ML20244B503
| ML20244B503 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/27/1985 |
| From: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Dynner A KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| References | |
| OL, NUDOCS 8906130144 | |
| Download: ML20244B503 (3) | |
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'BY TELECOPIER Alan R. Dynner,.Esq.
Kirkpatrick & Lockhart 1900 M Street, N.W.
Eighth Floor Washington, D.C.
20036
Dear Alan:
Your response to LILCC's settlement proposal reflects a-studied effort on ment discussions. your part to. avoid'any meaningful. settle-The suggestion that the offer'was not se-rious is completely. unnecessary -and counterproductive.
More-over,-your characterizations of the terms of the offer are inaccurate and misleading.
Finally, it is also significant that your letter.contains no.counterproposals or suggestions..
Centrary to y forchoosing3x10gur-assertion, tnereLis substantial basis.
- cycles for. additional testing.
As ycu know, Regulatory Guide l'.lCB' requires testing of diesels for 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> at s' continuous rat:.ng and two hours at-a short rating, a ratio of approximately ten to one.
term Applying this rationaletoLILCO'spropesaltouse3500Kgassinoverload rating leads to the conclusion that 1 x 10 cycles' constitute appropriate testing at.3500KW.
LILCO h offered to test up to a' total of 3 x 10gs gone further and cycles.
Further i
isalso'significanttonote,asDr. Bush'stestimogy(page,st 16-21) in the reopened proceeding reflects, 3 x 10 cycles is the. upper bound-of the values normally used for the h gh.
cycle fatigue limit.
Your claim that 3 x 106 cycles is inadequate because the original crankshafts failed after similar testing ignores a critical consideration.
Endurance' testing is intended to 8906130144 850227 PDR ADOCK 05000322!
O PDR L
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H t:NTox & WILLIAME Alan R. Dy'nner, Esq.
February 27, 1985 Page 2 t
demonstrate that crack Initiation will not occur.
~
LILCO'has committed to inspect the highest. stress areas of the crank--
shaft following testing to confirm that cracks have not tiated.
ini-nal crankshafts that had not failed, evidence of crack-You i
initiation was readily apparent.
by LILCO coupled with inspection following the test is ade-Thus, the quate to demonstrate that cracks.will not initiate at 3500KW.
median level of 3300KW is also incorrect.Your suggestion that As you know from testimony, instrument errors are less than 1 100KW and are likely to beirandem in nature.
More important, although the operators are given a t 100KW control band, they will be instructed to maintain the median reading as close to 3500KW as possible.
Your assertions to the contrary, LILCO did not ignore the County's block concerns.
testing is to demonstrate tnatThe purpose of endurance cracks will not initiate.
Once cracks have initiated, as they have in the DG 101 and 102 blocks, further testing to the fatigue endurance limit not meaningful.
What is tien analysis coupled with *ILCO's commitments for surveil-is m lance of the block cracks.
I should add that the DG 10 bicekhasbeentestedfor203 hours, essentially 3x10g cles, at 3500KW.
cy-Thus, further endurance testing on the DG 101 and 102 blocks would be unnecessary and unwarranted.
LILCO's settlement proposal is serious and responsive to Judge Brenner's comments.
parties, we believe the bes:
Given the impasse between the course of action is to' ask the Board to become actively involved in settlement discussions (see Tr. 28,256).
To that end, we intend to submit the set-tiement proposal and the related correspondence to the Board.
We vill, of course, make it clear that any settlement discus-sions before the Board are without prejudice to our respec-tive positions in the litigation.
close of business today if you have any objection to thisPlease let me kno course of action.
2:.
HusTo < & Wrr.LIAxs Alan R. Dynner, Esq.
February 27, 1985 Page 3 In any event,.let me close by noting LILCCi remains open settlement of the diesel litigati.on.to any reasonable suggest Sincerely yours, Anthony F. Earley, Jr.
Edwin J. Reis, Esq.
cc:
Fabian G. Palomino, Esq.
be:
Dr. Joseph W. McDennell W. Taylor Reveley, III, Esq.
T. S. Ellis, III, Esq.
Brian R. McCaffrey Bruce E. Germano I
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