (Tr. 23,509 Sarsten).

66. FaAA determined that the actual factor of safety for the replacement crankshafts was 1.48. This factor of safe-ty was not based upon a predetermined criteria. It was based upon an extensive engineering analysis to determine a true mar-gin of safety. There is more than adequate assurance that the replacement crankshafts are adequate for their intended ser-vice.

D. Shotoeenino

67. Joint Proposed Findings96-106 discuss the issue of'shotpeening. It is apparent from the proposed findings that the Intervenors have abandoned their contention that the origi-nal shotpeening damaged the crankshafts. (See Joint Proposed Findings 3, 106 n. 41). The Intervenors now merely argue that-it is impossible to precisely quantify che increase in the fa-tigue endurance limit attributable to shotpeening. Because the Intervenors have abandoned their shotpeening contention, LILCO l .will not specifically address Joint Proposed Findings96-106.

However, this should not be interpreted to mean that LILCO agrees-with Joint Proposed Findings95-106. The record sup-

- ports a finding that shotpeening increased the fatigue wm-- s 9 --y' s -ws v -w, w e er 2 --

~ sen v , -v--e,re ,-~~-w-=~ ~-

1 4

endurance limit by ten percent (10%) to twenty percent (20%).

(LILCO Proposed Finding 109).

Respectfully Submitted, LONG ISLAND' LIGHTING COMPANY

.1 BY VI C A'AE hVf Counsel /

6 E. Milton Farley, III John' Jay Range Hunton & Williams 2000 Pennsylvania Ave., N.W.

P. O. Box 19230

' Washington, D.C. 20036 T. S. Ellis, III Anthony F. Earley, Jr.

Hunton & Williams 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 Odes L. Stroupe, Jr.

David Dreifus Hunton'& Williams 333-Fayetteville Street P. O. Box 109 Raleigh, North Carolina 27602 DATED: December 3, 1984

l' L4 WITNESSES IN ALPHABETICAL ORDER Ogyg g l:  ;

'0A C": ' ~ s Following ' P3 :00 Witness Transcript Pace l* ~ ! " ~ ( e < ,. ,

Anderson,, Robert N. - 23,826 .

" Joint Direct Testimony of Dr.

Robert N. Anderson, Professor C

'^

Stanley G. Christensen, G. -

~'

Dennis Eley, Dale G. Bridenbaugh -

and Richard B. Hubbard regarding Suffolk County's Emergency Diesel Generator Contentions"

.Briden1auch, Dale G. 23,826

" Joint Direct Testimony of Dr.

Robert N. Anderson, Professor Stanley G. Christensen, G.

Dennis Eley,. Dale G. Bridenbaugh

'and Richard B. Hubbard regarding Suffolk County's Emergency Diesel Generator Contentions" Burrell, N. Ken 23,122

" Testimony of Clifford H. Wells, Duane P. Johnson, Harry F. Wachob, Craig Seaman, Dominic Cimino and N. Ken Burrell on behalf of

~Long Island Lighting Company Concerning Shotpeening of the i Replacement Crankshafts" Bush, Spencer H. 23,126

" Joint Testimony of Carl H.

.Berlinger, Spencer H. Bush, 1 Adam J. Henriksen, Walter W.

Laity, and Professor Arthur Sarsten on Contentions Concern-ing TDI Emergency Diesel

-Generators at the Shoreham Nuclear Power Station"~

-?

4 Following Witness Transcript Pace Chen, Simon K. 22,610

" Testimony of Roger L. McCarthy, Paul R. Johnston, Eugene F.

Montgomery and Simod K. Chen on behalf of Long Island Lighting Company on Suffolk County's Contention Regarding Replacement

. Crankshafts on Diesel Generators at Shoreham" Christensen, Stanley G. 23,826 L

" Joint Direct Testimony of Dr.

Robert N. Anderson,. Professor Stanley G. Christensen, G.

Dennis Eley, Dale G. Bridenbaugh and Richard B. Hubbard regarding Suffolk County's Emergency Diesel' Generator Contentions" Cimino,'Dominic 23,122

" Testimony of Clifford H. Wells, Duane P. Johnson, Harry F. Wachob, Craig Seaman, Dominic Cimino and N. Ken Burrell on behalf of Long-Island Lighting Company Concerning Shotpeening of the Replacement Crankshafts" Eley, G. Dennis 23,826

" Joint Direct Testimony of Dr.

Robert N. Anderson, Professor Stanley G. Christensen, G.

Dennis Eley, Dale G. Bridenbaugh and Richard B, Hubbard regarding Suffolk County's Emergency Diesel Generator Contentions" 4

t-a Following Witness Transcript Page Henriksen, Adam J. 23,126

" Joint Testimony of Carl H.

Berlinger,~ Spencer H. Bush, Adam J..Henriksen, Walter W.

Laity, and Professor Arthur Sarsten on Contentions Concern-ing TDI Emergency Diesel Generators at the Shoreham Nuclear.Po.er Station" Hubbard, Richard B. 23,826

" Joint Direct Testimony of Dr.

Robert N. Anderson, Professor Stanley G. Christensen, G.

Dennis Eley, Dale G. Bridenbaugh and' Richard B. Hubbard regarding

-Suffolk County's Emergency Diesel Generator Contentions" Johnson, Duane P. 23,122

" Testimony of Clifford H. Wells, Duane P. Johnson, Harry F. Wachob, Craig Seaman, Dominic Cimino and N. Ken Burrell on behalf of Long Island Lighting Company Concerning Shotpeening of the Replacement Crankshafts" Johnston, Paul R.. 22,610

" Testimony of Roger L. McCarthy, Paul R. Johnston,' Eugene F.

Montgomery and Simon K. Chen on behalf of Long Island Lighting Company on Suffolk County's Contention _Regarding Replacement Crankshafts on Diesel Generators at Shoreham"

t

.a-

-Following Witness Transcript Page McCarthy, Roger L. 22,610

" Testimony of Roger L. McCarthy, Paul R. Johnston, Eugene F.

Montgomery and Simod K. Chen on behalf of Long Island Lighting Company on Suffolk County's Contention Regarding Replacement Crankshafts on Diesel Generators at Shoreham" Montaomery, Eugene F. 22,610

" Testimony of Roger L. McCarthy, Paul R. Johnston, Eugene F.

, ' Montgomery and Simon K. Chen on behalf of Long Island Lighting Company on Suffolk County's Contention Regarding Replacement Crankshafts on Diesel Generators at Shoreham" Pischinger, Franz F. 22,610

" Testimony of Edward J.

Youngling and Franz F. Pischinger on behalf of Long Island Lighting Company on Suffolk County's Contention Regarding Replacement Crankshafts on Diesel Generators at Shoreham" Sarsten, Arthur 23,126 l

l " Joint Testimony of Carl H.

Berlinger, Spencer H. Bush, Adam J. Henriksen, Walter W.

Laity, and Professor Arthur Sarsten on Contentions Concern-ing TDI Emergency Diesel 1;t)

Following Witness Transcript Pace Generators at the Shoreham

Nuclear Power: Station" Seaman,.Craig 23,122

" Testimony of Clifford H. Wells, Duane P. Johnson, Harry F. Wachob, Craig Seaman, Dominic Cimino and N. Ken Burrell on behalf-of Long Island Lighting Company Concerning Shotpeening of the Replacement Crankshafts" Wachob, Harry F. 23,122

" Testimony of Clifford H. Wells, Duane P. Johnson, Harry F. Wachob,

-Craig Seaman, Dominic Cimino and N. Ken Burrell on behalf of Long Island Lighting Company Concerning Shotpeening of the Replacement Crankshafts" Wells, Clifford H. 23,122

" Testimony of Clifford H. Wells, Duane'P. Johnson, Harry F. Wachob, Craig Seaman,.Dominic Cimino and N. Ken Burrell on behalf of Long Island Lighting Company concerning Shotpeening of the Replacement Crankshafts" l

L 4 .

. ~5-

i

.4-Following Witness Transcript Pace Younclina, Edward J. 22,610

" Testimony of Edward-J.

Youngling and Franz;F. Pischinger

~

on behalf'of Long Island Lighting Company on Suffolk County's Contention Regarding Replacement Crankshafts on Diesel Generators at Shoreham" 6

l l

SEQUENCE OF CRANKSHAFT TESTIMONY Witness (Party) Date Transcr ipt Pace Where - Witness Sworn Chen (LILCO) 9/17/84 22.664 Johnston (LILCO) ;9/17/84 22,605 Montgomery (LILCO) 9/17/84 22,605 McCarthy (LILCO) 9/17/84 22,605 Pischinger (LILCO) 9/17/84 22,605 Youngling (LILCO) 9/17/84 22,605 Burrell (LILCO) 9/20/84 23,118 Cimino (LILCO) 9/20/84 23,118 4

Johnson (LILCO) 9/20/84 -23,118 Seaman (LILCO) 9/20/84 23,118 Wachob (LILCO) 9/20/84 23,118 Wells (LILCO) 9/20/84 b3,118 Bush (NRC) 9/20/84 23,118 Henriksen (NRC) 9/24/84 23,234 Sarsten (NRC) 9/24/84 23,234 Anderson (SC) 10/1/84 23,812 Bridenbaugh (SC) 10/1/84 23,812 Christensen (SC) 10/1/84 23,812 Ele.y (SC) 10/1/84 23,812 Hubbard (SC) 10/1/84 23,812 f

1

t 7e

. EXHIBITS BY PARTY AND NUMBER DCgT'O s'

av n , ne,-o Exhibit Identifi'ed ab -'r F. Admitted at Number Description Transcript Pace Transcript Pace C F F U.:E CF EELF f ~c.;v W:: ,v E r.

LILCO Ex. Evaluation of Emergency 22,610 ~~- 22 610 C-1 Diesel Generator Crank-shafts at Shoreham and Grand Gulf Nuclear Power Stations prepared for TDI _ _ _ ,

Diesel Generator Owners Group dated May 22, 1984 (hereinafter " Owners Group Crankshaft Report"),

Figure 3-4.

LILCO Ex. Specification for Diesel 22,610 22,610 C-2 Generator Sets, Shoreham Nuclear Power Station -

Unit 1, Spec. No. SH1-89, Revision 2, January 26, 1983, page 1-20.

LILCO Ex. U.S. Nuclear Regulatory 22,610 22,610 C-3 Commission Regulatory '

Guide 1.9, Revision 2, '

December 1979.

LILCO Ex. IEEE Standard Criteria 22,610 22,610 C-4 for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations, Std 387-1977.

/ l I

I

' Exhibit Identified at Admitted at Number Description Transcript Pace Transcript Pace LILCO Ex. Transcript of July 11, 22,610 22,610 C-5 1984 meeting of the TDI Diesel Generator Owners Group,,pages 124-25.

LILCO Ex. Available Logged Hours 22,610 22,673 C-6 of Operation of DSR-48, (Rejected)

Rated 3500 KW at 450 RPM.

LILCO Ex. TDI Diesel Generator 22,610 22,610 C-7 Run History - Shoreham Nuclear Power Station -

Unit 1 - August 6, 1984.

LILCO Ex. Results of non-destruct- 22,610 22,610 C-8 ive examinations of re-placement crankshafts at Shoreham after 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of operation at full load or greater.

LILCO Ex. American Bureau of Ship- 22,610 22,610 C-9 -ping, Rules for Building and Classing Steel Vessels (1983), S 37.17.1.

I LILCC Ex. American Bureau of Ship- 22,610 22,610 C-10 ping, Rules for Building and Classing Steel Vessels (1983), Table 34.3.

I Exhibit Identified at Admitted at Number _ Descrip~ tion Transcript Pace Transcript Page LILCO Ex. TDI Crankshaft Drawing Withdrawn C-ll Number 03-310-05-AC.

LILCO Ex. Ameridan Bureau of Ship- 22,610 22,610 C-12 ping Reports on Castings or Forgings of Replace-ment Crankshafts.

LILCO Ex. American Bureau of Ship- 22,610 ~22,610 C-13 ping letter to TDI dated May 3, 1984.

LILCO EX. Diesel Engine Manu- 22,610 22,610 C-14 facturers Association Standard Practices for Low and Medium Speed Stationary Diesel and Gas Engines (1972 ed.),

pages 53-56.

LILCO Ex. TDI Proposed Torsional 22,610 22,610 C-15 and Lateral Critical Speed Analysis, August 22, 1983.

LILCO Ex. Field Test of Emergency 22,610 22,610 C-16 Diesel Generator 103 with 13 x 12 Crankshaft, April, 1984.

4

~?

Exhibit Identified at Admitted at DescriDtion

~

Number . Transcript Pace Transcriot Pace LILCO Ex. Owners Group Crankshaft- 22,610 22,610 C-17 . Report.

LILCO Ex. Crankdhaft Torsional 22,610 22,610 C-18 Stress Calculations for 8L 17 x 21 Engine-Gen-erator Set, July 19, 1984.

LILCO Ex. Table 2.2 from Owners 22,610 22,610 C-19 Group Crankshaft Report

, showing natural. frequencies from TDI. analysis. ,

LILCO Ex. Table 2.4 from Owners 22,610 22,610 C-20 Group Crankshaft Report showing single order nominal stresses from TDI analysis.

LILCO Ex. Table 2.5 from Owners 22,610 22,610 C-21 Group Crankshaft Report showing nominal stresses calculated from torsiograph.

LILCO Ex. Crankshaft Torsional 22,610 22,610

- C-22 Stress Calculations for 8L 17 x 21 Engine-Generator Set, July 19, 1984, page 11.

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a y -. n <. - -- ,,--.w-e n-

--.-,,r- , s,,n 7 n., n,,, , ..,,y-,,,.,,,,g_n,,,.-n- ,.nn,- ,_,,7.,. ,,m_,, . , ,.g,,.,,.nw.-

Exhibit Identified at Admitted at Number Descrip~ tion Transcript Page Transcript Pace IILCO Ex. Figure 3-3 from Owners 22,610 22,610 C-23 Group Report showing comparison of measured and calculated torque.

LILCO Ex. Tables 3.6 and 3.7 22,610 22,610 C-24 from Owners Group Crankshaft Report showing

. comparison between analytical and test results.

LILCO Ex. Figure 3-13 from Owners 22,610 22,610 C-25 Group Crankshaft Report showing fatigue endurance limit of replacement crankshafts on Goodman diagram.

LILCO Ex. Oberg and Jones, 22,610 22,610 C-26 Machinery's Handbook (18th Ed.) pages 352-53; Shigley, Mechanical Encineering Desian (McGraw-Hill) pages 212-13; Rothbart (editor), Mechanical' Desian and Systems Handbook (McGraw-Hill) page 18-4.

LILCO Ex. Engineering and Design 23,121 23,122 C-27 Coordination Report No. F-46109G.

Exhibit Identified at Admitted at Number Description Transcript Pace Transcript Page LILCO Ex. Military Specification 23,121 23,122 C-28 No. 13165B, Amendment 2, June 25, 1979.

LILCO Ex. LILCO-Operational 23,121 23,122-C-29 Quality Assurance Reports (EDG 102 and 103 Crankshafts).

LILCO Ex. Metal Improvement 23,121 23,122 C-30 Company Certificate of Shot Peening (EDG 102 and 103 Crank-shafts).

LILCO Ex. Certificate of Non- 23,121 23,122 C-31 Destructive Testing Issued by Krupp Stahl AG (EDG 102 and 103 Crenkshafts).

LILCO Ex. LILCO Magnetic Particle 23,121 23,122 C-32 Testing and Liquid Penetrant Testing Records (EDG 102 and 103 Crank-shafts).

LILCO Ex. LILCO Ultra Sonic Test- 23,121 23,122 C-33 ing Records (EDG 102 and 103 Crankshafts).

4 6-

...r,. . . . _ , . . ~ _ , . _ _ ,7,. __,,_,., _ ,,._s _ _ . _ _ . , . _ . _ . , _ _ , . _ .

'e Exhibit Identified at Admitted at Number _ Descrio' tion Transcript Pace Transct.pt Page LILCO Ex. H. Fuchs and R. Stevens, 23,121 23,122 C-34 Metal Fatique in Encineerina (1980) at pages 226-227; H.

Uhlig, Corrosion and Corrosion Control at pages 132-133.

LILCO Ex. Metal Improvement 23,121 23,122 C-35 ccmpany certificate of Shot Peening (EDG 101 Crankshaft).

LILCC Ex. LILCO Operational 23,121 23,122 C-36 Quality Assurance Reports (EDG 101 Crankshaft).

LILCO Ex. Certificates of Non- 23,121 23,122 C-37 Destructive Testing Issued by Krupp Stahl AG (EDG 101 Crankshaft).

LILCO Ex. LILCO Magnetic Par- 23,121 23,122 C-38 ticle Testing, Liquid Penetrant Testing and Ultra Sonic Testing Records (EDG 101 Crankshaft).

Exhibit ' Identified at Admitted at

= Number Descrio' tion Transcriot Pace Transcript Pace LILCO Ex. . Kirk, Behavior of 23,121 .23,122 C-39 Peen-Formed Steel Strio on Isochronal Annealina,. Proceedings of the Second Inter-natic al Conference on Shot Peening at page 231, (May, 1984).

LILCO Ex. Pages 70 and 71 from 23,881 24,333 C-40 the May 10, 1984 Deposition of Dr.

Robert N. Anderson LILCO Ex. Rules and Regulations 24,010 24,333 C-41 for the Classification of Ships, Lloyd's Register of Shipping, Part 5, Chapter 2 (July, 1982) and Part 5, Chapter 1 (January, 1983)

LILCO Ex. Pages 129 and 130 from 24,143 24,333

.C-42 the July 18, 1984 Deposition of Woytowich, Blanding and Giuffra (ABS)

Staff Ex. PNL Evaluation of 23,236 23,236 1 Crankshaft Dimensions (Bound in) v Exhibit Identified at- Admitted at Number Description Transcript Pace Transcript Pace 1

Staff Ex. PNL Analysis of Torsional 23,236 23,236 2 Strasses for Sum of 24 (Bound in)

Orders of Vibration Staff Ex. PNL Analysis of Stress 23,236 23,236 3 Levels for Single Orders (Bound in)

Staff Ex. American Bureau of Shipping 23,236 23,236 4 letter to TDI dated (Bound in)

May 3, 1984 Staff Ex. Kohls, et al., Effects of 23,324 23,128 5 Multiple Shot-Peening / (Bound in)

Cadmium-Platino Cycles on High-Strength Steel .

County Design Review of TDI R-4 23,824 23,827 Ex. 7 and RV-4 Series Emergency Generator Cylinder Blocks and Liners, June 1984 ,

County Deposition testimony of 23,824 23,827 Ex. 10 Gerald Edgar.Trussell, pages 62, 45-48, 107, 111-113 County Deposition testimony of 23,824 23,827 Ex. 24 Maurice H. Lowrey, dated May 10, 1984, pages 1, 15-16, 62 l

n -.

i a

Exhibit Identified at Admitted at Number Description Transcript Page Transcript Page County Board Notification 84- 23,824 23,827 Ex. 35 101; Evaluation of Diesel Generator Fail-ure at Shoreham Unit 1, Franklin Research Center, pages 1-6, 33-34, 59-62, 63-68 County Calculations for 12" x 23,824 23,827

_ Ex. 36 13" Crankshafts under Lloyd's Register Rules by Professor Christensen County Calculations for 12" x 23,824 23,827 Ex. 37 13" Crankshafts under Lloyd's Register Rules by Mr. Eley County IACS-CIMAC Rules for the 23,824 23,827 Ex. 38 Calculation of Crankshafts i for Diesel Engines County TDI Calculations under 23,824 23,827 Ex. 39 IACS-CIMAC Rules on R-48 Crankshaft County Calculations under ABS 23,824 23,827 Ex. 40 Rules for Crankshafts with Solid Webs, by Professor Christensen County Deposition testimony of 23,824 23,827 Ex. 41 Franz F. Pischinger, dated June 21, 1984, pages 1, 94, 97-98, 100-101, 108, 110, 185-187

. - - ~ . . ., . . . . . ,

l 6.

4 Exhibit Identified at- Admitted at  !

Number Description Transcript Pace Transcript Page County Deposition testimony of 23,824 23,827 Ex. 43 Messrs. Woytowich,

- Blanding and Giuffra (ABS)c dated July 18, i 1984, pages 1, 80-81, 93, 98-99, 112, 163-165, 167-168 and exhib-it 3 to the deposition l

County May 3, 1984 letter from 23,824 23,827 z.

Ex. 44 ABS to TDI

} County - TDI submission to ABS 23,824 23,827-Ex. 45 entitled " Report on i Crankshaft Torsional Stresses, Transamerica

Delaval Model DRS-48, j Serial No. 74010/12 for Long Island Lighting

Company, by Roland Yang, April 4, 1984 i

County July 25, 1984 letter to 23,824- 23,827

Ex. 46 Howard C. Blanding (ABS) from Alan Roy Dynner, and documents 1-12 attached County ABS Check Calculations 23,824 23,827 Ex. 47 (Exhibit 3 to ABS deposi-5' tion) dated July 18, 1984 County Letter dated February 17, 23,824 23,827

. Ex. 48 1984 to Gregory M.

Beshouri (TDI) from Shinpel Dench (Kobe Steel Ltd.)

i

- -- -sw vm# v w-m - = - - s s ="e m s v,v,m - w w - e w + e , r , v- r w m rw--,nwo,w--e~w o n s ,-- v v -w -ww + w w - ,e m e s---m e -- e e r e- -r -- ma-m w m m --a w w w

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. Exhibit ,

Identified at Admitted at Number ~ Description Transcript Pace Transcript Pace County Field Test.of Emergency 23,824 23,827 Ex. 49 Diesel Generator 103 With 13 x 12 Crankshaft, April 1984,,.pages 1 and 7-3

' County Field Test of Emergency 23,824 23,827 Ex. 50 Diesel Generator 101, October 1983, pages 1 and 7-2 County Stone & Webster Engineer- 23,824 23,827 Ex. 51 ing Corporation Engineer-ing & Design Coordination Report No. F-46109G County Deposition testimony of 23,824 23,827 Ex. 52 Paul R. Johnston, May 9, 1984, pages 1, 39-40 County Stone & Webster Engineer- 23,824 23,827 Ex. 53 ing Corporation Inter-office Memorandum dated September 20, 1983.

County Deposition testimony of 24,272-74 24,333 Ex. 72 Messrs. Woytowich, Blanding and Giuffra (ABS) dated July 18, 1984, pages 114-130 i

i l

I i

LILCO, December 3, 1984

. . , ;i CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY _ .

(Shoreham Docket Nuclear Power No. Station, 50-322 (OL) UnitJ!& /1-)-[W F' I hereby certify that copies of LILCO'S REPLY TO SUFFOLK COUNTY AND STATE OF NEW YORK PROPOSED FINDINGS OF FACT were served this date upon the following by first-class mail, postage prepaid, or (as indicated by asterisk) by hand.

Judge Lawrence Brenner, Esq.* Atomic Safety and Licensing Chairman Appeal Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board, United States Commission Nuclear Regulatory Commission Washington, D.C. 20555 4350 East-West Highway Fourth Floor (North Tower) Martin Bradley Ashare, Esq.

Bethesda, Maryland 20814 Att: Patricia A. Dempsey, Esq.

County Attorney Dr. Peter A. Morris

• Suffolk County Dept. of Law Administrative Judge Veterans Memorial Highway Atomic Safety and Licensing Hauppauge, New York 11787 Board, United States Nuclear Regulatory Commission Richard J. Goodard, Esq.'*

4350 East-West Highway Office of the Executive Fourth Floor (North Tower) Legal Director Bethesda, Maryland 20814 U.S. Nuclear Regulatory Commission Dr. George A. Ferguson* 7735 Old Georgetown Road Administrative Judge Bethesda, Maryland 20814 Atomic Safety and Licensing Board Panel Alan Roy Dynner, Esq.*

School of Engineering Kirkpatrick, Lockhart, Howard University Hill, Christopher &

2300 6th Street, N.W. Phillips Washington, D.C. 20059 1900 M. Street, N.W.

8th Floor Washington, D.C. 20036 I

~

Secretary of Commission

• Hr. March W. Goldsmith U.S. Nuclear Regulatory Energy Research Group Commission 4001 Totten Pond Road Washington, D.C. 20555 Waltham, Massachusetts 02154 MHS Technical Associates Fabian G. Palomino, Esq.

1723 Hamilton Avenue Special Counsel to the Suite K Governor San Jose, California 95125 Executive Chamber, Rm 229 State Capitol Mr. Jay Dunkleberger Albany, New York 12224 New York State Energy Office Agency Building 2 Jonathan D. Feinberg, Esq.

Empire State Building New York State Albany, New York 12223 Depart. of Public Service Three Empire State Plaza Stephen B. Latham, Esq. Albany, New York 12223 Twomey, Latham & Shea 33 West Second Street Robert E. Smith, Esq.

P. O. Box 398 Guggenheimer & Untermyer Riverhead, New York 11901 80 Pine Street New York, New York 10005 James B. Dougherty, Esq.

3045 Porter Street Howard L. Blau Washington, D.C. 20008 217 Newbridge Road Hicksville, New York 11801 Ralph Shapiro, Esq.

Cammer and Shapiro, P.C.

9 East 40th Street New York, New York 10016 kd bu. ire iac >

6 HUNTON & WILLIAMS P. O. Box 109 Raleigh, North Carolina 27602 DATED: December 3, 1984