ML17297A642
| ML17297A642 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/28/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 8108100104 | |
| Download: ML17297A642 (15) | |
Text
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)981 Docket Nos.:
50-528/529/530 Hr.
E.
E.
Van Brunt, Jr.
Vice President - Nuclear Projects Arizona Public Ser vice Company P. 0.
Box 21666 Phoenix, Arizona 85036
Dear fir. Van Brunt:
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SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - PALO VERDE NUCLEAR GENERATING STATION In order to complete our review of Palo Verde, we find that we will need your response to the questions found in the enclosure.
These outstanding
- issues, which deal with the conduct of operations ~at APS, have been previously discussed with ttr. Quinn of your staff.
A review team will be meeting with you and your staff in Phoenix on August 5-6, 1981 to discuss your responses to the enclosure.
We will plan to begin our meetings at 9:00 a.m.,
Wednesday, August 6.
The review team will consist of Gerald Zwetzig, Office of Inspection and Enforcement (IE), Gaston Fiorelli (IE), Janis Kerrigan. Office of Nuclear Reactor Regulation (NRR), and George Rivenbark (NRR).
Part! I will consist of interviews with some of the key individuals in the APS organization, as identified in Enclosure 2.
Part II will consist of your responses to our questions as stated in Enclosure 1, and any additional questions that may arise in the course of the meeting.
In this regard, it will be necessary for your responses to be promptly documented for the public record.
If you have any questions regarding this meeting or the enclosures, please contact us.
Sincerely, QgfgIuel sIgned &jr I
Ted esco Robert L. Tedesco, Assistant Director for Licensing Divi i of Licensing OFFECE/
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Mr. E.
E.
Van Brunt, Jr;
'Vice President - Nuclear Projects Arizona Public Service Company P. 0.
Box 21666
- Phoenix, Arizona 85036 PALO VERDE CC:
Arthur C. Gehr, Esq.
Snell
& Wilmer 3100 Valley Center
- Phoenix, Arizona 85073 Charles S. Pierson Ass i s tant Attorney General 200 State Capitol 1700 West Washington Phoenix, Arizona 85007 David N. Barry, Esq., Senior Counsel Charles R. Kocher, Esq., Assistant Counsel Southern California Edison Company P, 0.
Box 800
- Rosemead, California 91770 Margaret Walker Deputy Director of Energy Programs Economic Planning and Development Office 1700 West Washington Phoenix, Arizona 85007 Mr. Rand L. Greenfield Assistant Attorney General Bataan Memorial Building Santa Fe, New Mexico 87503 Resident Inspector Palo Verde/NPS
'.S. Nuclear Regulatory Commission P. 0.
Box 21324 Phoenix, Arizona 85001 Ms. Patricia Lee Hourihan 6413 S. 26th Street Phoenix, Arizona 85040 Bruce Meyerson Arizona Center for Law in the Public Interest 112 North Fifth Avenue Phoenix, Arizona 85003
~ '
ENCLOSURE I R
uest for Additional Information Palo Verde Nuclear Generatin Station 1.
NUREG 0731, "Guidelines for Utility Management Structure and Technical Resources,"
(Draft Report for Interim Use and Comment),
dated September
- 1980, recommends in Section B.l an operations organization which provides:
a.
Integration of all necessary functional responsibilities under a single responsible
- head, and b.
The assignment of responsibility for safe operation of the nuclear power plant(s) to an upper level executive position.
In addition, it is also clearly desirable that the corporate officer responsible for nuclear activities should not have ancillary responsi-bilities that might detract from his attention to nuclear safety matters.
These recommendations are made to facilitate unambiguous management control and effective lines of authority and communications.
Such an arrangement also facilitates training of support personnel in administrative requirements which are unique to a nuclear facility.
Contrary to the above recommendation, the proposed APS operations'rganization appears to provide a diffuse arrangement combining non-nuclear responsibilities with nuclear responsibilities.
For
- example, the Executive Vice President for Operations who is stated to be responsible for technical suppor t and operation of PVNGS (FSAR Section 13.1.1.2) is also responsible (FSAR Figure 13.1-1) for Customer
- Services, Engineering and Construction, Gas Operations, Electric Operations (includes PVNGS),
and Nuclear Project Management (primarily nuclear construction and nuclear services).
Similarly, if responsibility for support and operation of PVNGS is delegated to the Vice President, Electrtc Operations (as indicated in Section 13.1.2), it is seen (FSAR Figure 13.1-2) that this officer is also responsible for Fossil Operati'ons, Power Operations, and System Electric Operations.
It is noted'hat, although this latter arrangement is not inconsistent with the guidance in NUREG 0731 regarding assignment of responsibility to an upper level executive, it does appear to be inconsistent with the goal of an 'integrated functional organization.'his is because technical support is also derived from the Nuclear Projects Management, Organization, which is outside the Electric Operations Organization, and from the Fossil Generation Department, which is unrelated to nuclear generation.
Accordingly, please explain how your organization meets the NUREG 0731 recommendations noted above, or describe how you plan to modify your proposed nuclear operations organization to conform to NUREG 0731 recommendations.
2.
FSAR Section 13.1.1.2.2.1 discusses the Nuclear Services Department and its component organizations.
Such a department, however, is not shown in the organization chart for the'parent unit, FSAR Figure 13.1-4.
Please clarify.
3.
Please indicate whether the offsite technical support staff includes expertise in the field of metallurgy and materials.
If so, furnish the qualifications of the incumbent(s); if not, describe your plans to provide such expertise.
4.
FSAR Section 13.1.1.2 states that the Executive Vice President f'r Operations is responsible for technical support and operation of PVNGS.
Please provide a resume'or this individual. If your response to guestion 1, above, results in assignment of this responsibility to another individual, please provide, instead, a resume'or this other individual, if not already provided in the FSAR.
(Note:
See qualification requirements for management official in overall charge of nuclear power as stated in NUREG 0731, Paragraph II.B.2.a.)
5.
Please provide the resume'or the individual selected to fill the position of PVNGS Operations Superintendent.
6.
a.
Please revise FSAR Section 13.1 to reflect your commitment to meet the guidance contained in ANS 3.1-1978 for all positions described in that editi on of this industry standard.
b.
Please justify the deletion in FSAR Section 13.1.3.1 of -the requirement for a Senior Reactor Operator's License for the Operations Superintendent when such a license appears to be required by Section 4.2.2 of all editions of ANS 3.1, or restore the requirement.
7.
a.
FSAR Figure 13.1-6 indicates that five shift crews are planned for each unit.
Experience indicates that five crews are inadequate to assure an effective training program for shift personnel.
This arises
- because, when allowance is made for,personnel
- turnover, illness, and vacation, a five crew staff is reduced to four or four-plus.
Since this is the minimum needed for a four shift
- rotation, a frequent result is that training and requalification lectures must be done on overtime.
Since, such an arrangement does not appear to be conducive to learning or to alertness on the job, please indicate the measures you plan to implement to ameliorate this concern.
4 3
b.
A number of utilities have deemed it advisable in staffing for initial operation to provide at least one individual per shift who has had previous experience as a licensed operator at a similar (PWR or BWR) facility during ccmmercial operation.
This has been accomplished either through recruitment of individuals with such qualifications or through use of vendor contractor per-sonnel.
Please describe your plans for providing such staffing during initial operation of each unit of PYNGS, and the duration of such staffing.
I 8.
a.
FSAR Figure 13.1-6 shows a plant QA/QC organization consisting of a Quality Supervisor and two quality personnel per unit.
This does not appear to be consistent with the plant QA/QC organization shown in Figure 17.2-1.
Please amend the FSAR text and figures to reflect the planned organization, and the associated staffing levels and staffing schedules.
b.
With regard to staffing, assuming the organization shown in Figure 17.2-1 is the planned organization, we note that a staff consisting of one supervisor and two quality personnel per unit (as shown in Figure 13.1-6) appears inadequate to perform the reviews, audits, observations, report preparation and QC inspections normally occurring at an operating reactor.
Please provide a
brief analysis of the personnel resources needed to perform the tasks expected to be assigned to this organization and commit to this level of staffing.
9.
FSAR Figure 13.1-6 shows six radiation protection personnel per unit.
This level of staffing appears adequate to provide one health physicist on duty per shift per unit with an adequate allowance for absences and training.
No personnel appear to be provided, however, for radiation protection record keeping, whole body counting, ALARA engineering, dosimetry control, radiation protection training, and radwaste processing and packaging.
Please describe your staffing plans with respect to these activities.
10.
Please indicate your commitment to the guidance relating to radiation-protection training as set forth in Regulatory Guide 8.27 (March 1981).
11.
Please describe the training and retraining to be provided to offsite personnel who support the operation of PYNGS; e.g.,
in the areas of design review and safety review, procurement of safety-related components, prompt notification requirements of the technical specifications,,
and the matters discussed in Paragraph II.B.2.d of NUREG 0731.
~'
12.
Please describe the program that has been completed, or your plans for conducting, a position task analysis or equivalent program for all personnel regularly assigned to PVNGS which provides a basis for defining the needed training and thus provides assurance that assigned tasks can be effectively carried out.
In addition, please state when this program was or will be completed.
13.
Please furnish the duration of the normal training/retraining course(s) and the organization providing the training for the following employee groups identified in the FSAR:
a.
Non-Licensed Supervisors (Section 13.2.1.1.5) b.
Maintenance personnel (Section 13.2.1.1.6) c.
General employees (Section 13.2.1.1.7) 14.
Please describe the extent to which the staffing and training schedules shown in FSAR Figures 13.1-7 and 13.2-1 are being met (relative to currently projected fuel loading date).
If either -of these schedules is not being met, describe your plans for correcting the condition.
15.
Please indicate your commitment that the PVNGS fire brigade. training, practice, drills, and records maintenance will, as a minimum, conform to the requirements stated in Section III.H of Appendix R to 10 CFR 50.
16.
Please indicate your commitment to provide fire protection training for non-Fire Brigade personnel which conforms. to the guidance contained in Enclosure l.
17.
Please identify the positions within the APS and PVNGS organizations responsible for the fire protection program at PVNGS.
Also state the authority delegated to each of these positions to implement these responsibilities, and describe the size, composition and qualifications of the staffs, if any, assigned to each of these positions.
18.
Please describe the composition, membership, qualifications, duties, responsibilities, quorum requirements, meeting frequency, and documentation
'requirements of the Plant Review Board referenced in FSAR Section 14.2.2.7.
In addition, your response should verify the following:
a.
The scope of the reviews performed by this Board include those specified by 10'FR 50.59 and Section 4.3 of ANSI NI8.7-1976.
~
f b.
Organizational arrangements provide for interdisciplanary review of subject matter.
c.
The qualifications of the personnel performing the review are at least equivalent to those described in Section 4.4 of ANS 3.1-1978.
d.
Reviews are documented and results are forwarded to appropriate members of management.
19.
Please confirm that, in addition to ANSI N18.7-1976, Paragraph 4.3.1, the qualifications of SAC members will also conform to the requirements of Paragraph 4.7 of ANS 3.1-1978.
20.
Please indicate your commitment that the Independent Safety Engineering Group (ISEG) which you plan to establish per your letter of April 6, 1981, will meet all of the guidance provided in Section I.B.1.2 of NUREG 0737 (November 1980).
Also, Please commit that the members of this group will satisfy the qualification requirements for Staff Special-ists as defined in Paragraph 4.7.2, ANS 3.1-1978; and that the group wHl provide to management, no less frequently than monthly, a
summary of their activities to advise management on the overall quality and safety of operation.
- 21.
Please indicate your commitment that the PYNGS procedures limiting overtime (as committed to in your letter of April 6, 1981) will conform to the guidance contained in Section I.A.1.3 of NUREG 0737 (November 1980).
22.
Section 14.2.3.2 of the FSAR includes the statement, "The Plant Manager has the approval authority for Phase I through Phase IV test procedures, and may delegate approval authority to appropriate plant personnel."
Please describe the circumstances under which such authority may be delegated and the job titles or qualifications of the individuals who might receive such authority.
23.
Please indicate your understanding that startup test procedures for post-fuel loading tests and changes to such procedures will be reviewed and approved in accordance with the requirements stated in the facility technical specifications.
24.
Please describe where the Shift Technical Advisor group and the Independent Safety Engineering Group are located in the APS nuclear operations organization.
Please furnish copies of the following procedures you committed to prepare in response to the TMI Task Action Plan Items listed below:
.I.A. 1. 2 I.A.1. 3.1 I.A.1. 3. 2 I.B.12 I.C. 2 I.C.3 I.C.4 I.C. 5 Shift Supe rvisor Admini s trative Outies Overtime Shift Manning and Movement of Key On-Shift Personnel Independent.Safety Engineering Group (Group Charter)
Shift Relief and Turnover Procedures Shift Supervisor Responsibilities Control Room Access Procedures for Feedback of Operating Experience to Plant Staff
ATTACHMENT 1
FIRE PROTECTION TRAINING - OTHER THAN FIRE BRIGADE A.
Station Em lo ees l.
Instruction a.
Instruction shall be provided for all employees once a year.
It shall be repeated on an annual basis.
The instruction shall be given, as appropriate, on (a) the fire protection
- plan, (b) evacuation
- routes, (c) procedures for reporting a fire, and (d) control of ignition sources.
b.
Instruction shall be provided for security personnel that addresses (a) entry procedures for outside fire departments, (b) crowd control for people exiting the station, and (c) pro-cedures for reporting potential fire hazards observed when touring the facility.
c.
Instruction should be provided to all shift personnel that complements that provided members of the fire brigade.
d.
Instruction shall be provided to temporary employees so that
'hey are familiar with (a) evacuation
- signals, (b) evacuation
- routes, (c) procedure for reporting fires, and (d) control of ignition sources.
2.
Drills All employees should participate in an annual evacuation drill.
B.
Fire Protection Staff Training for the fire protection staff members include courses in:
1.
Design and maintenance of fire detection, suppression and extinguishing
- systems, 2.
Fire prevention techniques and procedures, and 3.
Training and manual firefighting techniques and procedures for plant personnel and fire brigade.
C.
Off-Site Fire De artments Training for the off-site fire departments include courses in basic radiation principles and practices, typical radiation hazards that may be encountered when fighting fires and related procedures.
D.
Construction Personnel Training for construction personnel should include instruction in reporting fires, alarm responses, evacuation routes and control of ignition sources.
ENCLOSURE II List of Pros ective Interviewees Senior Corporate Official in Charge of Nuclear Operations Vice President, Nuclear Project Management Corporate guality Assurance Manager Nuclear Engineering Manager(s)
PVNGS Plant Manager Purchasing Manager PVNGS Assistant Plant Manager PVNGS Operations Superintendent PVNGS Maintenance Superintendent PVHGS Engineering 8 Technical Services Superintendent PVNGS Nuclear Supervisor PYNGS Operations Engineering Supervisor PVNGS Radiological 5 Chemistry Supervisor PVHGS Support Services Manager PVNGS Operations gA Manager PVHGS Chief guality Inspector PYNGS Fire Protection Supervisor
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