ML20076E148
| ML20076E148 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/22/1983 |
| From: | Mark Miller KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8308240163 | |
| Download: ML20076E148 (50) | |
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luMTED C01; U2SP05DENC8 00LKETED UNITED STATES OF AMERICA USNP.C NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAM b b b 0Fri:E CF SEtriGP -
00CKETmG & SEfWIC'.
} iiRANCH In the Matter of )
)
LONG ISLAND LIGHTING COMPANY )
) Docket No. 50-322 0.L.
(Shorehain Nuclear Power Station, )
Unit 1) )
)
APPLICATION FOR ISSUANCE OF SUBPOENAS Suffolk County hereby requests the Presiding Officer of this Licensing Board to issue subpoenas in the form attached hereto to (1) Titan Navigation, Inc. (" Titan") and its subsidiary or affiliated companies (collectively, the " Titan Companies") ,
(2) the State of Alaska, and (3) United States Steel Corporation
("U.S. Steel"). The subpoenas direct the Titan Companies, the State of Alaska and U.S. Steel to produce documents for inspec-tion and copying. Issuance of the subpoenas is authorized by.
10 CFR, Section 2.720.
The documents requested are directly relevant to Suffolk County's emergency diesel generator contention concerning the I cylinder head cracking problems'that have been experienced at the Shoreham Nuclear Power Station ("Shoreham") . The County's contention states that LILCO has failed to ensure rapid starting f and reliable operation of the Shoreham emergency diesel generators . . . (because) the diesels have suffered from cracking of (cylinder heads].
8308240163 g3aggy DR ADOCK 05000322 i
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't, LILCO and Transamerica Delaval, Inc. ("TDI"), the manu-facturer of the Shoreham emergency diesel generators, assert that, since originally supplying diesel cylinder heads to Shoreham, TDI has improved the casting and manufacturing processes employed in producing 6ylinder heads and the inspection and testing <
techniques used in detecting flaws in TDI's casting and manu-facturing processes. According to LILCO and TDI, these casting, inspection and testing improvements ensure that cracks and other casting defects will not occur in the cylinder heads currently produced by TDI (the "new heads") 1. / Accordingly, LILCO asserts that its commitment to replace all cylinder heads with the new heads prior to fuel load eliminates any concerns respecting the reliability of the cylinder heads on the Shoreham diesel generators.
In support of this assertion, LILCO and TDI rely upon the operating history of the new cylinder heads manufactured by TDI.2/ .
The. nexus sought to be established by LILCO and TDI between the reliability and the operating history of the new heads is illustrated by both the Pratt Affidavit and the deposition of Mr.
i Pratt of August 2 and 3, 1983 (the "Pratt deposition"), pertinent parts of which are attached as Exhibit 1 to this Application. I 1/ See, e.g., the Affidavit of Edward J. Youngling, the Shoreham Startup Manager, filed with this Board on July 7, 1983 (the
" Youngling Affidavit"), at 3-4. See also the Affidavit of ,
Richard A. Pratt, TDI's Customer Service Manager, filed uith this Board on July 7, 1983 (the "Pratt Affidavit"), at 9-10.
2/ See, e.g., Pratt Affidavit, at 10.
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Information regarding the operating history of the new heads was first provided in the Pratt Affidavit, where it was alleged that the new heads are " free from the casting imper-fections" detected in the original cylinder heads and that
[clurrent production cylinder heads installed in six marine DMR V12-4 TDI diesel engines have accumulated over 19,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of reliable operation without any evidence of similar casting imperfections or head cracking failures having occurred.3/
According to Mr. Pratt, these six marine diesel engines are aboard three vessels owned and operated by Titan: the Pride of Texas; the Star of Texas and the Spirit of Texas.-
4/
Further information regarding the operating history of the new heads was provided at the Pratt deposition when Mr. Pratt testified that TDI has produced approximately 6'00 of the new style cylinder heads since September of 1980 . . . and to date, we have experienced no failures simi-lar to the ones that occurred at Shoreham.5/
Mr. Pratt later revealed that TDI had actually manufactured 636 6
new cylinder heads since September, 1980 / and that his testimony regarding the operating history of these 636 new heads was based upon the fact that there had been "no warranty orders issued for f replacement of any of the new heads for failures similar to those encountered at (Shoreham]."7/
3/ Id.
4/ Pratt deposition, at 78-80 (see Exhibit 1).
5/ Id., at 42 (see Exhibit 1).
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6/ Id., at 65 (see Exhibit 1).
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7/ Id., at 77 (see Exhibit 1).
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Mr. Pratt, however, did not review all warranty orders applicable to the 636 new heads since, in his opinion, only seven diesel engines (other than the three Shoreham diesels) have accumulated enough hours to give " confidence in the reliability of the new production' heads."8/ These seven engines are the six .
12-cylinder engines aboard the three Titan vessels and a 16-cylinder engine aboard the M.V. Columbia, a vessel owned by the State of Alaska which, according to Mr. Pratt, was retro-fitted with 16 new heads approximately two years ago, and has accumulated about 4,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of operation since that time. Thus, Mr. Pratt reviewed only those warranty orders applicable to a total of 88 cylinder heads.9/ .
Mr. Pratt's testimony regarding the reliability of these 88 cylinder heads is suspect in light of documents discovered from LILCO following the Pratt deposition. These documents indicate that during September 1982, a cylinder head aboard the Star of Texas cracked in the intake valve port. This same documentation reveals that the Edwin H. Gott, a vessel owned by U.S. Stee and part l
j of that company's Great Lakes Fleet, has experienced numerous j cylinder head failures since 1979. These failures are relevant f to the reliability of the new heads produced by TDI since, by I
Mr. Pratt's own testimony, TDI had generally completed its 8/ Id., at 84 (see Exhibit 1).
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9/ Id. at 77-81, 89-90 (see Exhibit 1). .
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changes in the production,. inspection and testing tec'hniques for the'new heads as of late 1978.10/ Copies of the TDI docu .
ments relevant to the head failures on the Star of Texas and the Edwin H. Gott are attached as Exhibit 2 to this Application.
1 No documentation respecting the M.V. Columbia was produced by LILCO. ,
Based on the foregoing, Suffolk County hereby requests the Titan Companies, the State of Alaska and U.S. Steel to produce for inspection and copying.the documents described below.
The documents are plainly relevant, because they will tend to establish the actual operating history of the new heads installed on diesel engines owned or operated by entities either specifically refer: red to and relied upon by LILCO (Titan and the State of Alaska) or disclosed by documents discovered from LILCO (Titan and U S. Steel). Therefore, they are properly the subject of a t
subpoena under 10 CFR, Section 2.720. Further, it is necessary that the County have access to these documents in order to conduct l cross-examination of the LILCO witnesses durf.ng the hearing on i
! the County's diesel generator head cracking contention.
It is requested that the documents be produced within 15 i days of service of this Application and the applicable suLpoena at the offices of Suffolk County's undersigned counsel, 1900 M Street, N.W., 8th Floor, Washington, D.C. 20036, unless another time or location is mutually agreed upon.
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10/ Id., at 211-215 (see Exhibit 1).
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For purposes of this Application, the word " documents" is to be given its broadest meaning, including, without limi-i tation, correspondence, memoranda, photographs, reports, notes, written analyses, computer printouts, telexes, tele-copier transmissions,. telegrams, mailgrams, written evalua-tions, papers, criteria, standards, recordings, notes and minutes of meetings or of conversations or of phone calls, inter-office, intra-corporate memoranda or written communica- 'w tions of any nature, intra-agency memoranda or written communications of any nature, exhibits, appraisals, work papers, studies, opinions, assessments, surveys, projections, designs, i
drawings, contracts, agreements, diaries, charts, schedules -
and other written data and material, and all drafts, revisi'ons, and differing versions of any of the foregoing; and also all copies of any of the foregoing which differ in any way (in-cluding handwritten notations) from the original.
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Request 1 - Titan Navigation, Inc. and subsid'iary or affiliated companies j All documents in the possession, custody or control of I
the Titan Companies regarding the Star of Texas,- the Spirit 5_f . _,
L l Texas, or the Pride of Texas which relate in any way to cylinder, heads produced or manufactured by TDI since 1978. Without limitation, documents within the scope of Requ,est 1 include: >
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(a) All correspondence between the Titan Companies, TDI and/or hull and machinery insurance underwriters related to cylinder i
,, hea'd cracks or, casting' defects of any kind, including all warranty c15ims. -
(b) All analyses, reports, appraisals, memoranda or other documents which identify the occurrence of cracks or other casting defects in the cylinder heads, report the condition found and the repairs made or recommended, and disclose the specifi-cations of thC fuel used prior to failure of each cylinder head,
-the engine and cylinder head serial numbers and the name of the a
vessel involved, the engine model and horsepower rating, the power p develooed'by the engine prior to each cylinder head failure, and J , -
.tlut maximum firing pressure on rhe cylinders prior to failure of
.a each cylinder'heid?.?
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. ,i (c) All documentation which discloses the number of cylinder
, ieads manufactured since 1978 by TDI and used by the Titan Companies l
or_any of'them','the date of purchase cLf such cylinder heads or the date use~ commenced, and the. total accumulated hours for each such cylinder head, includingLthe total hours accumulated prior-to the occurrence of any cracking or other defect in any j
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t such cylinder ^ head.
, Request 2 - The State of Alaska
- All de'aumen'ts in th'e possession, custody or control of the 1
,t' State of Alask.t regarding-the M.V. Columbia which relate in any
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- way to cracks cnr feasting defe' cts in cylinder heads produced or s manufactured by'TDI since 1978. Without limitation, documents f within the scope of Request 2 include:
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(a) All correspondence between the State of Alaska, TDI and/ob hull and machinery insurance underwriters related to cylinder head cracks or casting defects of any kind, including all warranty claims.
t (b) All analyses, reports, appraisals, memoranda or other documents which identify the occurrence of cracks or other casting defects in the cylinder heads, report the condition 1.
found'and the repairs made or recommended, and disclose the specifications of the fuel used prior to failure of each cylinder head, the engine and cylinder head serial numbers and the name of the vessel involved, the engine model and horsepower rating, the power developed by the engine prior to each cylinder head failure, and the maximum firing pressure on the cylinders prior to failure of each cylinder head.
(c) All documentation which discloses the number of cylinder heads manu'factured since 1978 by TDI and used by the
, State!of Alaska, the date of purchase of such cylinder heads or the date use commenced, and the total accumulated hours for
,- each suc$ cylinder head, including the total hours accumulated D p,rior to he occurre,cce of any cracking or other defect in any f s
such cylinder head.
Request 3 bnited States Steel Corporation All documents in the possession, custody or control of U.S. Steel regarding the Edwin H. Gott which relate in any y way to cracks or casting defects _in cylinder heads produced n
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or manufactured by TDI since 1978. Without limitation, documents within the scope of Request 3 include:
(a) All correspondence between U.S. Steel, TDI and/or hull and machinery insurance underwriters related to cylinder head cracks or casting defects of any kind, including all warranty claims.
(b) All analyses, reports, appraisals, memoranda or other documents which identify the occurrence of cracks or other casting defects in the cylinder heads, report the condition found and the repairs made or recommended, and disclose the specifications of the fuel used prior to failure of each cylinder head, the engine and cylinder head serial numbers and the name of the vessel ,
involved, the engine model and horsepower rating, the power developed by the engine prior to each cylinder head failure, and the maximum firing pressure'on t,he cylinders prior to failure of each cylinder head.
(c) All documentation which discloses the number of cylinder heads manufactured since 1978 by TDI and used by U.S. Steel, the date of purchase of such cylinder heads or the date use commenced, and the total accumulated hours for each such cylinder head, f including the total hours accumnlated prior to the occurrence of any cracking or other defect in any such cylinder head.
Respectfully submitted, David H. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788
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1M;LN 7%fw Herbert H. Brown Lawrence Coe Lanpher Alan R. Dynner Michael S. Miller KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., 8th Fl'oor Washington, D.C. 20036 Attorneys for Suffolk County -
August 22, 1983 h
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EXHIBIT 1 CD 3
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3 UNITED STATES OF AMERICA i
2i NUCLEAR REGULATORY COMMISSION
< 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,
4 l 5 ---o00---
6 7 In the Matter of LOUG ISLAND LIGHTING COMPANY i <
S i (SHOREHAM NUCLEAR POWER STATION, No. 50-322 O.C.,
9 UNIT 1.) .
10I Deposition of RICHARD A. PRATT l 11 l '
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August 2, 1983 12!
VOLUME I i Pages 1 - 157 13 ;
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22 23 j 24 ,
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26 Reported by ADELE I. NOLAN, CSR No. 1641, LESLIE TANIMURA-WONG, CSR No. 5796 !
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W91.AW REPORTlWS SERYlCE INC.
1533 % Sweet $4m Francisco.CA 94109
'espnone i415: 928 8001 l
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1 INDEX 2
Page Number
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3 Examination by Mr. Dynner . . . . . . . . . 2 5 Afternoon Session . . . . . . . . . . . . . 86 6
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13 14 EXHIB ITS 15 Exhibit No.: ~
(g, 16 1 Document
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, 42 1 that caused the occurrences which we experienced there. :
- 2 The improvements in our casting techniques and pattern 3 equipment give me a far creater degree of confidence in the casting integrity and when coupled with all of these inspection a i 5! techniques, gives me a greater degree of confidence in the t !
integrity of the heads that are noing to be put onto the units li 6!
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at Shoreham._ '
E We have now produced approximately 600 of the new style 9 c'ylinder heads since September cif 1980 when these major
'O improvements were incorporated, and to date, we have experienced Shoreham.
11 no f ailures simila$ to the ones that occurred at I 12 We are rapidly accumulating numerous operating hours on 13.
the various installations that have these current production
'a heads which further reinforces my confidence in the new head 15 and the fact that the new head is not a totally new design, ec ~ but is an ongoing evolution of the older style head, with what i i 17 ; I would consider major iinprovements made to it, gives me further I
the head will exceed the already acceptable i 15i confidence that 19 reliability of the older style heads.
20 Q. Thank you, Mr. Pratt.
21 I would like to get back for a moment to the issue 22 raised by Mr. Ellis, which, as I understand it, is that if
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23 i dye penetrant examination was done with respect to the original 24 Shoreham heads, then how would the fact that you continue to 25 l use dye penetrant testing result in cylinder heads of a higher l 26 ! qualisv and reliability than the original heads produced for i
Shoreham?
27
! 28 ; [ Telephonic interruption.]
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WOLAW REPORTlWS SERYlCE IWC.
- 533 8 re St ee: San 8 aa: s:o CA 94:09
' Te'e:*ome 41Si 926-830' I
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1 MR. DYNNER: Okay.
2 MR. ALDEN: Also, I believe it calls f or a legal conclusior .,
3 but we will review it.
4 [ Discussion off the record.]
5 [Mr. Early entered deposition room. ]
6 MR. DYNNER: Q. Mr. Pratt, you testified that since 7 September, 1980, Delaval has produced approximately 600 of the 8 new style heads; is that correct? Is my recollection correct?
9 A. Yes, that is correct. It's slightly over; 636 to 10 be precise..
11 0 Now, do you know what portion of those cylinder 12 heads were installed in new diesel engines?
13 A. No, I would have difficulty putting-a figure on 14 that because a certain number of heads have been sold to
- 15 customers such as Long Island Lighting and other customers 16 which would detract from that number.
17 A ballpark nu::tber' to be used in installation on new 18 units would be 450.
19 MR. ELLIS: Mr. Dynner, I fail to see the relevance of 20 it. If you could point out to me the relevance, if it is 21 vital to some particular issue, we may endeavor to collect the 22 appropriate figure for you.
23 MR. DYNNER: The relevance of the number. /
24 MR. ELLIS: Whether they were put on new diesel engines 25 or old?
26 MR. DYNNER: I think you will see the relevance in a 27 moment, Mr. Ellis.
,- 28 Q. Does Delaval have a record of to whom and when the N.
WOLAW REPORTlWC SERYlCE INC.
- 1533 Pene Sweet San Fram:esco. CA 94109 Te.comone e415) 926 6001
. . .! 77 1 ' mischaracterized it or not.
2: MR. DYNNER: Let's ask Mr. Pratt.
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^- 3 THE WITNESS: I base that statement on the fact that I.
4 there had been no warranty orders issued for replacement of any 5 of the new heads for failures similar to those encountered at 6 LILCO.
7 MR. DYNNER: Q. Could you describe what you mean by 8 j warranty order?
I 9j A. Engines typically, when they are shipped from 10 our plant, are warranted for one year of operation after start-11 up.
12 Any part that does not function properly during that
- 13. ' one-year period and possibly for a considerable period af ter 14 : that time that we deem to be replaceable under that warranty, t
15 ' is ordered on our warranty order f orm. It is a form of no
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16 l charge parts ordering.
17 Q. Have you reviswed all of the warranty orders that 18 you believe could be applicable to the. 636 new heads?
19 A. I have reviewed what I would consider a sufficient 20 number of job files of engines which are in operation with the 21 new heads to, verify that, no, we have not had to replace any 22 of those heads for a failure mechanism similar to what occurred 23 /
at LILCO.
24 Q. What do you think is a sufficient number as you 25 stated?
26 MR. ELLIS: Well -- .
27 THE WITNESS: Give me a moment to add these up. The 28 number would be 88 cylinder heads.
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WeLAN REPORTlWC SERYlCE IWC.
1533 pene Stiert. San Francisco.CA 94109 Tewache 1415:926 8001
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Do I understand you to say you have 78 MR. DYNNER: O.
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2 l reviewed the warranty orders with respect to a total of 88 new i
3 cylinder heads?
4 MR. ELLIS: Mr. Dynner --
5 THE WITNESS: No.
6 MR. DYNNER: Q. Could you explain what you meant?
7 MR. ELLIS: Are you asking with respect to preparation 8 for this deposition or whether in the course of his business, 9 ' he ' reviews warranty orders?
10 MR. DYNNER: I am asking him on what he based the 11 statement that he made earlier, which I think is a correct 12 characterication of his testimony, that of the approximately 13 636 new style heads produced since September, 1980, there have 14 ! been no f ailures similar to those experienced at Shoreham.
15 ! Q. Is that a correct statement of your testimony,.
s 16 Mr. Pratt?
17 A. That's correct.
18 Q. And I am asking the witness the basis for his 19 statement.
20 Now, could you explain -- if there is no objection 21 from Mr. Ellis -- could you explain what you meant by your 22 review of warranty orders with respect to 88 heads?
23 A. Eighty-eight heads would be the total number of heads j 24 installed in the two particular jobs that I researched that 25 have accumulated the greatest number of hours since they were 26 manufactured and shipped from the plant. .
27 Q. What were those two particular jobs, Mr. Pratt?
28 A. That was the Levingston ship building, which our
- s NSLAW REPORTINC SEltYlCE IWC.
1533 *me Sveit. San Francis:o.CA 94109 Te.eoao** dt5! 926 8001 .
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l three vessels, each ' containing two V12 engines and the 2 Alaskan Marine Highway vessel, M/V Columbia starboard engine, 3 which is a V16 unit.
4 If we want to. consider, which I think we should, the 5 experience of the five new style heads that have been installed 6 at Long Island Lighting, we can expand that number to 93 and !
7 add the hours on those engines -- or sorry -- on those heads 8 which is now approaching about 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> apiece.
- 9 Q. If we take the particular job you referred to at 10 Levingston --
11 A. Yes.
12 Q. -- how many hours were each of the cylinder heads 13 on each of those engines operating based upon the research you 14 g
conducted?
15 A. The ini.tial ship has 9,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of operation; . {
the .second ship has 6,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of operation; and the third 16 !
17 ship, 4,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.
18 This is based on ressarch that was'done over a month 19 ago, so those times will have increased by now.
20 Q. What was the nature of your research?
The nature of the research was to get into the 21 ,
A.
l 22 service records for those engines since delivery of the I
there have been any cylinder head ship to verify whether or not 23 I 24 failures aboard those vessels similar to the failures encountered 25 at LILCO.
26 Q. By " service records," do you incl,ude anything other 27 than the warranty orders? f I
28 A. The warranty orders are the primary means of conductine i
Wei.AW REPORTlWS SERYlCE IWC.
' '533 Pee S'reet. San Francisco. CA 9M09 Teme one 4415)928-2001
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1 ; that survey.
,- 2' O. How did you determine the number of hours that each a
3 of these diesel engines had run?
4 A. By extracting the hours from either the warranty 5 orders or service reports written by our service representatives B when they are aboard the vessels.
7 Q. Did you request any information directly from 8 Levingston?
9 A. No; and these -- that may be a misnomer -- but no, 10 I did not request any information directly from Levingston.
11 Q. Is Levingston operating these vessels or did it just 12 build them?
13 A. Levingston was the constructor of the vessel.
I 14 Q. Do you know who is operating each of these three 15 vessels? ,
16 A. Yes. It's Titan Navigation in Houston, Texas.
17 Q. Is this all three of them?
18 A. Yes.
19 Q. Do you have the names of the three vessels?
20 A. The Pride, Star and Spirit of Texas.
21 Q. Did you have any communication with Titan Navigation .
22 with respect to the. number of hours that each vessel had 23 run? I' 24 A. No; I did not believe it was necessary to do so.
25 We have had extensive communications with Titan Navigation since 26 these vessels were put into service and I am confident of the 27 hours on the engines now.
- 2B Q. What are the dates that each of the three vessels wei.Aw arrenvius sEnvics twe.
1523 pene Sweet San Francisco.CA 94109 1e.eenone(415 978 8001
. . . ; 81 1 fwasput into service?
2l A. I do not have that on the top of my head.
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3l Q. Would you get that information for me, please?
4 MR. ELLIS: ,
We will take it under advisement.
5 It is 12:35; do you want to break?
6 MR. DYNNER: Let me ask a few more questions about 7 this and we will take a break, Mr. Ellis.
8 MR. ELLIS: Fine.
9, MR. DYNNER: Q. Mr. Pratt,,the engine on the Alaskan 10 Marine Highway has on the M/V Columbia --
11 A. Yes.
12 Q. -- do.you recall approximately the date that that 1.3 l engine was delivered?
I 14 i A. Yes; the engines were delivered ten years ago. -
- 15 Q. Was the engine on the M/V Columbia, the Starboard
- 16 V-16 engine a new engine that you were referring to?
17 A. No. It is the same ten-year old engine retrofitted 18 with 16 of the new current production heads.
19 Q. Do you remember the approximate date when it was 20 so retrofitted?
21 A. Two years ago.
22 Q. How did you obtain -- exc.use me -- how many hours i
23 /
( has that engine run?
24 A. Those vessels -- now, she is on her second operating 25 season; since the installation of those heads, those vessels 26 have accumulated 3500 hours0.0405 days <br />0.972 hours <br />0.00579 weeks <br />0.00133 months <br /> per season, so she now has about 27 4 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> on her since the replacement of the new heads --
- 28 with the new heads.
L ..uw nu.nnn. ==nes inc.
1523 Pine Speet San Francesec CA 94109 Te.conoae s415: 928 8001
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MR. ELLIS: You are obviously gcing to be longer on 1
- 2 this. Can we take a break after this question?
3 MR. DYNNER: Sure.
4 THE WITNESS : .Again, research of our service records 5 indicates whether or not a particular engine has started up 6 and when it would have started up; and, therefore, knowing the 7 operation of those engines and the approximate number of hours 8 that the engines would accumulate each year, I drew the 9 conclusion that- the Levingston and Alaskan Marine Highway and 10 LILCO heads were the only ones that I could reasonably look at 11 and justify as accumulating enough hours to give me confidence 12 in the reliability of the new production heads.
Q. Okay. Thank you, Mr. Pratt. We can 13 MR. DYNNER:
i 14 take a lu'nch break now. I'm sorry I went slightly over the r 15 12:30 point. .
'- 16 MR. ELLIS: Let me just say that we took this detour I am assuming then, 17 because you said you would cut through it.
to 18 that unless you want to, when we come back you may want 19 consider what, if any, part of the request you want to review 20 and we will take it up at that time.
2I MR. DYNNER: 1 think what is becoming clear, Mr. Ellis, 22 is that my request now becomes especially pertinent, because 2'~ it becomes obvious if one were to attempt to obtain accurate j 24 information with respect to each cylinder head, one needs in 25 the nature of the complete inf ormation that I have requested.
26 Now, it may be on the basis of what I think Mr. Pratt 27 has testified to that Delaval doesn't have documented information
- 28 about certain of the items that I am going to be interested in.
- l
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- 89 3
going to encourage you to focus on the ones he stated in his l 2
affidavit for your interrogation and not the 636 which his
[ 3 testimony is that that is the total number that has been j i
- manufactured under the new model number. !
i MR. D$NNER: O Mr. Pratt, is it correct that with 5
6 respect to your assertion either in your affidavit or in your 7 ! testimony here today that you are relying for your statement S
that the reliability record of the current production model
~
9 cylinder heads gives you assurance that the new cylinder heads .
10 are. free from the type of casting imperfections detected at i 11 : Shoreham, that- you are relying solely upon the operating history ,
12 i of the 83 heads that you identified previously today? l 13 A Yes. I think that's a valid assumption.
14 As Mr. Ellis was stating earlier, we have built 636 of 15 these heads since September of 1980; hoaever, numerous of them .
16 installed and sitting on shelves in the warehouse. ;
' '(.. are not ' .
17 i Numerous of them. ,- in f act the greater majority of them l I
18 ! are installed on new construction engir.es that have either not 19 been installed and started up yet, or have very minimal hours 20 on them, and therefore, I did not take them into account when I 21 was considering what jobs or heads to look at and base any kind and that's i 22 l of an assumption on reliability of the new heads, 23 why I focus my attention on the Texas class vessels which have l ,
1 24 . the 72 heads, on the M.V. Columbia, and on the five heads at ,
1 25 : LILCO.
i i
26 1
Now I should mention in passing that the LILCO engines !
I 27 i operate at a EMEP rating of 225 rating -- BMEP.
20 The cylinder heads on the Texas class vessels operate at l WOL AW REPORTlWC SERYlCE INC.
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2, at LILCO will see. ;
t 3
Therefore, they are stressed higher than tihe heads of l
- i l
' (
4 LILCO will be stressed, and I will state again that the 19,000 !
5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> that they have accumulated -- now that's 9,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per 6 hull, per engine, it's not 9,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> distributed over two 7 ! engines, so that's two engines that have 9,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> each on 8 them. I 9 If you are going to distribute it over the entire number 10 , of engines , it would be 38,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> total. I 11j 4 The Pride, you said, had two engines at 9,000?
I 12 i A Right.
13 ' O The Star, I think you said, had two engines at 6,000? ,
la A Correct. ,
15 O The Spirit has two engines at 4,000? -
i-( 16 '.
A Uh-huh. i 17 O And the -- ,
18 : A Columbia.
I 19 , O And the refitted engine on the M.V. Columbia has about j
20 ' 4,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />; is that correct?
2I A Correct.
22 What was that last figure? I'm sorry.
MR. ELLIS:
23 THE WITNESS: Fortv-five hundred hours.
' /
2# MR. DYNNER: O Do I take it that, in your view, the 25 operation of the cylinder heads in the marine application is 26 relevant to the reliability of the cylinder heads in a nuclear 27 application?
20 A Yes. That would be my opinion.
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' i UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION l l
3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l A .* i i ---o00---
S 6
7 .
. l 8 In the Matter of
9 LONG ISLAND LIGHTING COMPANY (SHOREHAM NUCLEAR POWER STATION, 10 UNIT 1.)
i 11 II t I
Deposition of ;
12 l RICHARD A. PRATT :
13 l August 3, 1983 VOLUME II 14 Pages 158 - 247 15 .
l l's 16 17 18 it ,
! i 19 i 20 21 i l
22 23 1 24 25 26 l
27 Reported by ADELE I. NOLAN, CSR No. 1641, LESLIE TANIMURA-WONG, CSR No. 5796 28 l
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s' 168 3, CROSS EXAMINATION BY MR. ELLIS i
4 ; FURTHER EXAMINATION BY MR. DYNNER 211 5
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They are not magically all incorporated as of l
- 2: September, 1980. i e '
! Q. S w uld it be -- are there new heads, as you use 3
, 4 ;
l the term new heads, that were manufactured prior to September 0 e of 1980, as you use the term?
5 i
6 A. Certainly.
I 7 Q. And given your definition of new heads, are the l l
8' heads that you -- strike that.
t 9
That's all the questions I have.
MR. DYNNER: All right.
10l '
11 FURTHER EXAMINATION BY MR. DYNNER MR. DYNNE: Q. Mr. Pratt, I would like to stick with 12 13 this discussion for just a few minutes.
14 ' You stated in response to Mr. Ellis that there were 15 . new heads, as you define them, manufactured prior to 1980. ,
16 Could you define for me exactly what you mean by new 17 heads? .
18 A. I would define a new head as a head that had been 19 completely MPI by our foundry, pre-heated prior to the 20 welding in of the valve seats, subjected to the two hydrostatic 21 test procedures at 100 psi, stress relieved and pickled. .t 22 Q. Now Mr. Pratt, what is the earliest date that all' !
23 of these things could have occurred with regard to the f 24 manufacture of a head? fi 1
25 g, 1978, ;
26 Q. Do you know when in 1978? .
27 A. Late 1978.
28 .
Q. Is it therefore f air to say that your definition of ;
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1! a new head is any head that was produced subsequent to late -
2' 1978?
3i A. That would be a fair statement, yes.
4 l The September, 1980 date is when we acquired the new 5 pattern equipment which caused an external visual appearance j 6 change, and was done primarily to incorporate the ongoing 7 changes to the old patterns, and in an effort to reduce 8! foundry rework.
9! Q. Were all of the changes in the casting techniques .
10 i made by late 1978 -- that is to say, all of the changes in ,
11 the casting techniques that you testified to yesterday, 12 alluded to this morning?
13l, , A. A great majority of them.
I4 The only change that I'm aware of that was not 15 i incorporhted by that time was the change in the gating, and 16 { I believe that was incorporated after September of 1980. .
17 Q. But you don't regard that as sufficiently important .
I 18 so that it would change your definition of the new heads; is 19
! that correct?
i 20 i A. No, I do not.
[
I
- 21 That would merely eliminate problems and foundry i
1 22 t rework.-
i.
'23 O. Well,- based upon this recent definition, your g
- i 24 :
definition of the new heads -- i 25 Read that back again.
MR. ELLIS:
26 MR. DYNNER: Q. Based on this recent definition that 27 l you have given of the new heads -- t 28 Are you implyina --
MR. ELLIS:
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- ' MR. DYNNER: Let me finish the question and then 3
. 2 y u can object if you wish.
Q. Is it fair to say that there have been more than 3,
4 636 new heads manufactured by Delaval?
i A. Yes.
5[ .
I 6 Q. When you gave us the history of operation of new !
7 heads yesterday, why did you refer only to the 636 heads that .
8 had been produced since September, 1980?
9 A. Because the --
MR. ELLIS: Let me object to the question.
10 'i 11 [
I think it's only fair to the witness that if we had .
i 12 j the transcript, I think that's the implicit -- implicit in 13 i the question.
14 But in any event, answer the question, Mr. Pratt.
15 MF. , DYNNER: Do you object to the question? .
T6 li MR. ELLIS: Yes, I do.
All right. Let me clarify the basis for ,
17 MR. DYNNER:
18 the question, Mr. Pratt.
19 Q. Do you recall yesterday we talked about your 20 ' definition of new heads -- I asked him -Atether he recalled.
You certainly can't object to that, can you?
21 22 MR. ELLIS: I don't object. .
-23 THE WITNESS: We discussed a definition for heads .
f I
24 that were termed as new, yes.
25 MR. DYNNER: Q. And do you recall that in my~ ques-26 tioning of you yesterday, we were talking about new heads as t
i 27 those that were manufactured since September of 19807 28 A. That was the general gist of the conversation at WSt.AW REPSRTlWS SERYlCE IWC.
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that time, yes. .
Yes.
2l Q.
3 A. Heads that ,incorporated the new -- or the cast 4 using the new pattern equipment.
5 O. Yes. And now the definition that you have given l you .
6 in response to Mr. Ellis' question would indicate that 7 are talking about new heads as being those that were manu-Bi f actured since late 1978; isn't that correct?
9 MR. ELLIS: I object to the question so far as it 10 implies you asked him for a definition yesterday of new heads 11 as he was using it in his affidavit.
12 Perhaps you did, and perhaps he answered as you said --
13 : I don't have the transcript before me, but I recall that was
" not his intention in my discussions with him -- that's why I 15 asked the question.
16 MR. DYNNER: I think you are mistaken, Mr. Ellis, but 17 I think we can ask the witness whether --
18 MR. ELLIS: I thought you asked him how many heads were 19 produced since September of 1980.
20! MR. DYNNER: I think the transcript will show we 21 I i arrived at a definition of new heads yesterday during the 22 course of my examination.
/
Be that as it may, would you please reread the question 23 ,
24 for us?
25 i THE REPORTER: [ Record read as followsr 26 Yes. And now the definition
" Question:
27 that you have given in response to Mr. Ellis' 28 question would indicate that you are talkinc g
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factured since late 1978; isn't that correct?") l 2
THE WITNESS: Again, that is not totally correct, 3
because it depends on the drawing of a specific line to deter-
- 5. mine whether or not a head is new.
I use the September, 1980 definition because that --
6 7
those are the heads that LILCO has, and will be putting on i s their engines now.
9 MR. DYNNER: All right. !
10 Q. Now, Mr. Pratt, were the changes that were made in 11 the production of the cylinder heads at Delaval, which you 12 '. believe solved the problems that arose with the Shoreham heads 13 made subsequent -- excuse me -- made by late 1978?
14 A. Yes, they were.
15 Q. So in your judgment, would the operation history 16 of heads that were manuf actured since late 1978, be relevant 17 I to the consideration of .the reliability of the Delaval heads?
i A. Yes, it would.
18{ ;
19 ' O. Now you very kindly yesterday gave us your view of had 20 the operating history of a portion of the 636 heads that 21 been manufactured since 1980 in September; is that correct?
22 A. Correct.
23 Q. Do you have information concerning the operating \ l i
24 history of heads produced between late 1978 and September of i
25 1980?
26 A. I do not have that material at my fingertips.
27 It would be available in our records , yes. ,
t.
28 Q. Have you reviewed that material in order to make
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. The' following are minutes of.a meeting held with Transamerica DeLaval on
. November 20, 1980 at the Lake Shipping Office - Duluth,, Minnesota i In Attendance: Mr. C'. Trussell Transamerica DeLaval Mr.sR.' Erickson Transamerica DeLaval Mr. C. King Transamerica DeLaval' Mr. S. Schumacher Transamerica DeLaval Mr. D. Wyr.cott Nalco Chemical Company Mr. S. Lamp Nalco Chemical Company Mr. R. McCartney USS Research Laboratory Mr. k'. Bertz USS Lake Shipping
! Mr. B. Liberty USS Lake Shipping i
Mr. E. Merry USS lake Shipping ,
r The purpose of the meeting was to discust and resolve certain outstanding problems n lative to the operation and maintenance of the DeLaval DMRV -
engines, Serial f75039-40, installed on the M/V EDWIN H.'GOTT.
l., Head Problems
- a. Review of 1980 Experf ence - Since fit-out 1980, five heads have failed. Four of these heads were on the starboard engine and one on the port. Of the five heads, the last failure on MM,-Qgg % November 13, 1980 was to a stress relieved and pickled head that gp accumulated 2,392 hours0.00454 days <br />0.109 hours <br />6.481481e-4 weeks <br />1.49156e-4 months <br /> prior to failure.
- b. Mr. King gave a review of Transamerica Delaval's resea reh into the head failure problem. He concluded that (1) locked up casting stresses in the heads precipitated cracking failure and (2) a severe aeratien probicm in the starboard engine contributed to hot spots which in turn caused head failures. The Water Trcatment Program supervised by halco Chemical Company did not contribute to the failures. .
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- c. At this point, Mr. Bertz stated that he would meet separately with -
Mr. King and Mr. Erickson to discuss any contributing financial responsibility on the part of U. S. Steel concerning the head failures. This meeting was held at the conclusion of the group meeting. Mr. Bertz again stated that U. S. Steel did not have any contributing responsibility for the head cracks and we would stand on the answer to the problem given in Mr. Bertz' letter to Mr. Durie .
dated June 13, 1980. Transamerica DeLaval indicated that the stand-pipe causing the' aeration was designed by the shipyard naval archi- j tect, R. A. Stearn, and therefore, was considered owner-furnished.
Mr. Bertz pointed out that the standpipe was constructed in accor-dance with information received from DeLaval and neither the ship-
_ yard nor U. S. Stesl was in possession of the Transamerii:a DeLaval drawing #00-700-01-D! showing a detail design of the standpipe for jacket water 'even though the drawing was dated in October 1973.
Mr. King acknowledged that this design information was not submitted to the owner prior to placing the engines in operation and this was ,
regrettabic. Mr. Bertz again pointed out that there was certainly no justification for U. S. Steel to share in the cost of the warranted hesd failures. Mr. King stated that he personally ac-
> cepted this explanation. If his superiors di.i not enre to appeal it, the matter would be considered closed.
... . -. -. - 2-~ . :: _
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Pile, S/N 75039/40 Janua ry 23, 1981 of head failures 7 This date is apprcximately two weeks af ter the engineers first noticed recalling the fos =inE proble=, and three weeks after the Nalco 2000 was put into the systa=. Dave Cliff ord recalled some f oaming problems early in the season. During subsequent review of the jacket water treatment and test logs, it was found that Nalco 2000 was used as the jacket water treatment early in the season also.
I was unaware of this condition previously.
The heads which have failed thus far and were found during ,
. lay up are as follows:
No. 3 R.B. starboard N30 344E 10-12-79 SR 4203 Ed Mrs 10,215 Eng. Mrs.
RMR 5814-78 cracked at Exh. bridge Replaced with P6B 891E 2-22-60 SRP
,No. 8 R.B. starboard J 29 138T 10.181 Ed Mrs 10,215 Eng Hrs RMR 5814-79 Cracked ( pin hole) at each area Repla:ed with H31 4345 2-24-76 SRP .
No. 6 L.B. port J16 156D 1-3-79 B,022 Ed Hrs 10,163 Eng Hrs R.9R 5814-80 Crackpd through intake seat Replaced with 026 589E SRP 12-7-79 No. 1 R.B. port J65 273D 6,723 Ed Hrs 10,163 Eng Mrs RMR 5814-81 Cracked through intake seat
- Replaced with l
l Water deposits also found on pistons:
No. 4 L.B. starboard No. 3 L.B. port No. 8 R.B. starboard No. 3 R.B. port I
l (This condition similar to that which exists on the cylinders j vith failed heads.)
Measured starboard engine valve stem wear. Wear is consider-ably worse than the port valves. Plotted data. Plot shows normal straight line wear up to 5000 hours0.0579 days <br />1.389 hours <br />0.00827 weeks <br />0.0019 months <br />. At this point the starboard exhaust guides were replaced with new guides. Plot shows accelerated wear on exhaust valve stems from SK to 10K -
hours. The f ollowing starboard valves were recommended replaced:
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Delaval -/'e.>.T- 9- ,J DEl$/ED Transamerica Detevat tne.
Engme and Compressor Dedsson ~ l
% I l lNTER-OFFICE CORRESPONDENCE
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To: Geoff King RECEiVEc / Date: February 27, 1981 MAY 0 6190
/ (g From: S. C. Schumacher [carJCf DIPg Cubject: M/V Gott Trip Report, S/N 75039/40, December 29, 1980 to
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February 8, 1981 ,
/A f 1"
Objective: To assist the owners in disassembly, evaluation, .
documentation, and reasse=bly of the main engines and related 7 ,.. .-
aux 111 aries. ,
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personnel Contacted: ' AA^ ~
Ralph Berts, Superintendent, U. S. Steel ; ..
Bruce E. Liberty, Senior Mechanical Engineer, U. S. Steel s i . .* s
- Laverne Pierson Chief Engineer U. S. Steel Bill Shugs, First Assistant Engineer, U. S. Steel
Introduction:
Due to the extended nature of this trip, I com-piled a daily log of specific work accomplished. The customer was given copies of that log on a weekly basis. (See attachment)
MY . . . .
1), ConEr'ols wo[rked satisfactorily during the season and will
[equireonlystandardmaintenanceduringlayup.
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[ 2) Four quantity heads failed vnter test. One cuantiev was an SR bead. Expect three more heads have failedT but passed the I water test.
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'N . 3) The jacket water systems of both_angines-foamed eTxesively N during the latter part of the season; air was trapped in the Q top of the standpipe, and was eventually pumped through the engines. ,
- 4) The new style gas tight manif olds performed well and have
, very little buildup in the slip ring area. .
- 5) One cylinder head stud was f ound broken on f 3 L.B. Port, 1/4" above the upper level of the head, in the thread area.
U. S. Steel was torquing to 3,300 ft.'1bs; will be reassembling Poem C.1066-3 (seew) 3/7s , _ _ _ _ _ _ _ _ _ _ _ _
UNITED STATES ShEEL CORP.
GREAT LAKE 5 FLEET WC&E8M/ MECHANICAL REPORT ISUMMER & LAY.UP)
CODE) ii' t i l i STEAMER /M.V.HhC_7i ITEM: NAME PLATE DATA & $1 RIAL NO.
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L 232f6.@_w J6-3-78DATE#,W OPENED //
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-d/- 79 DATE OPENED PREVIOUS _8 78 I/GB%choacdf>t A. ROUTINI INSPECTION in b REPORTER TROUBLE g .
- s. CONDmON rouND: 0/inden b-a d r ra cNc-d Throu m b in Ta b*t _gg hic n-- / -
d Sc el TE A REPAIR.5 MADE THIS TIME: c MC u) SQ b> T J/,5 2 93 n l-2 9-79 sn sa t D. PARTS USED. '
- Cu 4 er Nea o e FNo . o 3- 4 f.o - 0 3- 0 F
/-(sa< n ke-TM T Pa n 7^No . p-s u v E. RECOMMENDED REPAIRS FOR FUTURE, IF ANY:
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&-fM}/ AT .h.LL YC
%-mu-L&un CHIEF ENGINEER ,
l T. (IF ATTENDED) .
l NAME OF A.E.S. SURVEYOR FOR CLASS CREDIT l
j NAME OF U.S.C.G. INSPICTOR FOR INSP. REGI i
NAME OF USS REPRESENTATIVE A NAME OF MANUFACTURER'S REPRESENTATIVE l MAft CAP.r,0N CorY TO FLEET ENOINEER* OTFICE LAME TRie AS EACH JOr,15 con.PLETED.
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Transamenci.
HILHIU / , q .-
Delaval J r Transamence Delevet inc I Engine anc Conorepor Dmsion 5,
INTER-OFFICE CORRESPONDENbE To: C. S. Mathews
, , . - [Date: February 17, 1981
- cc: R. J. Pabers
/ ' ,
A. C. Barich From: G. E. Trusse11. /
/ (~)/[/-7['i4 -:
R. M. Erickson
Subject:
U.S. Steel ('EDWIN DMRV-16-A S/N 75039/40 .$ . 5 ,
/
l RECENED FEB191981 ? A 7 ~'[
$3y2 DEPM I visited the GOTT with Geoff King January 29, 1981 for'the purpose of reviewing main engine performance at sa.ason end, much in the manner we had visited last year. Our visit to the vessel was made in preparation for a meeting requested by Ralph Bertz where he and his stEff wished to discuss engine component problems experienced witn the plant during the last '
season. Ralph, with Dick Erickson's support, felt it mandatory we get together because he felt very strongly that serious deficiencies remained with the main engine.
Attached is an agenda prepared by Bruce Liberty for our meeting.' We met in a conference room provided by Advance Boiler. In attendanc.e were the following:
Ralph Bertz, Chief Engineer. U.S. Steel Great Lakes Shipping Bruce Liberty, Senior Mechanical Engineer, U.S. Steel Ed Merry, Port Engineer, U.S. Steel Bill Shuga, First Assistant Engineer, M/V GOTT -
Lavern Peterson, Chief Engineer, M/V GOTT Steve Schumacher, Customer Service Engineer, Transamerica Delaval Geoff Xing, Manager of Customer Service. Transamerica Delaval i Dick Erickson, District Sales Manager, Transamerica Delaval
-- G. E. Trussell, Manager of Engineering, Transamerica Delaval '
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Transamenci. Trenasmence Detest Inc Delaval Engene and Comornw bvcon gj' INTER-OFFICE CORRESPONDENC Date: February 17, 1981 To C. S. Mathews From:
G. E. Trussell
Subject:
U.S. Steel Page 2 <
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Delaval Transamenca Delavat inc g Engine and Compressor Dmseon E INTER-OFFICE CORRESPONDENCE To: C. S. Mathews Date: February 17, 1981 G
From: G. E. Trussell
Subject:
U.S. Steel Page 3 v
- 3. Follwing much discussion on the attributes of NALCO 2000 and NALCO 39L watt:r treatments, it was resolved that NALCD 39L would be used next season in bcth the main engines. NALCO 39L exhibits less propensity for foaming then does hk.C0 2000. Also, since two of the Caterpillar diesels foam with NALCO 2000, U.S. Steel will try NALCO 39L in the foaming engines to see if the foam ca'n be climinated. TDI Service will review its water treatment SIM recorrnendations and attempt to update the material to reflect improved knowledge in the treatment area. U.S. Steel will drain as much water as possible from the main engine cooling water systems and recharge with fresh treated water following any problem with cylinder head cracks to reduce the possibility of continued operation with combustion gas contaminated water. A specific sampling source (water pump discharge) will be used to take all samples for treatment analysis.
- 4. U.S. Steel has cut a purchase order for TDI to repair five cylinder heads returned for leak inspection, Two_ of the heads are stress relieved oickled-heads exhibitine vaftical cracks in the back wall M'l- D EE ofTna avhaus Cort. I advised TDI may~ want to cut one of'these
~
g heads up for the Foundry to assess the reason for these first-ever I
'r cracks. I will' advise later. Geoff asked U.S. Steel if there was d '5 0 '3 4 4 E. any interest in a sprayed-on ceramic coating applied to the fire deck and the exhaust port surfaces. Bertz and Liberty were interested and Geoff will follow up on this possibility.
- 5. Although it was necessary to rework all pistons to clean up the minor fretting at the crown skirt interface and the fourth ring groove.
U.S. Steel felt it best to bring pistons to current dimensional
- standards. Also, studs fonnerly torqued to 250 ft. Ibs. were replaced because of possibility of bending and twisting during installation.
Future studs should give piston life perfont.ance since the seating
/'
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.'. TraNsamence ~ M5'M0 A ej Transamerica Delavat Inc. [
h.S,
" g Engme and compressor divmon INTER-OFFICE CORRESPONDENC7 [
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. . Delaval Transamenca DelavalInc.
l Q Engine and Compressor Omsion
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INTER-OFFICE CORRESPONDENCE l 10 Bus / Trusse // - o.,. /-2l- H
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subject: M/P 64 U Mi n seik e s
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1.L n /d Il J L A '//i% s f yr s l
Form C 1066-2 tet own 3/79
g,s.an vpa.13 '&wM 00LKETED USNP.C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMM SI ggg BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFCEOFSELAUA' 00CKEilNG & SEBVlU BRANCH
)
In the Matter of )
~
)
LONG ISLAND LIGHTING COMPANY
~
)
) Docket No. 50-322 0.L.
(Shoreham Nuclear Power Station, )
- Unit 1) )
)
SUBPOENA DUCMS TECUM To: Titan Navigation, Inc. -
1 Allen Center, Suite 950 1200 Smith Street Houston, Texas 77002 ,
Lttention: Joseph Molini, Vice President, or any other officer or authorized representative of Titan Navigation, Inc. or its subsidiary or affiliated companies You are hereby directed to produce for inspection and f copying the documents specified under Request 1 of the attached
" Application for Issuance of Subpoenas." These documents shall be produced within 15 days of service of this subpoena at the offices of Kirkpatrick, Lockhart, Hil1, Christopher & Phillips,
! l l 1900 M Street, N.W., 8th Floor, Washington, D.C. 20036.
! If you oppose this subpoena, you may move'to quash or modify in accordance with 10 CFR, Section 2.720 (f) .
l.
- Lawrence J. Brenner Presiding Officer August. , 1983 r
l , - _ - _ . - - - , . _ _ __ _ . . . _ . _ _ _ , _ , _ _ . _ . . _ _ _ . . _ . . . _ . _ _ _ _ . _ ,_, _ __
.z. u _ . _ . L. *
^__. ~_ _ '__z_.~.._.' __ _
. - - . ~.- . - . .
v-l y. .,, . . a r .
COLKETED UNITED STATES OF AMERICA "SNRC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAS AW 23 101 :17 0FFl'E OF SEldtiAr -
00CKETmG & SE8vicr.
) BRANCH In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) ,
) Docket No. 50-322 0.L.
(Shoreham Nuclear Power Station, )
Unit 1) )
)
SUBPOENA DUCES TECUM ;
To: State of Alaska ,
i' Department of Transportation Division of Marine Highway System' Pouch Road Juneau, Alaska 99811 .
Attention: Martin Nussbaum or any other authorized >
representative of the Department of Transporta-tion, State of Alaska You are hereby directed to produce for inspection and copying the documents specified under Request 2 of the attached
" Application for Issuance of Subpoenas." These documents shall r
be produced within 15 days of service of this subpoena at the offices of Kirkpatrick, Lockhart, Hill, Christopher & Phillips, I
1900 M Street, N.W., 8th Floor, Washington, D.C. 20036.
l' 1
If you oppose this subpoena, you may move to quash or
, modify in accordance with 10 CFR, .Section 2.720 (f) .
l l
l
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Lawrence J. Brenner Presiding Officer August , 1983 l
i
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l . , _ _ z_. _ _ __ _ . . _ . . . . _ .. . _ . , _ _ _ _ , _ _ _ _ _ _.-_ _ _ _ _ _ _ _ _ _ _ ___._ _ . _
. o 00CKE E0 USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
, BEFORE THE ATOMIC SAFETY AND LICEN N tr$hbIl l7 GFFICE CF SELntir-00CKEiiNG & SEpvir,:
) BRANCH In the Matter of )
_ )
LONG ISLAND LIGHTING COMPANY )
) Docket No. 50-322 0.L.
(Shoreham Nuclear Power Station, )
Unit 1) )
)
SUBPOENA DUCES TECUM To: United States Steel Corporation Lake Shipping Office 400 Missabe Building Duluth, Minr.esota 55802 Attention: Any officer or authorized representative' of United States Steel Corporation's Lake Shipping Office You are hereby directed to produce for inspection and copying the documents specified under Request 3 of the attached
" Application for Issuance of Subpoenas." These documents shall be produced within 15 days of service of this subpoena at the offices of Kirkpatrick, Lockhart, Hill, Christopher & Phillips, 1900 M Street, N.W., 8th Floor, Washington, D.C. 20036. -1 If you oppose this subpoe'na, you may move.to quash or modify in accordance with 10 CFR, Section 2.720 (f) .
Lawrence J. Brenner -
Presiding Officer August , 1983
- ' - - - - = = - - e+ ---- - ---
, _ _ _ . . = . ..__ __._ __ . _ _ . . . . _ . . . _ _ _ . . . a.,.__._.. _._. _
. _ _ _ _ _ _ _ _ u, _ _ _ . .
EELergD ConRESPONDENCE 00CKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION T3 AG3 23 A11 :17 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CIFICE OF SECRETA A ,-
00CX57tNG & SEgyic;'
) BRANCH In the Matter of )
)
LONG ISLAND LIGHTING COMPANY )
^
) Docket No. 50-322 (0.L.) ,
(Shoreham Nuclear Power Station, )
Unit 1) ) *
)
CERTIFICATE OF SERVICE I hereby certify that copies of Suffolk County's "Applica-tion for Issuance of Subpoenas," " Subpoena Duce's Tecum" to Titan 'lavigation, Inc., " Subpoena Duces Tecum" to the State of Alaska, and " Subpoena Duces Tecuw" to United Statec Steel Cor-poration have been served to the following this ff8/ day of '
August, 1983 by U.S. Mail, first class, except as otherwise in-dicated.
- Lawrence J. Brenner, Esq. Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C. 20555 Howard L. Blau, Esq.
- Dr. George A. Ferguson 217 Newbridge Road Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board School of Engineering **W. Taylor Reveley III, Esq. 1 Howard University Hunton & Williams 2300 6th Street, N.W. P.O. Box 1535 Washington, D.C. 20059 707 East Main Street Richmond, Virginia 23212
- Dr . Peter A. Morris -
Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C. 20555 New York State Energy Offi~e c Agency Building 2 Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road Mineola, New York 11501
Mr. Brian McCaffrey Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea 175 East Old Country Road P.O. Box 398 ,
Hicksville, New York 11801 33 West Second Street Riverhead, New York 11901 Marc W. Goldsmith Mr. Jeff Smith Energy Research Group, Inc. Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O. Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Suilding San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David J. Gilmartin, Esq. H. Lee Dennison Suffolk County Attorney Building G. Lee Dennison Building Veterans Memorial Highway Veterans Memorial nighway Hauppauge, New York 11788 Hauppauge, New York 11738 Ezra I. Bialik, Esq.
Atomic Safety and Licensing Assistant Attorney. General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of Washington, D.C. 20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 Office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory
- Bernard M. Bordenick, Esq. Commission David A. Repka, Esq. Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jonathan D. Feinberg, Esq.
Staff Counsel, New York Stuart Diamond State Public Service Comm. I Environment / Energy Writer 3 Rockefeller P'.aza NEWSDAY - Albany, New York 12223 Long Island, New York 11747
Daniel F. Brown, Esq. Stewart M. Glass, Esq.
Atomic Safety and Regional Counsel Licensing Board Panel Federal Emergency Management U.S. Nuclear Regulatory Commission Agency Washington, D.C. 20555 26 Federal Plaza New York, New York 10278 James B. Dougherty, Esq.
3045 Porter Street, N.W.
Washington, D.C. 20008 Michael S. Miller KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATE: August J2 , 1983 1900 M Street, N.W., Suite 800 Washington, D.C. 20036
- By Hand
- Federal Express 4
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