ML20112D600

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Intervernor Exhibit I-SC-LP-32,consisting of Attachment 6 Re on 830812 Failure of Tdi Emergency Diesel Generator 102.Diesel Generator Defects Constitute Breach of Contract
ML20112D600
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 08/03/1984
From: Barrett E
LONG ISLAND LIGHTING CO.
To: Rich Smith
GUGGENHEIMER & UNTERMYER
References
I-SC-LP-032, I-SC-LP-32, OL-4, NUDOCS 8501140392
Download: ML20112D600 (4)


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rt E. Smith, Esq.

Guggenheimer & Untermyer c[C 80 Pine Street

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Dear Mr. Smith:

This letter is sent to you in your capacity as counsel to Transamerica Delaval Incorporated (Delaval).

As you know, on August 12, 1983, the crankshaft in emergency diesel generator 102 at our Shoreham Nuclear Power Station failed in the course of performance tests of the engine.

LILCO retained Failure Analysis Associates (FaAA) to conduct a thorough investigation of this failure.

In the course of this investigation, cracks were found in the crank-shafts of diesel generators 101 and 103 as well.

FaAA's final report on the cause or causes of the crankshaft failure demonstrates that the crankshaft failure occurred as a result of inadequate or defective design.

FaAA also investigated cracked connecting rod bearings and cracked pistons discovered on the engines.

FaAA's interim report on the cracked bearings indicates those failures occurred as a result of a combination of causes, including inadequate or defective design and manufacture.

FaAA',s investigation of the cracked pistons and other matters observed in the inspection of the' engines is continuing, but preliminary indications are that these, too, occurre'd as a result of defective or inadequate design.

Prior to the crankshaft failure, LILCO had experienced a number of occurrences attributable to defectively designed or f abricated diesel generator components, including three leaking cylinder heads, defective jacket water pu=ps, leaking fuel oil injection lines, inadequate turbocharger thrust bearing lubrication, inadequate piston skirt to piston crown attachment, broken rocker arm shaft bolts and cracked sub-cover assemblies.

While these occurrences were generally of the type experienced in the shakedown of large diesel ines, they appear, nonetheless, to be attributable to enfectivedesignorfabrication.

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Robert E. Smith, Esq. December 2, 1983 Eased on LILCO's currently available infor=ation, LILCO believes the defects in the diesel generator sets provided us by Delaval constitute a breach of the contract between LILCO and Delaval for the purchase and sale of those diesel generator sets, including but not limited to a breach of warranties contained in and arising out.of that contract.

This letter is solely for the purpose of providing notice of the breach.

Nothing contained herein should be construed as a release of any other claims that LILCO may have against Delaval or as a waiver of any rights and remedies LILCO may have in this matter.

Although LILCO is now giving Delaval notice of claims, we believe it is in LILCO's and Delaval's best interests to pursue aggressively the prompt repair and licensing of the Shoreham diesel generators.

We believe substantial progress has been made toward this goal and hope that Delaval and LILCO can work together in the future to ccmplete this important proj ect.

Sincerely,

</M b EMBilbs Edward M. Barrett s

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