ML20248B770

Affidavit of CA Mcneill,Executive Vice president-nuclear Philadelphia Electric Co.* Advises That Delays in Approval to Full Power Operation Will Impact Util Ability to Retain Qualified & Experienced Contractors.W/Certificate of Svc

ML20248B770
Person / Time
Site:	Limerick
Issue date:	06/05/1989
From:	Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20248B740	List: ML20248B735 ML20248B747 ML20248B770
References
OL-2, NUDOCS 8906090172
Download: ML20248B770 (5)

Text

_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

. . l i

UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION  !

i 1 l'

Before the Nuclear Rerulatory Commission In the Matter of )

)

Philadelphia Electric Company ) Docket No. 50-353 '

)

(Limerick Generating Station. )

Unit 2) )

Affidavit of Corbin A. McNeill, Jr.

Executive Vice President-Nuclear Philadelphia Electric Company Corbin A. McNeill, Jr., being first duly sworn, states as follows:

1. My name is Corbin A. McNeill. I am Executive Vice President-Nuclear of Philadelphia Electric Company, owner and operator of Limerick Generating Station, Units 1 and 2 (Limerick). I am responsible for the construction, licensing, and operation of Limerick and oversee the efforts of the Company in obtaining a license for Unit 2. ,

2. On February 28, 1989, the United States Court of Appeals for the Third Circuit issued its decision in Limerick Ecolorv Action. Inc. v. NRC, 869 F.2d 719 (3d Cir. 1989), affirming for the most part NRC action authorizing the licensing of Limerick. The Court remanded to the Nuclear Regulatory Commission the issue of whether severe accident mitigation design alternatives should be considered for Limerick pursuant to the National Environmental Policy Act (NEPA), 42 U.S.C. 54321 11 agg.

$gg6oggbc!$$0bh$2 o -

' ~

j

3. Despite the Third Circuit's explicit explanation that its decision should not impede the licensing of Limerick, the NRC Staff has nonetheless indicated that j it will not issue a license for Unit 2 until i i

(

completion of the proceeding on the remanded issue. l Past experience suggests. resolution of the remanded i i

proceeding will take many months, if not years, to  !

complete.

4. The schedule for completion of Unit 2 is such that the l plant will be ready to proceed to load fuel in the period of June 16-30, 1989. It is anticipated that Unit 2 will be ready to-exceed five percent power by I about August 1, 1989 and enter commercial operation by the end of.the year. l

5. Delays in the issuance of approval for proceeding to full power will result in a delay in the commercial operation of Unit 2. Such delays will increase the costs of Unit 2 by $35.7 million per month. This cost figure is made up of $30.4 million per month AFUDC and

$5.3 million per month operational, security and maintenance costs. In addition, the fuel costs of the  !

Company's customers will be increased by $11.9 million a month for each month of delay.

3

6. Delays in the issuance of approval for proceeding to full power operation could impact the capacity '

available to the PJM Interconnection of which the Company is part during a crucial period of this O

..;.s ~

summer, i.e., August through late September. Any power. generation frcm Limerick Unit 2 during this period is highly desirable and would help alleviate-

-power shortages if they were to occur. The PJM Interconnection is currently experiencing power '

shortages due to weather and unavailability of many-generating units.

7. Delays in the issuance of approval for proceeding to load fuel and to full power operation will impact the Company's ability to retain the highly qualified and

~

experienced. contractors who have been assembled to support start-up and power ascension testing activities.

8. PECo would agree that, for purposes of evaluation of SAMDA's, the cost / benefit analysis of alternatives for Unit 2 could be viewed as of the time of initial licensing. Hence, the evaluation would not be skewed by any incremental costs associated with . adding a design alternative after operation has commenced.

Based upon this evaluation, the fact that Unit 2 would be operated during the pendency of a hearing would not Prejudice the addition of design alternatives.

Executive Vice President-Nuclear Philadelphia Electric Company Subscribed.and sworn to before me This b day of June, 1989.

h*

-**ot.

.s =a.::ln c : ,,, , w_ ,

,c  !

+ . sb UNITED STATES OF AMERICA C'"

fir i NUCLEAR REGULATORY COMMISSION ~*

)

In the Matter of )

89 N -5 P3 :02

)

Philadelphia Electric Company ) Docket Nos p50-352

)

(Limerick Generating Station, )

v0%-35f*~

"' 4d Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Motion For Clarification Of The Commission's Delegation Of Authority And For Issuance Of An Operating License Or, Alternatively, For An Exemption From Any Procedural Requirement That A License For Limerick Unit 2 Cannot Issue Until The Contention Remanded By The Third Circuit Is Resolved" and

" Affidavit of Corbin A. McNeill, Jr., Executive Vice President-Nuclear, Philadelphia Electric Company" dated June 5 1989 in the captioned matter have been served upon the following by deposit in the United States mail or by hand delivery as noted this 5th day of June, 1989:

• Lando W. Zech, Jr.

• Kenneth M. Carr, Chairman, U.S. Nuclear Commissioner Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20551

• Thomas M. Roberts, Commissioner

• Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Office of the Secretary Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

• James R. Curtiss, Commissioner

• Morton B. Margulies, Esq.

U.S. Nuclear Regulatory Chairman, Atomic Safety Commission and Licensing Board Panel Washington, D.C. 20555 U.S. Nuclerr Regulatory Commission

• Kenneth C. Rogers, Washington, D.C. 20555 Commissioner U.S. Nuclear Regulatory

• Frederick J. Shon Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Hand Delivery 1

1 l

' . . .. . - o p 1

L-

• Dr. Jerry Harbour Mr. Ralph'Hippert Atomic Safety and Pennsylvania Emergency i Licensing Board Panel Management Agency  :)

U.S. Nuclear Regulatory B151 - Transportation Commission Safety Building Washington, D.C. 20555 Harrisburg, PA -17120

• Atomic Safety and Michael B. Hirsch, Esq. I Licensing. Appeal Panel Federal Emergency U.S. Nuclear Regulatory Management Agency Commission 500 C Street, S.W.

Washington, D.C. 20555 Room 840

. Washington, D.C. 20472

• Joseph Rutberg, Esq.

' Ann Hodgdon, Esq. Theodore G. Otto, Esq.

Counsel for NRC Staff Department of Corrections Office of the General Office of Chief Counsel

. Counsel P. O. Box 598 U.S. Nuclear Regulatory Camp Hill, PA 17011 Commission Washington, D.C. 20555 Docketing and Service Section

'

• Atomic Safety and U.S. Nuclear Regulatory Licensing Board Panel Commission

.U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Edward J. Cullen, Esq.

Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Charles W. Elliott, Esq.

325 N. 10th Street Easton,-PA 18064 Angus Love, Esq.

107 East Main Street Norristown, PA 19401 Robert R. Rader

• Hand Delivery

_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _