ML20097F239

Affidavit of Gr Leidich Re as-built Status of Standby Liquid Control Sys Initiation.Related Correspondence

ML20097F239
Person / Time
Site:	Perry
Issue date:	09/07/1984
From:	Leidich G CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20097F224	List: ML20097F217 ML20097F231 ML20097F239
References
OL, NUDOCS 8409180454
Download: ML20097F239 (6)

Text

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September 7, 1984 '84 FP 12 E0:l3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

THE CLEVELAND ELECTRIC Docket Nos. 50-440 O b 4 ILLUMINATING COMPANY ) 50-441 OL

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(Perry Nuclear Power Plant, )

,- Units 1 and 2) )

I AFFIDAVIT OF GARY R. LEIDICH -

ON AS-BUILT STATUS OF SLCS INITIATION STATE OF OHIC ) -

ss COUNTY OF LAKE )

Gary R. Leidich, being duly sworn, deposes and says as follows:

1. I, Gary R. Leidich, am General-Supervising Engineer, Nuclear Construction Engineering Section, of The Cleveland

Electric Illuminating Company. My business address is 10 Center Road, Perry, Ohio 44081. In my position, I have responsibility for all engineering activities to support construction, including the engineering activities to support construction of the Standby Liquid Control System ("SLCS"). A summary of my professional qualifications and experience is 8409180454 840910 PDR ADOCK 05000440 Q PDR

attached hereto ~as Exhibit "A." I have personal knowledge of the matters set forth herein and believe them to be true and Correct.

2. In' general terms, the SLCS consists of a storage tank 4 for boron solution, a test water tank, two pumps (SLCS Pumps C001A and C001B), two motor operated pump suction valves (Storage Tank Outlet Valves F001A and F001B), two explosive operated injection valves (squib valves F004A and F004B),

associated local valves, piping, instrumentation and controls.

Except for the controls, there would be no differences in the configuration of the SLCS whether its initiation mode were manual or automatic. The controls which would be used to manually initate SLCS are the two key-locked switches, C41A-S01A and C41A-S01B, which are located in Control Panel 1H13-P601 (the ECCS benchboard).

3. The controls for an automatically initiated SLCS would be in addition to tha: for the manually initiated system.

In general terms, automatic initiation would involve bringing the appropriate plant status indications (i.e., temperature, pressure) from the plant to the control system logic and sending appropriate activating signals from the control system logic to the SLCS pumps and valves. The control system logic for automatic initiation was built into the Redundant Reactivity Control System ("RRCS") panels (control room panels 1C22P001 and 1C22P002). The RRCS panels are the standard General Electric ATWS panels and include all Alternate 3A 4 - -- --,

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features, including automatic initiation. The automatic initiation capability is provided in a few of the plug-in printed circuit cards and memory chips which are incorporated in the RRCS " panels. These panels were installed in the control room in early 1984.

4. The RRCS panels themselves cannot automatically initiate SLCS. To convert to automatic initiation, considerable additional equipment would have to be built into the plant. This includes the following circuits:

From Control Room Panel (lH13P)

Circuit or Motor Control To Control Designation Center (lR24S) Room Panel C22AXX010 lH13P601 1C22P001 C22AXX012 1H13P601 1C22P001 C22AXX014 lH13P601 1C22P001 C22AXX018 lH13P601 1C22P002 C22AXX110 lH13P632 1C22P001 C22AXX111 lH13P632 1C22P001 C22AXX112 1H13P632 1C22P001 -

C22AXX113 lH13P632 1C22P001 C22AXX114 1H13P632 1C22P002 C22AXX115 1H13P632 1C22P002 C22AXX116 lH13P642 1C22P001 C22AXX117 lH13P642 1C22P001 C22AXX118 lH13P642 1C22P002 C22AXX119 lH13P642 1C22P002 C22AXX120 lH13P642 1C22P002 C22AXX124 lH13P632 1C22P002 C22AXX125 1H13P632 1C22P002 C22AXX126 1H13P632 1C22P002 C41AXX012 lH13P632 lH13P601

C41AXX018 lH13P632 lH13P713E

, C41AXX019 lH13P642 1H13P710A

C41AXX021 1H13P601 1H13P702B  !

! C41AXX022 lH13P601 lH13P642 I 1

C41AXX023_/ 1H13P601 1H13P632 l

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1/ This cable had been placed in floor duct prior to issuance of FDDR No. KLI-964 (see para. 6 below), but not termi-nated at either end.

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C41AXX026 lH13P601 1H13P702E C41AXX029 lH13P601 lH13P702E 1C22B7A . 1R24S018 lH13P713E 1C22B8B 1R24S023 1H13P710A 1C22C54A2 / 1R24S018 lH13P713E 1C22C55A- 1R24S018 lH13P713E 1C22C5882 / 1R24S023 lH13P710A 1C22C59B 1R24S023 lH13P710A Additional relays would also be required:

Designation Location (Control Room Panels)

C41A-K3A lH13P632 C41A-K4A lH13P632 C41A-K5A lH13P632 C41A-K6A 1H13P632 C41A-K3B lH13P642 C41A-K4B lH13P642 C41A-KSB 1H13P642 C41A-K6B lH13P642 Pump switches C41A-S01A and C41A-S01B which now have an 8 contact conf!guration would have to be replaced by a 10 contact size. Except for the cables mentioned in footnotes 1-2, none of these additions or replacements were ever installed at Perry.

5. As noted above, the installed RRCS panels included automatic initiation capability. This was in accordance with the statement in a letter from CEI to GE (H.L. Hrenda and H.A.

Putre to R.C. Mitchell, dated August 9, 1982, Exhibit "B" hereto) that the manual initiation feature "should not be incorporated on the (RRCS] panels prior to delivery," but that

-2/ These cables were pulled from the motor control center to the control room and terminated at both locations. They were never connected to the appropriate control panel.

They are now identified as spares.

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GE should perform its work so that the change to manual initiation "can be made after equipment delivery." This was done to avoid. delays in delivery which could impact construction and fuel load schedules.

6. Because GE had not yet revised the electrical elementary drawings to reflect manual initiation, CEI on July 22, 1983 directed GE to issue the appropriate documentation to assure that equipment needed for automatic initiation was not installed in Perry. Exhibit "C" hereto.

GE's Field Disposition Disposal Request ("FDDR") No. KLI-964, originated October 20, 1983, was issued as a result. Exhibit "D" hereto. Except for the circuits' identified in footnotes 1-2, which were installed before FDDR No. KLI-964-was issued, and the RRCS panels, none of the SLCS automatic initiation equipment was ever installed.3/

3/ The statement in an internal CEI memorandum dated September 28, 1983 that GE had been requested to prepare an FDDR "to remove the cables that were involved with au-tomatic initiation" (Exbibit "E" hereto), meant that the cables should be removed from the drawings and did not in-dicate that the cables had already been physically in-stalled.

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7. As of the date on which the final ATWS rule was issued (June 26, 1984), the SLCS installation was essentially complete. Installation of the manual initiation feature is at least 90% complete; all circuitc are installed and only a few circuits have not been terminated. On August 27, 1984, SLCS subsystem C41A was turned over by Construction to Nuclear Testing. On July 31, 1984 SLCS subsystem C41B was turned over.

This permits manual testing of the SLCS from the motor control centers. Thus, as of the date the ATWS rule was issued, the Perry SLCS was already being built as a manually initiated system.

8. Based on the facts set forth in this affidavit, the SLCS cannot be considered to have been built to' include automatic initiation.

Gary. R. L idich

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Subscribed and sworn to before me on this 7 day of September, 1984.

ilu n/s b J

~ Notary Public Hy Commission Expires:

PATRICIA G. DEDEK, Notary Pub 8c STATE OF OHIO (Lake County)

My Commission Expires April 16,1985

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