ML20108F216
| ML20108F216 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/17/1984 |
| From: | Dynner A, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#484-679 OL, NUDOCS 8412190279 | |
| Download: ML20108F216 (27) | |
Text
(0 hk o~
p D0E!ft U%AL SUFFOLK COUNTY, 12/17/84
'84 CEC 18 All:59 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Uf f CE OF SR8tled
- 00thETING & SUWi
,\\
ERANCH 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)
)
)
JOINT MOTION OF SUFFOLK COUNTY AND NEW YORK STATE TO ADMIT EDG LOAD CONTENTION By an Order Confirming Grant of LILCO's Motion to Reopen Diesel Engine Hearings, December 4, 1984, the Board confirmed the reopening and supplementing of the record to litigate the EDG contentions with respect to LILCO's proposed maximum " qualified load" rating of 3300 kW.
The Board stated that any party may submit a contention challenging that lower load, if the contention meets the regulatory requirements for a timely contention.
Suffolk County and New York State hereby jointly move the admission of the EDG Load Contention attached hereto as Attachment 1.
The EDG Load Contention is set forth with particularity and presents the bases for each portion of the contention with reason-able specificity, as required by 10 C.F.R. Section 2.714(b).
These bases are given by references to particular documents, including transcripts of depositions of witnesses for LILCO and 8412190279 841217 PDR ADOCK 05 M 322 h$o}
Q PDR
'O.
4 the NRC. Staff, and by an affidavit of Dale G.
Bridenbaugh, attached as an exhibit to the EDG Load Contention.
On December 18, 1984, LILCO and the NRC Staff will depose by oral examination Mr. Bridenbaugh and his colleague, Mr. Gregory C.
Minor, and thereby have an opportunity to discover additional details concerning the EDG Load Contention.
Mr. Minor assisted Mr. Bridenbaugh in the development of the EDG Load Contention.
We have informed the parties that if the EDG Load Contention is admitted, Messrs. Bridenbaugh and Minor will be our witnesses.
We do not believe the third portion of the EDG Load Conten-tion, dealing with whether the LILCO " confirmatory" testing has properly qualified the EDGs at 3300 kW, needs to be made a part of a new contention.
The Board's Order permits litigation of the results of such testing even absent a new contention.
December 4 Order at 5.
We have included that portion of the EDG Load Con-tention, however, because it is closely related to other parts of the Load Contention and to give the parties advance notice of our concerns.
Respectfully submitted, Martin Bradley Ashare Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788
_ : n -- -
Alan Roy Dynne ti j/'
Joseph J.
Bri Douglas J. S eidt KIRKPATRICK & LOCKHART 1900 M Street, N.W.,
Suite 800 Washington, D.C.
20036 Attorneys for Suffolk County
.. Fabian G. Palomino
. MM 2-c
/
Special Counsel to the Governor Executive Chamber, Room 229 State Capitol Albany, New York 12224 Attorney for Mario M. Cuomo, Govenor of the State of New York December 17, 1984 t
?
e 4
ATTACHMEE4T.1 EMERGENCY DIESEL GENERATOR LOAD CONTENTION Contrary to the requirements of 10 C.F.R. Part 50, Appen-dix A, General Design Criterion 17 -- Electric Power Systems, the emergency diesel generators at Shoreham ("EDGs") with a maximum " qualified load" of 3300kW do not provide suf ficient capacity and capability to assure that the requirements of clauses (1) and (2) of the first paragraph of GDC 17 will be met, in that
( a')
LILCO's proposed " qualified load" of 3300kW is the maximum load at which the EDGs may be operated, but is inade-quate to handle the maximum loads that may be imposed upon the EDGs.
Unlike at other nuclear plants, there is no effective short-time overload rating (over 3300kW) for the EDGs.
(b)
There is little or no margin between 3300kW and the maximum emergency service loads for the EDGs, in sharp contrast to emergency diesel generators at other nuclear plants where a substantial margin orovides adequate assurance of requisite reliability under GDC 17.
(c)
The EDG qualification test run per formed by LILCO was inadequate to assure that the EDGs are capable of reliable operation at 3300kW.
Factual matters supporting the foregoing include:
1.
LILCO's proposed FSAR Revision 34 (November 1984) pro-vides that the " qualified load" of 3300kW "will be used for all pu r po se s. "l/
It is thus the maximum load at which the EDGs may be operated.2/
However, the maximum loads imposed on the EDGs may exceed 3300kW:
(a)
Intermittent or cyclic loads increase the maxi-mum emergency service loads to 3426.1kW for EDG 101, 3380.7kW for EDG 102, and 3414.lkW for EDG 103.3/
At other nuclear plants and as contemplated by Regulatory Guide 1.9, intermit-tent or cyclic loads are bounded, if not by the continuous rat-ing, by a short-time overload rating.1/
1/
Section 8.1.4, page 9.1-3.
2/
LILCO has proposed to change the Shoreham Technical Speci-fications to provide a 3300kW limit.
Draft Supplemental Safety Evaluation Report, Emergency Load Requirements for Emergency Diesel Generators, December 3, 1984 ("Dec.
SSER") at 5.
See Deposition of John Knox, December 13, 1994, at 41-2.
-3/
See Af fidavit of Dale G. Bridenbaugh, attached hereto as Exhibit 1.
4/
Deposition of John Knox, December 13, 1984, at 20, 87-8; Dec. SSER at 7.
(b)
A single worst case operator error would load EDG 103 to 3583.5kW in a LOOP /LOCA condition, and would load EDG 101 to 3784kW in a LOOP only condition.1/ There.is no as-surance that changes in plant procedures or training can elimi-nate such operator error, especially in view of the potentially lengthy period of a LOOP or LOOP /LOCA event.
(c)
LILCO's calculated, maximum emergency service loads of 3253.3kW, 3208.7kW and 3225.5kW for EDGs 101, 102 and 103 respectively,i/ are nonconservative, in that they fail to account for:
( i) future degradation of system con-ditions; (ii) potential non-conservative as-sumptions in the modeling of EDG performance during a LOCA, (iii) variation of flows due to instru-ment errors,
( iv) need for equipment adjustments for degradation of pumps, or (v) off-standard operating conditions of engineered safeguards equip-ment.
5/
Dec. SSER at 5.
1/
FSAR Revision 34, Table 8.3.1-1A (October 1984), at 3.
The EDGs have no protection against over-voltage on the emer-gency buses or for significant frequency variations from 60 cy-clesl/, which could increase EDG loads.
LILCO's emergency operating procedure is inadequate to prevent loads from exceed-ing 3300kW and in fact could permit operation at 3512kW.
2.
The difference between the highest EDG maximum emer-gency service lo,ad calculated by LILCO (3253.3kW) and the 3300kW maximum load at which the EDGs may operate is only 46.7kW, or 1.4% of the maximum load allowed.
This small margin assumes no increases in the maximum emergency service loads due to the factors discussed in paragraph 1 above.
In contrast, the margins between maximum permitted loads (rated loads) and maximum emergency service loads of emergency diesel generators at 19 boiling water reactors licensed by the NRC over the past 15 years range from 10.5% to 34.6%, with an average of 29%.8/
3.
The much larger margins at licensed nuclear plants (shown in Table 1 to Exhibit I hereto) serve to provide ade-quate assurance that the types of factors described in 1/
Deposition of J. Notato, E. Youngling, G. Dawe and W.
Schiffmacher, Dec. 12, 1984 ("LILCO Deposition") at 41-42.
8/
See Exhibit 1 and Table 1 thereto, which presents data prepared from the County's survey.
-4
paragraph I will not increase loads beyond the maximum rating of the emergency diesel generators and thus jeopardize reliability.
The EDGs have virtually no such margin of safety.
Accordingly, they do not provide the standard of reliability, capability and capacity hitherto required to satisfy the re-quirements of GDC 17.
d.
The EDGs were not adequately tested at 3300kW to prove their reliable operation at that load level.
The so-called EDG confirmatory load test on EDG 103 purported to demonstrate that the EDGs are capable of running at or above 3300kW for ten to the seventh cycles (approximately 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br />).
However, the plant instrumentation to measure the kilowatt load during the test had a tolerance of +112kW, was not calibrated during or af ter the last 525 hours0.00608 days <br />0.146 hours <br />8.680556e-4 weeks <br />1.997625e-4 months <br /> of the test, and may not have been calibrated before that portion of the test.1/
Accordingly, there is no assurance that EDG 103 was operated for some 525 hours0.00608 days <br />0.146 hours <br />8.680556e-4 weeks <br />1.997625e-4 months <br /> of the 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br /> at more than 3188kW.
5.
The cylinder block of EDG 103 is of a dif ferent grade of grey cast iron and of a different block top design than the blocks of EDGs 101 and 102, both of which contain numerous cracks in the block top.
Accordingly, the " confirmatory" 3/
LILCO Deposition at 72-73, 76.
testing of EDG 103 does not demonstrate that EDGs 101 and 102 can be reliably operated at the loads to which EDG 103 was subjected during'that testing..
EXHIBIT 1 AFFIDAVIT OF DALE G.
BRIDENBAUGH 1.
My name is Dale G. Br id enbaugh.
I am President of MHB Technical Associates, a principal consultant with that
-firm, a mechanical engineer and a registered professional nu-clear engineer in the State of California.
My qualifications have previously been submitted in this proceeding.1/
2.
I have evaluated the proposed reduced qualified load (3300kW) and emergency service loads described by amendment No.
52 to LILCO's license application, Revision 34 to the Shoreham FSAP.
In the course of my review I have examined documents submitted by LILCO to the NRC in support of this amendment, reviewed the amendment itself, and attended the depositions of LILCO and NRC Staff personnel in this matter.
I also have conducted a review of EDG load ratings and LOOP /LOCA loads es-timated by. other utilities in the licensing of approximately 20 other boiling water reactors licensed for operation over the last 15 year period.
The relevant data I have evaluated are summarized in attached Table 1.
My review was based upon in-formation obtained from the U.S. NRC's Public Document Room in Washington, D.C.
s-1/
See Attachment 5 to Joint Direct Testimony of Robert N.
Anderson,- et al.,
Regarding Suffolk County's Emergency Diesel Generator Contentions, filed July 31, 1984.
3.
As a result of my review and analyses, I have con-cluded that LILCO's proposed EDG qualification program and LOOP /LOCA emergency load specification does not provide an ade-quate margin between the EDG capability and the possible maxi-mum emergency service loads to assure that the operation of the Shoreham plant will be in compliance with 10 C.F.R. Part 50, Appendix A, GDC 17.
Specific reasons for my conclusion are contained in the following paragraphs.
4.
LILCO's original LOOP / LOC A load requirements, as specified in FS AR Table 8.3.1-1, projected that the maximum co-incident demand for the highest loaded EDG was 3881.4kW.
(FSAR Table 8.3.1-1, page 3, Revision 31).
This load was estimated to be approximately constant for the first ten minutes of the accident.
After ten minutes, manual action was assumed that resulted in reducing the post-ten minute maximum load to 3409.2kW.
5.
I have reviewed the correspondence between LILCO and the MRC Staff discussing possible changes to reduce the E03 loads. The level of the reduced " qualified" load was calculated by LILCO, and LILCO advised the NRC that a 3300kW test run would be performed on EDG 103 that would extend the operating time on that unit to approximately 740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br />.
This length of
_7_
i
time was selected to coir. cide with a crankshaf t fatigue cycle level of approximately ten to the seventh stress cycles.
The LILCO test run commitment was confirmed in LILCO's SNRC-1094 letter dated 10/18/84, and Exhibit A thereto.
Since LILCO claimed credit for 219 hours0.00253 days <br />0.0608 hours <br />3.621032e-4 weeks <br />8.33295e-5 months <br /> previously run on EDG 103 at or above 3300kW, it called for an additional run of 521 hours0.00603 days <br />0.145 hours <br />8.614418e-4 weeks <br />1.982405e-4 months <br /> at a load of 3300kW +100kW.
6.
In this same letter (SNRC-1094), LILCO also advised that an FSAR revision would be submitted in the near future which would provide the basis for the qualification of the EDGs at the reduced load requirement of 3300kW.
This revision to Section 8.3.1 of the FSAR was formally submitted by LILCO on November 29, 1994 as Amendment 52, consisting of FSAR Revision 34 (Submitted via SNRC-1115, J.D.
Leonard to Harold R.
Denton, Nov. 29, 1984).
7.
Revision 34 contains a number of changes to the orig-inal emergency load definition that are of particular rele-vance.
They are:
(a)
Two new load terms were added that did not ap-pear on the original Table 9. 3.1-1.
The first,
" Maximum emergency service load" is defined as the maximum load which would exist during a LOOP /LOCA.
It consists of both nameplate and measured loads.
The second term, " qualified load," is defined as an upper bound of the maxi-mum emergency service load of all three EDGs.
(FSAR, Fevision 34, page 8.3.6).
(b)
Revisions were made to Table 8.3.1-1 of the FSAR.
The changes included the removal of two major loads on EDG-103 f rom the automatic start category, adjustments to several loads made on the basis of measured rather than nameplate data, and the addition of footnotes indicating that other loads are to be tripped intentionally and in some cases prevented from starting until ten minutes after the LOCA signal.
(c)
An additional table, 8.3.1-1A, entitled " Maximum Emergency Service Loads" ("MESL") was added. This table develops MESL totals for each EDG by re-moving from the Table 8.3.1-1 totals all loads that are cyclic or intermittent or that are tripped or manually initiated after a LOCA sig--
nal.
By these deletions, LILCO was able to de-velop loads that are less than 2% below the in emergency power voltage and frequency.
Such off-standard operating conditions must be guarded against for future operation.
Accord-ingly, if pump efficiency deteriorates or in-strument, error worsens, adjustments will be needed to compensate for the degraded flow con-ditions.
Such adjustments will generally. work to increase the increased required electrical load in order to assure that technical specifi-cation minimal flows are being delivered.
These variations will not be large, but LILCO has pro-vided no margin to account for such uncertainties.
(b)
Overload capability.
Setting the qualified load almost precisely at the continuous emergency required load provides no margin to_ accommodate cyclic and intermittent loads, and for the starting transients imposed by the subsequent addition of other pumps and loais.
I have cal-culated that, based on LILCO's own figures, the intermittent or cyclic loads increase the maxi-mum emergency service loads to 3426.lkW for EDG 101, 3380.7kW for EDG 102, and 3414.lkW for I :
EDG 103.
Regulatory Guide 1.9 indicates that 1
less conservative load definition is permissible at the operating license review stage since the design is fixed and the loads are more clearly-defined.
However, the Regulatory Guide assumes that margin will still be available "within the short-time rating of the-diesel-generator unit".
(Regulatory Guide 1.9, Revision 2, December 1979, page 1.9-2).
The proposed LILCO loading conditions are particularly deficient with re-gard to overload capability.
There is no confirmed overload capability for these EDGs and the qualified load (3300kW) is only 1.4% greater than the maximum continuous emergency service load (3253.5kW).
It is a near certainty that the cyclic and intermittent loads arbitrarily removed from the schedule by LILCO will drive the actual EDG load some 5% higher in the first minutes of EDG operation.
This is because the event will require the stroking of numerous motor-operated valves early in the cycle, and the starting of the diesels will draw down the starting air tank pressure, automatically actuating the EDG air compressors for fifteen minutes or more.
I have reviewed the intermit-tent and cyclic loads as well as those loads that can be manually connected subsequent to the LOCA signal.
The potential effects of these in-termittent and manually added loads is summa-rized on attached Table 2.
9.
I have not yet quantified the total magnitude of the
- additional load that could be imposed by the uncertainties and intermittent and manual loads described in paragraph 8 above.
I do know that they can be a net positive addition to the MESL, and I will be working further to quantify them during the next month.
10.
I have obtained data from the NBC's Public Document Foom in Washing ton, D.C.
to compare the range of emergency load capability safety margins present~at previously licensed olants.
The results of my review and analyses are summarized in Table 1 attached.
This review covered the majority of boiling water reactors licensed for operation since 1969.
It includes nineteen different units ranging in size from 597 to 1152 MW.
I find that none of these units has been licensed with less than 10.5% margin between the maximu.m predicted
_g-
emergency service load and the qualified continuous or overload rating of the respective EDGs.
The range of margins varies from 10.5% to 34.6% and averages approximately 28%.
This ap-pears to be the desirable and commonly applied degree of margin to accommodate the uncertainties and cyclic loads described in the preceeding paragraphs.
11.
The availability of additional margin in the load ca-pability described in paragraph 10 above is desirable for yet another purpose -- to allow for the effect that the worst caso single operator error could have on the EDG load during a LOOP /LOCA or LOOP event.
In response to the Staff questioning, i
LILCO confirmed that EDG 103 could be loaded to as high as 3583.5kW in the post-LOOP /LOCA condition by the single operator error of manually starting the fourth react or ' building service water pump.
For the LOOP event, the worst case operator error load addition would be the starting of a core spray pump on EDG 101 which would result in a total diesel generator load of 3784kW.2/
LILCO has responded to NRC Sta f f questions on this subject that the possibility of such an event will be precluded by additional operator training and procedures.
I certainly 2/
See Staf f Supplemental Sa fety Evaluation Repor t dated
~
12/3/84, page 5.
I -
recommend that such steps be taken, but human error cannot be totally eliminated.
I am aware that under normal interpreta-tion of the single failure criteria, such operator errors are not required to be considered in the review.
However, there is no assurance that the LOOP /LOCA or LOOP events will be termi-nated in any precise short period of time (in fact, such events could continue for hours or days).
In actual accident cases (such as at Three Mile Island-2), errors have been made subse-quent to the initiation of the e. vent.
It is unreasonable to ignore the possibility of such events and to fail to provide some conservatism in the load margins, particularly since LILCO proposes to operate this plant with EDGs having a long history of serious design and quality problems.
12.
In addition to the' inadequate load margin discussed in the paragraphs above, the actual qualification of the EDGs at 3300kW is suspect.
EDG 103 recently completed a 740-hour test run at load levels of approximately 3300kW, but only after a maior rebuild of the engine af ter 219 hours0.00253 days <br />0.0608 hours <br />3.621032e-4 weeks <br />8.33295e-5 months <br /> of operation at that load or greater.
The installation on EDG 103 of a com-pletely new and redesigned engine block made of a dif ferent grade of cast iron makes suspect the relevance 7f the comple-tion of the "740-hour run" on this renovated unit to the two other engines with cracked blocks which have not been replaced. t
13.
There are other factors which further bring into question the 740-hour run.
LILCO indicated that the load for the qualification run would be mair'tained at a level of 3300kW
+100kW.3/
In a deposition on December 12, LILCO witnesses confirmed that normal station instrumentation was utilized in establishing the load level for the run and that no calibration of the instrumentation was required before, during, or af ter the run was completed.4/
Thus, there is no assurance that the accuracy of the instrumentation even meets the nominal 2% full scale accuracy that was specified from the 5600kW EDG load in-strument.
Even if the instrumentation is within the specified accuracy, it would still be possible for a portion or some of the test run to have been carried out at a load level of less than 3200kW.,
I have examined the single handwritten log sheet provided to the County by LILCO, which indicates the EDG load every one-half hour for three hours on 10/31/84.
The load level recorded is exactly 3300kW for each entry.
I know that the load would vary some amount from hour to hour, and am concerned that the load level was not precisely recorde1.
It 3/
SNRC-1094, October 18, 1984, Confirmatory Testing of TDI Diesel Generators.
4/
Deposition of J.
Notaro, E.
Youngling, G. Dawe, and W. Schiffmacher, Dec. 12, 1984, at 41-42. !
I i
is therefore possible that the operators could have interpreted 1
the instructions that the load was to be set at approximately 3300kW and recorded only a nominal level.
If the instrumen-tation was off by plus 2%, and the actual load was running at the low end of a nominal range, the actual load could thus have been well below 318CkW; 4.f a nominal range of 1100kW is as-sumed, the actual load could have been 3088kW.
Taking all of the above uncertainties into account, 14.
it is possible that the load qualification test per formed on EDG 103 was conducted at levels of only 3200kW or even lower.
This is obviously less than the continuous emergency load, and the actual peak emergency load will be higher than the continu-ous load.
There are two different times during the course of the accident when this could be particularly acute.
- First, during the early minutes, adding the intermittent loads to the MESL (continuous) load of 3253.5kW will 1 cad to an actual LOOP /LOCA EDG load of as high as 3426.44W.
Later in the acci-dent (after ten minutes), load adjustments including the possi-ble addition of an RBSW pump and an PRCLCW pump, require
" juggling" of the loads.
As shown on Table 2, there is a po-l tential fo-the load on one EDG to reach as high as 4126.0kW i
under.this condition.
The EDG Emergency Operating Procedure cautions the operator in the post-accident condition to limit l
the EDG load to 3300kW 1100kW.1/
tio guidance is given as to 5/
SP 29.015.01, Revision 6, Loss of Of fsito Power Emergency
(
Procedure.
exactly how this caution is to be enforced.
The most likely method would be to rely uoon the control room indicating kW meter provided for each EDG.
These instruments have an accura-cy that is specified as 12% accuracy full scale.
Thus, it is nossible that the 3300kW 1100kW load stated in the procedure could in actuality reach as high as 3512kW on the EDG.
I reach this value by assuming the maximum load permitted by the proce-dure (3400kW) and adding to it the 2% full scale instrument error permitted (112kW).
Thus, it is possible that the maximum emergency service load peak could exceed the 30R8kW potential lowest level at which EDG 103 was tested by 10.9 percent for the intermittent peak, and by 13.7 percent for the worst case manually loaded condition in the post-accident condition. '
i
TABLE-1 Comparative BWR EDG Ra tings _an_d LOOP /L_O,C,A L,o,a,ds Unit kW (4)kW Plant Rating MW In Service EDG Rating Peak Load
% Margin l
Oyster Creek 650 1969 2500(1) 1950 28.2 Duane Arnold 597 1975 3250(3) 2510 29.5 Cooper 836 1974 4000(1) 3619 10.5 Dresden 2-3 800/900 1970/71 2860(2) 1950 46.7 Quad Cities 1-2 800/900 1972/72 2850(2) 2122 34.3 Pilgrim 655 1972 2750(2) 2398 14.7 Peach Bottom 2-3 1152/1152 1974/74 3250(1) 2560 26.9 i
Brunswick 1-?
821/821 1977/75 3850(2) 2860 34.6 Hatch 1 850 1975 11700(5) 9670 21.0 Match 2 850 1979 3500(3) 3100 12.9 i
L19alle 1-2 1078/1078 1984/85 3250(3) 2719 19.5 WPPS-2 1103 1984 4650(2) 3860 20.5 L
Susquehanna 1-2 1152/1152 1983/85 4700(2) 3542 32.7 27.7%
AVERAGE
=
No te s (1)
Continuoun R1 ting (2) 2000 Hour Rating (3) 30 Minute Rating (4)
Peak Loads are those automatically loaded on LOCA/ LOOP (5)
Assuming 4 of 5-2925kW EDGs start (6)
All data tsken from USNRC Public I
Document Room FSAR3
e f
TABLE-2 Shoreham Emergency Service Loads (in kW)
(Data extracted from Proposed Reitsion 34 to the FSSR);
LOOP /LOCA Maximum Emergency Service 1
Loads (Per LILCO Proposed Table 8.3.1-1A) 1253.3 1208.7 3_225._5 Auto-Start Cyclic & Inter-mittent Loads
-(Remarks 5, 7,
& 8):
Air Comp.
12.0 12.0 12.0 Fuel Oil Transfee 0.4 0.4 0.4 480V M-G Set 141.0 141.0 176.0 MOVs 19.7 18.3 0.7 SUBTOTAL 173.1 171.7 189.1 Auto-Start Loads as a
% of 3300 5.2 5.2 5.7 Maximum Auto-Start Loads Emergency Service Loads 3426.4 3380.4 3414.6 Loads Which May De Added Manually or After Ten Minutes (ex-cludes those that are illogical such l
as EDG heaters, re fueling plat-
, t
--,n----
n---,
TABLE-2 I
Shoreham Fmerjency Service Loads (in kW)
~
(Data extradted from Propdidd~pe71sion 34 to the F.%R),
i EDG EDG EDG 101 102 103 form, etc.)
358.0 f
80.0 4
52.0 109.0 109.0 26.4 7.0 3.5 4
180.0 20.0 20.0 20.0 2.4
'2. 4 r
2 206.1 206.1 80.0 80.0 t
i 1.6 1.6 49.0 48.0 o,4 32.0 8.0 8.0 12.0 1.2 1.2 8.0 8.0
}
1.2 1.2 l
32.0 32.0 10.0 45.0 L
3.0 3.0 95.9 75.3 SU9 TOTAL 700.4^~~~
635.7 601.4 I
~
i Maximum Potential Emergency Service t
Load Af ter l
4 Ten Minutes 4126.8 4016.1 4017.0 p
1 t
i I
{
l i
I f
=
CX Mif f LML UNITED STATES OF AMERICA
'84 CEC 18 N1:59 NUCLEAR REGULATORY COMMISSION BeforetheAtomicSafetyandLicensingBoakkrNf,5j,Y$.[,
bnAhus
)
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 copics of JOINT MOTION OF SUFFOLK COUNTY AND NEW YORK STATE TO ADMIT EDG LOAD CONTENTION, dated December 17, 1984, have been served on the following this 17th day of December 1984 by U.S. mail, first class, except as otherwisc indicated.
Lawrence J.
Brenner, Esq.*
MHB Technical Associates Administrative Judge 1723 Hamilton Avenue Atomic Safety and Licensing Board suite K U.S. Nuc1 car Regulatory Commission San Jose, California 95125 Washington, D.C.
20555 E. Milton Parley, 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 a Williams 333 Fayetteville Strcot Dr. Potor 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 uuilding 2 Empire State Plaza Edward M. Barrett, Esq.
Albany, New York 12223 General Counsel Long Island Lighting Company James B. Dougherty, Eng.
250 Old Country Road 3045 Porter Street, N.W.
Mincola, New York 11501 Washington, D.C.
20008
o
, Robert E. Smith, Esq.
Stephen B. Latham, Esq.
Guggenheimer 8,Untermyer Twomey, Latham & Shea 80 Pine Street P.O. Box 398 New York, New York 10005 33 West Second 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, Now York 11792 Hauppauge, New York 11788 Joel B1'au, 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 Executivo Martin Bradley Ashare, Esq.
H. Loc Donnison Building Suffolk County Attorney Veterans Memorial Highway H. Lee Dennison Building Hauppauge, New York 11788 Votorans Memorial Highway Hauppauge, Now York 11788 Fabian G. Palomino, Esq.#
Special Counsel to the Atomic Safety and Licensing Board Governor Panel Executivo Chambor U.S. Nuclear Regulatory Commission Room 229 Washington, D.C.
20555 State Capitol Albany, New York 12224 Docketing and Service Section Offico 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. Rois, Esq.*
Bernard M.
Bordonick, Esq.
Jonathan D. Feinborg, Esq.
Richard J. Goddard, Esq.
Staff Counsel Office of Exoc. Legal Director New York State Public U.S. Nuclear Regulatory Commission Service Commission Washington, D.C.
20555 3 Rockofoller Plaza Albany, Now York 12223
4 -
I Stewart M. Glass, Esq.
o Regional Counsel Federal Emergency Management Agency 26 Federal Plaza i
Eleanor L. Frucci, Esq.*
Atomic Safety 4 Licensing Board l
U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 i
t i
r Alan Roy Dygfier /
KIRKPATRICf a LOCKHART 1900 M Street, N.W.,
Suite 800 Washington,-D.C.
20036 DATE:
December 17, 1984 j
i By Federal Express By Hand' Delivery l
i l
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