ML20138B463

Affidavit of Gr Leidich in Response to Ocre Motion for Stay Pendente Lite Re No Costs of Downtime

ML20138B463
Person / Time
Site:	Perry
Issue date:	10/10/1985
From:	Leidich G CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20138B407	List: ML20138B403 ML20138B436 ML20138B449 ML20138B463 ML20138B470
References
OL, NUDOCS 8510150366
Download: ML20138B463 (6)

Text

- =

UNITED STATES OF AMERICA NITCLEAR REGULATORY COMMISSION f

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) )

AFFIDAVIT OF GARY R. LEIDICH County of Lake )

ss:

State of Ohio )

I, Gary R. Leidich, being duly sworn, depose and say as follows:

1. I, Gary R. Leidich, am General Supervising Engineer, Nuclear Test Section, of The Cleveland Electric Illuminating Company ("CEI"). My business address is 10 Center Road, Perry, Ohio 44081. In my position, I have responsibility for all start-up and testing activities of the Perry Project. A state-nont of my professional qualifications and experience is atta-ched hereto as Exhibit A. I have personal knowledge of the matters set forth herein and believe them to be true and cor-rect. This affidavit is in response to Ohio Citizens for Re-sponsible Energy's Motion for a Stay Pendente Lite. The motion states at page 9 that if the Perry Standby Liquid Control Sys-tem ("SLCS") were converted from manual activation approved by the Atomic Safety and Licensing Board to an automated system J

t lM*'2Mit 8%8lan PDR r

c

'e j l

prior to operation, "there are no costs of downtime.'" This f

statement is' incorrect. Conversion.of the SLCS to automatic '

initiation would cause very substantial costs of " downtime,"

i.e., delay in operation of the plant.

i

j. 2.- The purpose of this affidavit is to' provide an esti-mate of the time required to convert the Perry SLCS from a msn-J ual. initiating system to an automatic initiating system, if CEI

. were required to do:so. This affidavit also provides a current

. estimate of the direct costs for such a conversion.

3. CEI currently estimates that it would take a minimum of'six weeks to convert Perry's manual SLCS to an automatic initiating system. This estimated. duration includes the time j required to procure and deliver mate' rials, to perform engineer-i .

j ing and construction, to finalize procedures, and to' perform the necessary inspections and tests.to confirm adequacy of the sytstem. This estimate assumes that all materials (including switches, relays, cable, connectors, solid; state devices, and other material)1/'could !be acquired and received at the site i .

~

'during the first'two weeks following a. decision to convert, and that the materials would already have'the-necessary environ-

mental qualifications. Delays in obtaining necessary materials would extend the six week duration-estimate.

t

~

! 1/ For.a description of the materials.that would be

- convert the manualESLCS to an automatically initiated needed to system, l 'see Affidavit of Gary R. Leidich on As-built Status of SLCS 1

. Initiation (September-7, 1984), attached to Applicants' Re- -

sponse to ASLB Request for Information on ATWS Rule and the-Perry SLCS (September 7,-1984).

l-j  :

4

n ,

i t 4.; As indicated in.the Affidavit of Murray R. Edelman, which accccpanies this affidavit, the current best estimate for Unit 1 fuel loading is November-8, 1985. Any delay in the fuel loading date is estimated to cost a minimum of $2.1 million per day, as indicated in Mr. Edelman's affidavit. If a stay of the PerryoperatinglicenseweregrantedbytheAphealBoard,a,nd g if CEI were to begin converting to an automatic SLCS immediate-ly following an Appeal Board decision on the merits of OCRE's appeal requiring an automatic initiating' system, the conversion process itself would delay the estimated fuel loading date by a

. minimum of six weeks, or 42 days. At $2.1 million peg day, the delay attributable to automating the SLCS is estimated to cost

)

a minimum of $88.2 million dollars. This would be in addition s , ,-

to the delay in fuel loading caused by the stay.

s ,

y b s

I

^

4 s b

i 1 7 3 , ,

, t

\

F lll \

I h-

...... .. ... . . . .. _- m.-_~ . . c.- -. ..u

5. CEI's current estimate of the direct cost that would be incurred in automating the SLCS is approximately $110,000.

This includes the estimated costs for engineering, constructicn inside and outside the control room, material.conpletion and approval of procedures, and testing. This represents a $40,000 increase over the estimate of $100,000 given by CEI in its February 29, 1984, supplementary response to OCRE *nterrogatory No. 22. The increase is primarily attributable to increased costs of labor and material since that time, and to the additional costs of retesting the SLCS and related systems at this advanced stage of construction. .

4t4-f -

GaryR.pidich Subscribed aad sworn to before se this & day of October 1985 On rthe Notary Public My Commission Expires:

'504E 3,150rr Neeuy Pune. state of chin 9 Demmiselon Empires Febevery 20,1990

. --_- m 6mus anty 9

i

' Exhibit A

' . RESUME OF GARY R. LEIDICH EDUCATION AND TRAINING: - Bachelor.of Science,. Electrical Engineering,

i. University of Toledo, 1972 '

Master of-Science Degree.in Engineering Sciences,' University of Toledo, 1974 i

EXPERIENCE: i 1974-Present'- The Cleveland Electric Illuminating Company Joined CEI in 1974 as an Associate Engineer in l- various fossil plant electrical' engineering a responsibilities in Plant and Substation Engi-neering Department. Responsible Engineer for -

precipitator retrofit.

In 1975, was assigned to the Perry Project and l was Responsible Engineer for procurement of plant electrical equipment. Also. responsible for. Perry electrical system design calculations, voltage and short-circuit studies and transmis-sion system interface criteria.

! In 1978, served as Lead Electrical Engineer and was responsible for supervision of personnel in-volved in all electrical engineering aspects.

In 1980, was Senior Engineer on assignment as i Supervisor of Construction Quality Engineering.

Responsibilities included supervision of' person-nel involved-in monitoring contractors' QA/QC performance during construction.

' In 1982, was Senior Engineer.in' Nuclear Con-struction Engineering Section. Responsibilities included supervision of engineering personnel, providing construction support for electrical, civil, structural and chemical disciplines.-:Was also responsible.for cost and. schedule control h of all primary engineering consultants.

i l

-l- ,

t i,

,_.-. L, .- ., , , , . . ,, .. . ; i , . - - . . . , - . - ~_ ,._-._-. -,

In 1984, was General Supervising Engineer, Nu-clear Construction Engineering Section, and was responsible for the on-site engineering to sup-port the construction program for the Perry

. Plant.

In 1985, was named to present position of Gener-al Supervising Engineer, Nuclear Test Section.

Responsible for all start-up and testing activi-ties for the Perry _ project.

PROFESSIONAL MEMBERSHIPS: - Secretary, Nuclear Power Engineering Committee of Power Engineering

- Society of Institute of Electrical and Electronic Engineers

- Registered Professional Engineer, ,

State of Ohio 1

l l

1 l

\ .