ML20138B470

Affidavit of MR Edelman Summarizing Util Best Estimates for Achieving Full Power Operation of Unit 1 & Costs of Delay. Certificate of Svc Encl

ML20138B470
Person / Time
Site:	Perry
Issue date:	10/09/1985
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20138B407	List: ML20138B403 ML20138B436 ML20138B449 ML20138B463 ML20138B470
References
OL, NUDOCS 8510150368
Download: ML20138B470 (8)

Text

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i Before the Atomic Safety and Licensing Appeal Board In the Matte.- of )

)

THE CLEVELAND ELECTRIC ) .

ILLUMINATING COMPANY, ET'AL. ) Docket Nos. 50-440

) 50-441 (Perry Nuclear Power Plant, .)

Units 1 and 2) )

AFFIDAVIT OF MURRAY R. EDELMAN Q

j- County of Lake )

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State of Ohio )

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Murray R. Edelman, b'ing. e duly sworn, deposes and'says as

) follows:-

l. I, Murray R. Edelman, am Vice President-Nuclear Group, of The Cleveland Electric Illuminating Company ("CEI"). ,

i My business address is Perry Nuclear Power Plant, 10 Center-Road, Perry, Ohio 44081. In that position, I have responsibility for all areas of the Perry Project, including construction, engineering and operation.. A statement.of my ,

professional qualifications and experience is attached hereto i

as Exhibit A. I have personal knowledge of the-matters set forth herein and believe them to be true and correct. 'This

_ . affidavit is in response to Ohio Citizens for Responsible Energy's Motion for a Stay Pendente Lite.

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2. The. purpose of this affidavit is to summarize CEI's current best estimates for achieving full power operation of the Perry Nuclear Power Plant, Unit 1 and the economic costs which Applicants would incur should that schedule be delayed.

3. The current best estimate for Unit 1 is as follows:

Milestone Date Fuel. loading November 8, 1985 Operation above 5% power January 28, 1986 Completion of power ,

ascension program May 10, 1986 -

A delay in fuel-loading will result in an equivalent delay in -

f the subsequent milestbne dates.

l 4. Substantial costs will be incurred for every day that i

the fuel loading (and therefore subsequ'ent milestone dates) of Unit 1 is delayed. Without even considering the_ higher fuel costs for replacement power, the added-interest costs and the i

costs to maintain Unit 1 readiness will total about $2.1 million for each day _of delay.

5. Delay in the milestone dates will result in. increased I

interest costs. Until Unit 1 is placed in service, each of the

'Applicanth continues to accrue AFUDC (allowance for funds used during! construction). .The accrued AFUDC represents the 3

interest costs on the' money _that has been invested in'the plant. Based upon the actual bookedLvalues'forL-AFUDC for each of-the Applicants, each day of delay;would cost an additional

$1.1 million. The share for each individual Applicant is:

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Cleveland Electric $350,000 Duquesne Light 140,000 Toledo Edison 220,000 Ohio Edison 360,000 Pennsylvania Power 50,000 These amounts were calculated in accordance with the guidance provided by the Federal Energy Regulatory Commission in 18 C.F.R. S 1.101.

6. Additional delay costs will also be incurred as a result of maintaining the plant in a state of readiness for e

plant operation. Should issuance of the operating license be delayed by the stay sought by Ohio Citizens for Responsible

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Energy, CEI would continue to keep Unit 1 in a state of readiness pending the conclusion of the appeals process.

Keeping Unit 1 in a' state of readiness would necessitate paying the salaries of plant staff and support personnel (both CEI employees and contractor personnel), maintaining the supplies of-consumables, tools and spares, and paying the cost of maintenance activities by craft labor. The direct cost of these plant readiness requirements is estimated to be about $1 million per day.

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7. Thus, the cost of a stay in the issuance of an operating license for Unit I would be a minimum of $2.1 million for each day that issuance of

! the license is delayed. These costs would be borne by the Applicants, their stockholders and/or their customers.

4 Murray R. Edelman Subscribedagsworntobefore me this (/ day of October, 1985

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Notary Public My Commission Expires:

MNE E MOTT Notary Put& State of ONo My Commission Empires February 20,1990

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EXHIBIT A STATEMENT OF PROFESSIONAL QUALIFICATIONS MURRAY R. EDELMAN My name is Murray R. Edelman. My current position is Vice President-Nuclear Group, of The Cleveland Electric Illumirating

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Company ("CEI"). My business address is Perry Nuclear Power Plant, 10 Center Road, Perry, Ohio.44081.

I joined CEI in 1961. Between 1961 and 1972 I occupied various non-nuclear engineering positions in the CEI Civil and Mechanical Engineering Department, including Engineering Assis-tant, Engineer and Senior Engineer. During this period I was a Project Engineer on several CEI fossil plant projects.

I began working on the Perry Nuclear Power Plant ("PNPP")

in 1972 as the CEI Senior Licensing Engineer responsible for PNPP NRC licensing activities. In 1975 I was promoted to Gen-eral Supervising Engineer of the Licensing and Administration Section of the Nuclear Engineering Department. I retained my licensing responsibilities and also became responsible for other administrative areas.

In 1977 I was transferred from the Perry Project to the

-Civil and Mechanical Engineering Department as a General Su-pervising Engineer.

'Between April 1978'and April 1981 I held the position of Manager, CEI Nuclear Quality Assurance Department. In that ca-pacity I was responsible for planning and directing:the PNPP quality as'surance program. I reported directly to CEI's Vice President, System Engineering and Construction Group.

In' April .1981 I was appointed Manager, . Nuclear Engineering Department,'a position I held until April 1982. In that posi-tion I was responsible for PNPP engineering, construction, testing, procedures, records, licensing and cost control and reported to the Vice President, System Engineering and Con-struction Group.

Between April 1982 and December 1982 I was CEI Division Manager, Nuclear Engineering end Construction Division, respon-sible for all PNPP nuclear engineering, construction, licens-ing, fuel management, and cost administration. I continued to report.to the-Vice President, System Engineer'ing and Construc-tion Group.

Since December 1982 I have held the position of CEI Vice President-Nuclear Group. I have responsibility for all areas of the Perry Project,-including construction, engineering, and operation, and report to CEI's Executive Vice President.

I obtained a Bachelor of ScienceLin Mechanical Engineering from case Institute of Technology in 1961, and Juris Doctor

'from Cleveland Marsha.1 Law School in 1965.

My professional memberships. include the American Society of Mechanical Engineers, Cleveland Engineering Society, and the American Nuclear Society.

.t October 10, 1985 DN r.. ED UNITED STATES OF AMERICA UShE ,

NUCLEAR RECULATORY COMMISSION i Before the Atomic Safety and Licensing Appeal Boar 5 (CT l' P1124

$ OfflCE OF SECRGA6 :

In the Matter of ) 00CHETiNG & SERvlCf.

) ERANCH THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, _)

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Appli-cants' Answer to Ohio Citizens For Responsible Energy's ' Motion for a Stay Pendente Lite'" were served.by deposit in the United States Mail, First Class, postage prepaid, this 10th day of October, 1985, to all.those on the attached Service List.

WMk MICHAEL A..SWIGER 00QCA

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DATED: ' October 10, 1985 I

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

SERVICE LIST James P. Cleason, Chairman Atomic Safety and Licensing 513 Gilmoure Drive Appeal Board Panel Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jerry R. Kline -Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Clenn O. Bri Fht Colleen Woodhead, Esquire Atomic Safety and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Alan S. Rosenthal, Chairman Atomic Safety and Licensing Terry Lodge, Esquire Appeal Board Suite 105 U.S. Nuclear Regulatory Commission 618 N. Michigan Street Washington, D.C. 20555 Toledo, Ohio 43624 Dr. W. Reed Johnson Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board Lake County Administration Center U.S. Nuclear Regulatory Commission 105 Center Street Washington, D.C. 20555 -Painesville, Ohio 44077 Mr. Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 John G. Cardinal, Esquire- Ms. Sue Hiatt Prosecuting Attorney 8275 Munson Avenue.

Ashtabula County Courthouse Mentor, Ohio 44060 i

Jefferson, Ohio. 44047 l

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