ML20244B503

Advises That Lilco Remains Open to Any Reasonable Suggestions from Suffolk County Re Settlement of Diesel Litigation.Settlement Proposal & Related Info Will Be Submitted to Board Due to Impasse Between Parties

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:

studied Your response effort on to LILCC's settlement proposal reflects a-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

- cycles for. additional testing. Asbasis. 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 term rating, a ratio of approximately ten to one. 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 cycles. further and Further i isalso'significanttonote,asDr.

16-21) in the reopened proceeding Bush'stestimogy(page,st reflects, 3 x 10 cycles is the. upper cycle fatigue limit.

bound-of the values normally used for the h gh.

Your claim that 3 x 106 cycles is inadequate because the a original critical crankshafts failed after similar testing ignores consideration. Endurance' testing is intended to 8906130144 850227 "

PDR ADOCK 05000322!

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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.

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committed to inspect the highest. stress areas of theLILCO'has crank--

shaft tiated. following testing to confirm that cracks have not ini-i nal crankshafts that had not failed, evidence of crack-You 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 As you know from suggestion that testimony, instrumentinerrors likely to beirandem nature. are less than 1 100KW and are More important, although the operators are given a t 100KW control band, they will be instructed as possible. to maintain the median reading as close to 3500KW Your assertions the County's to the contrary, LILCO did not ignore 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 102meaningful.

not blocks, further testing to the fatigue endurance limit is What tien analysis coupled with *ILCO's commitments for surveil-is m lance of the block cracks. I should add that the DG 10 bicekhasbeentestedfor203 cles, at 3500KW. hours, essentially 3x10g cy-Thus, further endurance testing on the DG 101 and 102 blocks would be unnecessary and unwarranted.

to Judge LILCO's settlement Brenner's comments. proposal is serious and responsive parties, we believe the bes: Given the impasse between the Board to28,256).

course of action is to' ask the become actively involved in settlement discussions (see Tr. 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 theinBoard tive positions are without prejudice to our respec-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 suggesti Sincerely yours, Anthony F. Earley, Jr.

cc: Edwin J. Reis, Esq.

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

e i

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