ML20104A639
| ML20104A639 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/29/1985 |
| From: | Twana Ellis LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-322 OL, NUDOCS 8502010423 | |
| Download: ML20104A639 (14) | |
Text
{{#Wiki_filter:,. m.. p TED LILCO, January 29, 1985 . <. 'i-s .h0 -UNITED STATES OF AMERICA L NUCLEAR REGULATORY COMMISSION 4 B'efore the Atomic Safety and Licensino OdardY3J g7 n ':: %., ~ -In:the M'atteriof' ) N'S ) LONG : ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL) ~ ) ..(Shoreham Nuclear-Power Station, ) l: - Unit 1) ) LILCO'S RESPONSE TO 'SUFFOLK COUNTY'S MOTION TO STRIKE - By motion dated January 22, 1985,-Suffolk County has ~ moved to. strike portions of LILCO's additional testimony .Leoncerning crankshafts'and cylinder-blocks". LILCO disagrees and'here sets'forth its reasons. ~ I. Cylinder Block ~ Testimony-i Suffolk County-seeksIto.. strike four. portions of LILCO's ,4 , 1 2~ additional. cylinder-block' testimony.$-Oneportionconcernsan D , 3 alleged mischaracterization of the. stipulation on cani. gallery 1 g
- cracks..;The remaining three portions are treated as a group-by:
Ethe' County.
- In the' County's1 view, tihese three portions.should J
be' stricken-because..they concern. cumulative.dama'ge. calculations (- ' based on "a refinedEdetermination of stresses from1the.(precon-m ' !firmatory test): strain gauge: testing." .~So. viewed, asserts =the County,Lthese portions represent an " attempt to supplement the w . ~ m
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r a: s p: .,c _2_ b record'on.-issues that are already closed, in this case the ade ' lquacy.of-the blocks at 3500/3900 KW. Suffolk County is incorrect on all counts as is demonstrated below for each por- ~ -tion.- 'A.- Pace 9, Answer 9,;Second Paracraph. The County's argument.for striking this portion of the testimony wholly misses the mark. In the first place, the cu- .mulative damage. calculations referred to in the answer's second _ paragraph are r. 't based on and have nothing whatever to do with, "a. refined determination of stresses from the strain ' gauge ~ testing.".Rather, they are the cumulative damage calcu-lations already in. evidence and testified to at length._ More- -over,. contrary to the County's assertion, the reference to
- these calculations in this context:is not an effort to supple-
~ ment the record on'"the adequacy of the blocks at-3500/3900 KW." Rather, the calculations are part of LILCO's basis for concluding that' the blocks are cdequate.at 3300 KW and.that.no .further testing in needed. As such, it is directly responsive tb one_of SC's newly admitted contentions. A review of the ' context amply illustrates this.. p: f ~ e _d
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- , Question 9, which appears on page 8, is Should the replacement block have been tested for 745 hours at or above 3300 KW to~ confirm its adequacy for nuclear ser-vice?
This question is'a paraphrase of, and responds directly to, County contention _.(c)(i), which the Board ordered litigated in the reopened block proceeding. Given this, the question is undeniably relevant. So, too, is the entire answer, including the second paragraph which the County attacks here. In the'first para-graph (not attacked here),.Mr. Youngling and.Dr. Rau state, in direct response to-the question, that it was not necessary to subject-the EDG 103 replacement block.to the entire 745 hours
- of testing to demonstrate its suitability for nuclear service.
Two reasons are given. First, Dr. Rau and Mr. Youngling point
- out.in the first paragraph that the 745-hour confirmatory test was-performed primarily to evaluate the adequacy of the re-placement crankshaft.
Still.in_the first paragraph, Dr. Rau
- and Mr.-! Youngling testified that operation of the EDG 103 re-placement-block for more.than 849_ hours, of which more than 577 hours ware at'or.above 3300 KW, confirmed their previous opin-ion, based on the extensive testing of_the'R-5 engine, that the replacement. block-is both proven and adequately tested.
,ad aj ,.The second paragraph, here attacked by the County, . refers to'the cumulative damage calculations as yet another reason further testing >is unnecessary. Dr. Rau states that since~the replacement block had'not developed any ligament cracks after more than 577 hours of operation at or above 3300 KW, furtherftesting was unnecessary because prior cumulative damage analyses-demonstrated that any ligament cracks that might hypothetically be' assumed to develop would not impair the
- operation of'the engine.1/
In1 sum, this reference to cumulative damage ~ calculations, contrary to SC's1 claims, is not based on a re-fined determination of strain gauge stresses, is not directed to the! adequacy of - the blocks at :3500/3900 KW, and imposes no .unduetburden.on the County. _This reference to prior cumulative l damage calculations - is admissible because it respon'ds directly ~ 4 to one of: the County's newly. admitted contentions. s. ~ 1/. Pertinent, too, in this context is the following directive in the Board's January 18, 1985 order, at-page 2. As'is generally.the case, any necessary further testimony on reopened _and supple-mented issues shall make use of the exist-ring record to the extent:possible. l
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k~ En . 4 . B. Pace 3, Answer 3.2, Third sentence This portion of the testimony the County seeks to . strikeLreads as follows: Further, cumulative damage analysis shows that, if a postulated LOOP /LOCA occurs, the EDGs will perform their intended function with greater margin at the qualified load than at the higher loads previously analyzed. ' The reference here is to cumulative damage analysis at - 3300 KW-performed by FaAA since the last hearings. Suffolk County / contends, inter alia, that this testimony is outside the " permissible scope of evidence contemplated by the Board's December 4, 1984 order." Suffolk County motion, page 1. While 4 the Board's December 4 order does not,specifically mention cu-mulative damage analyses at 3300 KW, it seems apparent that the Board's' purpose in granting the, reopening was to permit LILCO an opportunity.to show that the blocks will perform their intended function at 3300 KW. LILCO's reference in the testimony on page 3 to-cumulative damage analysis at 3300 KW ' responds to this purpose. Quite apart from this, it is important to note that'the
- County's recent additional testimony regarding the cylinder block criticizes LILCO for not having undertaken a detailed t
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- crack. propagation: analysis to ascertain the mechanics and rate
-of crack propagation. Testimony of Dale G. Bridenbaugh dated JJanuary'25,:1985, page 2. LILCO's cumulative damage analysis 'at: 3300 KW in? f act'.does' just this. The County seems to want to have it both ways -- to preclude LILCO from using its 3300 KW ' analysis and to: criticize LILCO for not doing or presenting 'such an analysis. This is: manifestly unfair. The appropriate reso1ution is to admit the testimony and permit SC to cross ex- ~ . amine.to: see.whether.-~any criticisms of the analysis are war- . ranted. 4 f . C.- L Pace 13. Answer 15 This question and answer concern the additional ~ cumulative; damage analyses performed by FaAA since the '( conclusion of'the: previous ~ hearings. These analyses do employ !a refined determination of: stresses from'the original EDG 103 ~ strain gauge testing'. gThe' pertinent calculations wer'e re-flected in the final generic block. report issued and distrib- ~uted to the Board -and : parties' in December,1984. Calculations L .were performed!at 3300 KW and at the previous loads.which.per-- ~
- mits a valid comparison-to be made.
This type of comparison .was anticipated by the. Board in! ruling ~on LILCO's motion to re-open the record. -See Tr."26,924.- Since the calculations show 4 - e =+
. that there is greater margin at 3300 KW than at 3500 KW, testi-many concerning the calculations is pertinent to the issue at ~ hand - the adequacy of the blocks at 3300 KW. D. Pace 17, Answer 18 'Here SC claims LILCO has mischaracterized the stipulation on cam gallery cracks. This objection is unfounded and trivial. Specifically, Suffolk County objects to the phrase on-page 17 which provides:- . the parties have stipulated that the oxide layer was formed at high tem-peratures.at the time of the casting' pro-cess'and that the layer was not due to . fretting corrosion or graphitic corro-sion. The County asserts that the answer should be phrased-that-the evidence " indicates" that the oxide layer was formed at high temperatures, etc. Similarly, the County objects to the sentence-on-page 17 which states:. the parties-have-stipulated that the evidence justifies the conclusion that the cracks in the cam' gallery areas of EDG 101 and 102 formed during the casting process,'and that this supports J
i . the conclusion that the cam gallery ~ cracks in the EDGs 101~and 102 did not propagate during or as a result of EDG operation. The; County argues that the testimony should read that "the parties have. stipulated that the evidence ' indicates' that the cracks in the. cam; gallery areas. LILCO cannot see-what earthly difference this makes. There is surely nothing to be misled about and, in any event, the stipulation _was attached to LILCO's testimony as. Exhibit B-67..Moreover, there is, so far as LILCO knows, no dispute between the parties regarding the Stipulation or its effect. The County has stipulated that it "does not seek to disqualify ^ the use'of-the blocks of the EDGs 101 and 102 and the new block of EDG 103 on the basis of the existence of cam gallery . cracks." Clearly, the County and the State of New York would not have so stipulated if they did not believe that-the x-ray crystallography. established that the-oxide layer formed at high temperatures during the time of the casting process and that these layers were not due.to fretting or-graphitic corrosion. The1 ounty's Motion.to Strike merely plays word games. C Whether " indica.tes,"-" demonstrates," "means," or " supports the -conclusion" is used, the bottom line is that the County
_g_ stipulated, based on the x-ray test results, that the oxide layer formed at high temperatures during the time of the
- casting process, that these-layers were not due to fretting or graphitic 1 corrosion, and that the cracks have not propagated during or as.a result of EDG operation.
If the County now in- .tends to argue.to the contrary with respect to any of these points, then LILCO.is surprised and has been seriously misled
- in'this process.
In-summary, nothing in SC's Motion to Strike requires that 'this answer be -stricken or revised. II. Crankshaft Testimony lA. Page 4,~ Answer 8 SC. seeks to strike those portions'of Answer 8 on page 4 -that refer to "new. safety factor calculations (at 3500.KW) under the.Kritzer-Stahl criteria-using a lower UTS" (ultimate tensile strength). Presumably, the County is specifically .. referring to tvo portions of thatLanswer, (i) the third sentence and (ii)~a derivat'ivefphrase'in the last sentence. These are as follows. Third sentence: 7
LThe actual-safety margin at 3500 KW is l~.248, based on a UTS of 700 Newtons per square millimeter, while it is.l.239 based on a UTS of 695 Newtons per square millimeter. -Last sentence with phrase underscored: Thus, as.one can see, the safety factor is essentially the same for each -respective-load regardless of whether one utilizes-695 or 700 Newtons per square millimeter for the ultimate tensile strength. First,. contrary to SC's suggestion, there is nothing new in the~ third sentence. In the previous hearing, Dr. ~ ..Pischinger testified.on cross-examination by the Staff that the safety margin at 3500 KW using.a UTS'of 700 Newtons per square centimeter is.l.247.- Tr. 22,993, 23,004. Dr. Pischinger also
- testified that.using a UTS of-695 would make a~ difference of lessithan.one1 percent or.8% less.
- See, e.g., Tr. 22,993.
Fi-nally,iDr. Pischinger further testified that using the lower >UTS-made-no;significant difference. Id. The only. difference -between':the thir'd" sentence of Answer 8 and his'previousLtesti-e... LmonyLis that the actual. figure is given rather than just' the fpercentage difference. The' factor'of.1.239 is easily-and'ap-
- proximately obtained using the percentage difference.
By no stretch ofLth'e~ imagination,'then, does the. addition of the
- safety factor. figure-impose any burden.
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- p IMore1 importantly,.this evidence relating to 3500 KW is k [directly... responsive to-SC's newly-admitted qualified load m (cont'ention,E and :therefore should not be stricken. In para- ' graphs l(a) ( i)',j ( ii), (iii)'and (iv) of the contention (and in -fitsftestimony,Ltoo),- the-County asserts that intermittent'and . cyclic loads'orfoperator errors may result in diesel generator loadsfabove 3300'KW. The purpose of a portion of Dr. !g: ~ Pischinger's additional 1 testimony-(including Answer 8) is to Lestablish~that;in his' opinion any. alleged excursions over 3300 L KW' postulated!by the[ County.would not adversely affect the > crankshaft even:if they were to occur.2/ One of Dr.- Pischinger's' stated bases for' this conclusion is his previous testimonyfthat:the;cra'nkshafts are adequate at-3500 KW and have ~ 4" - -?unlimi_ted'lifeJat:that load level with a safety factor of 1.248 4 -atta1UTStof 700-and a safety factor approximately.8% less.at a ~ ~UT,S ofl695.- r ,.N..
- In? summary, the'relis nothing new :in -Dr. Pischinger's :
referenceiin Answer.8 to 3500 KW' safety factors. Moreover,'no %:~ j@portionsio'f Answerf8.should'be stricken because the' answer is a ~ C ; %' a' J .in turn, is-prydi'cate:for Dr.cPischinger's1 testimony that, 7 ~c &w l2_/[ -~See,-e.Q.,? Answers 25, 26;and127,' Additional Crankshaft 1 q .'.;Testimonyfof~ Franz F.iPischinger,lDuane P. Johnson and!Milford-s - t* H.' LSchu' ster, pagesfil-13. N _
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'^g-, directly responsive to portions of SC's newly admitted load contention. LONG ISLAND LIGHTING COMPANY 7 7 T. 5 P t IS, til T. S. Ellis, III Anthony F. Earley, Jr. Hunton & Williams 707: East-Main Street
- P. O. Box 11535 Richmond, Virginia 23212 John Jay Range-
-Hunton & Williams-2000. Pennsylvania Avenue, N.W. ~P. O.: Box 19230-Washington,_D.C. 20036 Odes.L. Stroupe, Jr. Hunton & Williams 333 Fayetteville Street P. O.: Box :109 . Rale'igh, North-Carollina - 27602-DATED::-January-29, 1985 4 7 N A s - - -, + e-
3 LILCO, January 29, 1985 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY L(Shoreham Nuclear Power Station, Unit 1) Docket No. 50-322-OL-4 (Low Power) I.hereby certify that copies of LILCO's Response to Suffolk-~ County's Motion to Strike were served this date upon the following by first-class mail, postage prepaid, or by hand, Tas. indicated by as asterisk: Lawrence Brenner, Esq.* Atomic Safety-and Licensing-TAtomic Safety and Licensing Appeal Board Panel . Board Panel U.S. Nuclear Regulatory -Commission .U.S. NRC Washington, D.C. 20555 '4350 East-West Highway Fourth Floor-(North Tower) -Bethesda, Maryland 20814 Atomic Safety and Licensing Board Panel Dr. Peter A. Morris
- U.S. Nuclear _ Regulatory Atomic Safety and Licensing Commission
-Board Panel Washington, D.C. 20555 ,U.S. NRC 4350 East-West Highway Robert E. Smith, Esq.- Fourth Floor (North Tower) Guggenheimer & Untermyer-Bethesda, Maryland 20814 80 Pine: Street New York, N.Y.~ 10005 Dr. George A. Ferguson* iAtomic Safety;and Licensing Robert G. Perlis, Esq.* .. Board' U.S. : Nuclear Regulatory School'of-Engineering -Commission Howard University. 37735 Old'Georgetown Road; 2300 6th Street,-N.W. . Maryland' National Bank Bldg. Washington, D.C.. 20555-Bethesda,_ Maryland.20814-Sec'retary of the Commission. Alan R.!Dynner, Esq.* L U.~S.1 Nuclear Regulato,ry ' Kirkpatrick'& Lockhart ' Commiss ion-' 1900 M Street, N.W. LWashington,'D.C. 20555 Washington,'D.C.- 20036 ~ Mr.: Marc W.~ Goldsmith Stephen B. Latham, Esq._ ~ . Energy:Research Group Twomey, Latham & Shea .400lLTotten Pond Road 33 West 1Second Street
- Waltham, Massachusetts. 02154 P. O. Box 398
.Riverhead, New York 11901 w
j *- - MHB Technical Associates Ralph shapiro, Esq. 1723. Hamilton Avenue Cammer and Shapiro, P.C. Suite K' 9 East 40th Street San Jose, California 95125 New York, N.Y. 10016 - Mr.: Jay Dunkleberger James Dougherty, Esq.
- New York State Energy Office 3045 Porter Street Agency-Building 2 Washington, D.C.
20008 Empire State Plaza Albany, New York 12223 Martin Bradley Ashare, Esq. Attn: Patricia A. Dempsey, Esq. Jonathan D. Feinberg, Esq. County Attorney State of New York _Suffolk. County Department of Law Department of Public Service Veterans Memorial Highway Three-Empire State Plaza Hauppauge, New York 11787 ' Albany,-New1 York -12223 ' Howar'd 1 L. Blau 217.Newbridge Road . Hicksville,-New York 11801 h/T. S. ELLIS, m T. S._ Ellis,.III John Jay Range Hunton.&: Williams. 707 East; Main Street P.O.? Box 1535 Richmond, Virginia 23212-DATED: -January 29, 1985. l' '.}}