ML20100R076

Intervenor Exhibit I-10,consisting of Pages 62,45-48,107 & 111-113 to Transcript of GE Russell 840507 Deposition (Vol Ii,Afternoon Session) in San Francisco,Ca

ML20100R076
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/01/1984
From:	Russell G AFFILIATION NOT ASSIGNED
To:
References
OL-I-010, OL-I-10, NUDOCS 8412170302
Download: ML20100R076 (10)

Text

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~. +50 s . ~3 2 BEFORE THE ATOMIC SAFETY AND A:ID LICE. IG ' B

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s 4 In the matter of ) -

lot!G ISLAND LIGHTING COMPANY, )

(Shorenam :!uclear Power )

6 S tation, Unit 1) )

)

7 ) DOCKET NO. 50-332-OL d

9 10 11 DEPOSITION OF GERALD EDGAR RUSSELL '

12 MAY 7, 1984 13 VOLUME II, ;fternoon Session 14 15 15 17 RE2CRTED BY :

id OndCTA L'ARNOCX , C.S . R. NO 4732 13 20 i

22 2.5 TCOKER & AST2 24 CERTIFIED SHORTHisND RE?ORTER3 681 MAR.<ET STREET, SUITE 9 25 23 3A:t FRld!CISCO , CALIFOR: IIA 34105 415/392-0650 26 27 g 8412170302 B41001 COMPUTERJZED PDR ADOCK 05000322 Q pyg TRANSCRIPT

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FRE0ERIC R. TOOKER KEMBL2 ?.NTI

45 1 A. -Yes.

2 Q. And what is that name ?

3 A. Shot peening.

4 Q. Did Delaval recommend that the replacement 5 crank shaft be shot peened?

6 A. No.

7 Q. Did Delaval recommend that the replacement 8 crank shaft not be shot peened?

'9 A. I don't recall.

10 Q. Who was responsible in your organization for 11 supplying the replacement crank shaft to LILCO?

12 A. Supply -- can you give me the question one more 13 time?

14 Q. Who was responsible in your organization for 15 the supplying of the replacement crank shaft for LILCO?

16 And it may be more than one person. I am asking who.

17 A. As to the supplies, the parts manager.

18 Q. Yes. Who was responsible for giving the 19 recommendation as to whether or not the replacement crank 20 shaft should be shot peened?

21 A. I was.

22 Q. And do you now recall what your recommendation 23 was in that regard?

24 A. My recollection is that I recommended against 25 shot geening.

26 Q. Why did you recommend against shot peening?

27 A. The detailed drawing for that part did not call 28 for shot peening.

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TOOKER & ANTZ 681 Market S treet San Francisco 94105 415/392-0650

46 1 Q. Who prepared the detailed drawing for that part?

2 A. I don't know.

3 Q. Was it Delaval who supplied the detailed 4 drawing for that part?

5 A. Yes.

6 Q. Was there any discussion within the Delaval 7 organization concerning whether or not the detailed 8 drawing should or should not provide for shot peening of 9 the replacement crank shaft?

10 A. Yes.

11 Q. What was the basis for the conclusion that it 12 should not contain the requirements for shot peening?

13 A. The basis for that conclusion lay in an opinion 14 that mechanical improvement by shot peening did not 15 substantially improve the fatigue strength of the crank 16 shaft.

17 Q. Did it improve the strength of the crank shaf t 18 at all?

19 A. Yes.

20 Q. Are there disadvantages to shot peening the 21 crank shaft?

22 MR. SMITH: You are talking about the specific 23 shaft in question here, I assume?

24 MR. DYNNER: Yes, right.

25 THE WITNESS: No.

26 MR. DYNNER: Q. So as I understand your 27 testimony -- please correct me if I'm wrong -- there are 28 no disadvantages to the shot peening in this crank shaft, 3

TOOKER & ANT 2 681 Market Street San Francisco 94105 415/392-0650

47 1 there was an advantage in that it somewhat increased the 2 strength of the crank shaft, and yet you recommended 3 against shot peening; is that correct?

4 A. That's correct.

5 Q. On what was that recommendation based?

6 MS. TARLETZ: Asked and answered.

7 MR. SMITH: I will join in that objection.

8 MR. DYNNER: Q. Aside from the fact thqt the 9 detailed drawings did not call for the shot peening.

10 MR. SMITH: The question has been asked and 11 answ e red'.

12 MR. DYNNER: I don't think so.

13 THE WITNESS: What is the question?

14 MR. DYNNER: Q. The question is On what was 15 your recommendation against shot peening based aside from 16 your prior testimony that -- when I asked the question -

17 previously -- that it was based upon the f act that the 18 design drawings did not call for shot peening?

19 MR. SMITH: Well, note my objection to the form 20 because I don't think that was -- I think the record will 21 show that that was not the only basis against the 22 recommendation that the witness has already testified to.

23 THE WITNESS: The recommendation against shot 24 peening was based in part on, A, the experience that shot 25 peening did not provide a substantial improvement in the 26 fatigue strength of the shaft, and in part on a 27 discussion with, I believe it was, P rofessor Wallace.

23 Q. Well, what did P rof essor Wallace have to say L

TOOK ER & ANTZ 681 Market Street San Francisco 94105 415/392-0650

so 1 about the shot peening?

2 A. I'm going to have to paraphrase the thing, but 3 I believe Jack indicated to us that the shot peening 4 technique is section sensitive and since we were involved 5 here with a heavy section, the improvement would not be 6 s ubs tr.n tial.

7 Q. What does "section sensitive" mean?

8 A. I would like to give an example that would 9 provide a comparison.

10 Shot peening a thin piece of steel of the same 11 specifications of the. crank shaf t would substantially 12 improve its fatigue strength while applying the same 13 surface improvement technique to a thick section, like a 14 crank shaft, would not provide a substantial improvement 15 in the fatigue strenath of the piece.

16 MS. TARLETZ: Could I have that answer read 17 back, please.

18 (Question and answer read.)

19 MS. TARLETZ: Thank you.

20 MR. DYNNER: Q. Mr. Trussell, what do you mean 21 by a substantial improvement?

22 A. Something more than five percent.

23 Q. Did anyone disagree with your recommendation 24 against shot peening the replacement crank shaf t?

25 A. Are you asking for a specific name?

26 Q. Anyone .

27 A. Someone did.

28 Q. Who?

5 TOOKER & ANTZ 681 Market S treet San Francisco 94105 415/392-0650 '

107 1 Q. Overheating means where the temperature exceeds 2 that which is normal for operation at that power level.

3 A.. I don't know.

4 Q. With respect to the A3 piston, what is the 5 Delaval design figure for the side load on the piston 5 skirt?

7 A. I don't remember.

d 2 Do you know approximately?

9 A. No.

10 Q. Is that number documented anywhere?

11 A. I believe it is.

12 Q. Where?

13 A. Design dejartment.

14 Q. By cesign department, you mean the design group 13 in the engineering department?

16 A. Yes, I do.

17 Q. Is that one of the design parameters for the AE 18 piston?

19 A. I don't know.

26 2 Who do you think wculd know the ansser to tnat 21 question, Mr. Trussell?

22 A. Mr. Losry might know.

23 Q. Did Delaval test the AE piston bef ore supplying

_4 it to customers in the field?

25 A. I:o.

26 Q. To vaat customers did Dolaval supply the AE 27 model piston?

03 A. Kodiak Electric Corporation. L LCO. I belie ve D

TOCK ER & ANTZ 681.4arket S treet San *rancisco

/ 94105 413/392-0650

111 1 say it in his own words -- my understanding is that the 2 witness, Mr. Trussell, will not be available for 3 deposition past 5:30; is that correct?

4 MR. SMITH: That's correct.

5 MR. DYNNER: I have acked that the witness be 6 available to go on this evening and that request is 7 denied ; is that correct, Mr. Smith?

8 MR. SMITH: Well, I wish you wouldn 't put it in 9 question and answer form, but you are accurate.

10 MR. DYNNER: All right. And I further 11 requested that since we started late, that is , 10 :00 12 o'cicek ratner enan 9 :30, we go at least for another half 13 hour until 6 :00 o' clock and, that was denied.

14 :ta. SMITH: I think it is one statement. I am

~15 not willing to go vast 5:30 tonignt. The record will 16 snow we began at ten o ' clock this morning. .

17 MR. DYNNER: Thank you.

18 Q. Trussell, does Delaval have a expected life for 19 tae AE piston?

20 A. No.

21 J. Do yua know what the expected life of a 22 component of a diesel engine means?

23 A. Yes.

"4

Q. Have you estaoliched expected life for any 25 otaer components in the 34 series engine?

26 A. nc nave come.

27 Q. Wnat does expected life cean?

2J A. In my o; inion taat is -- the expected life of TOOdE2 & ANrZ 631 :tarke t S ttce t San Francisco 94105 415/392-0650

112 )

1 the component is that life that component gives before it 2 has to be replaced.

3 Q. And as far as you know, that is Delaval's use 4 of that term also; is that correct?

5 A. Yes, I believe so.

6 Q. What components does Delaval have an expected 7 life for in the R4 engine?

6 A. I don't know that I can name them all. Tc give 9 some examples, I believe we have expected life on valves, 10 piston rings, bearings, fuel injection nozzle tips, 11 possiuly cylinder liners.

12 3 Is there an expected life for cylinder heads in 13 the 24 ongine?

14 A. To ,the best of my knowledge, no.

15 Q. Nell, you have not established an expected life?

16 Does that mean that the component is expected to last for 17 the full life of the engine itself?

16 A. Yes.

19 Q. Is there an expected life for the cylinder 20 bloc:: of the R4 engine? ,

21 A. No.

22 Q. Is tnere an ex)ected life far the engine base 23 of the R4 engine ?

24 A. No. ,

23 g. Is there an e::pacted life for the replacemcat 25 cesakshaft uodel for the DSR 48 engine? .

27 A. No.

2J Q. iihat is t' a a ex c uctec life of the OSR 48 eitgines 0

TDCKER & ANT 6dl :tarket Street San Francisco 94105 415/392-0650

113 1 at Shoreham?

2 A. 40 years, I belie ve .

3 Q. Does that 40 years postulate any level of 4 operation per year?

5 A. I don't know.

6 Q. Is tne life of the engine expected to be the 7 saoe whether it operates not at all or operates d continuously for 40 years?

9 A. Say that again, please?

10 Q. I said, does it make any difference in the 11 expected life of the engine whether it doesn't operate at 12 all during 40 yearn or wnether it operates continuously

~

j 13 for 40 years?

14 A. Yes.

15 Q. Does Dclaval have some standard expectations 16 for cac life of the engine at all aside from the 40 years, 17 enat is to say, in terms of its operation during those 40 13 years?

19 MR. S:CTH: I don't think I understand your i

20 question. I ob]ect to the form of question. See if you 21 can reparase it. I am not objecting to your inquiry into f 22 this line, but see if you can reparase the question.

I 23 MR. DYNNER: All rignt, I can see.

24 MR. SMITH: The objection is it's 25 incoa c cencasicle.

26 .4R. DYNNER: To Counsel.

27 MR. S:iITH: At least at a minimum.

2'd MR. DYNNER: We haven 't heard from the witness TOCKER & Nh2 6 81 Market S treet San Francisco 94105 415/392-0650