ML20106D147
| ML20106D147 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/11/1985 |
| From: | Range J HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-540 OL, NUDOCS 8502130016 | |
| Download: ML20106D147 (5) | |
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LILCO, Fdbruary 11, 1985 c
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 85 FR! 11 P4 :36 Before the Atomic Safety and Licensino Board
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LONG ISLAND LIGHTING COMPANY
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(Shoreham Nuclear Power Station,
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Unit 1)
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LILCO'S MOTION TO STRIKE PORTIONS OF NRC STAFF TESTIMONY OF JOHN L. KNOX AND PORTIONS OF NRC STAFF JOINT TESTIMONY OF SPENCER H.
(1)
LILCO, by counsel, moves to strike the first and second full paragraphs on page 6 of the testimony of NRC Staff witness John L. Knox on the grounds that such testimony is unresponsive, unfounded and not within the scope of diesel gen-erator load contention a(i) and (iv).
First, this testimony is unresponsive because it has nothing whatever to do with inter-mittent and cyclic loads, the subject of the question.
The question concerns estimates relating to the worst case cyclic and intermittent loads.
The portions of the testimony that LILCO seeks stricken do not relate in any way to cyclic or in-termittent loads. 'Hence the answer is unresponsive and should be stricken.
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- Second, the portions of the testimony LILCO seeks stricken here include opinions concerning break mean effective pressures (BMEP's) that may result from certain fuel rack posi-tions or fuel settings on the diesel engine.
Such opinions re-quire expertise in mechanics, dynamics and thermodynamics.
NRC Staff witness Knox has no such expertise.
Rather, he is an electrical engineer in the Power Systems Branch.
Nothing in his testimony or resume indicates that he has any expertise or training in the operation or analysis of diesel engines.
Ac-cordingly, this portion of NRC Staff witness Knox's testimony should be stricken as unfounded and incompetent.
Third, NRC' Staff witness Knox's testimony is explic-itly directed solely at subparagraphs a(i) and (iv) of the die-sel generator load contention.
Paragraph a(i) concerns the ex-clusion of intermittent and cyclic loads from the qualified load and paragraph (iv) concerns operator error.
The portion of the testimony LILCO seeks stricken here is wholly unrelated to either of these sections of the contention.
Accordingly, this testimony should be stricken as outside the scope of the contention ~.
(2)
LILCO, by counsel, moves to strike all references to Det Norske Veritas on page 21 of NRC Staff witness Sarsten's.
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testimony on the grounds that such references are outside the scope of the contention and irrelevant.
By Order dated September 7, 1984, the Board ruled that Det Norske Veritas, among.others, was outside the scope of the crankshaft conten-tion.
A related exhibit was also stricken.
See Order dated September 7, 1984 at page 8.
Accordingly, this previous Board Order requires the exclusion of this testimony.
So too, by im-plication, does the Board's clarification of the scope of the reopening that appears at Tr. 26,929-30.
LONG ISLAND LIGHTING COMPANY
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T. S. Ellis, III Anthony F. Earley, Jr.
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Hunton & Williams P. O. Box 1535 Richmond, Virginia 23212 Odes L. Stroupe, Jr.
Hunton & Williams P. O.
Box 109 Raleigh, North Carolina 27602 John Jay Range Hunton &' Williams P. O. Box 19230 Washington, D.C.
20036 DATED:
February 11, 1985
d JC CERTIFICATE OF SERVICE c
In the Matter of
-w LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, UniA 1)FEB 11 P4 :36 Docket No.'50-322 (OL) 03 I hereby certify that copies of Lilco's MoAion to Strike Portions of.NRC Staff Testimony of John L. Kno10and. Pofttions of NRC Staff Jint Testimony of Spencer H. Bush, et alDMebe served this date upon the following by first-class mail, post-age prepaid, or by hand as indicated by an asterisk:
Lawrence Brenner, Esq.*
Secretary of the Commission
- Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 4350 East-West Highway Appeal Board Panel Fourth Floor (North Tower)
U.S. Nuclear Regulatory Bethesda, Maryland 20814 Commission
.Dr. Peter A. Morris *-
Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board-Panel U.S. Nuclear Regulatory Commission U.S. Nuclear-Regulatory
. Washington, D.C.
20555
-Commission 4350 East-West Highway Fourth Floor (North Tower)
Robert E. Smith, Esq.
Bethesda, Maryland.20814 Guggenheimer &.Untermyer 80 Pine. Street Dr. George A. Ferguson*
- Administrative Judge School of Engineering
-Herbert H. Brown, Esq.*
Howard University Lawrence Coe Lanpher, Esq.
Alan R. Dynner, Esq.
' Room 1114 Joseph J.
Brigati, Esq.
- 2300 6th Street, N.W.
-Washington, D.C.
20059 Kirkpatrick & Lockhart 1900 M Street,-N.W.
8th Floor Washington, D.C.
20036
8 Bernard M. Bordenick, Esq.*
Stephen B.
Latham, Esq.
David A. Repka, Esq.
Twomey, Latham & Shea Richard J. Goddard, Esq.
33 West Second Street U.S. Nuclear Regulatory Post Office Box 398 Commission Riverhead, New York 11901 Maryland National Bank Bldg.
7735 Old Georgetown Road Ralph Shapiro, Esq.
Bethesda, Maryland 20814 Cammer and Shapiro, P.C.
9 East 40th Street Martin Bradley Ashare, Esq.
New York, New York 10016 Attn:-Patricia A. Dempsey, Esq.
County Attorney James Dougherty,-Esq.
Suffolk County Department 3045 Porter Street of Law Washington, D.C.
20008 Veterans Memorial Highway Hauppauge, New York 11787 Jonathan D.
Feinberg, Esq.
New York State Mr. Marc W. Goldsmith Department of Public Service Energy Research Group Three Empire State Plaza 4001 Totten Pond Road Albany, New York 12223 Waltham, Massachusetts 02154 Howard L.
Blau MHB Technical Associates 217 Newbridge Road 1723 Hamilton Avenue Hicksville, New York 11801 Suite K San Jose, California 95125 Fabian G. Palomino, Esq.
Special Counsel to the Mr. Jay Dunkleberger Governor New York State Energy Office Executive Chamber, Room 229
-Agency. Building 2 State Capitol Empire State Plaza Albany, New York 12224 Albany, New York 12223 1.
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20036 DATED:
February-11, 1985
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