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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* 1995-10-18
[Table view] Category:TRANSCRIPTS
MONTHYEARML20245K9371989-04-20020 April 1989 Transcript of Commission 890420 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-5 ML20247R4421989-04-20020 April 1989 Transcript of Commission 890420 Press Conference in Rockville,Md.Pp 1-10 ML20245G5661989-04-17017 April 1989 Transcript of 890417 Discussion of Plant Full Power OL in Rockville,Md.Pp 1-70.Supporting Documentation Encl ML20236E1021989-03-0303 March 1989 Transcript of Commission 890303 Affirmation,Discussion & Vote in Rockville,Md Re SECY-89-77, Shoreham Sanction Decision. Pp 1-5 ML20247R4321989-03-0303 March 1989 Transcript of Commission 890303 Press Conference in Rockville,Md Re Shoreham Proceedings.Pp 1-10 ML20235V6301989-03-0101 March 1989 Testimony of F Kantor,Em Podolak & Rt Hogan of NRC Staff on Scope of Exercise.* Purpose of Testimony Is to Rebut Testimony of Intervenors Re Contention 1 ML20235V3841989-03-0101 March 1989 Direct Testimony of Iw Husar & Jh Keller Concerning June 1988 Emergency Preparedness Exercise.* Certificate of Svc Encl.Related Correspondence ML20235N1221989-02-24024 February 1989 Rebuttal Testimony of Jr Asher,Dm Crocker,Rb Kelly,Jj Kozak & Cl Stovall on Contention 1 (Scope of Exercise).* Related Documentation Encl.Related Correspondence ML20235N1501989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 6 (Emergency Broadcast Sys Messages) & 7.E & F (Enc).* Attachments Encl. Related Correspondence ML20235N1641989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 18 (Communications Equipment & Reception Failures).* Related Correspondence ML20235Y5811989-02-21021 February 1989 Transcript of Commission Oral Argument on 890221 in Rockville,Md Re Sanction Issue in Shoreham Proceeding ML20247R4091988-12-31031 December 1988 Transcript of Commission 881221 Press Conference in Rockville,Md.Pp 1-31 ML20196F2881988-12-0606 December 1988 Transcript of 881206 Hearing in Bethesda,Md Re Plant. Pp 1-122 ML20154E4761988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Appeal of Initial Decision Concerning Emergency Exercise.Pp 1-91 ML20154E4631988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Util Reception Ctrs That Will Be Used in Event of Radiological Emergency.Pp 1-98 ML20151C3041988-07-19019 July 1988 Transcript of 880719 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,830-22,074.Witnesses:F Jones,We Regan, R Shepherd & D Davidoff ML20151B3391988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,537-21,720.Witnesses:N Kelly & D Axelrod ML20151B3671988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,721-21,829.Witnesses:N Kelly, D Axelrod & Aj Geramo ML20150E0791988-07-11011 July 1988 Transcript of 880711 Hearing in Bethesda,Md Re Emergency Planning.Pp 20,944-21,174 ML20150F7781988-07-11011 July 1988 Transcript of 880711 Evening Session in Bethesda,Md Re Emergency Planning.Pp 21,175-21,290.Witnesses:JD Papile & DA Devito ML20196J4891988-06-29029 June 1988 Transcript of 880629 Conference in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,929-20,943 ML20196A4261988-06-24024 June 1988 Transcript of 880624 Hearing in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,894-20,928 ML20155K5671988-06-17017 June 1988 Transcript of 880617 Telcon Hearing in Bethesda,Md Re Emergency Planning/School Bus Driver Issue.Pp 20,863-20,893 ML20154D1181988-06-15015 June 1988 Transcript of FEMA 880615 Public Meeting in Patchougue,Ny Re Util.Pp 1-131 ML20155E1751988-06-10010 June 1988 Transcript of 880610 Telcon in Washington,Dc Re Remand/ Emergency Planning.Pp 20,845-20,862 ML20197E3231988-06-0303 June 1988 Transcript of 880603 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 20,686-20,844.Supporting Documentation Encl.Witness:D Hartgen ML20154R2881988-06-0202 June 1988 Transcript of 880602 Hearing in Happauge,Ny Re Emergency Planning.Pp 20,555-20,685.Supporting Documentation Encl ML20197E0401988-05-31031 May 1988 Corrections to Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Bases & Accuracy of Lilco Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20154M8571988-05-27027 May 1988 Transcript of 880527 Hearing in Hauppauge,Ny. Pp 20,440-20,554.Witness:T Urbanik ML20154M8511988-05-26026 May 1988 Transcript of 880526 Hearing Re Emergency Planning/School Bus Driver Issue in Hauppauge,Ny.Pp 20,245-20,439.Supporting Documentation Encl.Witnesses:Bg Brodsky,Ej Doherty, Hm Koenig,Ar Rossi,Rw Petrilak,Nf Muto,Jt Smith,Rn Suprina ML20197E1201988-05-26026 May 1988 Surrebuttal Testimony of Dt Haertgen on Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20197E1631988-05-24024 May 1988 Addendum to Direct Testimony of Bg Brodsky,Ej Doherty, Hm Koenig,Nf Muto,Rw Petrilak,Ar Rossi,Jt Smith & Rn Suprina on Behalf of Suffolk County Re Contention 25.C.* W/ Certificate of Svc.Related Correspondence ML20154F7741988-05-18018 May 1988 Transcript of 880518 Hearing in Hauppauge,Ny. Pp 19,831-19,998.Witnesses:D Mileti,Mk Lindell,Rb Kelly ML20154H7981988-05-18018 May 1988 Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Base & Accuracy of Lilco Hosp Evacution Time Estimates.Certificate of Svc Encl ML20154F7421988-05-17017 May 1988 Transcript of 880517 Hearing in Hauppauge,Ny. Pp 19,612-19,830 ML20154D4751988-05-16016 May 1988 Transcript of 880516 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 19,390-19,611.Supporting Documentation Encl.Witnesses:Dm Crocker,D Mileti,Mk Lindell, RB Kelly ML20154D9221988-05-12012 May 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Immateriality Issues.* Hartgen Resume & Certificate of Svc Encl.Related Correspondence ML20153H6721988-05-10010 May 1988 Transcript of 880510 Prehearing Conference in Bethesda,Md. Pp 19,323-19,389 ML20154B4621988-05-10010 May 1988 Lilco Supplemental Testimony on Remanded Issue of Role Conflict of School Bus Drivers.* Certificate of Svc Encl ML20154B7841988-05-0606 May 1988 Direct Testimony of Gc Minor & Sc Sholly on Behalf of Suffolk County Re Immateriality.* Certificate of Svc Encl. Related Correspondence ML20154B5421988-05-0606 May 1988 Testimony of DM Behr,Dm Crocker,Dp Dreikorn,Eb Lieberman & Ja Weismantle on Best Efforts Contentions EP 1-2,4-8 & 10.* Supporting Documentation & Certificate of Svc Encl.W/One Oversize Map.Related Correspondence ML20154C7511988-05-0404 May 1988 Transcript of 880504 Annual Briefing on State of Nuclear Industry in Rockville,Md.Pp 1-60. Introductory Remarks, State of Industry Rept & Status Rept on Util Research... Encl.Served on 880509 ML20151V9271988-04-28028 April 1988 Transcript of 880428 Hearing in Bethesda,Md Re Emergency Preparedness Exercise.Pp 1-94 ML20151Z0711988-04-28028 April 1988 Testimony of Jj Boursy.* Addresses Issue of Measured Signal Strength of Fm Radio Station Wplr,New Haven,Ct within EPZ for Plant.Related Correspondence ML20154B7061988-04-22022 April 1988 Deposition of D Axelrod.* Deposition Taken in Albany,Ny Re Emergency Planning ML20154H6621988-04-21021 April 1988 Deposition of Gc Minor.* Transcript of Gc Minor Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154H6311988-04-21021 April 1988 Deposition of Sc Sholly.* Transcript of Sc Sholly Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154B6861988-04-19019 April 1988 Deposition of Pg Halpin.* Deposition Taken in Happauge,Ny Re Emergency Planning/Best Efforts Issue ML20148T0191988-04-13013 April 1988 Testimony of DM Crocker,Rb Kelly,Mk Lindell & Ds Mileti on Remanded Issue of Role Conflict of School Bus Drivers.* Addl Info Re Bus Driver Issue During Emergency Evacuations Encl.W/Certificate of Svc.Related Correspondence ML20151N9191988-04-13013 April 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Util Hosp Evacuation Time Estimates Not Reliable for Stated Reasons.Certificate of Svc Encl.Related Correspondence 1989-04-20
[Table view] Category:DEPOSITIONS
MONTHYEARML20245K9371989-04-20020 April 1989 Transcript of Commission 890420 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-5 ML20247R4421989-04-20020 April 1989 Transcript of Commission 890420 Press Conference in Rockville,Md.Pp 1-10 ML20245G5661989-04-17017 April 1989 Transcript of 890417 Discussion of Plant Full Power OL in Rockville,Md.Pp 1-70.Supporting Documentation Encl ML20236E1021989-03-0303 March 1989 Transcript of Commission 890303 Affirmation,Discussion & Vote in Rockville,Md Re SECY-89-77, Shoreham Sanction Decision. Pp 1-5 ML20247R4321989-03-0303 March 1989 Transcript of Commission 890303 Press Conference in Rockville,Md Re Shoreham Proceedings.Pp 1-10 ML20235V6301989-03-0101 March 1989 Testimony of F Kantor,Em Podolak & Rt Hogan of NRC Staff on Scope of Exercise.* Purpose of Testimony Is to Rebut Testimony of Intervenors Re Contention 1 ML20235V3841989-03-0101 March 1989 Direct Testimony of Iw Husar & Jh Keller Concerning June 1988 Emergency Preparedness Exercise.* Certificate of Svc Encl.Related Correspondence ML20235N1221989-02-24024 February 1989 Rebuttal Testimony of Jr Asher,Dm Crocker,Rb Kelly,Jj Kozak & Cl Stovall on Contention 1 (Scope of Exercise).* Related Documentation Encl.Related Correspondence ML20235N1501989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 6 (Emergency Broadcast Sys Messages) & 7.E & F (Enc).* Attachments Encl. Related Correspondence ML20235N1641989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 18 (Communications Equipment & Reception Failures).* Related Correspondence ML20235Y5811989-02-21021 February 1989 Transcript of Commission Oral Argument on 890221 in Rockville,Md Re Sanction Issue in Shoreham Proceeding ML20247R4091988-12-31031 December 1988 Transcript of Commission 881221 Press Conference in Rockville,Md.Pp 1-31 ML20196F2881988-12-0606 December 1988 Transcript of 881206 Hearing in Bethesda,Md Re Plant. Pp 1-122 ML20154E4761988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Appeal of Initial Decision Concerning Emergency Exercise.Pp 1-91 ML20154E4631988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Util Reception Ctrs That Will Be Used in Event of Radiological Emergency.Pp 1-98 ML20151C3041988-07-19019 July 1988 Transcript of 880719 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,830-22,074.Witnesses:F Jones,We Regan, R Shepherd & D Davidoff ML20151B3391988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,537-21,720.Witnesses:N Kelly & D Axelrod ML20151B3671988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,721-21,829.Witnesses:N Kelly, D Axelrod & Aj Geramo ML20150E0791988-07-11011 July 1988 Transcript of 880711 Hearing in Bethesda,Md Re Emergency Planning.Pp 20,944-21,174 ML20150F7781988-07-11011 July 1988 Transcript of 880711 Evening Session in Bethesda,Md Re Emergency Planning.Pp 21,175-21,290.Witnesses:JD Papile & DA Devito ML20196J4891988-06-29029 June 1988 Transcript of 880629 Conference in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,929-20,943 ML20196A4261988-06-24024 June 1988 Transcript of 880624 Hearing in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,894-20,928 ML20155K5671988-06-17017 June 1988 Transcript of 880617 Telcon Hearing in Bethesda,Md Re Emergency Planning/School Bus Driver Issue.Pp 20,863-20,893 ML20154D1181988-06-15015 June 1988 Transcript of FEMA 880615 Public Meeting in Patchougue,Ny Re Util.Pp 1-131 ML20155E1751988-06-10010 June 1988 Transcript of 880610 Telcon in Washington,Dc Re Remand/ Emergency Planning.Pp 20,845-20,862 ML20197E3231988-06-0303 June 1988 Transcript of 880603 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 20,686-20,844.Supporting Documentation Encl.Witness:D Hartgen ML20154R2881988-06-0202 June 1988 Transcript of 880602 Hearing in Happauge,Ny Re Emergency Planning.Pp 20,555-20,685.Supporting Documentation Encl ML20197E0401988-05-31031 May 1988 Corrections to Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Bases & Accuracy of Lilco Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20154M8571988-05-27027 May 1988 Transcript of 880527 Hearing in Hauppauge,Ny. Pp 20,440-20,554.Witness:T Urbanik ML20154M8511988-05-26026 May 1988 Transcript of 880526 Hearing Re Emergency Planning/School Bus Driver Issue in Hauppauge,Ny.Pp 20,245-20,439.Supporting Documentation Encl.Witnesses:Bg Brodsky,Ej Doherty, Hm Koenig,Ar Rossi,Rw Petrilak,Nf Muto,Jt Smith,Rn Suprina ML20197E1201988-05-26026 May 1988 Surrebuttal Testimony of Dt Haertgen on Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20197E1631988-05-24024 May 1988 Addendum to Direct Testimony of Bg Brodsky,Ej Doherty, Hm Koenig,Nf Muto,Rw Petrilak,Ar Rossi,Jt Smith & Rn Suprina on Behalf of Suffolk County Re Contention 25.C.* W/ Certificate of Svc.Related Correspondence ML20154F7741988-05-18018 May 1988 Transcript of 880518 Hearing in Hauppauge,Ny. Pp 19,831-19,998.Witnesses:D Mileti,Mk Lindell,Rb Kelly ML20154H7981988-05-18018 May 1988 Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Base & Accuracy of Lilco Hosp Evacution Time Estimates.Certificate of Svc Encl ML20154F7421988-05-17017 May 1988 Transcript of 880517 Hearing in Hauppauge,Ny. Pp 19,612-19,830 ML20154D4751988-05-16016 May 1988 Transcript of 880516 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 19,390-19,611.Supporting Documentation Encl.Witnesses:Dm Crocker,D Mileti,Mk Lindell, RB Kelly ML20154D9221988-05-12012 May 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Immateriality Issues.* Hartgen Resume & Certificate of Svc Encl.Related Correspondence ML20153H6721988-05-10010 May 1988 Transcript of 880510 Prehearing Conference in Bethesda,Md. Pp 19,323-19,389 ML20154B4621988-05-10010 May 1988 Lilco Supplemental Testimony on Remanded Issue of Role Conflict of School Bus Drivers.* Certificate of Svc Encl ML20154B7841988-05-0606 May 1988 Direct Testimony of Gc Minor & Sc Sholly on Behalf of Suffolk County Re Immateriality.* Certificate of Svc Encl. Related Correspondence ML20154B5421988-05-0606 May 1988 Testimony of DM Behr,Dm Crocker,Dp Dreikorn,Eb Lieberman & Ja Weismantle on Best Efforts Contentions EP 1-2,4-8 & 10.* Supporting Documentation & Certificate of Svc Encl.W/One Oversize Map.Related Correspondence ML20154C7511988-05-0404 May 1988 Transcript of 880504 Annual Briefing on State of Nuclear Industry in Rockville,Md.Pp 1-60. Introductory Remarks, State of Industry Rept & Status Rept on Util Research... Encl.Served on 880509 ML20151V9271988-04-28028 April 1988 Transcript of 880428 Hearing in Bethesda,Md Re Emergency Preparedness Exercise.Pp 1-94 ML20151Z0711988-04-28028 April 1988 Testimony of Jj Boursy.* Addresses Issue of Measured Signal Strength of Fm Radio Station Wplr,New Haven,Ct within EPZ for Plant.Related Correspondence ML20154B7061988-04-22022 April 1988 Deposition of D Axelrod.* Deposition Taken in Albany,Ny Re Emergency Planning ML20154H6621988-04-21021 April 1988 Deposition of Gc Minor.* Transcript of Gc Minor Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154H6311988-04-21021 April 1988 Deposition of Sc Sholly.* Transcript of Sc Sholly Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154B6861988-04-19019 April 1988 Deposition of Pg Halpin.* Deposition Taken in Happauge,Ny Re Emergency Planning/Best Efforts Issue ML20148T0191988-04-13013 April 1988 Testimony of DM Crocker,Rb Kelly,Mk Lindell & Ds Mileti on Remanded Issue of Role Conflict of School Bus Drivers.* Addl Info Re Bus Driver Issue During Emergency Evacuations Encl.W/Certificate of Svc.Related Correspondence ML20151N9191988-04-13013 April 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Util Hosp Evacuation Time Estimates Not Reliable for Stated Reasons.Certificate of Svc Encl.Related Correspondence 1989-04-20
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20245K9371989-04-20020 April 1989 Transcript of Commission 890420 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-5 ML20247R4421989-04-20020 April 1989 Transcript of Commission 890420 Press Conference in Rockville,Md.Pp 1-10 ML20245G5661989-04-17017 April 1989 Transcript of 890417 Discussion of Plant Full Power OL in Rockville,Md.Pp 1-70.Supporting Documentation Encl ML20236E1021989-03-0303 March 1989 Transcript of Commission 890303 Affirmation,Discussion & Vote in Rockville,Md Re SECY-89-77, Shoreham Sanction Decision. Pp 1-5 ML20247R4321989-03-0303 March 1989 Transcript of Commission 890303 Press Conference in Rockville,Md Re Shoreham Proceedings.Pp 1-10 ML20235V6301989-03-0101 March 1989 Testimony of F Kantor,Em Podolak & Rt Hogan of NRC Staff on Scope of Exercise.* Purpose of Testimony Is to Rebut Testimony of Intervenors Re Contention 1 ML20235V3841989-03-0101 March 1989 Direct Testimony of Iw Husar & Jh Keller Concerning June 1988 Emergency Preparedness Exercise.* Certificate of Svc Encl.Related Correspondence ML20235N1221989-02-24024 February 1989 Rebuttal Testimony of Jr Asher,Dm Crocker,Rb Kelly,Jj Kozak & Cl Stovall on Contention 1 (Scope of Exercise).* Related Documentation Encl.Related Correspondence ML20235N1501989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 6 (Emergency Broadcast Sys Messages) & 7.E & F (Enc).* Attachments Encl. Related Correspondence ML20235N1641989-02-24024 February 1989 Lilco Rebuttal Testimony on Contention 18 (Communications Equipment & Reception Failures).* Related Correspondence ML20235Y5811989-02-21021 February 1989 Transcript of Commission Oral Argument on 890221 in Rockville,Md Re Sanction Issue in Shoreham Proceeding ML20247R4091988-12-31031 December 1988 Transcript of Commission 881221 Press Conference in Rockville,Md.Pp 1-31 ML20196F2881988-12-0606 December 1988 Transcript of 881206 Hearing in Bethesda,Md Re Plant. Pp 1-122 ML20154E4761988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Appeal of Initial Decision Concerning Emergency Exercise.Pp 1-91 ML20154E4631988-09-14014 September 1988 Transcript of 880914 Hearing in Bethesda,Md Re Util Reception Ctrs That Will Be Used in Event of Radiological Emergency.Pp 1-98 ML20151C3041988-07-19019 July 1988 Transcript of 880719 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,830-22,074.Witnesses:F Jones,We Regan, R Shepherd & D Davidoff ML20151B3391988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,537-21,720.Witnesses:N Kelly & D Axelrod ML20151B3671988-07-14014 July 1988 Partial Transcript of 880714 Hearing in Bethesda,Md Re Emergency Planning.Pp 21,721-21,829.Witnesses:N Kelly, D Axelrod & Aj Geramo ML20150E0791988-07-11011 July 1988 Transcript of 880711 Hearing in Bethesda,Md Re Emergency Planning.Pp 20,944-21,174 ML20150F7781988-07-11011 July 1988 Transcript of 880711 Evening Session in Bethesda,Md Re Emergency Planning.Pp 21,175-21,290.Witnesses:JD Papile & DA Devito ML20196J4891988-06-29029 June 1988 Transcript of 880629 Conference in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,929-20,943 ML20196A4261988-06-24024 June 1988 Transcript of 880624 Hearing in Bethesda,Md Re Remand/ Emergency Planning.Pp 20,894-20,928 ML20155K5671988-06-17017 June 1988 Transcript of 880617 Telcon Hearing in Bethesda,Md Re Emergency Planning/School Bus Driver Issue.Pp 20,863-20,893 ML20154D1181988-06-15015 June 1988 Transcript of FEMA 880615 Public Meeting in Patchougue,Ny Re Util.Pp 1-131 ML20155E1751988-06-10010 June 1988 Transcript of 880610 Telcon in Washington,Dc Re Remand/ Emergency Planning.Pp 20,845-20,862 ML20197E3231988-06-0303 June 1988 Transcript of 880603 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 20,686-20,844.Supporting Documentation Encl.Witness:D Hartgen ML20154R2881988-06-0202 June 1988 Transcript of 880602 Hearing in Happauge,Ny Re Emergency Planning.Pp 20,555-20,685.Supporting Documentation Encl ML20197E0401988-05-31031 May 1988 Corrections to Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Bases & Accuracy of Lilco Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20154M8571988-05-27027 May 1988 Transcript of 880527 Hearing in Hauppauge,Ny. Pp 20,440-20,554.Witness:T Urbanik ML20154M8511988-05-26026 May 1988 Transcript of 880526 Hearing Re Emergency Planning/School Bus Driver Issue in Hauppauge,Ny.Pp 20,245-20,439.Supporting Documentation Encl.Witnesses:Bg Brodsky,Ej Doherty, Hm Koenig,Ar Rossi,Rw Petrilak,Nf Muto,Jt Smith,Rn Suprina ML20197E1201988-05-26026 May 1988 Surrebuttal Testimony of Dt Haertgen on Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Certificate of Svc Encl ML20197E1631988-05-24024 May 1988 Addendum to Direct Testimony of Bg Brodsky,Ej Doherty, Hm Koenig,Nf Muto,Rw Petrilak,Ar Rossi,Jt Smith & Rn Suprina on Behalf of Suffolk County Re Contention 25.C.* W/ Certificate of Svc.Related Correspondence ML20154F7741988-05-18018 May 1988 Transcript of 880518 Hearing in Hauppauge,Ny. Pp 19,831-19,998.Witnesses:D Mileti,Mk Lindell,Rb Kelly ML20154H7981988-05-18018 May 1988 Rebuttal Testimony of Eb Lieberman & Dp Dreikorn on Remanded Issue of Base & Accuracy of Lilco Hosp Evacution Time Estimates.Certificate of Svc Encl ML20154F7421988-05-17017 May 1988 Transcript of 880517 Hearing in Hauppauge,Ny. Pp 19,612-19,830 ML20154D4751988-05-16016 May 1988 Transcript of 880516 Hearing in Hauppauge,Ny Re Emergency Planning/School Bus Driver Issue.Pp 19,390-19,611.Supporting Documentation Encl.Witnesses:Dm Crocker,D Mileti,Mk Lindell, RB Kelly ML20154D9221988-05-12012 May 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Immateriality Issues.* Hartgen Resume & Certificate of Svc Encl.Related Correspondence ML20153H6721988-05-10010 May 1988 Transcript of 880510 Prehearing Conference in Bethesda,Md. Pp 19,323-19,389 ML20154B4621988-05-10010 May 1988 Lilco Supplemental Testimony on Remanded Issue of Role Conflict of School Bus Drivers.* Certificate of Svc Encl ML20154B7841988-05-0606 May 1988 Direct Testimony of Gc Minor & Sc Sholly on Behalf of Suffolk County Re Immateriality.* Certificate of Svc Encl. Related Correspondence ML20154B5421988-05-0606 May 1988 Testimony of DM Behr,Dm Crocker,Dp Dreikorn,Eb Lieberman & Ja Weismantle on Best Efforts Contentions EP 1-2,4-8 & 10.* Supporting Documentation & Certificate of Svc Encl.W/One Oversize Map.Related Correspondence ML20154C7511988-05-0404 May 1988 Transcript of 880504 Annual Briefing on State of Nuclear Industry in Rockville,Md.Pp 1-60. Introductory Remarks, State of Industry Rept & Status Rept on Util Research... Encl.Served on 880509 ML20151V9271988-04-28028 April 1988 Transcript of 880428 Hearing in Bethesda,Md Re Emergency Preparedness Exercise.Pp 1-94 ML20151Z0711988-04-28028 April 1988 Testimony of Jj Boursy.* Addresses Issue of Measured Signal Strength of Fm Radio Station Wplr,New Haven,Ct within EPZ for Plant.Related Correspondence ML20154B7061988-04-22022 April 1988 Deposition of D Axelrod.* Deposition Taken in Albany,Ny Re Emergency Planning ML20154H6621988-04-21021 April 1988 Deposition of Gc Minor.* Transcript of Gc Minor Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154H6311988-04-21021 April 1988 Deposition of Sc Sholly.* Transcript of Sc Sholly Deposition in Washington,Dc Re Emergency Planning.Supporting Documentation Encl.Related Correspondence ML20154B6861988-04-19019 April 1988 Deposition of Pg Halpin.* Deposition Taken in Happauge,Ny Re Emergency Planning/Best Efforts Issue ML20148T0191988-04-13013 April 1988 Testimony of DM Crocker,Rb Kelly,Mk Lindell & Ds Mileti on Remanded Issue of Role Conflict of School Bus Drivers.* Addl Info Re Bus Driver Issue During Emergency Evacuations Encl.W/Certificate of Svc.Related Correspondence ML20151N9191988-04-13013 April 1988 Direct Testimony of Dt Hartgen,On Behalf of State of Ny Re Hosp Evacuation Time Estimates.* Util Hosp Evacuation Time Estimates Not Reliable for Stated Reasons.Certificate of Svc Encl.Related Correspondence 1989-04-20
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RELATED ccMEW November 7, 1984 COMETED
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY )
) Docket No. 50-322-OL (Shoreham Nuclear Power Station, )
Unit 1) )
)
)
REBUTTAL TESTIMONY OF DR. ROBERT N. ANDERSON, PROFESSOR STANLEY G. CHRISTENSEN, AND G. DENNIS ELEY Ctb \
C'@M 8411090444 841107 C) {f PDR ADOCK 05000322 s3 --
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i 1.Q. Dr. Anderson, based on FaAA's description of the samples it took from the cylinder blocks of EDG's 101 and 102, do you believe that FaAA has an adequate basis for concluding that those blocks do not contain quantities of Widmanstaetton graphite similar to the quantity found in the old EDG 103 block?
A. (Anderson) No. As I understand FaAA's testimony, they took two small specimens and about ten replications from each block. Based on the FaAA witnesses' descriptions of the sampling performed, they evaluated less than 100 grams of material from each block, and each block weighs 24,000 pounds. Therefore, they have based their conclusions on analysis of approximately 10 parts per million,and that is hardly sufficient to warrant a high degree of scientific certainty about the composition of the EDG 101 and 102 blocks. The fact that FaAA did observe areas in the EDG 102 block samples that had characteristics similar to Widmanstaetton graphite (Tr. 24,754 (Wachob)) underscores my concern about the thoroughness of their sampling in this particular.
2.0 Could residual stress create tensile forces in the block top and cam gallery areas of the cylinder blocks?
A. (Anderson) Yes, and those forces could be substantial because of the complex geometry of the casting in both of those areas.
3.Q. Do you believe it is possible to predict the existence and amount of residual stress in those areas using any analytical
! methods short of actual testing?
i A. No, and no one can do that with any reasonable degree of scientific certainty. The preferred way to evaluate the amount of residual stress in a structure with any degree of scientific certainty is to undertake strain gage testing of the surface in its existing state and compare those results to strain gage readings of the same surface after a piece has been removed from the vicinity.
4.Q. Dr. Anderson, Dr. Rau testified that he did not observe the " multiple small disconnected cracks branching out into the cast iron material" below the tip of the 3/8-inch circumferential crack reported in your Supplemental Testimony (Answer to Question 18, pp. 11-12), and suggested that you may have confused artifact of Widmanstaetten graphite for the cracks you described. Is it possible that you confused artifact of Widmanstaetton graphite for cracks?
A. (Anderson) No. I viewed the particular specimen under a microscope with power varying from 20X to 60X. I did observe random artifact in the area, and I assumed that to be Widman-staetton graphite. However, the branch-like cracks I described in the cited testimony were quite different. The cracks I observed and described in the cited testimony had an organized appearance consistent with the orientation of the larger crack above them and were not random as I would expect artifact from Widmanstaetton graphite to be.
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5.Q. Dr. Wells testified that he considered the risk of structural failure from circumferential cracks to be highly unlikely because one-third of the circumference of the liner landing area consists of stud bosses. Tr. 25,100-01 (Wells).
Do you agree?
A. (Eley, Christensen) No. We cannot be sure that a circumferential crack in the cylinder liner landing area is likely to extend deeply enough to cause a structural failure, but it is clearly possible and cannot fairly be characterized as unlikely. A more serious concern is, as described in our Supplemental Testimony (Answer to Question 20 at p. 13), that such a crack could cause the liner landing to flex under the force created by the 1600-1700 pounds of firing pressure, causing movement of the cylinder liner and leakage of combustion gases outside the cylinder into the cylinder liner landing area.
In that event, and if the circumferential crack extends through the 1-inch depth of the liner landing area that does not consist of stud bosses (about two-thirds of the circumference), then gases would enter the cooling jacket water system. Such gases in the cooling jacket water could cause overheating and require engine shut-down. The alternative to engine shut-down would be to risk the same consequences of overheating due to loss of coolant described at pp. 152-53 of our Revised Joint Testimony, dated October 29, 1984.
6.A. Dr. Anderson, Dr. Rau testified that there is no way you can conclude that the weld material in the cam gallery crack
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' 'sectioned'by FaAA from the old EDG 103 block pulled free from the crack surface due to operating stresses and not due to heat shrinkage as you testified in your supplemental Testimony (Answer to Question 11 at p. 8). Do you stand by your. testimony?
A. (Anderson) Yes. Based on my examination of the crack samples sectioned by FaAA, it appeared that the weld material had
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been simply " puddled" into the crack after it was widened by grinding or arcing. It did not appear that the crack site had been subjected to any pre- or post-heat treatment as part of the welding operation. If these premises are correct, then the weld material would adhere to the cast iron relatively uniformly and would break cleanly from that base metal if the moving force were tensile stress resulting from weld shirkage. The fact that some cast iron was still adhering to the weld material that had separated from one side of the crack therefore makes it more likely that the separation was caused by operating stress and not weld shrinkage.
7.Q. Aside from that analysis, do you have any reason to question Dr. Rau's conclusion that the separation of the weld material from the cast iron in the crack which was sectioned by FaAA from the old EDG 103 block had been caused by tensile stress from shrinkage of the weld material itself?
4 A. (Anderson) Yes. I understand that the weld material is i
l a nickel-iron alloy. The characteristics of nickel-iron weld material are such that they minimize shrinkage and therefore ,
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minimize the likelihood of tensile stress caused by post-cooling shrinkage.
8.Q. Dr. Rau testified that, because of the general shape of the cracks in the old EDG 103 block, even if such a cam gallery crack did propagate, its deepest extension through the 1-1/4 inch cam gallery wall could cause only a pinhole leak at the inner wall. Tr. 25,249-50 (Rau). Do you agree, Dr. Anderson?
A. (Anderson) No, there is no scientific basis for assuming that a cam gallery crack which propagates through the wall in that area would be limited to a pinhole at the inner wall based on the shape of the crack indications that I observed.
Although it is conceivable that the initial extension through the inner wall would begin as a pinhole leak, I would expect it to expand very rapidly once the initial penetration occurs so that the crack surface along the inner wall could extend up to a couple of inches in length.
9.Q. Professor Christensen and Mr. Eley, Dr. Wells testified that even if a cam gallery crack were to penetrate through the wall, there is a horizontal channel and perhaps other pieces of metal in the cam gallery area sufficient to provide support for the camshaft bearing. Tr. 25,254-55 (Wells). Do you agree?
A. (Christensen, Eloy) Yes, provided that Dr. Wells intended his conclusion to be limited to the vertical support for the crankshaft bearing. Our concern in this area as dis-cussed in our Revised Joint Direct Testimony dated October 29, 1984, at p. 176 relates to flexing of the crankshaft horizontally i
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along the plane of the cam gallery wall, not vertically as suggested by Dr. Wells' testimony.
We continue to believe that such horizontal flexing is a concern that is not eliminated by the structural support discussed by Dr. Wells in his 4 testimony.
10.Q. Dr. Rau and/or Dr. Wachob testified that they did not believe that the relatively low temperature environment of the engine when it is not operating would cause the volume of oxidation present on the samples of the cracks removed from the old EDG 103 block -- Dr. Anderson, do you agree?
A. (Andorson) No. As I understand it, the old EDG 103 block was manufactured in the mid-1970s and was maintained during a substantial part of the period af ter that time in a room temperature of 70*F. It is also my understanding that the jacket water temperature in the engine when it is not in opera-tion is maintained at approximately 140*F and I would therefore expect the cast iron in the cam gallery wall to be approxi-mately that temperature. Those temperatures are sufficient to cause oxidation in the quantities measured on the cam gallery crack samples (0.2-0.5 mm) over a period of a few years depen-ding, of course, on other conditions.
11.Q. Mr. Schuster testified that the entire shaded region depicted on Suffolk County Diesel Exhibit 77 was " arced and perhaps subsequently ground out" before the weld metal was puddled in. Tr. 25,456 (Schuster). Do you agree with Mr.
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Nchuster.baseduponyourexaminationofthesamplesandphoto-
.' graphs, Dr. Anderson?
A. (Anderson) I have-no basis for agreeing or disagreeing s
based upcn my review of the samples or photographs -- the appear-5 ance of the repaired cracks is consistent with either arcing or #
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.gg rinding preparatory to welding. However, IvisitedTDIanp observed that in making weld repairs to engine components, TDI
'followed the practice of grinding cracks,' not arcing them. Ob s
course,.I cannot state that they followed the same procedureA in 1 '
1975 but that is a reasonable assumption.
. 12.Q. Dr. 'nderson, assuming thab.the oxide discovered on the cam gallery crack specimen removed from the old EDG 103 m
block was formed during the casting process and assuming that .
s TDI attempted to repair those cracks subsequently, in your opinion is it reasonable to believe that therc' woull be as much t
as 0.5 mm of oxide still adhering to the side of the crack to which the weld material had been applied but from which it is s
now separated?
A. (Anderson) No. The crack. specimens which I examined definitely showed evidence of having been either arced or ,
k ground out in preparation for welding. Regardless of whether
-the cracks were widened by arcing or grinding, I would expect s
any oxide that had been adhering to the crack surface to be removed in the normal course of arcing or grinding. Neither process is so precise that the surface of both sides of the i crack would be undisturbed in the course of it. Moreover, it l
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a would make no sense to attempt to avoid disturbing one par-ticular side of the crack because it is normal welding prepara-tion to remove any oxide adhering to the surface to be welded in order to permit better weld adhesion.
12.Q. Dr. Wachob testified that FaAA did not perform any tests to determine whether the oxide on the cam gallery crack surface removed from the old EDG 103 block is a wustite, a hematite or a magnetite oxide. Tr. 25,414 (Wachob). Dr.
Anderson, in your opinion would such a test be useful in deter-mining the origin of the oxide?
A. (Anderson) Yes. If the oxide were a wustite it would tend to confirm FaAA's theory because wustite only forms at very high temperatures. On the other hand, if the oxide were hematite or magnetite, it would disprove FaAA's hypothesis concerning its formation because those oxides form only at much lower temperatures.
13.0 Is there an accepted method for testing oxide to determine whether it is wustite, hematite or magnetite?
A. (Anderson) Yes. The method is by x-ray diffraction.
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It is not a very complicated procedure.
14.A. Dr. McCurthy testified that the addition of 20 l
gallons of water to the engine lubricating oil would not com-promise the lubricating systems of the Shoreham EDGs. Tr.
l 25,273 (McCurthy). Mr. Eley do you agree?
A. (Eley) Absolutely not. It is normal operating pro-cedure to regularly test the lubrication oil in large diesel
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engines for the existence of water. The reason for that practice is that relatively small-amounts of water in the lubricating oil can have catastrophic effects on the engine, particularly piston seizure and bearing failure. The amount of water that would be a problem depends on the type of oil. The lube oil system capacity for each Shoreham EDG is 700 gallons so that 20 gallons would amount to almost three percent. Regardless of the type of oil used, that volume of water in the lube oil of a diesel engine would be dangerous. We have checked with Mobil 011 Company to determine how much water they believe is permissible in the Mobil Delvac 40 oil used in the Shoreham EDGs durina engine operation. Mobil's chief engineer responded that when the water reaches 0.15 percent, the Delvac 40 oil should be discarded. He also advised that he would be " concerned" about operating the engine with as little as 0.2 percent water in Delvac.
15.Q. Professor Christensen, do you agree with Mr. Eley's testimony concerning operation of a diesel engine with water in the lube oil?
A. (Christensen) Yes, I do, but I had no communications with Mobil Oil Company on the subject. .
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. UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION
-Before the Atomic Safety and Licensing Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) _ Docket No. 50-322-OL
)
(Shoreham Nuclear Power Station, )
Unit 1) ).
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY'S REBUTTAL TESTIMONY OF DR. ROBERT N. ANDERSON, PROFESSOR STANLEY G. CHRISTENSEN, AND G. DENNIS ELEY, dated November 7, 1984, have been served on the following this 7th day of November 1984 by U.S. mail, first class, except as otherwise noted.
i e
Lawrence J. Brenner, Esq.* MHB Technical Associates Administrative Juage 1723 Hamilton Avenue Atomic Safety &nd Licensing Board Suite K U.S. Nuclear Regulatory Commission San Jose, California 95125 Washington, D.C. 20555 E. Milton Farley, III, Esq.*
Dr. George A. Ferguson* Hunton & Williams Administrative Judge P.O. Box 19230 Atomic Safety and Licensing Board 2000 Pennsylvania Ave., N.W.
School of Engineering Washington, D.C. 20036 Howard University 2300 6th Street, N.W. Odes L. Stroupe, Jr., Esq.
Washington, D.C.- 20059 Hunton & Williams 333 Fayetteville Street Dr. Peter A. Morris
- Raleigh, North Carolina 27602 Administrative Judge Atomic Safety and Licensing Board Mr. Jay Dunkleberger U.S. Nuclear Regulatory Commission New York State Energy Office Washington, D.C. 20555 Agency Building 2 Empire State Plaza Edward M. Barrett, Esq. Albany, New York 12223 General Counsel Long Island Lighting' Company James B. Dougherty, Esq.
250 Old Country Road 3045 Porter Street, N.W.
Mineola, New York 11501 Washington, O.C. 20008
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Robert E. Smith, Esq. Stephen B. Latham, Esq.
Guggenheimer & Untermyer
- Twomey, Latham a Shea 80 Pine Street P.O. Box 398 New York, New York 10005- 33 West Secor.d Street Riverhead, New York 11901 Mr. Brian R. McCaffrey Long Island Lighting Company Mr. Frank R. Jones Shoreham Nuclear Power Station Deputy County Executive P.O. Box 618- H. Lee Dennison Building North Country Road Veterans Memorial Highway Wading River, New York 11792 Hauppauge, New York 11788 Joel Blau, Esq. Mr. Stuart Diamond New York Public Service Commission Business / Financial The Governor Nelson A. Rockefeller NEW YORK TIMES Building New York, New York 10036 Empire State Plaza Albany, New York- 12223 Hon. Peter F. Cohalan
-Suffolk County Executive Martin Bradley Ashare, Esq. H. Lee Dennison Building Suffolk County Attorney Veterans Memorial Highway H. Lee Dennison Building Hauppauge, New York 11788 Veterans Memorial Highway Hauppauge, New York 11788 Fabian Palomino, Esq.#
Special Counsel to the Atomic Safety and Licensing Board Governor Panel Executive Chamber U.S. Nuclear Regulatory Commission Room 229 Washington, D.C. 20555 State Capitol Albany, New York 12224 Docketing and Service Section Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board
, 1717 H Street, N.W. U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Edwin J. Reis, Esq.*
Bernard M. Bordenick, Esq. Jonathan D. Feinberg, Esq.
Richard J. Goddard, Esq. Staff Counsel Office of Exec. Legal Director New York State Public U.S. Nuclear Regulatory Commission Service Commission Washington, D.C. 20555 3 Rockefeller Plaza Albany, New York 12223
i Stewart M. Glass, Esq..
' Regional Counsel Federal Emergency Management Agency 26 Federal Plaza New York,'New York 10278
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^#p J5sep/ J./ Brig'ati /'
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/ KIRK @ TRICK & LOCKhART 1900 M Street, N.W., Suite 800 Washington, D.C. 20036 DATE: ;iovember 7, 1984
- By Federal Express By Hand Delivery I
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