ML20244B511
| ML20244B511 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/26/1985 |
| From: | Dynner A KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Earley A HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| References | |
| OL, NUDOCS 8906130147 | |
| Download: ML20244B511 (2) | |
Text
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y KIRKPATRICK & LOCKHART.._
i 1900 M MIrr. N.W.
UNF TAsHD80 Toff. D.c. 20Ch ma nomm PLAcz tomm. ha ens
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- u seEAmna CFFICE Or SECRETART Y Un 09CnETING & SERVICf.
BRANCH umouvst suuse February 26, 1985 mneumon rA mu warrsks omscrtw mesa a wwuo (202) 452-7044 e.a.,
(BY TELECOPY)
Anthony F. Earley, Jr., Esq.
Hunton & Williams P.O. Box 1535 707 East Main Street Richmond, Virginia 23212
Dear Tony:
We have reviewed LILCO's preposal for a settlement of the EDG litigation and are disappointed that it does not appear to be serious.
The proposal fails to address the County's concerns, which are well known to LILCO.
The crankshafts do not meet cigssification society rules at 3500 kW.
Operation for only 3 x 10 cycles is insufficient to prove the reliability of the crankshafts at that level, as shown by testimony in this proceeding as well as by the number of hours the EDGs operated before their criginal crankshafts failed.
LILCO's proposed additional testing ignores issues of instrument error and sufficient margin to cover additional loads operators could erroneously add during a LOOP or LOOP /LOCA event.
It appears to call for testing for cnly about 220 hours0.00255 days <br />0.0611 hours <br />3.637566e-4 weeks <br />8.371e-5 months <br /> at a median power level as low as 3300 kW, taking into consideration instru-ment error (+ 100 kW) and test tolerances Q 100 kW).
The LILCO proposal also ignores our concerns with the cracked blocks of EDGs 101 and 102, since it again selects EDG 103, with the replacement block, as the vehicle for the testing.
We have other problems with the proposal as drafted, but need not discuss them at this point given the proposal's non-respon-siveness to the basic issues in the litigation.
If, after 8906130147 850226 PDR ADOCK 05000322' G
- ' et
- b IGRXPATRICK &. LOCKHART Anthony F. Earley, Jr., Esq.
February 26, 1985 Page 2 reflection, LILCO makes a serisas and responsive settlement proposal, as we believe was suggested by Judge Brenner's repeated comments to LILCo's counsel, such a proposal would be. considered.
by us.
Very truly yours, Alan Roy ynner ARD/dk cc Edwin J. Reis, Esq.
Fabian G. Palomino, Esq.
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