ML18017B429

Revised Mgt Capability Rept.

ML18017B429
Person / Time
Site:	Harris
Issue date:	07/31/1981
From:	CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML18017B428	List: ML18017B427 ML18017B429
References
NUDOCS 8108030263
Download: ML18017B429 (298)

Text

Carolina Power & Light Company Shearon Harris Nuclear Power Plant Management Capability Report Table of Contents Page 1 ~ 0 INTRODUCTION ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

2.0 MANAGEMENT OP ROUTINE NUCLEAR OPERATIONS 2.1 On Site (Harris Plant Staff) ..................,......,.. 2-l 2.1.1 Harris Plant Staff Organization .................. 2-3 2.1.1.1 Plant Operations Unit ................... 2-3 2.1.1.2 Administration Unit 2.1.1.3 Technical Support Unit .................. 2-3.4 2.1.1.4 Planning & Scheduling Unit 2.1.2 Plant Staff Personnel Resources 2.1.3 Training .........................................

2.1.3.1 Plant Management and Supervisory Personnel Training................... 2-22 81073i 8i08030263 05000400 PDR ADQCK A PDR

~Pa e 2.1. 3.2 Shift Engineer (Shift Technical Advisor) Training .....,..............

2.1.3.3 On-shift Technical Requirements 2.1.3.4 Technical Personnel Training ....... 2 37 2.1.3.5 Auxiliary (Non-Licensed) 1t Operator Training ........... 2 39 2.1.3.6 General Employee Training ................ 2 39 2.1.3.7 Fire Protection Training ................. 2 4O 2.2 Offsite Nuclear Operations Support 2.2.1 Offsite Organization,..................... . 2-41 2.2.1.1 Nuclear Operations Department ............ 2-44 2.2.1.2 Operations and Maintenance ........,...... 2 45 2.2.1.3 Technical Services Department 2.2.1.4 Corporate Quality Assurance ..............

2.2.1.5 Engineering and Construction ............. 2 64 2.2.1.6 Corporate Nuclear Safety ................. 2 7O 2.2.1.7 Corporate Health Physics,...... ~ ~ ~ ~ ~ ~ 4 2 76 2.2.1.8 Fuel and Materials Management ............ 2 79

2. 2. 2 Offsite Management Resources ...................... 2 82 2.2.2.1 Power Supply and Engineering 6 Construction Groups 2.2.2.2 Technical Services Department .;.... 2 83 2.2.2.3 Fuel Department """"'"'""""'""'-85

Table of Contents (continued)

Page 2.2.2.4 Engineering and Construction Management ........................... 2-85 2.2.2.5 Quality Assurance and Quality Control .... 2-87 2.2.2.6 Corporate Nuclear Safety ................. 2-89 2.2.2.7 Corporate Health Physics ................. 2-90 2.3 Senior Management Oversight Functions .................... 2-91 2.4 Off-site Technical Staff Resources ....................... 2-95 2.4.1 Power Supply Group ..o....o.oooo..o....woo..o.ooooo 2-95 2.4.2 Fuel Department 2-99 2.4.3 Engineering 6 Construction Group .................. 2-99 2.4.4 Quality Assurance ................................. 2-102 2.5 Coordination of Interdepartmental Technical Staff Support ..................................... 2-104 2.6 Off-site Staff Training .................................. 2-105 2.7 Outside Contractural Assistance .......................... 2-106 3.0 EMERGENCY, RESPONSE CAPABILITIES 3.1 Onsite Resources and Activities 3-1 3 .1.1 Action Levels .......................... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 3-1 3.1.2 On-site Resources ..................- ~ 3-2

Table of Contents (continued)

~Pa e 3.1.3 Procedures ........................................ 3-4 3.1.4 Training o ~ ~ ~ ~ ~ ~ o ~ ~ e ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 3-5 3.1.5 Recovery Manager ....................... . ~ ~ ~ ~ ~ 3-5 3.2 Off-site Resources and Activities ............ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

3 3.2.1 Emergency Operations Facilities 3-6 3.2.2 Organization ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ 3-7 3.2.3 Management Resources 3-7 3.2.4 Off-site Recovery Staff Resources 3-8

'3.2.5 Off-site Contractural Assistance ......... ~ ~ ~ ~ ~ ~ ~ ~ 9 3.2.6 Training and Requalification ...................... 3-9

3. 2.7 Procedures 3-10 4.0 HARRIS UNIT 1 STARTUP 4.1 Startup Organization ...............,.....................

4.2 Harris Pre-Startup Preparations .......................... 4-2 5.0 ADDITIONAL INFORMATION 5.1 Recruiting Program .................................

'IGURES 1 12 EXHIBITS 1 4

CAROLINA POWER Er LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT MANAGEMENT CAPABILITY REPORT

1.0 INTRODUCTION

On April 17, 1980, the USNRC Commissioners, in the Matter of Carolina Power &

Light Company (Shearon Harris Nuclear Power Plant), issued an order which directed, in part, that the NRC Staff "conduct the preliminary assessment and follow the other conditions described by the Appeal Board in ALAB-577, as part of the Staff's review of the Harris operating license application acceptance review (10CFR2.101(a)), a condition precedent to publication of notice under 10CFR2.105 . . .

" and " . . . adopt[ed] the Appeal Board's rationale for these conditions as its own."

The Appeal Board in ALAB-577 ruled, in part, that the NRC Staff should conduct, ". . . on the basis of the content of the operating license application and supporting documentation, . . . a preliminary evaluation of the applicant's capability to manage the operation of the facility. . ." This report provides the supporting documentation which demonstrates that Carolina Power 6 Light Company is well qualified to operate the Shearon Harris Nuclear Power Plant in a safe and reliable manner.

The Company has safely managed the operation of H. B. Robinson Unit 2 for more than ten years, Brunswick Unit 2 for over six years, and Brunswick Unit 1 for more than four years. During these ten years of Company nuclear operations, we have continued to revise the Corporate management structure as necessary to respond to the needs of our increasing nuclear operations activities. Based in part on lessons learned as a result of the Three Mile Island accident, we have further revised our Corporate management structure as shown on

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Figure 1, to more sharply focus nuclear activities within separate departmental and organizational structures. Based on operating experience at our Brunswick and Robinson plants, we have recently implemented the following improvements within the Company:

1. The organizations at our operating nuclear plants have been analyzed and significant modifications and additions have been made to those organizations. These modifications are directed toward ensuring improved management and supervisory coverage of all plant activities and increasing the operating staff for the nuclear plants. Some of the significant aspects of these changes are: (1) the establishment of the position -of Assistant to the General Manager, having direct management responsibility for the plant's administrative functions; (2) the establishment of the position of Director Planning &

Scheduling, who has direct responsibility for planning long-term and short-term outages and for planning and scheduling backfit and modification work; (3) the addition of a Principal Engineer Operations who has direct responsibilities for the activities of the Shift Technical,.Advisors, Fire Protection group, and the technical staff supporting shift operations personnel and the addition of two Project Engineers Operations who report to him and whose sole duties are to review operations engineering problems for their respective units; (4) the Radiation Control and Environmental & Chemistry functions have been separated into two groups (a Radiation Control Supervisor is responsible for the Radiation Control functions and an Environmental & Chemistry Supervisor is responsible for the Environmental & Chemistry functions); (5) a Radwaste Supervisor has been added and is responsible for the safe, reliable, and efficient operation of the plant's radwaste facility; and (6) the creation of a Project Engineer Mechanical and Project Engineer Electrical at the Brunswick Plant to supervise the mechanical and electrical technical staffs assigned to the Maintenance Subunit.

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2. Additional organizational changes at the Corporate level were implemented in 1979 to provide closer management support of our Nuclear Operations activities. Significant changes involved the splitting of the Generation Department into a Nuclear Operations Department and a Fossil Operations Department, with the Nuclear Operations Department being under the control of the Vice President Nuclear Operations. In addition, the Power Plant Engineering Department was split into two departments, one of which, the Nuclear Plant Engineering Department, includes on-site Engineering Staffs at our Brunswick and Harris plants to provide dedicated engineering support. During 1980, further organizational changes were made within the Power Supply Group. The Technical Services Department was moved from the Engineering 6 Construction Group to the Power Supply Group. This move was to improve support to the operating plants. Three sections in the Nuclear Operations Department (Nuclear Operations Administration Section, Nuclear Training Section, and Environmental and Radiation Control Section) were transferred to the Technical Services Department. This move was made to give the Vice President Nuclear Operations Department more time to devote to the safe operation of our nuclear plants.

Also, the Fossil Plant Construction activities were removed from the Power Plant Construction Department to allow the Vice President Nuclear Plant Construction to focus on nuclear plant construction and modification activities.

3. A new Corporate Quality Assurance Department was formed to consolidate the Company's QA/QC activities. The functions of the Operations Quality Assurance Section were transferred from the Nuclear Operations Department to this new department. The Engineering 6 Construction QA/QC activities were transferred from the Technical Services Department to the new department, and the Corporate QA audit functions were transferred from the Nuclear Safety and Research Department. An on-site QA/QC unit at each nuclear facility now reports off-site to a Corporate QA/QC manager.

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The Corporate Quality Assurance Department manager reports independently to the Executive Vice President Power Supply and Engineering & Construction.

4. A new on-site nuclear safety group was established at each operating nuclear plant, and reports independently off-site to a Corporate Manager in the Nuclear Safety and Research Department.

5. Improvements in training have been implemented to provide for additional simulator experience for requalification of operators; our PWR simulator has been programmed to simulate transients similar to those experienced at Three Mile Island; and a contract has been awarded for the procurement of a BWR simulator.

6. A Corporate Emergency Plan with supporting procedures has been developed to ensure that our corporate response to a nuclear emergency is well organized and coordinated. Plant Emergency plans and procedures have been re-written to conform with current NRC guidance. Lessons learned during a recent emergency exercise at Robinson Unit No. 2 have been incorporated. Further refinement of our Emergency Plans and Procedures will be accomplished following an additional emergency exercise scheduled for the Brunswick Plant in the late summer.

7. Essex Corporation has been contracted as a consultant to CPSL in order to review the design of the control boards at our nuclear plants and the control board of the SHNPP simulator utilizing human factor engineering principles. This comprehensive review encompasses procedures utilized by the operators that interface with the control boards, labeling of instruments and controls and the consistency with which this labeling is utilized in procedures, location and grouping of instruments, controls and annunciators, and information utilized by operators in making decisions concerning plant operation as well as the flow of this information. The 1-4

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results of this study will be reviewed to provide for improvements in the man/machine interface for the control operators. The SHNPP control board will be revised based on these studies.

8. In addition, CP&L has actively participated in the formulation of industry, organizations in response to lessons learned from the Three Mile Island incident. These include the Nuclear Safety Analysis Center (NSAC); the Institute of Nuclear Power Operations (INPO);

Owners Groups activities related to TMI; and other industry organizations such as EPRI, EEI, and AIF task forces.

Carolina Power & Light Company's current organization ensures that the Company's other operational activities will not detract appropriate management attention from the safe operation of our nuclear plants. The details of these organizational structures and our capabilities to manage our nuclear plant operations during routine and emergency situations are discussed further in this report.

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MANAGEMENT OF ROUTINE NUCLEAR OPERATIONS 2.1 ON SITE (HARRIS PLANT STAFF)

Shearon Harris Nuclear Power Plant (SHNPP) is a four reactor nuclear power plant. The overall plant staff, when all four units are operational, is projected to consist of more than 900 Carolina Power 6 Light personnel.

However, since Units 3 and 4 are not scheduled for operation until the 1990s, a functional organization has been developed to maximize the efficient operation of Units 1 and 2 while retaining the flexibility to expand to encompass Units 3 and 4 at a later date. It is recognized that many lessons will be learned in the operation of Units 1 and 2 that can be used to optimize

, the final four-unit organization. For this reason, the following description of plant organization will describe the Unit 1 and 2 organization only.

The organization for the SHNPP has been developed based on experience gained with the, start-up and operation of the H.B. Robinson Unit No. 2 and Brunswick Units 1 and 2. The organization is designed to ensure clear lines of responsibility, authority, and communication among the various units of the organization, and to provide for clear and effective managerial and supervisory control. Functionally, this organization is similar to the organization for our Brunswick and Robinson plants. As shown on Figure 2, the plant organization is headed by a plant General Manager, who has the overall responsibility for plant operations. The organization is divided into four units: Administration, Plant Operations, Planning 6 Scheduling, and Technical Support.

The Administration Unit under the" Assistant to the General Manager provides the staff support to the entire plant organization in the areas of cost control, document control, material/stores control, secretarial/stenographical and clerical/mail support, security, and emergency preparedness.

The Plant Operations Unit is divided into four major subunits. The Environmental and'adiation Control Subunit provides the chemical/

environmental services and radiation protection services for all plant areas.

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'he Maintenance subunit provides day to day corrective and preventative maintenance for both operating units and the common support facilities such as radwaste systems, fuel storage facilities, etc. To increase efficiency and allow the personnel to become most familiar with one area of plant maintenance, this subunit has been divided into a Unit 1: Maintenance Group, a Unit 2 Maintenance Group, and a Support Facilities Maintenance Group which will perform all routine maintenance on the common systems, and non-routine maintenance on each unit during outages. Another ma)or subunit is Start-up, which is responsible for the initial checkout and preoperational testing of each unit as it is completed by construction forces and prior to turnover to operational forces for initial fuel loading and startup testing. The fourth subunit is Operations, which on a shift basis, operates both units under the direction of an on-shift Operating Supervisor. The Operations organization consists of six Operating Supervisors, one for each shift, providing a supervisor for both units and six Shift Foremen and crews for each unit. The sixth shift is provided as a training shift plus one additional Shift Foreman and five Senior Reactor Operators are available to supplement any shift with additional work, personnel out sick or shore-handed or training requirements.

The Planning & Scheduling Unit provides staff functions to the entire plant for outage planning and scheduling of engineering modifications during regular operation periods and outages.

The Technical Support Unit provides the staff functions to the entire plant for engineering support and regulatory compliance.

In the following sections, each unit, subunit, and the major organizational structures depicted on Figure 2 are described with primary responsibilities, listing of supporting organizations, and to whom the member of the management group reports.

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. 2.1.1 Harris Plant Staff Organization The SHNPP organizational structure is based on an analysis of the kinds of key activities needed to achieve the objectives of the organization, and the interrelationship of these activities. The organization is based on experience, on accommodating the Three Mile Island Lessons Learned, and on similar organizations at the Brunswick and Robinson plants.

The General Mana er Harris Plant is responsible for all phases of plant

'anagement, including administration, operation, maintenance, and technical support. He manages and controls the organization through personal contact with the four unit heads and through written reports, meetings, conferences, and in-plant inspections. He is responsible for adherence to all requirements.

of the Operating License, Technical Specifications, Corporate Quality Assurance Program, and Corporate Health Physics and Nuclear Safety Policies.

He is supported in these responsibilities by the Manager Plant Operations, Manager Technical Support, Director Planning 6 Scheduling, and the Assistant to the General Manager. The General Manager reports directly to the Vice President of Nuclear Operations.

2.1.1.1 Plant Operations Unit All key activities that directly contribute to power production are consolidated in the Plant Operations Unit. Operations related activities are decentralized under the Manager Operations, Manager Maintenance, and Manager Environmental 6 Radiation Control. The Operations, Maintenance, and EGRC subunits are responsible for activities in their respective areas.

Startup is consolidated into the Plant Operations Unit under the Superintendent Startup to ensure that all start-up and preoperational testing activities are coordinated with plant objectives.

The Mana er Plant Operations is responsible for the operation, chemistry, radia'tion control, environmental support, and maintenance support of all units, operating and in Start-up. He is 'also responSible for refueling operations. This is accomplished through a staff which includes the 2-3

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Manager Operations, Manager Maintenance, Manager Environmental 6 Radiation Control, and the Superintendent Startup. The Manager Plant Operations reports to the General Manager and assumes all responsibility and authority of the General Manager in his absence.

Operations The Manager Operations is responsible for the safe and efficient operation of the two units and required support facilities. He is responsible for primary and secondary system performance and the timely completion of the scheduled periodic tests, and for adherence to the requirements of the Operating License and Technical Specifications. He is also responsible for coordinating and overseeing the duties of the various Shift Operating Supervisors assigned to the plants, the Radwaste Supervisor, and the Principal Engineer Operations. He is responsible for orderly and safe operations, turnovers, and compliance with operating instructions. He is supported in these responsibilities by a staff of Operating Supervisors, Radwaste Supervisor, and Engineers/Specialists. The Manager Operations reports to the Manager Plant Operations.

The Operatin Supervisors Units 1 6 2 are responsible for supervising plant operations during their shift and are the designated individuals in charge of the plant on back shifts unless specifically relieved of this responsibility by either the Manager Operations, Manager Plant Operations, or the General Manager. They are responsible for adherence to the requirements of the Operating License and Technical Specifications, and for the personnel assigned to their shift, including operators, mechanics, electricians, chemistry and environmental technicians, radiation control technicians, and 1&C technicians.

They accomplish this through the various foremen and personnel assigned to their shift. The Operating Supervisors report to the Manager Operations.

The Shift Foremen are responsible for ensuring the safe, dependable, and efficient operation of their assigned unit. They are responsible for adherence to the operating procedures, the Operating License and Technical Specifications. It is the responsibility and authority of the Shift Foreman to maintain the broadest perspective of operational conditions affecting the safety of the plant and to keep this as the highest priority at all times when 2-4

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on Control Room duty. The Shift Foreman, until properly relieved, remains in the Control Room at all times during accident situations to direct the activities of Control Room Operators. He may be relieved only by qualified persons holding SRO licenses. During routine operations when the Shift Foreman is temporarily absent from the Control Room, a Senior Control Operato'r will be designated to assume the Control Room command function. He is supported by and supervises Senior Control Operators, Control Operators, and Auxiliary Operators. The Shift Foremen report to the Shift Operating Supervisor.

The Radwaste Supervisor is responsible for the shift operations of the Waste Processing System. This includes the working procedures and operation of the equipment necessary to generate all the process water utilized within plant systems and to ensure safe and efficient handling and storage of plant generated contaminated wastes until final disposition. He is assisted by the Radwaste Shift Foremen, Radwaste Operators, and Radwaste Auxiliary Operators.

The Radwaste Operations Supervisor reports to the Manager Operations.

The Shift Foremen Radwaste are responsible for ensuring the safe, dependable, and efficient operation of the Waste Processing System. It is the responsibility and authority of the Shift Foremen Radwaste to direct the activities of the Radwaste Operators to ensure efficient handling, processing, storage, and shipment of plant generated contaminated wastes. They are supported by and supervise Radwaste Control Operators and Radwaste Auxiliary Operators. The Shift Foremen Radwaste functionally report to the Radwaste Supervisor but are under the direction of the Shift Operating Supervisor to ensure that Radwaste operations support is compatible with overall plant operations.

The Principal En ineer Operations is responsible for providing technical and engineering support to the plant operating personnel. He is responsible for the implementation and efficient operation of the shift technical advisor (STA) program at the plant as well as providing direct technical support in the areas of: (1) Plant Operations; (2) Fire Protection as necessary to support safe, efficient, reliable operations; and (3) reactor core management 2-5

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to meet system load demands and compliance with regulatory requirements. He is assisted by Shift Technical Advisors, a Fire Protection Specialist, and a staff of engineers and technicians. The Principal Engineer Operations reports to the Manager Operations.

The Shift Technical Advisor is responsible for providing to shift operations personnel accident assessment, technical advice concerning plant safety, and 10CFR21 evaluations. He accomplishes this by performing engineering evaluations of plant'perations, maintaining and broadening his knowledge of normal and off-normal operations, and diagnosing off-normal events. The Shift Technical Advisors report to the Principal Engineer Operations.

Shift Operatin Crew The Harris Plant has twelve (12) Shift Operating Crews, six shifts assigned to Unit 1 and six shifts assigned to Unit 2. Each shift is supervised by a Shift Operating Supervisor (SRO license), and as a minimum, is composed of two Shift Foremen (SRO license), two Senior Control Operators (SRO license), three Control Operators (RO License), and four Auxiliary Operators. Each Shift Operating Crew is charged with the responsibility of operating its assigned unit in a safe and economical manner within the plant's Technical Specifications, Operating Procedures, Corporate Nuclear Safety Policy, Corporate Quality Assurance Program, Corporate Health Physics Policy, Corporate ALARA Program, and NRC and other regulatory requirements.

Eight of the Shift Operating Crews work on three rotating shifts to operate the two units; two crews are used as a relief shift for vacationing and sick operators, and the remaining crews are in training. Each shift periodically rotates to the relief or training shift. With the rotating shifts, relief shift, and training shift, there are ample opportunities for all personnel to accomplish training and retraining without any requirements for excessive or unusual working hours.

Each Shift Operating Crew at SHNPP shall meet the following requirements:

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a) when any unit has fuel in the reactor core, there shall be a Shift Foreman with an SRO license on site at all times.

b) For each nuclear power reactor with fuel in the core, there shall be a licensed operator in the control room at all times.

c) For each reactor that is operating, there shall also be a licensed SRO in the control room at all times.

d) For each control room from which a reactor is operating, there shall be an additional licensed operator to provide relief for the control room operator and to perform duties outside the control room that need to be performed by a licensed operator.

e) For each reactor containing fuel, there shall be an auxiliary operator above the requirements of (a) through (d) above, plus an additional auxiliary operator for each control room from which a reactor is operating.

f) For all core alterations, there shall be a licensed SRO or SRO limited to Fuel Handling to directly supervise the core alteration.

This SRO shall not be assigned any other concurrent operational duties.

g) The Shift Foreman shall be assigned only the minimal administration duties required to operate his shift.

In order to ensure that each on-site crew collectively has the requisite technical qualifications in reactor physics and control, nuclear fuel, thermal hydraulics, transient analysis, instumentation. and control, mechanical and structural engineering, radiation control and health physics, electric power, chemistry, and plant operation and maintenance, an extensive training program has been established and is described in detail in Section 2.1.3.

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Maintenance The Maintenance Subunit performs all corrective and preventive maintenance on plant systems and equipment. The Manager Maintenance is responsible for corrective and preventive maintenance for all units and common support facilities. These include ensuring that equipment, instrumentation, controls, mechanical, and electrical systems of all facilities are maintained at optimum dependability and operating efficiency. He is responsible for the coordination of these functions and for approval of working procedures and standards. He is assisted by the Unit 1 Maintenance Supervisor, Unit 2 Maintenance Supervisor, Support Facilities Maintenance Supervisor, and a staff of foremen, mechanics, engineers, technicians, and specialists. The Manager - Maintenance reports to the Manager Plant Operations.

The Maintenance Supervisors Units 1 6 2 are responsible for ensuring that equipment, instrumentation, controls, mechanical, and elecrical systems of his assigned Unit are maintained at optimum dependability, safety, and operating efficiency to comply with plant Technical Specifications, QA, Security, Radiation Control, plant procedures, and regulatory requirements. They accomplish this by planning, directing, and controlling a trained staff, inspecting maintenance work, providing effective maintenance procedures and standards, and developing improvements in the Preventive and Corrective Maintenance Program. They are assisted in these functions by a staff of foremen, mechanics, engineers, technicians, and planner/analysts. The Maintenance Supervisors report to the Manager Maintenance.

The Support Facilities Maintenance Supervisor is responsible for ensuring that plant instrumentation and control, electrical, and mechanical systems common to the various units including radwaste and fuel storage facilities are maintained at optimum dependability, safety, and operating efficiency to comply with plant Technical Specifications, plant procedures, QA, Security, Radiation Control, and regulatory requirements. He is also responsible for the maintenance of equipment and electrical and mechanical systems of the individual Units whenever such maintenance requires an extended plant outage.

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necessary to maintain neat, properly insulated plant systems. He accomplishes this by planning, directing, and controlling a trained staff, inspecting maintenance work, providing effective maintenance procedures and standards, and developing improvements in the Preventive and Corrective Maintenance Programs. He is assisted by a staff of foremen, mechanics, engineers, technicians, and planner/analysts. The Support Facilities Maintenance Supervisor reports to the Manager Maintenance.

The Project Engineer -'lectrical is responsible for providing technical support to plant electrical maintenance and assisting the Manager Maintenance in assuring that plant instrumentation, control, and electrical systems are maintained at optimum dependability, safety, and operating efficiency, while remaining in compliance with all Technical Specifications and regulatory requirements.

The Project En ineer Mechanical is responsible for providing technical support to the plant mechanical maintenance organization and assisting the Manager Maintenance in assuring that plant equipment and mechanical systems are maintained at optimum dep'endability, safety, and operating efficiency, while remaining in compliance with all Technical Specifications and regulatory requirements.

The Project En ineer Computer is responsible for providing process computer system maintenance support and technical expertise to ensure that all plant process computer systems are fully operational for the safe, reliable, and efficient operation of the plant. The Project Engineer - Computer reports to the Manager Maintenance.

Environmental and Radiation Control The Manager Environmental & Radiation Control (E&RC) is responsible for conducting the plant radiation safety and control (health physics) program, chemical control of plant reactors and systems and the environmental programs to ensure that environmental and radiation control is maintained in a manner to protect the plant, employees, visitors, general public, and the surrounding 2-9

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community. His primary responsibility is organizing, planning, and controlling E&RC resources to provide the required support while ensuring compliance with plant Technical Specifications, ALARA, and all applicable State and Federal regulations and permit requirements.

Some of his major responsibilities include: (1) ensuring that programs and related procedures are developed and administered to meet plant needs and regulatory requirements; (2) maintaining an awareness of current and pending regulations in the areas of radiation control, chemistry, and environmental matters concerning plant operations; (3) providing adequate documentation pertaining to individual radiation exposures, account for radioactive effluents, chemical control of plant systems and environmental surveillance and ensuring that these records are maintained in an up-to-date, retrievable manner. He is assisted in these functions by an Environmental & Chemistry Supervisor, a Radiation Control Supervisor, and a staff of radiation control and chemistry specialists. The Manager Environmental & Radiation Control reports to the Manager - Plant Operations.

The Environmental & Chemistry Supervisor is responsible for planning, organizing, and directing chemistry control and environmental surveillance programs, for the laboratory procedures, test results and records, and for adherence to the requirements of the Operating License and Technical Specifications. He accomplishes these responsibilities through Foremen and Technicians. The Environmental and Chemistry Supervisor reports to the Manager Environmental & Radiation Control.

The Radiation Control Supervisor is responsible for the plant Radiation Control (Health Physics) Program and for ensuring that all plant activities are conducted in a manner to protect the plant, employees, visitors, general public, and the surrounding community. His primary responsibility is organizing, planning, and controlling Radiation Control Subunit resources to provide the required support while ensuring compliance with plant Technical Specifications and all applicable State and Federal regulations and permit requirements. He accomplishes this through Foremen and Radiation Control 2-10

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Technicians. The Radiation Control Supervisor reports to the Manager Environmental & Radiation Control.

Startup The Superintendent Startup is responsible for successfully implementing and accomplishing, on schedule, the Shearon Harris Nuclear Power Plant preoperational and startup test program in accordance with the Startup Manual. He is assisted by a staff of supervisors, engineers, and technicans.

The Superintendent Startup reports to the Manager Plant Operations.

The Startup Supervisors are responsible for checking out and starting up on schedule the systems assigned in their areas in accordance with the Startup Manual and regulatory requirements. Each supervisor is assigned engineers and technicians and reports to the Superintendent Startup.

2.1.1.2 Administration Unit The Administration Unit provides support functions such as cost control, security, office services, document control, emergency preparedness, and materials requisition, storage, and issue to ensure compliance with regulations and readily available service for the proper functioning of the entire plant staff.

The Assistant to the General Manager is responsible for providing administrative support to the General Manager; managing plant Administrative functions, including Budgeting and Cost Control, Document Control, Office Services, Stores, and Security; directing Emergency Preparedness planning and activities; handling additional administrative tasks in the absence of the plant manager; representing the plant manager in specified meetings; handling Public Relations for the plant, including communications with the media and the general public; and maintaining cognizance of and providing support in implementing regulations and requirements of the NRC and other Federal and State agencies. He is assisted in these duties by an Administrative 2-11

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The Administrative Supervisor is responsible for the plant cost control functions; coordination and follow-up of the budget; the office services functions; the document control functions of receipt, distribution, storage, and retrieval of plant records; the requisition, receiving, storage, and issue of spare parts, equipment, and material; and plant industrial security. He is supported in these responsibilites by a Specialist Cost Control, an Office Services Supervisor, a Senior Specialist Document Control, Stores Foremen, and a Senior Specialist Security. The Administrative Supervisor reports to the Assistant to the General Manager.

The Specialist Cost Control is responsible for administering a plant cost control program to assist plant management in budgeting and accounting; controlling plant operating and maintenance expenses in accordance with plant, company, and regulatory requirements; planning, directing, and coordinating the activities of a competent cost control staff in accurately recording costs and monitoring plant expenditures; assisting with the preparation of Plant Construction Budget Requests and the 06M Budget; providing budget information and costs reports; and processing of invoices, petty cash statements, and contractor time sheets. He is assisted by a staff of clerks and technical aides. The Specialist Cost Control reports to the Administrative Supervisor.

The Senior Specialist Document Control is responsible for establishing and maintaining a document control system which ensures that the plant QA records, procedures, drawings, technical manuals, and other documents are maintained in accordance with plant, company, and regulatory requirements. He ensures that documents can be promptly retrieved and that current documents are provided to appropriate personnel by planning and directing a competent document control staff. The staff is responsible for receiving, microfilming, reproducing, retrieving, distributing, storing, and maintaining accountability of Plant QA records in the Storage Vault; plant drawings, technical manuals, instructions, etc., in the Plant Library; and master drawings in the Storage Vault. He 2-12

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He is assisted by a staff of a Specialist, Technical Aides, Clerks, and Draftsmen. The Senior Specialist - Document Control reports to the Administrative Supervisor.

The Stores Foremen are responsible for ensuring that spare parts, equipment, materials, and expendable supplies are available to support the operation and maintenance of the plant by maintaining the required levels of inventory; warehouse and storeroom procedures and good housekeeping; ensuring proper tools are available for all required tasks; and ensuring that tools are properly secured. They are assisted by a staff of Storekeepers. The Stores Foremen report to the Administrative Supervisor.

The Office Services Supervisor is responsible for providing the secretarial/

stenographic support for the entire plant staff, including clerical assistance to all plant management for filing, mail distribution, reproducing paperwork, stocking of office supplies for the plant staff, and maintaining the personnel folders for the plant staff. The Supervisor is assisted by the Plant Office Services Coordinator, Stenographers, and Clerks. The Office Services Supervisor reports to the Administrative Supervisor.

N The Senior Specialist - Security is responsible for developing, implementing, and maintaining a security program which ensures that the security of the plant is maintained in accordance with regulatory requirements. He develops and maintains a close working relationship with local Law Enforcement Agencies to insure compliance with existing regulations. He provides input to the Training Unit so that employees requiring access to the plant are properly trained and badged. He ensures that equipment and guards are available and in a state of readiness. The Senior Specialist Security is assisted by a Technical Aide and a contract security guard force. The Senior Specialist Security reports/ to the Administrative Supervisor.

The Senior Specialist Emer ency Preparedness is responsible for the development, implementation, and continuing refinement of the plant Emergency 2-13

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Preparedness Program which ensures that a "state of readiness" is maintained at the plant to cope with any classification of emergency. He incorporates the provisions of the plant Emergency Plan in the program and revises the program and related procedures as changes are made in the plant Emergency Plan. The Senior Specialist Emergency Preparedness reports to the Assistant to the General Manager.

2.1.1.3 Technical Support Unit The Technical Support Unit provides engineering and regulatory compliance support for the entire plant staff both in terms of investigations of day-to-day equipment and system operation, including routine reportabilities, and modification tasks to keep the plant in compliance with new regulations or to improve efficiency of operation.

The Manager Technical Support is responsible for development and testing of plant modifications and providing technical support for plant outages, plant operation and maintenance as well as managing the plant inservice inspection (ISI) and performance programs. He also ensures that all plant operations conform to regulatory requirements and that all reporting requirements are met. He is supported by the Engineering Supervisor and the Project Specialist Regulatory Compliance. The Manager Technical Support reports to the General Manager.

The En ineerin Supervisor is responsible for all plant modifications and for providing technical direction and coordination for plant engineering studies.

He develops and implements the in-service inspection program and plant performance program as well as procedures, instructions, and guidelines for plant engineering functions. He is supported in these tasks by a staff of Engineers, Specialists, Engineering Technicians, and draftsmen. The Engineering Supervisor reports to the Manager Technical Support.

The Project Specialist Regulatory Compliance is responsible for coordinating regulatory activities at the plant to ensure that commitments, responses, records, and reports are prepared, submitted, and maintained in accordance

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with regulatory requirements. He maintains a tracking system for the resolution of all plant safety and environmental concerns. He serves as the NRC contact on site and provides the License and Technical Specification expertise necessary to support plant activities. He is assisted by a staff of Technicians and Specialists. The Project Specialist Regulatory Compliance reports to the Manager Technical Support.

2. 1.1.4 Plannin & Schedulin Unit The Planning & Scheduling Unit is responsible for providing planning, scheduling, and coordination for long-term and short-term outages and backfit and modification work for the entire plant. The unit plans the annual refueling outages, maintenance outages and on a year-round basis plans backfit and modification work to provide the shortest downtime and/or the least interference with plant operations.

The Director Plannin & Scheduling is responsible for the comprehensive and detailed planning, scheduling, and coordination of both long-term and short-term maintenance and refueling outages and backfit and. modification work performed at the plant. He coordinates the plant activities with Nuclear Plant Engineering and Nuclear Plant Construction department personnel to ensure that work is sequenced into the plant operations and/or the "outage windows." He is assisted in these activities by a staff of engineers and engineering technicians. The Director Planning & Scheduling reports to the General Manager.

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4RI 2. l. 2 Plant Staff Personnel Resources The organization shown on Figure 2 for the SHNPP is designed to provide adequate numbers of personnel with the requisite qualifications and experience levels to ensure safe and proper operation and maintenance of the facility at all times, provide opportunity for development of personnel so as to ensure that adequate resources are available to cover future needs, and ensure that major functional areas are organized and staffed in a manner that will provide for a high level of management and supervisory 'attention.

The following Table 2.1 provides a cross-reference of the minimum training and experience qualifications for the various plant positions:

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oo ~N Q 4g e/ ee Ooe Q > ee 4'0 e~ e~e egg @+ QQ e v (P e~ Qe eQ Y 4~y N/4 0 Qy REMARKS General Manager X X 3 4 X~ *Must,have experience and training required for SRO license.

Manager Plant Ops. 3 3 4 X~ *Must have experience and training required for SRO license.

Manager - Ops. X X 3 3 X Oper. Supv. X X 2 2 X Shift Foreman 2 2 X *May be filled by academic or technical training.

Radwaste Supv. X X *May be filled by chemical processing plant experience.

Shift Foreman- X *May be filled by, Radwaste chemical processing plant experience.

Prin. Eng. Ops. X X 2 2 *Must have experience and training required for SRO license.

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Assist. To General X X Manager Admin. Supv. X X~ *A Business Degree is an acceptable alternate.

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Eng. & Specialists X X Foremen STA' X X Technicians *Must include 1 year of related technical training.

Mechanics/ X Electricians Operators Minimum education and experience requirements are the cumulative total of columns 3, 4, and 5. The years of supervisory experience listed in column 6 are included in columns 4 and 5.

Individuals who do not possess the formal educational requirements specified in Table 2.1 shall not be automatically eliminated where other factors provide sufficent demonstration of their abilities. These other factors will be evaluated on a case-by-case basis. Positive factors which may be considered in making this determination are as follows:

a) High shool diploma or GED b) Sixty (60) semester hours of related technical education taught at the college level (900 classroom or instructor-conducted hours) c) Qualified as an NRC senior operator at the assigned plant d) Four (4) years of additional experience in the area of responsibility e) Four (4) years of supervisory or management experience f) Demonstrated ability to communicate clearly (verbally and in writing) g) Successful completion of the Engineer-In-Training examination h) Professional Engineer License i) Associated degree in engineering or related science g) Four year degree in a related field or other formal studies completed.

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The following definitions shall also apply for Table 2.1:

Nuclear Power Plant Experience Experience acquired in the preoperational and startup testing activities, or operation of nuclear power plants.

1) Experience in design and construction may be considered applicable nuclear power plant experience and will be evaluated on a case-by-case basis.

2) Experience acquired at military, non-stationary or propulsion nuclear plants may qualify as equivalent on a one-for-one time basis up to a maximum of three years.

3) Experience acquired in non-power plants such as test, training,=

research, or production reactors may qualify as nuclear plant experience on a one-for-one time basis, up to a maximum of one year's credit.

4) Training may qualify as nuclear power plant experience if acquired, in appropriate reactor simulator training programs, on the basis of one month's training being equivalent to three month's experience, to a maximum of one year's credit.

5) Training programs, associated with operating nuclear power plants, the culmination of which involves actual reactor operation, may qualify as equivalent to nuclear power plant experience on a one-for-one time basis for up to a maximum of two years'redit.

6) On-the-job training may qualify as equivalent to nuclear power plant experience on a one-for-one time basis for up to two years'redit.

7) A Master's Degree may be considered equivalent to one year of professional experience, and a Doctor's Degree may be considered equivalent to two years of experience where course work related to the particular specialty is involved.

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2.1.3 Training Plant Staff Training Program The objective of the SHNPP training program is to develop and maintain an operating organization capable of and responsible for the safe and efficient operation and maintenance of the plant. This training program is designed to comply with the intent of the requirements of Regulatory Guide 1.8, Revision 1, "Personnel Selection and Training." The program provides training based on individual employee experience and intended position in order to fulfillNRC licensing and personnel qualification requirements for the initial plant staff, replacement personnel, and maintenance and upgrading of plant personnel. All personnel attend certain orientation programs and specialized courses; e.g., security, health physics, and safety, in addition to receiving specialized training as required in their job skills.

2.1.3.1 Plant Management and Supervisory Personnel Trainin The formal training program for the plant management and supervisory personnel provides these personnel with the qualifications necessary to assure that the plant will be operated in a safe and efficient manner. Qualifications required by ANSI/ANS 3.1, September 1979 draft, are met at the time of initial core loading or appointment to the position, whichever is later. Managers required to have acquired the equivalent training normally required for a Senior Reactor Operator's license shall participate in training programs described in ANSI/ANS 3.1, September 1979 draft, as necessary to fulfill this requirement. The following positions are included in this category: General Manager, Manager Plant Operations, Manager Operations.

Specialized training courses such as those described below are available to plant supervisory personnel.

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Chemistry A 12-week training course taught by the Nuclear Services Division of Westinghouse Nuclear Energy Service (WNES). This pressurized water reactor (PWR) chemistry course provides PWR systems training and details of routine chemistry surveillance, and updates and extends knowledge in specific areas of chemistry. Topics covered in the program include the PWR, mathematics review, reactor chemistry, radiochemistry (theory), radiochemistry (laboratory procedures), and operating plant training laboratory procedures.

Instrumentation and Control A 12-week training course taught by the Nuclear Services Division of WNES. This instrumentation and control engineering course provides an in-depth understanding of the instrumentation and control systems used in the Westinghouse PWR. Topics covered in the program include introduction to nuclear power plants, flux mapping system, nuclear instrumentation system, rod control system, solid state protection system, radiation monitoring system, rod position indication system, process instrumentation, and system interface.

Nuclear Engineering A 12-week training course taught by the Nuclear Services Division of WNES. This nuclear engineers'ourse provides detailed information in those areas for which the Senior Engineer (Operations) is normally responsible, as well as less detailed discussions of those areas in which he interacts with the remainder of the plant staff. Topics covered in the program include review of reactor physics and reactor systems, fuel consideration, core design, initial reactor start-up program, physics testing, measurement techniques and data reduction, power distribution analysis, plant computer, and load flow.

Mechanical Maintenance An 8-week training course taught by the Nuclear Services Division of WNES. This maintenance management program provides familiarization with those aspects of maintenance which are significantly different from that of a fossil-fired plant. Topics covered in the program include introduction to nuclear power plants, radiation protection, nuclear power plant equipment maintenance, and maintenance management.

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~ ~ ~ Shift Technical Advisor Training The Shift Technical Advisors will be provided with training in the following areas, as a minimum: duties and responsibilities of the Shift Engineer, plant design and layout, accident analysis, thermohydraulics and fluid flow, integrated plant responses, and capabilities and limitation of plant instruments and control.

Additionally, Shift Technical Advisors will receive a minimum of two weeks of training on the SHNPP simulator.

2.1.3.3 On-Shift Technical Requirements Each Shift Operating Crew will have appropriate technical training and qualifications in the areas of reactor physics and control, nuclear fuel, thermal hydraulics, transient analysis, instrument and control, mechanical and structural engineering, radiation control and health physics, electric power, chemistry, and plant operation and maintenance. These qualifications will be ensured by virtue of formal Shift Operating Crew training programs, as follows:

The formal training program to license the Shift Operating Crews will be conducted by CP&L personnel with assistance which may be contracted from qualified training organizations. The program is made up of a series of segments which train personnel with various backgrounds.

Initial Nuclear Trainin Plant operations and supervisory personnel who must qualify for license examinations are categorized by experience into the following groups:

a) Individuals with no previous nuclear experience; b) Individuals with nuclear experiences at facilities not subject to licensing; 2-24

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c) Individuals holding or who have held licenses for comparable facilities.

Persons in (a) above will participate in all portions of the Licensed Operator Training Program.

Persons in (b) above will receive training as required based upon their experience on a case-by-case basis.

Persons in (c) above will receive on-site training to prepare them for the NRC license examination.

The training program for the Harris operating crews consists of:

a) Basic Auxiliary Operator (AO) Program b) Nuclear Auxiliary Operator (AO) Program c) SHNPP Cold License Lecture Series d) Plant System On-the-Job Training e) Cold License Simulator Training f) Pre-License Review Series and Audit The Basic AO and Nuclear AO programs a) and b) above are presently being taught, supporting the Company's Brunswick, Harris, and Robinson plants.

Items c) through f) above are specifically tailored to the Harris Plant. The Shift Operating Crews complete this program prior to initial fuel loading of Unit No. l.

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Each section of the training program and its duration is detailed below:

a) Basic Auxiliary Operator Training Program This course consists of twelve weeks of classroom training interspersed with nine weeks of structured on-the-gob training. The course is designed to provide theoretical training and in-plant training to provide reinforcement of the basic science and technology of power plant operations. This course is presently available and constitutes a major portion of the training program for Operators at all of CP6L's plants, both nuclear and fossil. The topics covered in the course are listed below:

1) Purpose of power plants

2) Mathematics I (review through algebra)

3) Mathematics II (problem solving)

4) Plant science

5) Plant cycle

6) Plant auxiliaries

7) Plant systems

8) Basic electricity

9) Instrumentation and control

10) Water chemistry ll) Combustion

12) Boilers

13) Water treatment

14) Turbines

15) Environmental protection

16) Power generation

17) Electrical systems

18) Protection

19) Diesel Generators Examinations are given regularly throughout this phase of training to monitor the trainees'rogress. Each trainee must achieve no less than a 70 percent average grade in this course prior to entering the next phase of the training program.

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b) Nuclear Auxiliary Operator Training Program This program is designed to provide those persons with little or no nuclear background with the necessary theoretical knowledge to become licensed reactor operators. The program consists of approximately.

twenty weeks of formal classroom training presented by CP&L instructors interspersed with at least sixteen weeks of on-the-gob training at operating nuclear power plants. This course is presently available and is being used in the training of Operators for CP&L's two operating nuclear plants. Employees are now enrolled in this course, assigned to the Harris organization, but temporarily assigned for training purposes to an operating plant with the understanding that they will transfer to Harris.

The on-the-gob training is structured through the plant's existing auxiliary operator qualification programs. The topics covered in the classroom portion of this program are listed below:

1) Mathematics

2) Nuclear theory

3) Heat transfer

4) Radiation protection

5) Chemistry

6) Reactor theory

7) Instrumentation and control

8) Reactor protection Also included in the classroom portion of this course is one week of applied nuclear theory, radiation protection, and reactor operations at the North Carolina State University PULSTAR reactor, and one week of introduction to power plant control board operation on the SHNPP simulator.

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Examinations are given regularly throughout this course to monitor the trainees'rogress. In order to successfully complete this course, a trainee must achieve a minimum grade of 70 percent on Topics 1-8, and achieve a minimum course average grade of 70 percent including comprehensive examinations.

c) SHNPP Cold License Lecture Series This formal 15-week training program will be conducted by CP6L. Approximately half of each day will be spent in the classroom with the remaining half day spent in the plant identifying the equipment associated with the topic covered in the classroom session. The plant systems and procedures to be covered are listed below:

1) Nuclear steam supply systems and procedures

2) Engineered safety systems and procedures

3) Turbine-Generator systems and procedures

4) Electrical systems and procedures

5) Auxiliary systems and procedures

6) General and abnormal operating procedures

7) Emergency procedures

8) Radiation protection procedures

9) Chemistry procedures

10) Plant computer

11) Technical specifications Review and examinations are given regularly throughout the program to evaluate the effectiveness of this phase of training.

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d) Plant System On-The-Job Training During this 9-week portion of the Cold License Training Program, the students will gain additional knowledge of actual plant systems configuration and operation through in-plant hands-on training. This training will be structured, controlled, and monitored by the plant training staff through the use of a qualification card system. Knowledge of plant systems will also be augmented by participation in procedures development, system acceptance testing, and later, in hot functional testing.

e) Cold License Simulator Training This 9-week portion of the Cold License Training Program will be subdivided into three segments.

All segments will be conducted by CP&L personnel at the SHNPP simulator. The first segment will consist of approximately 3 weeks devoted to control board familiarization and review, analysis and practice in the areas of normal, abnormal, and emergency operations.

The second segment will consist of approximately two weeks of classroom instruction in the areas of integrated plant response under normal, abnormal, and emergency conditions with emphasis on control room instruments response and the operator's monitoring, diagnosis, and control functions. The third segment will consist of approximately four weeks of simulated plant operation on a continuing shift rotation schedule. This segment will provide experience and further training in the areas of total plant operation and control under normal, abnormal, and emergency conditions in a realistic control room environment including shift relief and rotation. The training staff will monitor progress and performance in this segment and instruct as required through periodic off-shift critiques.

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f) Pre-License Review Series and Audit This portion of the Cold License Training Program will be conducted by Westinghouse or CP&L personnel at the SHNPP site during the period between the completion of hot functional testing and the administering of NRC licensing examinations. The pre-license review series consists of approximately 3 weeks of instruction including 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per day of classroom work with the remainder of the day being used for special instruction, plant tours, and individual study. The topics covered in this lecture series include:

1) Reactor physics and kinetics

2) Reactor control and protection systems

3) Health physics and plant chemistry

4) Technical specifications

5) Transient, instrument failure, and accident analysis

6) Normal, abnormal, and emergency operating procedures

7) Heat transfer, fluid flow, and thermodynamics.

The audit phase of this portion of the Cold License Training Program will consist of written and oral examinations administered and graded by Westinghouse personnel. The purpose of this audit will be to identify any areas requiring additional training effort.

Individuals or group work areas identified by this audit will be corrected by intensive training efforts for those involved and training program modifications to minimize recurrence in future classes.

Auxiliary Operators will participate in the Basic Auxiliary Operator Training Program and the Nuclear Auxiliary Operator Training Program as described above. This training, along with a qualification card system, will provide sufficient training and evaluation for these individuals to become qualified Auxiliary Operators.

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Replacement and Retraining Following initial licensing of operating personnel for the Harris Plant, an on-going training program will be utilized to maintain the proficiency of the plant operating organization after the initial plant start up. This training program will include, as described below, requalification training for licensed personnel, and training for replacement personnel. This program will be based in concept on similar programs already in effect at the Brunswick and Robinson plants.

a) Licensed Operator Requalification Training Following the initial licensing of cold license candidates, a requalification training program will be initiated to maintain and demonstrate the continued competence of all licensed personnel.

This requalification training program will be conducted on an as-required basis to permit each licensed operator to attend retraining annually, and will include preplanned lectures, on-the-job training, and regular and continuing operator evaluation.

The SHNPP simulator will be used to fulfillappropriate portions of this retraining program.

b) Lectures A,minimum of six pre-planned lectures will be presented during each requalification cycle. These lectures will be scheduled throughout the year, taking into account heavy vacation periods and infrequent operations such as refueling periods and forced outages. Content of the lectures shall take into consideration the categories as listed in 10CFR Part 55, Appendix A, heat transfer, thermodynamics, operating experiences from similar plants, and the results of the annual examination. Training aids such as films, video tapes, and slides may be used and some selfstudy may be required in con)unction with the lectures.

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All licensed individuals will be required to attend every preplanned lecture except those specifically exempted. Exemptions will be allowed only for individuals scoring greater than 80 percent in the corresponding areas on the previous examination.

c) On-the-Job Training The on-the-gob training portion of the requalification program will consist of the following:

Control Manipulation Licensed Operators shall manipulate and Senior Licensed Operators shall manipulate, direct, or evaluate the activities of those manipulating the station controls through a minimum of ten reactivity changes during each annual cycle. These manipulations are divided into two categories: (1) those which must be performed annually, and (2) those which must be performed on a two-year cycle. The following manipulations are listed for these two categories:

1) Performed Annually (at operating plant or on a simulator) a~ Startup to the point of adding heat

b. Manual steam generator control during startup and shutdown

c. Any significant (10 percent) power changes in manual rod control

d. Loss of coolant

1) Including significant steam generator leaks

2) Large and small including leak rate determination

3) Resulting in saturated RCS

e. Loss of forced coolant flow/natural circulation

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b. Boration and/or dilution during power operation C~ Turbine startup and shutdown

d. Loss of instrument air

e. Loss of electrical power and/or degraded power sources Loss of service water and/or component cooling water ge Loss of circulating water/condenser vacuum

h. Loss of shutdown cooling

i. Loss of component cooling system or loss of CCW to individual components Loss of normal feedwater or normal feedwater system failure

k. Loss of protective system channel Control rod misalignment or drop Inability to drive control rods

n. Conditions requiring emergency boration 0~ High activity in reactor coolant pe Turbine or generator trip

q. Malfunction of automatic control system(s) which affect reactivity Malfunction of CVCS system S ~ Reactor trip Main steam line break (inside or outside containment) uo Nuclear instrumentation failure(s)

Knowled e of Plant Systems Individuals licensed as Reactor Operators and Senior Reactor Operators shall demonstrate an understanding of the operation of controls and equipment and shall be familiar with the operating proceduxes in each area for which they axe licensed.

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Demonstration methods will include at least one of the following:

1) Manipulation of the systems and their associated equipment.

2) A walk-through of the procedural steps required to start, stop, or change conditions of the system.

3) Use of the SHNPP simulator.

Knowledge of Facility Desi n, Procedure, and Facility License

~Chan es: Licensed Reactor Operators and Senior Reactor Operators shall be made aware of safety-related facility design changes that affect station operating, operating procedure changes and facility license changes.

Demonstration methods include any of the following:

1) Lectures conducted by the Operating Supervisor or other appropriate personnel.

2) Staff meetings.

3) Written communications to each licensed individual from facility management.

4) Explanation of major changes as part of the preplanned lecture series.

Knowled e of Abnormal and Emergency Operatin Procedures: Licensed Reactor Operators and Senior Operators shall review the contents of abnormal and emergency operating procedures periodically such that knowledge of these procedures is maintained.

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Demonstration methods may include any of the following:

1) Actual performance under abnormal and emergency conditions.

2) Drills using the SHNPP simulator.

3) A walk-through of the procedural steps necessary to cope with the situation.

4) Brief lectures conducted by the shift supervisor or other appropriate personnel.

5) Self-study combined with items 1) through 4) above.

d) Evaluation.

The evaluation program for licensed personnel will include the following:

Annual Written Examination: Annual examinations comparable in scope and degree of difficulty to an NRC examination shall be given to each licensed reactor operator and senior reactor operator. The examination will contain categories of examination questions as follows:

1) Theory and principles of operation

2) General and specific "operating characteristics

3) Plant instrumentation. and control systems

4) Plant protection systems

5) Engineered safety systems

6) Normal, abnormal, and emergency operating procedures

7) Radiation control and safety

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9) Applicable portions of Title 10, Chapter 1, Code of Federal Regulations

10) Operating experience from similar plants

11) Heat transfer, fluid flow, thermodynamics, and mitigation of accidents involving a degraded core.

A grade of less than 70 percent in any category shall require accelerated requalification in that category. A grade of less than 80 percent overall shall require accelerated requalification in all categories grades less than 80 percent.

Annual Observation and Written Evaluation: Observation and evaluation of the performance of Licensed Reactor Operators and Senior Reactor Operators by supervisors or training staff members P

will include evaluation of performance during actual or simulated abnormal and emergency conditions. Observation and evaluation of the performance of licensed personnel during simulated abnormal and emergency conditions may be conducted by simulator training staff personnel. Discussions of actions taken or to be taken during abnormal or emergency situations may be used as evaluation tools in lieu of, or in addition to, the above methods. Any licensed reactor operator or senior reactor operator given an unsatisfactory overall evaluation shall require accelerated requalification.

e) Accelerated Requalification Persons requiring accelerated requalification as a result of annual evaluation shall not perform licensed duties until successfully completing the program. Accelerated requalification shall be given in the categories required or areas identified in the annual observation and written evaluation. The Training Supervisor will tailor the scope and duration of the accelerated program to the individuals'emonstrated deficiencies. Successful completion of the program shall be measured by a reexamination of individual 2-36

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categories repeating an entire written annual examination or reevaluation by observation or oral examination. Successful completion of an accelerated requalification program shall be determined by the grade criteria outlined above.

2.1.3e4 Technical Personnel Training Technical personnel who require specialized training to properly perform in their areas of responsibility will attend formal training courses in their particular specialities as well as receive on-the-job training at the plant site prior to startup. This training is described below:

Radiation Control and Test (RC) and Environmental & Chemistry (E&C) Technician

~Tralnin RC and ERC Techniciana will be required to complete the applicable training programs des'cribed below.

1) Basic Course Series RC and E&C Technician III Basic Chemistry 2 weeks Basic Health Physics 2 weeks Basic Counting Room 1 week Basic Environmental 1 week

2) Intermediate Course Series RC and E&C Technician II Intermediate Chemistry 1 week Intermediate Health Physics 1 week Intermediate Counting Room 1 week Intermediate Environmental 1 week These courses are presented by Carolina Power & Light Company's personnel. At and above the RC and E&C Technician I level, specialized training will be provided as necessary by Carolina Power & Light Company or by vendors.

Radiation Control and Environmental & Chemistry personnel will also receive 2-37

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on-the-gob training by participating in systems checkout and start-up, preparing the laboratories for service, participating in initial radiation surveys, and participating in the writing, review, and study of radiological and chemical procedure manuals.

Instrumentation and Control (I&C) Technician Training I&C Technicians not having the appropriate qualifications will be required to complete the applicable training programs described below prior to appointment to their respective positions.

1) Basic I&C Course Series I&C Technician III Basic Electronic Instrumentation 1 week Basic Pneumatic Instrumentation 2 weeks Basic Electromechanical Devices 1 week

2) Intermediate I&C Course Series IIC Technician II Intermediate Electronic Instrumentation 1 week Intermediate Pneumatic Instrumentation 2 weeks Intermediate Electromechanical Devices 1 week All of these courses are presented by CP&L personnel. At and above the I&C Technician I level, specialized training will be provided as necessary by Carolina Power & Light Company or by vendors. Additionally, Instrumentation and Control Technicians will receive on-the-)ob training prior to startup by participating in checkout and testing of control circuits, annunciator responses, computer inputs, calibration of controls and instruments, and troubleshooting various equipment problems.

Mechanic and Electrician Trainin Mechanics and Electricians will be required to complete 4-week basic and/or 4-week intermediate courses in their respective crafts. These courses will be presented by Carolina Power & Light Company's personnel. Additionally, Mechanics and Electricians will receive 2-38

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on-the-)ob training with the equipment on the plant site. Mechanics and Electricians may receive advanced or specialized training for their individual functions as necessary through attendance at Carolina Power & Light Company or I

vendor courses.

Radwaste Operator Training Radwaste Operations personnel will be required to complete a training program in radwaste operations. This program will be conducted by Carolina Power 6 Light Company's personnel with assistance from vendors as necessary. The program will consist of Radiation Control 6 Chemistry courses augmented by classroom and structured on-the-job training in the areas of radwaste systems and procedures and related technical specifications. Initially, the Radwaste Operators will participate in the I

Basic Auxiliary Operators course. Additionally, radwaste operations personnel will receive on-the-gob training in their area of responsibility thro'ugh participating in system checkout and startup. A qualification card system has been developed and will be utilized by all Radwaste Operators.

2. l. 3. 5 Auxiliary (Non-Licensed) Operator Training Auxiliary Operators will participate in the Basic Auxiliary Operator Training Program and the Nuclear Auxiliary Operator Training Program. This training, along with a qualification card system, will provide sufficient training and evaluation for these individuals to become qualified Auxiliary Operators.

2.1.3a6 General Employee Training All permanently employed plant personnel (those assigned on a day-to-day basis) will participate in a General Employee Training Program consisting of, but not limited to Radiological Health and Safety, Quality Assurance, Industrial Safety, Plant Security, Emergency Plan, and other appropriate plant plans and procedures. General employee training will be provided by Carolina Power 6 Light Company's personnel at the time of employment at the plant or as soon thereafter as practicable. This training is designed to qualify personnel to be badged for unescorted entry into various parts of the 2-39

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operating plant and to be able to function safely and recognize problems that need to be reported within these areas. There will be annual requalification training and testing to ensure that all plant personnel remain current in the areas of plant plans and procedures.

The Nuclear Operations Department has an orientation program for all new employees that is designed to acquaint the new employee with the policies, procedures, and practices of the Company and the Department. Included in this orientation are reviews of the "Corporate Quality Assurance Program Policy Statement," "Corporate Nuclear Safety Policy," and "Corporate Health Physics Policy." These policy statements are contained in an orientation program manual that is provided to each new employee.

2.1.3.7 Fire Protection Training The plant fire protection staff, fire brigade members, other plant employees, and construction personnel, as appropriate, will receive training to ensure an adequate and effective response to a fire at the plant. This training will combine classroom instruction with practical drills and will include instruction in fire hazards identification, location and use of fire fighting equipment, and fire protection procedures and practices.

The initial fire protection training program will be completed prior to receipt of fuel at the site. The Emergency Plan implementing procedures for fire protection will be completed at least three months prior to receipt of fuel. Sufficient fire protection drills will be performed immediately prior to fuel receipt to provide assurance that the plant staff is adequately trained to cope with fire-related emergencies.

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OFFSXTE NUCLEAR OPERATIONS SUPPORT 2.2.1 Offsite,Organization Based in part on lessons learned from the Three Mile Island accident, the offsite Corporate support organizations have been modified to more sharply focus nuclear activities within separate departmental and organizational structures. This philosophy further ensures that the Company's other nonnuclear activities will not detract appropriate management attention from safe nuclear operation. As shown on Figure 4, the offsite Corporate support for nuclear operations is managed by the Vice Chairman, Mr. J. A. Jones, who reports to the President/Chairman, Mr. Sherwood H. Smith, Jr. Reporting to Mr. Jones is one officer whose organization provides offsite technical and managerial support of nuclear operations: Executive Vice President Power Supply and Engineering & Construction Groups, Mr. E. E. Utley. Reporting to Mr. Utley are four officers and a department manager whose organizations further subdivide offsite technical and managerial support into five areas:

Senior Vice President -Power Supply Group, Mr. L. W. Eury; Senior Vice President Engineering & Construction Group, Mr. M. A. McDuffie; Senior Vice President Fuel & Materials Management Group, Mr. J. M. Davis, Jr., Vice President Corporate Nuclear Safety and Research Department, Dr. T. S.

Elleman; and Manager Corporate Quality Assurance, Mr. H. R. Banks.

The Corporate Nuclear Safety and Research Department conducts the independent safety review of nuclear operations, and the corporate health physics program and assessment. The Vice President Corporate Nuclear Safety & Research also provides the Senior Management oversight function by formal feedback mechanisms with Senior Management up to and including the President/Chairman.

The Corporate Quality Assurance (CQA) Department is responsible for quality assurance (QA) and quality control (QC) within the Company, including engineering, construction, and operations. In addition, the CQA Department is responsible for QA audit functions. This department was formed in early 1981 to provide more efficient.and effective QA/QC within the Company, by 2-41

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consolidating the QA/QC functions that had been under the Technical Services, Nuclear Safety and Research, and the Nuclear Operations Departments.

Conducting independent nuclear safety, health physics assessment, and quality assurance oversight functions in organizations separate from the Power Supply Group and Engineering 6 Construction Group provides effective mechanisms for strong independent assessments at the Senior Management level of how well these programs are working. These offsite technical resources and Senior Management oversight mechanisms are described in detail in Sections 2.2.2.1 through 2.2.2.4.

The Power Supply Group provides offsite technical and managerial support of nuclear operations in the areas of environmental and radiation control, emergency planning, training and retraining, industrial security, maintenance support and planning, operating experience review, plant chemistry and radiochemistry, regulatory compliance, fire protection, outside contractural supervision, operational management, environmental monitoring, meteorological and seismic monitoring, and nuclear licensing activities.

The concentration of the above listed offsite power supply activities in organizational groups separate from the nuclear safety, quality assurance, and engineering and construction support activities, provides a strong, independent management focus on safe and reliable nuclear operations support.

Offsite management in the Power Supply Group is organized to minimize conflict with the application of other resources applied to other nuclear and non-nuclear activities within the Company. It includes a manageable scope of support activities which is not diluted by the need for management attention to engineering and construction activities and Corporate nuclear safety and quality assurance assessment, which is managed by others who report to an equal senior management level.

The Engineering 6 Construction Group provides a source of offsite technical resources to assist and support the operating plants in areas of civil design, 2-42

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instrumentation and controls, computers, mechanical, electr'ical, nuclear engineering, metallurgical analysis, and construction.

The Fuel and Materials Management Group provides offsite technical and managerial support in the areas of nuclear fuel procurement, refueling operations support, and plant procurement support.

The Company has established clear lines of responsibility and effective interface mechanisms between the Engineering & Construction Group, the Power Supply Group, and the Fuel and Materials Management Group which ensures that independent management attention to each of these support activities complements and strengthens the total attention to offsite support of nuclear operations.

The major offsite support organization for nuclear operations is the Power Supply Group, which includes the Nuclear Operations Department support staff, the operating and maintenance support st'aff of the Fossil Operations Department, and the Technical Services Department.

This Power Supply and Fuel & Materials Management Groups'ff-site support organization is shown on Figure 5.

Resources of each of the units or sections shown are available to the plants or other units as needed. Routine lines of communication exist between the personnel of each off-site unit and their appropriate counterparts at each nuclear plant. Support of each nuclear plant is the function of the off-site organization, and assistance requested by the plants is routinely provided without a requirement for formal management action. In the event that higher level coordination is required for some projects, the Section Managers maintain frequent communication, and the Vice President Nuclear 'Operations is fully informed. In order to stay in touch with plant performance and personnel, the Vice President Nuclear Operations communicates with the Plant General Manager on a daily basis and visits each plant on a frequent basis, 2-43

normally at least once a month. In addition, members of Senior Management visit each plant periodically.'.2.1.1 Nuclear Operations Department The Nuclear Operations Department operates within the guidelines of the Corporate Policy Statements on Radiation Protection and Nuclear Safety, and the Corporate Quality Assurance Manual. The Vice President Nuclear Operations is responsible for all aspects of operation and maintenance of the Company's nuclear plants.

Some of the Vice President's functional responsibilities include:

1) The establishment and approval of the qualification requirements for all plant staff positions and the personal review of the qualification of specific personnel for managerial and supervisory positions.

2) Review and concurrence of plant programs established to implement requirements in radiation protection, industrial security, quality assurance, fire protection, training, operations, and maintenance.

3) Review of the regulatory compliance record of the nuclear power plant including NRC IE inspection reports, LER performance history, and review of correspondence with the NRC Office of Nuclear Reactor Regulation and the Office of Inspection and Enforcement concerning operating nuclear power plants.

4) Review of reports from the various independent company audit and review groups, such as Corporate Nuclear Safety or Corporate Quality Assurance.

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2.2.1.2 Operation and Maintenance Section Generation Operation and Maintenance Section, Fossil Operations Department provides staff support to all plants in the areas of operations and maintenance and aids in the planning and scheduling of maintenance or overhaul of plant equipment by coordinating with the System Operations Department to permit the optimization of the maintenance outage schedule. This support also takes the form of assisting the plants in the development of. CPM charts or other scheduling methods to ensure a coordinated outage program. By providing available statistics of manpower and time utilization from previous maintenance operations, the section assists in the proper scheduling of maintenance.

The continuing analysis of current maintenance problems permits the improvement of maintenance methods and cost reductions. Current methods are compared with methods used by other utilities or with manufacturers recommendations, and suggestions for improvement of maintenance methods are recommended to the plant. The accumulation and analysis of data on plant availability and equipment reliability is used to assist plant operating staffs in developing and implementing programs to improve plant reliability.

2.2.1.3 Technical Services Department The Technical Services Department provides Operations support in the areas of environmental and radiation control, regulatory compliance, licensing, health physics, administration (contracts, security, special prospects), environmental technology, emergency preparedness, and training.

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The Department was moved from the Engineering 6 Construction Group to the Power Supply Group in early 1981. In order to enable the Vice President Nuclear Operations to devote more time to plant operations, many of the operating support staff functions were transferred from the Nuclear Operations Department to the Technical Services Department. These included the Administration, Nuclear Training, and Environmental and Radiation Control Sections. In addition to these three sections, the Technical Services Department contains two other sections and one unit that provide operating plant support: the Licensing & Permits Section, the Environmental Technology Section and the Emergency Preparedness Unit. The responsibilities of each of these groups are discussed below, and the department is structured as shown on Figure 5.

Nuclear Operations Administration Section The Nuclear Operations Administration Section provides staff support to the generating plants in the areas of plant security, contract administration, control board human factors review, and general administrative functions. The section is organized into units having functional responsiblity in the areas specified below.

Security Unit The Security Unit is responsible for development of the security program and for monitoring its implementation at the operating nuclear plants to ensure compliance with all pertinent regulatory requirements. The unit maintains an industry-wide knowledge of developments in the field of nuclear security, and keeps the Department Manager and Plant General Managers, through their Security Specialists, informed of current or anticipated actions which do, or may, impinge on plant operations. The head of the Security Unit has directly supervised the efforts of the SHNPP Security Specialist to develop a security program at SHNPP to include drafting the Security Plan, the Safeguards 2-46

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e contact with local and state authorities; providing timely, expert advice on contract or purchase of various elements of the computer-based, integrated security system; and assisting in clarifying regulatory directives and guidelines by seeking and obtaining information from contacts developed in government and the electric utility industry. By virtue of its organizational position, the Security Unit provides direct, independent channels of communication among management personnel who are resposible for operational nuclear security.

Administration Unit The Administration Unit is responsible for providing coordination of the Nuclear Operations Department's administrative functions such as: development and implementation of Departmental Procedures; maintaining Departmental records and files in the central office; assembling, preparing, and submitting routine and special reports; and administration of the Department's contracts.

The Administration Unit's responsibility in contract administration is to ensure that contract support by qualified people is available to the plants.

Consultants are often contracted to supplement Department resources in manpower and specialized expertise.

Special Projects Units Control Board Human Factors Review This unit, under the direction of a Project Specialist Special Pro)ects, is coordinating a study that is being performed under contract with the Essex Corporation. This study involves a design review of control boards for our operating plants, as well as the Shearon Harris Nuclear Power Plant, for the purpose of evaluating the human engineering aspects of the control boards. It is anticipated that this study will identify modifications that may be necessary for these control boards in order to improve the man/machine interface.

Special Pro)ects This unit, under the direction of a Project Specialist Special pro)ecto is coordinating special pro)ecto such as Three Mile island 2-47

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follow-up, Employee-Information System, Records Management System, the establishment of a micrographics program, and the Corporate Materials Management System.

Licensin & Permits Section The Licensing & Permits Section acts as the Company's interface with the NRC Offices of Nuclear Reactor Regulation and Inspection and Enforcement, and provides special technical expertise in the areas of seismology and meteorology. The section is organized into units with the following functional responsibilities:

Re ulatory Compliance Unit The function of the Regulatory Compliance Unit is to coordinate the regulatory activities of the Nuclear Operations Department such that the plants operate in a safe manner and meet all regulatory requirements. This unit is charged with the responsibility of coordinating the activities of each of the plant's Regulatory Compliance staffs with the activities of the Nuclear Plant Engineering Department and the Technical Services Department to ensure that l

replies to NRC concerns are technically accurate, responsive to the concerns expressed and prepared in a timely manner to meet the requested response time.

Requests for modifications to Plant Technical Specifications are coordinated through this unit.

The Regulatory Compliance Unit discharges its responsibilities by maintaining daily contact with the representatives of the appropriate CP&L Departments.

This frequent contact provides an update on the status of various action items and allows the unit to identify items requiring management attention and recommend appropriate corrective actions. In addition, the unit personnel are also in frequent communication with their counterparts at other utilities and various vendors, and therefore, maintain an awareness of the broader regulatory issues. In this way, the unit not only provides advice and interpretations on issues currently facing CP&L plants, but also provides 2-48

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information on issues being dealt with by other utilities which may ultimately be of concern to CP&L.

Nuclear Licensin Unit The Nuclear Licensing Unit is responsible for coordination of all Office of Nuclear Reactor Regulation (ONRR) activities affecting the Company's seven nuclear units. This includes the coordination and preparation of responses to all ONRR activities, and the preparation of license amendment requests and licensing documents such as the Harris FSAR. It is responsible for the maintenance of operating licenses and revisions to the Technical Specifications, advises management on critical licensing issues, and ensures that all incoming NRC correspondence is routed properly and responses are prepared to accurately address licensing issues.

Earth Science and Metorology Units The Earth Science and Meteorology Units establish and operate the Harris seismic monitoring program and the Harris, Brunswick, and Robinson meteorological data collection programs.

Environmental Technology Section The Environmental Technology Section conducts the Company's environmental monitoring and assessments, and conducts plant analytical chemistry and metallurgical laboratory services for the Company at the Harris Energy &

Environmental Center in New Hill, North Carolina.

Nuclear Trainin Section Carolina Power & Light Company has established a comprehensive training program to provide required training for both licensed and unlicensed nuclear plant operations personnel'such as Auxiliary Operators, Control Operators, Senior Control Operators, Shift Foreman, Shift Supervisors, and Shift Technical Advisors. The program also provides for the training of other craft 2-49

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and technical personnel such as Radiation Control and Environmental and Chemistry Technicians, Instrumentation and Control Technicians (ISC), and Mechanics. The training program makes use of a combination of off-site training conducted at the Shearon Harris Energy 6 Environmental Center (SHEEC) combined with on-the-gob training at appropriate generating plants.

Off-system training such as vendor training programs is utilized where appropriate. Within the Technical Services Department, the training program is coordinated by the Nuclear Training Section under the direction of the Manager of Nuclear Training.

The Manager, Nuclear Training, provides staff support to the Nuclear Operations Department in the areas of Operations, Technical and Craft Training, and the operation of the simulator and other training facilities at the Harris Energy 6 Environmental Center, and at the operating nuclear plants.

The primary purpose of the Nuclear Training Section is to assure that we have highly qualified personnel available to maintain and operate the nuclear generating plants in a safe and efficient manner. These responsiblilities and services are provided from an organization consisting of six units which support nuclear power plants: the Nuclear and Simulator Training Unit, the Craft Technical Training Unit, and the Curriculum Development Unit at the SHEEC; and the H. B. Robinson Training Unit, the Brunswick Training Unit, and Shearon Harris Nuclear Power Plant Training Unit located at their respective nuclear plants.

The Nuclear Training Section units at the SHEEC are responsible for continuing support of present and future department needs; assisting plants in determining training needs and performing task analysis; monitoring regulatory and audit requirements; evaluating and providing simulator training; and providing support to plants in areas such as instructor training, evaluations, and consultants. The training supervisors at each nuclear plant are responsible for planning and conducting, in coordination with the SHEEC 2-50

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r training units, Operator, Craft, and Technical Training and Retraining. They work closely with all other plant management personnel to identify, develop, and present specialty training for plant employees. They develop, coordinate, and arrange for the presentation to Company and contractors'mployees various training and indoctrination programs, i.e., security, and health physics.

Plant training supervisors are also responsible for maintenance of training documentation and records for all plant personnel.

Formal training work sessions (at least quarterly) are held to ensure timely and deliberate interface and control of assignments between the plant training supervisors and SHEEC training section personnel to further coordination, communications, and consistency in all training-related matters, and the timely implementation of the respective responsibilities and assigned tasks.

In addition to the quarterly training work sessions, a Training Evaluation &

Planning Committee has been established. This committee is charged with evaluating existing training programs and planning future programs. It provides an opportunity for personnel from the plants and from the SHEEC to

)ointly participate. The committees'valuations are broad in scope and include operation and administration of training programs, suitability of programs to meet regulatory and/or legal requirements, program effectiveness, or any other aspect of training that affects plant operation or overall training efficiency. The planning activities of the committee focus on the general program mix that will be appropriate to meet training and retraining needs in the next year. Additionally, the committee is charged to promote and assure consistency with regard to qualification programs for personnel in Operations, Radiation Control, Environmental and Chemistry, I&C, and other Craft and Technical disciplines; to improve communications and share ideas in regard to training; and to monitor the effort to staff the Shearon Harris Nuclear Power Plant while maintaining a qualified staff at each of the other operating nuclear plants. The Manager, Nuclear Training, is the Chairman of this committee.

The Nuclear Training Section staff works to maintain academic quality in all training programs by providing qualified instructors from its own staff, or when necessary, contracting for instruction services with universities and 2-51

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technical colleges or other vendors. For example, in the fall of 1980 local universities were contracted to provide credit courses at an operating nuclear plant in the areas of mathematics and nuclear engineering; also, a local university was contracted to teach mathematics at the SHEEC to students in our Nuclear Auxiliary Operator Training Program.

The Nuclear Training Section includes the following units:

Nuclear and Simulator Trainin Unit The Nuclear and Simulator Training Unit is responsible for providing both classroom and simulator training at the SHEEC for nuclear plant. operations personnel. This training is coordinated with that portion of the overall training conducted by the training supervisors at each nuclear plant. The unit's responsibilities include providing training for auxiliary operators, simulator certification for RO and SRO license candidates, STA simulator training, and simulator retraining for plant operations personnel.

The PWR simulator at the SHEEC, an integral part of CPGL's operator training program, was declared operational in February 1978. It has been continually improved and updated since that time. During 1979, model changes were made to improve simulation of the Three-Nile Island incident, and the computer capacity was increased. A major modification to the Radiation Monitoring System of the simulator is planned to begin in 1981 and be completed in the spring of 1982. The Training Center at the SHEEC was constructed with adequate space for three power plant simulators and their associated computers. CPSL has awarded a contract to install a BWR simulator in December of 1982 in order to further improve operator training. This new simulator will simulate Brunswick Plant Unit No. 2.

Operator training is a combination of classroom, in-plant, and simulator training which requires approximately 30 months for licensing an individual with no prior experience and approximately 18 months for a person with considerable experience such as ex-Navy Nuclear operators. The in-plant training is provided at the plant for which the individual will be licensed.

2-52

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A portion of the classroom and all PWR simulator training is provided at the SHEEC, BWR simulator training will continue to be provided at vendor simulators until the installation of the BWR simulator in December of 1982.

The Nuclear & Simulator Training Unit coordinates the operator training program ensuring that on-the-job, in-plant, classroom, and simulator training are welded into a cohesive program.

Craft Technical Training Unit The Craft Technical Training Unit is responsible for the training of both craft and technical personnel. Major responsiblilites in support of nuclear generating plants include the initial, specialized, and advanced training for personnel in Radiation Control, Environmental and Chemistry, ISC, mechanical, electrical, and radwaste operator disciplines. This unit has already provided training for personnel working on the Harris Plant Safety Analysis Report.

There are laboratory and shop facilities as well as classrooms in use by this unit to provide both practical theory and hands-on instruction. The Instrumentation and Control Training Laboratory has equipment such as oscilloscopes, dead-weight testers, power plant instrumentation, and hand tools. The Health Physics and Chemistry Laboratory contains equipment such as dose-rate meters, air samplers, balances, sulfur analyzer, and neutron detectors. A Craft Training Building housing equipment such as welding machines, lathes, radial drills, motor control trainers, electric power supply, hand tools, and a hydraulic crane has been completed and is in use.

There are separate laboratories for mechanical, welding, and electrical training as well as three classrooms and support areas. These facilities are designed to provide well qualified craftsmen with the required skills for all the power plants.

Course series for all crafts are divided into three levels basic, intermediate, and specialized/advanced. In general, the basic and intermediate series for each craft are four to six weeks in duration, the specialized/advanced training is normally given after the completion of basic and intermediate training, and is accomplished "as-needed," as defined by the 2-53

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plant training supervisors and training sections. Vendor schools are used whenever appropriate. The general subject areas for each craft are:

1) Radiation Control-Chemistry, Health Physics, Environmental Counting Room

2) I&C-Pneumatics, Electronics, Electrical

3) Radwaste Operators-Auxiliary Boilers, Off-Gas, Chemical/Liquid Treatment, Solid Waste, Radwaste Management

4) Mechanics-Welding, General Shop, Plant Mechanical Systems

5) Electricians-Practical Theory, Wiring Practices and Electrical Distribution, Plant Electrical Systems, Electromechanical Controls, Motors, and Generators Curriculum Development Unit The Curriculum Development Unit is responsible for providing assistance in the development of educational programs and means for evaluating the effectiveness of programs offered. This unit also provides administrative support in long-range planning, pro)ection of training requirements, scheduling of students to attend training programs, and in the development of training aids.

Of key and equal importance, is the unit's participation in task analysis, the performance of employee follow-up evaluations after completion of training, and assistance to advisory committees on craft training course content.

The unit has conducted task analyses for each of the sections'raft and technical training programs in order to validate these courses of study. To further the depth and to provide third-party input into the sections'rograms, contracts with university faculty in such areas as thermodynamics and hydraulics, private consultants with extensive operator training and evaluation expertise, and liason with the community colleges and technical institutes are actively pursued. Maintenance of a number of active contracts with outside contractors ensures continuing access to qualified personnel when and if they are needed to supplement our own resources.

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Environmental and Radiation Control Section The Manager of the Environmental & Radiation Control Section, reporting to the Vice President Technical Services, provides staff support in the areas of health physics, chemistry, and environmental activities and for the effective operation of the environmental dosimetry and chemistry laboratory. The E&RC Section has responsibilities identified in the Corporate Emergency Plan to provide health physics and environmental support to the nuclear plants in the event of an accident. These responsibilities and services are provided from an organization consisting of three units, each headed by a principal specialist.

Health Physics Unit The Health Physics Unit provides support and services to the plants in the area of Health Physics and Radiation Protection. This support includes advice and guidance in implementing and maintaining the ALARA program evaluation of the plant health physics programs, assistance in developing and implementing health physics procedures, assistance in selecting and procuring monitoring equipment, technical support to assist in evaluating and resolving health physics related problems, and providing professional and technician support for major outage activities.

This unit is responsible for administering the personnel monitoring program.

This responsibility includes reading of all TLDs and maintaining Company records on radiation exposure. The Health Physics Unit is also responsible for maintaining the Nuclear Operations Department Radiation Protection Manual which defines how radiation protection procedures and programs are implemented at our nuclear facilities.

The Health Physics Unit also provides support in the deployment of the recovery organization to support the Corporate Emergency Plan. This includes onsite support during emergency situations in the areas of environmental assessment and dose calculations and projections.

2-55

II In carrying out these responsibilities, personnel from the Health Physics Unit work closely with cognizant personnel on the plant staffs as well as the Corporate Health Physics Section of the Corporate Nuclear Safety & Research Department. They maintain an awareness of current and proposed regulations and work closely with plant and Department management to ensure that requirements are understood and effectively implemented. Periodic meetings are held with the plant Environmental and Radiation Control Supervisors for the purpose of reviewing programs and problems related to health physics and approaches for resolution of those problems.

Environmental Unit The Environmental Unit provides support to the plants through the Radiological Environmental Lab, located at the Harris Energy 6 Environmental Center. The Radiological Environmental Lab is well equipped with laboratory equipment such as a Low Beta Counting System, Liquid Scintillation Detection System, Ge Li System, Beta Gama Counting System, and a ND 4400 Counting system. This equipment is used by this unit to provide radiological environmental surveillance services to the operating plants and preoperational surveillance for the Harris Plant. This unit performs radiochemical analy'ses of environmental monitoring samples, prepares and distributes routine and special radiological environmental monitoring reports,and plans and implements radiological environmental monitoring programs for new plants.

The Environmental Unit maintains a close working relationship with each plant by making routine visits to each facility. These visits are made to monitor plant programs and procedures and to assist plants with problems. One example of this type of program is the manner in which the unit assists the plant in maintaining the radwaste system by reviewing plant programs and procedures and making recommendations for improving systems operations. In addition to the permanent staff, this unit also utilizes support from various consultants.

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This unit is also responsible for assisting the plants with the implementation and maintenance of programs relating to the Radiological Effluent Technical Specifications.

In order to maintain a high standard of excellence, the Environmental Lab participates in Quality Assurance Programs in conjunction with State and Federal agencies. This program consists of analysis of spiked samples issued by the agencies, or the analysis of split samples and the comparison of laboratory results. A laboratory quality assurance program is also conducted by the Company, which consists of the analyses of unknown samples and interlaboratory comparison of results.

The Environmental Unit maintains a cognizance of existing and proposed regulations and coordinates closely with plants and Departmental management to ensure that regulations are understood and effectively implemented.

Chemistry Unit The Chemistry Unit provides staff chemistry support to the operating nuclear and fossil plants and operates the HENDEC radiochemistry lab in support of the plants.

The Chemistry Unit staff assists the plants in developing chemistry programs, procedures, and specifications. Continuous review of the plant chemistry programs is maintained through review of weekly and/or monthly chemistry data and reports from each plant. These reports are also transmitted to consultants who are experts on the various plants, and the consultants'eviews are coordinated by the Chemistry Unit staff. The staff periodically visits the plants to discuss the reviews of chemistry programs and procedures, to inspect the plant for chemistry conditions, or to coordinate recommendations from the staff and/or consultants. The Chemistry Unit staff also maintains industry contact through various organizations such as EPRI, the EEI Chemistry Subcommittee, and ASTM.

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The radiochemistry lab provides services to the plants by performing chemistry analyses which may be beyond the capability of the plants or are special one-time studies for which the plants are not equipped or staffed. Examples are radwaste evaporator bottoms studies, quality assurance checks on bulk chemicals specifications, and chemical cleaning solution analyses.

The radiochemistry lab conducts a round robin program where standard unknown solutions are sent to the plant labs for analysis. The results are analyzed by the Chemistry Lab Supervisor and returned to the plants with recommendations for improvements in procedures or techniques. This program includes samples for standard chemical analysis and samples for radioisotope analysis. This serves as an important quality assurance check for the plant labs.

Emer ency Preparedness Unit The Emergency Preparedness Unit of the Technical Services Department is responsible for: directing and coordinating Corporate Emergency Planning to ensure, regulatory compliance; assessing the readiness of all CP&L emergency plans and programs; serving as interface with regulatory agencies on emergency preparedness matters; providing emergency preparedness support for CP&L nuclear plants; maintaining training qualifications of plant personnel in emergency response; testing emergency preparedness; ensuring the availability and operational readiness of emergency facilities equipment and supplies; developing dam failure emergency plans for the hydro plants; and for providing coordination with Federal, State, and Local agencies.

2.2.1.4 Corporate Quality Assurance Department The Corporate Quality Assurance Department was recently formed in order to consolidate the quality assurance, quality control, and audit functions which were previously performed separately for engineering and construction activities, operations activities, and corporate quality assurance audit activities. One QA/QC unit at each nuclear plant will now oversee QA/QC activities for engineering, construction, and operations. The Directors of these on-site units will report to off-site corporate managers in order to maintain the independence of their responsibilities. The off-site corporate managers report to the Manager Corporate Quality Assurance Department, who 2-58

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reports directly to the Executive Vice President Power Supply and Engineering 6 Construction. In this manner the Corporate QA Department Manager oversees the QA/QC activities of both the Power Supply and the Engineering 6 Construction Groups while maintaining independence from any responsibilities within those groups. This organization further provides the Vice President Nuclear Operations Department the enhanced capability to concentrate his activities on safe nuclear operations by removing the additional, direct Operations QA/QC responsibilities from within his department.

The Corporate Quality Assurance Department is organized into four functional entities: Engineering & Construction QA/QC, Operations QA/QC, Performance Evaluation, and Training and Procedures, as described below.

Engineering 6 Construction QA/QC Section The Engineering and Construction Quality Assurance/Quality Control Section of the Corporate Quality Assurance Department has the prime responsibility for the Harris Plant Quality Assurance/Quality Control in the engineering and construction phase and during startup. Its purpose is to anticipate and preclude safety-related nonconformances.

The four units comprising the Engineering and Construction Quality Assurance/Quality Control Section are:

1. The Engineering Quality Assurance Unit. Its responsibilities include:

a. Review of design and site procurement specifications for inclusion of QA requirements;

b. Review of A-E's and NSSS procurement documents for inclusion of QA requirements; 2-59

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c. Review of Harris construction and site quality assurance/

quality control procedures; and

d. Maintaining liaison with the A-E's and NSSS'A organizations for exchange of quality-related information and resolution of quality-related problems.

2. The Vendor Surveillance Quality Assurance Unit. Its responsibilities include:

aO Qualification of vendors'A programs of site procured safety-related items.

b. Conducting shop inspections and "release-for-shipment" inspections for vendors of site procured items; and c ~ Participating in shop inspections for vendors of Ebasco and Westinghouse procured items.

3. The Site Construction Quality Assurance/Quality Control Unit. Its responsibilities include:

a. Receipt inspection of nuclear safety-related items and material;

b. Inspection and testing of concrete materials;

c. Sampling and testing concrete;

d. Inspecting and testing reinforcing steel bar splices;

e. Gradation analysis of aggregate; Visually inspecting and performing nondestructive examination of welds in piping systems and structural steel; go Performing inspections to ensure ASME "N" Stamp program requirements are fulfilled;

h. Identifying and controlling nonconforming items and conditions; 2-60

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i. Placing stop orders on work or activities which would result in a significant nonconformance; Reviewing field procurement documents;

k. Reviewing construction's administrative procedures; Monitoring construction work in progress for compliance with drawings, specifications, and procedures.

Reviewing construction, installation, and testing records to e

ensure important functions have been performed in accordance with specifications;

n. Monitoring storage and issuance of QA-related materials and supplies; 0~ Reviewing manufacturing data for nuclear safety-related items and materials; po Organizing, filing, and maintaining records significant to the functional capability of plant structures, systems, and components; Conducting surveillance of Harris site construction inspection activities; and Conducting surveillance of start-up activities.

4. The NDE Unit. This unit is staffed by qualified NDE personnel. Its responsibilities include:

a. Providing nondestructive examination (NDE) procedures;

b. Perform the required NDE; C~ Review applicable contractor NDE procedures; and

'd ~ Maintain Radiation Isotope License issued by the State of North Carolina.

Operations QA/QC Section This Section is responsible for assuring proper application of quality standards, practices, and procedures associated with plant operation, 2-61

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maintenance, or modification. The Manager Operations QA/QC Section and his staff are responsible for:

a. Providing QA/QC services at the plant;

b. Reporting quality-related problems for correction; C~ Stopping maintenance or modification work which does not meet requirements and documenting this action;

d. Reviewing modification and plant maintenance documents, the Plant Operating Manual, and other plant procedures and instructions as appropriate to assure that quality requirements are adequately prescribed;

e. Ensuring holdpoints have been inserted in work control documents and conducting inspections and witnessing for maintenance and modification of the plant;

f. Accepting correction of items and conditions by means of inspections, examinations, or tests; ge Providing guidance or check lists for accumulation of documentary evidence of quality and other QA records for retention;

h. Coordinating/conducting surveillance of on-going plant activities, reporting results to the appropriate Plant Supervisor, and following up to assure that timely corrective action is taken, when necessary;

i. Evaluating the effectiveness of the QA program, and as appropriate, recommending revisions; Providing procedures instructions necessary for the accomplishment of QA activities;

k. Reviewing purchase requisitions and ensuring that QA/QC requirements are specified, except when reviewed by E&CQA; Review Nuclear Operations generated A-E contracts and NSSS inquiries and contracts to ensure inclusion of necessary QA/QC requirements;

m. For Nuclear Operations generated contracts, maintain liason with the A-E and NSSS Supplier in accordance with this Corporate QA Program to keep up-to-date on project QA/QC activities and status, and to assure timely resolution of quality-related problems; 2-62

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n. Review site generated design specifications and procurement documents, including revisions to these documents which alter QA/QC requirements, to ensure inclusion of QA/QC requirements; and 0~ Review of the Corporate QA Program and proposed revisions, as appropriate.

The Director QA/QC Unit at each operating plant reports to the Manager Operations QA/QC. He is the senior Operations QA/QC Section representative at the plant. He is responsible for conducting the site QA/QC activities in accordance with the Corporate QA Program and QA/QC procedures.

He supervises the CPGL QA/QC Specialists, Technicians, and Inspectors and has stop work authority.

Performance Evaluation Unit The Performance Evaluation-Unit is responsible for conducting an independent corporate audit program. Personnel in this unit have no responsibilities for quality achievement, nor for quality assurance other than auditing. They are trained to prepare for audits, conduct and report audits, and follow-up, as necessary, to assure timely correction of conditions, practices, and items that could degrade plant quality.

This unit assures by audit that all Company functions related to nuclear power plants are carried out in accordance with the Corporate Quality Assurance Program. This program is based on the 18 Quality Assurance Criteria in Appendix B of 10CFR50. Other commitments audited are environmental reports, safety analysis reports, technical specifications, nuclear plant procedures, ASME Code, security plans, fire protection plans, and training programs.

Both internal and external audits are conducted. Included as internal audits are: Nuclear Plant Engineering, Nuclear Plant Construction, Nuclear Plant 2-63

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Operations, Nuclear Fuel Section, Engineering & Construction QA/QC Section, and Operations QA/QC Section. Included as external audits are: A-E, NSSS, nuclear fuel suppliers, contractors, and vendors. Audit reports identify and require corrective action for areas found deficient during the audits.

Training and Procedures Unit The Training and Procedures Unit is responsible for implementation of a training program designed to qualify QA/QC personnel for maximum interchange-ability among various QA/QC activities. In concert with appropriate departments, it will also develop, modify and determine control of standard procedures to be utilized at construction and operating sites. The unit is responsible for preparation and maintenance of the Corporate QA Manual, the ASME "N" Stamp QA Manual, and QA/QC procedures for corporate and/or field use.

2.2.1.5 Engineering and Construction CP&L's nuclear project management experience began with the H. B. Robinson Plant project. Robinson Unit 2 was a "turn key" pro)ect, whereby the initial responsiblity for design and construction rested with the prime contractor,.

Westinghouse Electric Corporation, and CP&L's participation in construction and site quality assurance was limited. CP&L did, however, take active roles in the areas of licensing, startup testing, and operation, and retained ultimate responsibility for the entire plant.

This approach proved to be sound for that period as shown by the fact that Robinson has been one of the most reliable nuclear power plants constructed in the United States. Acceptable proposals for turn key plants diminished, however, and the need for more direct control by CP&L in future nuclear construction became apparent. Consequently, at Brunswick, CP&L assumed greater engineering and construction management responsibilities. For example, separate contracts were awarded for engineering and construction with 2-64

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CP&L assuming more responsibility for coordination of the total project than it had at Robinson.

As Brunswick progressed, we realized that in the future even more direct management responsibility for engineering and construction of our nuclear plants would be essential. This resulted in a change in the Company's construction management policies and led to our creating an organization which could assume direct control of construction management activities for Harris.

Our experience during Robinson and Brunswick construction provided the background we needed to develop the personnnel and the corporate management expertise required for the Harris Project. Specifically, for the Harris project we engaged an Architect-Engineer (in this case Ebasco) for design.

CP&L provides the construction management for the contractors hired to do the actual construction work. In this case, Daniel Construction Company has the prime contract for construction of the power block and associated facilities.

As construction manager, CP&L is responsible for job coordination and communication, planning, cost control, inspection, quality assurance, accounting, warehousing, procurement, field engineering, milestone scheduling, and establishing and monitoring the master schedule. The master construction schedule is expanded by CP&L .into a critical path network by use of PMS-IV, a computerized project management tool. This exercise of construction management by CP&L aids in making the actual determination as to the rate and sequence of construction, as well as the determination as to which portions of work will be accomplished by Daniel and which portions are better handled by separate contracts let directly by CP&L. In addition, CP&L retains and exercises authority to approve or disapprove prime contractor recommendations on construction methods and force levels, provides the communications"link between the designer (Ebasco) and builder (Daniel and others) and controls site delivery dates. By retaining these responsibilities, the real burden of construction management remains with CP&L rather than being delegated to a constructor, as was our past practice.

The above experience supports the contention that CP&L has the management resources necessary to safely design and construct Harris Units 2 through 4, 2-65

while providing the required technical backup resources for Harris Unit 1 operations.

Engineering & Construction Group Technical Staff Resources The Engineering and Construction Group supports nuclear operations in the areas listed on Figure 4.

En ineerin Resources Engineering support of the Harris Project is provided by the Nuclear Plant Engineering Department which is organized into two sections: The Harris Plant Engineering Section and the Engineering Support, Nuclear Plants Section.

The Harris Plant Engineering Section is responsible for providing the design and engineering for the Shearon Harris Nuclear Power Plant, including engineering support of site activities. This includes evaluation and preparation of responses to the NRC I&E Bulletins and Orders, engineering of plant modifications, plant system problem resolution and providing expertise in the nuclear, civil, instrumentation and controls, electrical, and mechanical disciplines. The section fulfills these responsibilities by generation- of engineering documents, by managing the contract for A-E services, by providing direction for project design, by providing resolution of field problems, and by managing the procurement of engineered equipment.

This Section is organized into three primary units: Mechanical, Electrical, and Civil. Each of these units is headed by'a PrincipalEngineer. The units are organized into subunits to handle specialized areas of each discipline such as power and Z&C, radwaste, nuclear steam supply, and hangers and restraints.

The Harris Plant Engineering Section is located at the Harris Site and works on a day-to-day basis with the site construction organization, site start-up 2-66

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organization, and Harris Plant operations organizations to assure overall success of the project.

The Engineering Support, Nuclear Plants Section is responsible for providing engineering support for CP6L's operating nuclear plants., The Section is organized into three units: the Brunswick Engineering Support Unit, the Mechanical Unit, and the Electrical Unit. The Brunswick Unit is headed by a Resident Engineer and the other two units by Principal Engineers. In addition, the section has the capability and is experienced in adding contract engineers and designers to supplement its forces. These contract personnel work under Department supervision and to CP&L procedures.

The Brunswick Engineering Support Unit is located at the Brunswick Plant in order to be able to make the necessary daily decisions. The other two units are located in the General Office.

The Vice President Nuclear Plant Engineering also has on his staff a Director Nuclear Engineering Safety Review, who is responsible for assuring that operations and engineering feedback on both internally and externally generated nuclear plant safety issues are incorporated into new plant design and into modifications to operating plants. He additionally assures that a program is in place and implemented to ensure that Departmental personnel are trained in their responsibilities to meet NRC regulations, codes, standards, and other commitments made by the Company.

Engineering Support for Harris Unit 1 Start-up and Operations Engineering support for the testing start-up and operation of the Harris Plant is provided by the Nuclear Plant Engineering Department through the Harris Plant Engineering Section located at the Harris Site.

At the time of hot functional testing on Harris Unit 1, the Harris Plant Engineering Section will be realigned as shown functionally, in Figure 9. This organization will provide the required engineering support to the units under construction as well as those in various phases of start-up testing The existing section will be functionally organized into two major and/or'peration.

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. responsible for the review of design drawings and specifications to ensure ease of construction, the administration of contracts, the coordination of CPGL-owned tools and equipment, participation in construction methods, selection planning, and direct supervision and inspection of the constructor and contractors.

The Manager Engineering and Construction, Brunswick and Robinson Plants, has the management responsibility for construction and engineering for the Brunswick and Robinson generation facilities as required to complete project assignments in a manner which minimizes impact on plant operations, keeps management informed, and meets all requirements. Site staffs have been established at both the Brunswick and Robinson Plants to perform construction work assigned to the Nuclear Plant Construction Department. These staffs are termed the Brunswick and Robinson Site Management Units. The work being performed by these units includes major modifications or additions to the existing plants which are beyond the scope which can be conveniently handled by the plant organizations and which are specifically assigned by the Nuclear Operations Department.

The Brunswick Site Management Unit and the Robinson Site Management Unit have been assigned the responsibility to manage, administer, supervise, and inspect both firm-price and reimbursable contractors who are performing modifications and additions for the respective plants. Activities include review of design drawings to ensure ease of construction, implementation of the construction ALARA program, cost control, schedule, and coordination and direction of contractor activities. These units participate in selection of construction methods, planning and scheduling, providing engineering support, and in direct supervision and inspection over several contractors.

At the Brunswick site, a Resident Engineering Unit of the Nuclear Plant Engineering Department has been set up on site to perform engineering and engineering support of modifications to the existing plant. This organization functions as an extension of the general office department and is.particularly 2-69

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involved in those modifications which require a considerable amount of field verification for appropriate design.

The Manager Construction Procurement and Contracting, has the responsibility for providing all procurement and contracting activities required to support the completion of construction project assignments. He supervises professionals in providing both firm-price and reimbursable contracts, site procurement, expediting, and construction equipment and tool management. Site procurement staffs have been established both at Harris and Brunswick Plants to perform procurement of materials and equipment to support construction assigned to the Nuclear Plant Construction Department.

2.2.1.6 -

Corporate Nuclear Safety Section The CNS Section monitors the Company's operating nuclear plants on a continuous basis to assure that the associated nuclear safety programs are carried out in an effective manner. The Section constitutes the "independent off-site review group" required by ANSI 18.7 commitments. Its existence is mandated by each of the Company's three nuclear facility Technical Specifications, Section 6. These Technical Specifications briefly define the Section's function as review of significant plant changes, tests, and procedures; verification of appropriate action regarding reportable occurrences; and detection of trends which may not be apparent to a day-to-day observer.

In an effort to stay in close contact with day-to-day operations and better assess the manner in which plant activities are conducted, the Section has On-site Nuclear Safety subunits at each operating plant. These subunits are composed of one Principal Engineer with three Project Engineers as subordinates. These subunits report off-site to the Director On-si,te Nuclear Safety, who reports to the Manager CNS.

The major role of the CNS Section is the performance of the independent review of plant safety-related documents as defined in ANSI 18.7. This function has been performed via the dedicated unit approach versus the committee approach 2-70

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since 1976. The unit performing this activity was located off-site. In early 1981 it was decided to expand the organization to include permanent subunits located at each operating plant site and reporting off-site.

The responsibilities of these On-site Nuclear Safety Subunits are threefold, as follows:

1. Provision of an independent review function as required by the facility Technical Specifications and commitment to ANSI N18.7;

2. Administration of the Company operational experience feedback and information dissemination at each plant (Item I.C.5 of NUREG-0660); and

3. Assessment of plant activities that impact nuclear safety to assure efficient and safe operation is being maintained.

There is no distinction between on-site and off-site capabilities and qualifications for independent review. The on-site subunits assume most of the duties in meeting Technical Specification independent review requirements.

This process is described in detail below.

The operating experience feedback function consists of screening assigned documents for applicability to the plant. Documents such as plant reports, NRC issuances, Company reports generated external to the plant, and industry assessments of operating experience are included in the system. The subunits determine if an item is applicable and then route it to the cognizant party with a specified action to be taken. A document control system is used to assure proper action.

The third ma)or responsibility is evaluation of plant safety-related activities to assess the overall quality and safety of operations. This activity is carried out by actual surveillance of the daily routines of operations and maintenance personnel, discussions with plant personnel, examination of logs and operating data, and plant tours. Documentation is 2-71

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via checklists and/or logs, and periodic reports are issued providing a summary of evaluation, conclusions, and any appropriate recommendations. A distinct part of this responsibility is the evaluation of safety-related procedures and modifications.

The off-site unit continues to conduct independent reviews of assigned documents, but the ma)ority of these reviews are by the on-site subunits.

When assistance is required or expertise is available off-site, the Director On-site Nuclear Safety calls on the off-site unit to provide review.

The off-site unit's time is devoted largely to conducting special investigations into potential problem areas and plant system operational history. These investigations constitute in-depth studies of selected areas in an effort to actively identify problems prior to their occurrence. The subject of the investigations is determined by the Principal Engineer of the unit the Director On-site Nuclear Safety, and the Manager CNS. If the on-site subunits identify an area that is felt bears study, they request off-site assistance to look at the item in detail.

The off-site unit also performs review of industry operational experience items to identify items of generic concern and/or applicability to Company plants. When an item is found that appears to have potential applicability, it is routed to the on-site group for input into the operational experience feedback system. As a part of this activity, the unit is also the Company's NOTEPAD coordination point and the focus of the NSAC technical contact.

Additionally, the Vice President Nuclear Safety and Research forwards to the Vice President Nuclear Operations, the Vice President Power Supply, and the Executive Vice President Power Supply and Engineering & Construction, on a monthly basis, the LER Trend Analysis which contains the status of USNRC identified problems. As a result of these documents, they may request additional information or through the Vice President Nuclear Operations request a surveillance be performed by the Manager OQA.

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The LER Trend Analysis contains an analysis of LERs and graphs depicting the various categories of events. The analysis portion of the document concerns itself with:

Reason for the LER Repeatability Corrective action Timeliness of submittal of the LER The section's independent document review activity consists of review of the following documents:

Plant procedure changes meeting 10CFR50.59 review criteria, Plant design changes meeting 10CPR50.59 review criteria, Licensing actions, Test or experiments not described in the facility FSAR, Plant operational occurrences (LERs),

Regulatory violations, Technical Specification changes, Plant Nuclear Safety Committee (PNSC) meeting minutes, Conformance to regulatory requirements, and Any item deemed appropriate for review relative to safe operations.

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Required reviews are processed in the manner described below:

Safety-related items are evaluated by the responsible members of the respective plant staff. If the item contains an unreviewed safety question, Technical Specification change, FSAR change, or is deemed safety-significant bv the Plant General Manamer. it is forwarded to the ONS gertion for independent review. Upon receipt, the litem 4s lo~~ed 4n ~nB sent to the 1

resnert4ve Prlnrln~l Fnofnppr On-site Nurlear Safety or referred tn the prinripal Fn~ineer of the off-site unit. Dependinl. on the extent of the item and the disciplines or areas involved, the Principal Engineer assigns the detailed review to one or more of the Pro)ect Engineers in his subunit. He specifies considerations to be included in the review and also indicates the time frame in which the review is to be completed.

With respect to both time and detail, the Project Engineer has a significant amount of latitude in carrying out the assignment. Sometimes he will uncover additional details that need to be considered in the review that were.not earlier specified, or a given review may produce unforeseen complexities that require more time than first estimated. In these instances the Project Engineer feeds back information to appropriate personnel and adjusts the scope and time as necessary with the concurrence of the Principal Engineer. Once the Pro)ect Engineer is satisfied that the assignment is finished, he documents his comments and sends the package to the Principal Engineer for concurrence. The Principal Engineer evaluates the package. If satisfied he sends it to the Director On-site Nuclear Safety for final approval and filing. If not satisfied the Principal Engineer returns the package to the reviewer with specific comments that need resolution before approval. For each item reviewed at least three specified signatures are required to show that the item has been adequately evaluated. The final signature is normally the Director On-site Nuclear Safety. In all cases where Technical 2-74

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Specification changes are submitted to the NRC or where a modification or test constitutes an unreviewed safety question, formal approval must be obtained from CNS prior to implementation. In the case of modifications which do not constitute unreviewed safety questions, an approval memorandum is required, but the modification work can proceed before receipt. Formal approvals are issued under the signature of the Manager CNS.

If a specific item cannot be closed out with regard to resolution of all aspects yet the open aspect does not constitute an immediate safety problem, a "follow-up item" may be issued. The review item is closed out in these cases, and a specific follow-up document is initiated to trace and readdress the long-term point of the review. These follow-ups are serialized, updated, and closed out in a time frame consistent with their priority. The respective Principal Engineer reviews the status of his outstanding items to assure they are being handled in a timely manner.

Most items are resolved via direct contact between the Pro)ect Engineer and the appropriate individual of the plant staff. However, if such efforts are not successful and it is determined that further action is required to enhance plant safety, a formal concern or recommendation is issued. A recommendation results from a decision that a specific course of action is desired to improve the potential health and/or safety impact on the public relative to an identified nuclear safety hazard potential. A concern is voiced when the course of action is unspecified but there is a deficiency which requires rectification to improve public health and safety relative to a potential nuclear hazard. Formal correspondence -describing the concern or recommendation is initiated and sent to the Vice President Nuclear Operations Department for resolution of the problem. Target dates for resolution and final corrective action are agreed upon, consistent with the safety implications. If the problem is of immediate safety concern, it is verbally communicated to the Plant General Manager and Vice President Nuclear Operations Department for prompt resolution. Additional reports to Senior Management are discussed in Section 2.3.

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A major portion of the items reviewed consists of Licensee Event Reports (LERs). These LERs are examined for safety implications, adequacy of corrective action, and adequacy of corrective action to prevent recurrence.

Repetitive events are examined closely for safety significance and proper corrective action. Trends of LERs relative to equipment, procedure, and personnel deficiencies are also examined to highlight areas which may need attention. Additionally, NRC LER computer tapes are utilized to identify generic industry trends which may be applicable to the Company's facilities.

These tapes list all LERs reported to the NRC. A computer program has been developed whereby the information can be searched to compile data specific to particular types of problems. For example, common component failures, personnel errors, system problems, and events relative to key words such as "pipe crack" can be accessed. These tapes are periodically updated to maintain data concerning the most current events. This is supplemented by monthly reviews of LER summaries provided by the NRC in hard copy. In the same vein, Section members attend national meetings and short courses to gain perspective on what is happening in the industry. These efforts are directed to early identification of problem areas rather than participating solely in a reactive role.

In the routine conduct of Corporate Nuclear Safety Section activities, informal contacts are required throughout the Operations Groups of the Company. The unit's members are unconstrained in these contacts and have the organizational freedom, authority, and independence to contact any person regarding safety matters. Other than members of the plant organizations, frequent contacts are made with the support functions in the Nuclear Operations Department and the Engineering and Construction Group.

2. 2. 1.7 Corporate Health Physics The Corporate Health Physics Section, under the supervision of the Director Corporate Health Physics, consists of personnel with education and/or work experience in fields of radiation hygiene or health physics. The section is also responsible for the formulation and recommendation of 2-76

0 corporate level health physics policies and programs, evaluation of existing health physics programs and recommending any needed improvements and modifications, and providing health physics expertise throughout the Company.

The Corporate Health Physics Section is responsible to Company management for formulation and recommendation of corporate level health physics policies and programs, evaluating existing health physics programs and recommending any needed improvements to these programs, providing support to the licensing and corporate nuclear safety activities of the Company, maintenance and distribution of the Corporate Emergency Plan, development and distribution of the Corporate ALARA Program, and periodic review of the various ALARA programs developed to comply with the Corporate ALARA program.

The section staff has the flexibility to review all aspects of the Company's health physics programs including staffing, training, procedures, equipment, management support, etc. The staff conducts a range of activities to accomplish this review including assignments at operating nuclear plants to assist in health physics activities, attendance at meetings with health physics personnel associated with nuclear plant operations, and review of NRC inspection and enforcement reports, Corporate QA audit reports, and incoming NRC correspondence.

The section staff reviews proposed NRC and EPA regulations; NRC regulatory guides, and industry standards pertaining to health physics activities to assess the potential impact on Company operations. Company management is advised of the results of these evaluations as appropriate to assist management in planning to meet any future requirements. These proposed

=requirements are circulated to appropriate Company health physics personnel for their review and information. The Director Corporate Health Physics participates in several health physics task forces and ad hoc industry groups to assist in efforts to assess nuclear industry health physics activities.

This information is used to keep appropriate Company personnel informed about the activities for possible utilization in Company operations. Discussions 2-77

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with health physics personnel at other utilities and visits to their 1 facilities are used to assess and incorporate, as appropriate, information obtained from other utilities.

The Director Corporate Health Physics is responsible for investigating known or suspected radiation overexposures as defined in applicable state or federal regulations and reporting the results of the investigation to the Vice Chairman including steps that have been taken to prevent similar incidents in the future. The staff also reviews other matters of noncompliance pertaining to Company health phy'sics activities and has the organizational freedom to review in-depth the circumstances surrounding the noncompliance and report the results of the in-depth'investigation to management levels as determined by the Director Corporate Health Physics.

The Director Corporate Health Physics is also responsible for the development, implementation, and maintenance of the Corporate ALARA program.

The Corporate ALARA Program defines the scope and requirements for individual ALARA programs for Company health physics activities as well as activities which affect health physics programs, such as nuclear plant engineering and construction. The line organizations are required to implement appropriate ALARA programs that comply 'with the Corporate ALARA program.

The Director Corporate Health Physics has been assigned the responsibility for conducting a periodic management review of the off-site nuclear sa'fety review program and the quality assurance audit program. The review of'hese programs is conducted twice each year and results are documented in reports and discussed with the Vice President Corporate Nuclear Safety and Research and the Vice Chairman. The reports are also sent to the Chairman/President of the Company.

The Director Corporate Health Physics has complete freedom to discuss health physics matters with anyone within the Company including the Chairman/President. The Corporate Health Physics Section has no line responsibility for engineering, construction, and operation. The section is 2-78

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primarily'responsible for reviewing the Company health physics programs to determine if adequate Company resources are being expended in these programs.

If problems are identified, the staff has the organizational freedom to discuss the problems with the appropriate levels of management to resolve the problems. If the problems are not resolved at one level of management, the matter is pursued with higher management until resolution satisfactory to the Director Corporate Health Physics is obtained. These Senior Management feedback mechanisms are discussed in Section 2.3.

Strong interfaces have been established between the Corporate Health Physics Section staff, the Nuclear Plant ETC Managers and their staffs, and the .

Manager -Environmental and Radiation Control and his staff. Additional interfaces with the Nuclear Plant Engineering Department and Technical Services Department have been established to assist them in their health physics related activities.

2.2.1.8 Fuel and Materials Management Group The Nuclear Fuel Section of the Fuel Department provides operations support to CP&L nuclear units by giving technical assistance in four key areas:

refueling support, startup support, analytical support, and fuel performance monitoring.

Prior to plant refueling outages, Nuclear Fuel Section personnel work with the plant staff to develop fuel shuffle procedures to assure proper core loading and to minimize critical path downtime. During the. physical fuel movement activities, Nuclear Fuel Section personnel recommend and assist in various irradiated fuel inspection programs and shipping procedures. Technical recommendations are given for test result interpretations and, if required, fuel reshuffling plans are developed. In the event a fuel assembly is damaged, the Nuclear Fuel Section is responsible for taking corrective action and coordinating activities regarding a replacement bundle.

Nuclear Fuel Section personnel are on site during startup physics testing to provide assistance in test procedure development and review, to assist in 2-79

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performing the physics tests, and to give technical assistance in data reduction and interpretation. Comparisons are made between measured and predicted results with any discrepancies analyzed and explained in detail.

Nuclear analysis support involves all activities relating to core management and operation including fuel cycle planning and the evaluation of nuclear design changes and planned plant maneuvers. Plant licensing and core physics design are reviewed for each core loading. When required, process computer constraints are verified.

Carolina Power 6 Light Company maintains an ongoing fuel performance monitoring program in which routine reports are generated, detailing statistics on past generation, remaining fuel generation capability, power and exposure distributions, margins to Technical Specification limits, and reactor coolant activity levels. Startup physics test results are documented and compared to predictions. Fuel performance information is also collected and transmitted to the fuel supplier for his review and analysis.

In addition to the above operations support activities, the Nuclear Fuel Section coordinates the Company's special nuclear material accountability program and monitors and supports the Company's spent fuel transportation and management activities.

In carrying out its operations support responsibilities, the Nuclear Fuel Section interfaces with other Company departments with primary contact being made with Nuclear Operations Department and Technical Services Department personnel. In addition to those activities described above, interaction with the Nuclear Operations Department involves periodic planning for optimum fuel operating strategies and core control. Daily contact is maintained between the Nuclear Fuel Section staff and nuclear plants'ngineering and operations 2-80

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I Continuing interactions with the Nuclear Licensing Unit of the Technical Services Department provides for detailed reload fuel licensing review and coordination.

Materials Management Department The Purchasing Section of the Materials Management Department provides procurement support to the operating nuclear plants. An Expediting Unit within Purchasing also is staffed to provide support for expediting shipment of material to operating nuclear plants.

The Purchasing Section is assisting in procurement of spare parts for the Harris Plant. The Inventory Control & Warehouse Section is assisting in layout of warehouse and cataloguing of materials for the Harris Plant.

Interface with the Nuclear Operations Department includes coordination with nuclear plants'taffs and Operations Quality Assurance personnel. The interface with the nuclear plants'taffs involves procurement of standard and quality assurance related materials and.services, clarification of quality assurance requirements, problem resolution, and securing necessary documentation. The interface with Operations Quality Assurance involves resolution of problems relative to supplier qualification, quality assurance requirements, internal and external quality assurance audits and training coordination.

Purchasing interfaces with the Corporate Quality Assurance Department in areas of quality assurance audit and supplier qualification. The audit is performed to ensure compliance with the Corporate Quality Assurance Program and other related programs and manuals.

Offsite Management Resources CP&L offsite management is well qualifed to direct the design, construction, and operation of the Harris Plant. The Company has continuously increased its offsite management involvement in nuclear plant design, construction, and operations from 1966, when the H. B. Robinson Plant project commenced, to the present, when seven nuclear units are under CP&L construction and operations management.

The Company offsite management is experienced in coordinating complex nuclear operations which require close coordination between design, construction, and operating forces. An example of these types of activities is the start-up and operation of Brunswick Unit 2 while Brunswick Unit 1 was still under construction, with security separation of common control rooms. In addition, CP&L was one of the few utilities to complete the design and installation of all equipment modifications and administrative changes resulting from the Three Mile Island Short-Term Lessons Learned Task Force at all three of our operating units by the December 31, 1979 deadline. Further, CP&L has the only nuclear unit with an approved SER for Fire Protection (BSEP). This experience, as well as our additional experience with the Harris Plant project demonstrates the Company's capability to safely manage all nuclear activities simultaneously. These, management resources are described in more detail in the following sections.

2.2.2.1 Power Supply and En ineerin & Construction Groups The Executive Vice President Power Supply and Engineering & Construction Groups, Mr. E. E. Utley, manages offsite nuclear operations support activities in the areas of power supply, engineering support, and nuclear fuels and materials. Mr. Utley has 29 years of experience with CP&L, including serving as superintendent of three plants, and manager of power supply activities for the past 10 years. The structure of these groups is shown on Figures 5 and 6.

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The Senior Vice President Power Supply Group, Mr. L. W. Eury, reports to Mr. Utley, and within his group provides the primary offsite management resources for nuclear operations. Mr. Eury holds a bachelors degree in electrical engineering, is a registered professional engineer, and has 21 years of experience in various engineering and management positions at CP&L.

The Vice President Nuclear Operations Department, Mr. B. J. Furr, holds a bachelors degree in mechanical engineering and has eighteen years of engineering experience, twelve of which is nuclear power experience. He has been Plant Manager of both the Robinson and Brunswick Plants. He has held an SRO license on the Robinson plant and was involved on both Robinson and Brunswick during start-up testing and operation.

2.2.2.2 Technical Services Department The Vice President Technical Services Department, Mr. P. W. Howe, holds a bachelor of science degree in chemistry, and has 29 years of experience in the fields of nuclear fuels; he has served as department head at Lawrence Radiation Laboratory, a member of the U.S.A.E.C. Atomic and Safety Licensing Board; and Chief, Site Environmental and Radiation Safety Group, U.S.A.E.C. in addition to his involvement in management of the Company's environmental and technical services activities.

Licensin & Permits Sections The Manager - Licensing & Permits Section holds a bachelors degree in engineering, is qualified as a reactor operator in the U. S. Naval Nuclear Power Program, is a registered professional engineer, and has 18 years experience in nuclear engineering fields.

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Environmental Technology Section The Manager, Environmental Technology Section, holds a bachelor and master of science degree in biology, a doctorate degree in zoology, and has 15 years of experience in environmental assessment and monitoring fields.

Nuclear Operations Administration Section The Manager of this Section has a bachelors degree in chemical engineering and thirteen years of experience, all in the nuclear area.

Nuclear Trainin Section The Manager of the Nuclear Training Section has a masters degree in nuclear engineering and 32 years of nuclear experience, including three years as professor at the Air Force Institute of Technology, 13 years as professor of Nuclear Engineering at North Carolina State University, with emphasis on

'I nuclear operations engineering and systems design; and seven years as special consultant to NRC Operator Licensing Branch and DOE Safety Division. He is a registered Professional Engineer. He has been a Project Engineer on the design, construction, and operation of three major nuclear facilities.

Environmental and Radiation Control Section This section is headed by a manager with a bachelors degree in physics and twenty-two years of experience in the area of health physics, with eighteen of those years associated with power or research reactors. He is certified by the American Board of Health Physicists.

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Emergency Preparedness The Director of this unit has a bachelors degree in industrial engineering, has U.S. Naval Nuclear Power Program experience, is a registered professional engineer, and has 13 years of experience in nuclear engineering.

2.2.2.3 Fuel and Materials Mana ement Group The Senior Vice President - Fuel and Materials Management Group, Mr. J. M.

Davis, Jr., reports to the Executive Vice President - Power Supply and Engineering & Construction Groups. Mr. Davis holds a bachelors degree in mechanical engineering, is a registered professional engineer, and has 22 years of experience in engineering and management.

The Vice President Fuel Department, Mr. R. A. Watson, holds a bachelors degree in nuclear engineering, a masters degree in physics, is a registered professional engineer, and has 23 years of experience in nuclear engineering activities. Reporting to the Vice President Fuel Department, is the Manager Nuclear Fuel Section, who holds a bachelors degree in nuclear engineering, is a registered professional engineer, and has 14 years of experience in nuclear engineering activities.

2. 2.2.4 Engineerin & Construction Management As shown in Figure 6, the Senior Vice President Engineering & Construction Group has two department managers, five section managers and a Director, Nuclear Engineering Safety Review, who provide the management for the Company's nuclear plant engineering and construction. The Senior Vice President, Mr. M. A. McDuffie, holds a bachelors degree in civil engineering, is a registered professional engineer, and has over 28 years of experience in power plant engineering and construction, including 14 years experience in nuclear plant construction and engineering.

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4 The Vice President Nuclear Plant Engineering Department, Mr. A. B. Cutter, holds a bachelors degree in chemical engineering, a masters degree in nuclear science and engineering, and has 20 years of experience in Navy nuclear engineering and operations, light water reactor and breeder reactor engineering. The Nuclear Plant Engineering Department is divided into two sections: the Harris Plant Engineering Section and the Engineering Support, Nuclear Plants Section. In addition to the two sections, the department Vice President has a Director Nuclear Engineering Safety Review on his staff.

The Manager Harris Plant Engineering Section, who is responsible for providing the design and engineering for the Shearon Harris Nuclear Power Plant project, including engineering support of site construction, startup, and operating'ctivities, holds a bachelors degree in electrical engineering, a professional degree in nuclear engineering, is a registered professional engineer, and has 17 years of engineering and power plant operations experience, 13 years of which are nuclear engineering experience. The Manager Engineering Support, Nuclear Plants Section, who is responsible for providing engineering support for the Company's Brunswick and Robinson nuclear plants, holds a bachelors degree in engineering, a masters degree in nuclear engineering, is a registered professional engineer, and has 21 years of experience in nuclear engineering fields. The Director Nuclear Engineering Safety Rev'iew holds a bachelors degrees in nuclear engineering, industrial engineering, and engineering math, is a registered professional engineer, and has 21 years of experience in nuclear operations, nuclear regulation and nuclear power plant engineering management. He is responsible for engineering safety review of the department's activities and for processing operations and engineering feedback to prev'ent known problems from occurring in the design of the Harris plant or in modifications to operating plants. He also assures that a departmental training program is developed and implemented to provide department personnel knowledge of the responsibilities of their duties.

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Smith, holds a bachelors degree in civil engineering, is a registered professional engineer, and has 32 years of construction experience.

All Nuclear Plant Construction Department construction activities at the Harris Plant are managed by the Site Manager Harris Plant, who holds a bachelors degree in civil engineering and has 14 years of experience in nuclear power plant construction management. The nuclear construction activities relating to the Brunswick and Robinson Plants are managed by the Manager Engineering 6 Construction, Brunswick and Robinson Plants, who holds a bachelors degree in civil engineering, is a registered professional engineer, and has 32 years of construction experience, including 13 years of nuclear construction management. Construction procurement and contracting activities relating to the Harris, Brunswick, and Robinson Plants are managed by the Manager Construction Procurement and Contracting, who holds a bachelors degree in science and has 30 years of construction experience, including 15 years of nuclear construction.

2.2.2.5 Quality Assurance and Quality Control As shown on Figure 1, the Manager Corporate Quality Assurance, who reports to Mr. Utley, manages all QA/QC functions within the Company except certain construction inspection activities that have been delegated to the Harris Site Management Section. In such cases the Corporate QA Department will conduct surveillance of those activities. The Manager of this Department, Mr. H. R.

Banks, has 33 years of experience, which includes 20 years of Navy experience and 13 years in various engineering management positions with CPSL. His experience includes 22 years in the nuclear power field. The Corporate Quality Assurance Department is organized into four separate functions, as shown below.

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Operations Quality Assurance/Quality Control Section This Section's Manager has fifteen years of engineering experience, nine of which are with CPSL. He has held a variety of engineering and management positions at the General Office including assignments in nuclear licensing, siting, system planning, and corporate communication. He has a bachelors degree in engineering, a masters degree in nuclear engineering, and is a registered professional engineer.

Engineering 6 Construction Quality Assurance/Quality Control Section This Section has the prime responsibility for the Harris Plant Quality Assurance/Quality Control in the engineering and construction phase and during start-up. The manager of this section has 28 years of QA experience, including 27 years in managerial positions.

Performance Evaluation Unit This unit is responsible for evaluating the Company's QA/QC performance. The Principal Specialist who supervises this unit has 24 years of QA experience.

Training and Procedures Unit This unit is headed by a Project Specialist who has 17 years of QA experience.

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2.2.2.6 Corporate Nuclear Safety The independent safety review function is accomplished by the Corporate Nuclear Safety and Research Department. The Vice President Corporate Nuclear Safety and Research Department, Dr. T. S. Elleman, holds a doctorate degree in physical chemistry and has 23 years of nuclear engineering experience, most recently as head of the nuclear engineering department at North Carolina State University.

As shown in Figure 7, the Corporate Nuclear Safety Section and the Corporate Health Physics Section report directly to the Vice President Corporate Nuclear Safety and Research Department. These sections conduct the independent nuclear safety reviews of the Company's nuclear activities.

The Manager Corporate Nuclear Safety holds a bachelors degree in engineering, a masters degree and a doctorate degree in nuclear engineering, is a registered professional engineer, has four years of experience in the U.S. Marine Corps, and nine years of experience in nuclear power plant engineering and safety review.

The Section is composed of a Corporate Nuclear Safety Unit (off-site) and an On-site Nuclear Safety Unit consisting of three subunits at each plant site.

The qualifications of these units are discussed below.

The Director On-site Nuclear Safety, holds a bachelors degree in mechanical engineering and a masters degree in management, has three years of engineering experience relative to naval nuclear propulsion plants, and nine years of experience with nuclear power plant operation and nuclear safety review. The two Principal Engineers reporting to him have a combined experience of 26 years.

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There will be an additional on-site Nuclear Safety Subunit staffed and assigned to the Harris Plant. This subunit will be activated as the preoperational test program nears. This subunit is to include one Principal Engineer and three Project Engineers.

2.2.2.7 Corporate Health Physics The Director Corporate Health Physics, is responsible to the Vice Chairman through the Executive Vice President - Power Supply and Engineering &

Construction, and the Vice President Corporate Nuclear Safety and Research.

He holds bachelors and masters degrees in nuclear engineering and has 16 years of experience in nuclear power, of which 13 years are utility nuclear experience.

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z~ Senior Management Oversi ht Functions At CP&L, the Vice President Corporate Nuclear Safety and Research Department provides Senior Management, up to and including the Chairman/President and the Board of Directors, a continuing assessment of current nuclear safety programs. Additionally, should any nuclear safety or quality assurance issue require immediate attention, the Vice President Corporate Nuclear Safety and Research has the authorized organizational freedom to contact anyone with the Company, up to and including the and the Chairman/President and the Board of Directors, in order to resolve such concern to his satisfaction. Figure 8 shows these administrative channels and direct communications channels. The Corporate policies for nuclear safety and quality assurance are set forth in Exhibits 1 and lA.

To ensure that communication occurs to resolve items of nuclear safety concern, the Vice Chairman has directed in writing (see Exhibit 2, memorandum from Mr. J. A. Jones to Messrs. E. E. Utley, M. A. McDuffie, and T. S.

Elleman) that those Managers and Directors of nuclear safety and quality assurance activities shall meet with the Vice President Corporate Nuclear Safety and Research no less than once each quarter (or as immediate attention dictates) to discuss safety and quality assurance issues. If the Vice President Corporate Nuclear Safety and Research is absent, or in the event he does not respond satisfactorily, each of the listed Managers and Directors are required to -communicate directly with the Vice Chairman or the Chairman/President.

Finally, the Chairman/President has directed the Vice President Corporate Nuclear Safety and Research in writing (see Exhibit.3, memorandum from Mr. Sherwood H. Smith, Jr., to Dr. T. S. Elleman) to initiate meetings with him no less than semiannually and immediately if the, situation dictates, to discuss nuclear safety and quality assurance matters. If the Vice President Corporate Nuclear Safety and Research is not satisfied with the Chairman/President's response, he is directed to meet with a member of the Board of Directors to express his concerns.

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This strong program which implements an effective Senior Management feedback system, independent of the normal administrative channels, ensures that those within the Company who administer nuclear safety and quality assurance programs maintain complete organizational freedom to act with written Corporate authority.

A similar Corporate Policy exists with respect to health physics and radiation protection (see Exhibit 4, memorandum from Mr. J. A. Jones to members of Senior Management), in which the goals and objectives of the radiation protection programs are established and mechanisms for Senior Management oversight are delineated. Additionally, documentation which implements this policy is included in Exhibit 4.

Additional Senior Management oversight is routinely effected by routine reports. Nuclear safety concerns and recommendations are tabulated on a bimonthly basis and their status documented in a formal report to Company Senior Management. Ma)or addressees are the Chairman/President, Vice Chairman, Executive Vice President Power Supply and Engineering 6 Construction, Senior Vice President Power Supply Group, and Vice President Nuclear Operations Department. A "management advisement" may be included in the report if a commitment does not appear to be sufficient to resolve a problem by the established target date. Items of interest regarding safety areas are also briefly summarized as a means of keeping senior management apprised of ongoing activities of importance.

Another mode of communication to Senior Management is in the form of a meeting between the Vice Chairman and the Manager Corporate Nuclear Safety (CNS).

When available, the Vice President Corporate Nuclear Safety and Research Department, attends these briefings. The discussions include trends that 2-92

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potentially affect nuclear safety and presentation of an overview of the Company's nuclear operations from the CNS vantage point. This avenue of communication is open at all times as necessary to resolve any item of safety concern that cannot be satisfactorily handled at a lower management level.

Senior Management also receives direct feedback on the results of quality assurance audits. An audit report describes the audit scope, participants, results, recommendations, and details of nonconformances. There are two types of findings that are included in the report: nonconformances and concerns. A nonconformance requires documented corrective action for resolution. A concern is a weakness which may present a potential problem and may not require documented action. The report is addressed to the Company President/Chairman, the Vice Chairman, the Executive Vice President Power Power Supply and Engineering & Construction, and the Senior Vice President Supply, with copies to the activity which was audited. Within 30 days after receipt of the report, the audited activity must formally indicate the corrective action and schedule for resolving each finding. The Manager reviews these responses for adequacy and contacts the responsible managers to resolve any problems.

In addition, monthly reports of the status of all quality assurance audits are sent to Senior Management. The key to the success of this audit program is its innate ability and freedom to identify deficiencies to Senior Management at the same time they are identified to middle management. This ensures independence from internal middle management pressures.

Senior Management responsible for nuclear plant operations are keenly interested in all aspects of plant operations and maintain an up-to-date awareness of any concerns that may affect nuclear safety. On a daily basis, the Executive Vice President Power Supply and Engineering & Construction 2-93

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receives written reports of the status of operating units, load reductions, and reasons for those reductions. Through direct discussions and staff meetings, the Vice President Nuclear Operations also keeps the Senior Vice President Power Supply advised of any significant concerns affecti'ng the nuclear plants..

Power On a periodic basis, the Vice Chairman, the Executive Vice President Supply and Engineering 6 Construction Groups, the Senior Vice President Power Supply, and the Vice President - Nuclear Operations, meet at the operating nuclear plants to review matters related to nuclear plant operations with Plant Management personnel.

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14 Off-Site Technical Staff Resources Figure 4 shows the off-site technical staff functions provided by the groups and departments which report to the Vice Chairman. This technical staff has already displayed the capability to accomplish complex nuclear operations which require close coordination between design, construction, and operating forces. Examples of these types of activities include: (1) startup'nd operation of Brunswick Unit 2 while Brunswick Unit 1 was still under construction, with accompanying security separation of common control rooms; and (2) completing the design and installation of all equipment modifications and administrative changes resulting from Three Mile Island short-term lessons learned at all three operating nuclear units by the required deadline, one of the few utilities to accomplish this task. This experience, as well as the simultaneous planning for startup and operation of the Harris Unit 1, demonstrates the Company's capability to support all nuclear activities with the proper technical staff resources.

2.4.1 Power Supply Group Technical Staff Resources As shown on Figure 4, the Power Supply Group provides off-site technical staff resources for an extensive number of support functions.

The support staff available from the Power Supply Group through the Nuclear Operations, Fossil Operations, and Technical Services Departments is a highly qualified group of individuals of diverse backgrounds. The Nuclear Operations Department is presently staffed with 215 professionals with a total of 2970

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years of experience. The Technical Services Department is presently staffed with 76 professionals with a total of 1209 years of experience. There are over fifty individuals who have technical expertise dealing directly with the special concerns of nuclear power plants and of these, fifteen including the Nuclear Operations Department Vice President, have held permanent technical, and supervisory positions at one or both of CPGL's operating nuclear power plants. The remainder have a variety of industry or nuclear Navy experience 2-95

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and many have spent extensive periods of time on-site at nuclear power plants assisting in various special tasks such as refueling outages. This experience base provides the entire group with an excellent background in actual plant conditions and needs. The background of this group provides one or more individuals who can provide technical support in each of the following areas:

Nuclear, mechanical, structural, electrical, thermal hydraulic, and fluid systems each of the individuals with plant experience has a basic practical knowledge of these areas and, in addition there are several individuals with design experience, particularly in the nuclear and mechanical areas.

Metallurgical and materials Support within the Technical Services Department is in the area of inspection techniques and requirements and practical plant experience with materials problems.

Instrumentation and Controls Engineering The experience in this area is also of the practical hands-on variety consisting of years of use and maintenance of the actual equipment in use at our plants.

Plant Chemistry There is excellent coverage by personnel who routinely work closely with the plants in this area.

Health Physics This area too, is covered by highly qualified individuals who interact daily with the plant personnel, including a health physicist who is certified by the American Board of Health Physicists. (CPGL has a total of three health physicists certified by the American Board of Health Physicists, one of whom is Manager of Environmental and Radiation Control at Brunswick).

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Fuel and Refueling Support This area is covered by personnel with previous nuclear fuels or operating experience at the plants.

Maintenance Support This area is covered by a number of experienced people including a former plant Maintenance Supervisor.

Technical or Engineering Management There are two individuals available with more than ten years of nuclear power experience and several years of engineering management and project coordination experience as well.

Operational Management Several managers have held supervisory positions in plant operations who can provide support and guidance in this area.

While there are more than enough qualified off-site personnel in the Technical Services and Nuclear Operations Departments to deal with only one area, most of the personnel within these two Departments have ample qualifications to provide support in several of the areas discussed above. The extent of this "cross-qualification" provides a flexibility and depth of support which exceed the number of people involved.

The Technical Services Department also provides technical staff resources to support the Harris Plant Project operations in various other specialized areas, such as obtaining state and federal licenses and permits, emergency preparedness planning support, conducting environmental monitoring programs, purchasing properties required for plant operations, and providing laboratory services to analyze metallurgical and chemical samples. This support is provided by.two sections and one unit which directly support nuclear operations: Licensing and Permits Section, Environmental Technology Section, and the Emergency Preparedness Unit.

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The Licensing and Permits Section has responsibility for securing all required permits and licenses in accordance with established construction and operation schedules, including necessary interfacing with regulatory commissions and agencies and related development of information and necessary strategic planning; and providing special technical expertise in the areas of seismology and meteorology. The Earth Science and Meteorology units establish and operate the Harris seismic monitoring program and the Harris, Brunswick, and Robinson meteorological data collection programs. The Nuclear Licensing Unit is responsible for the preparation, publication, and modification of the Preliminary and Final Safety Analysis Reports and Environmental Reports for the Nuclear Regulatory Commission in support of construction permits licensing. It is responsible for the maintenance of operating and'perating licenses and revisions to the Technical Specifications. It serves as prime contact with the NRC Office of Nuclear Reactor Regulation on licensing matters, advisesi management on critical licensing issues, and ensures that all incoming NRC correspondence is routed properly and responses are prepared to accurately address licensing issues. The Regulatory Compliance Unit is responsible for assuring operating plant compliance with all NRC requirements and commitments, and serves as the prime contact with the NRC Office of Inspection and Enforcement.

The Environmental Technology Section is responsible for the formulation and implementation of biological and scientific programs necessary to identify and quantify actual and potential environmental impacts associated with the construction and operation of fossil, hydro, and nuclear power plants. This section also provides analytical chemistry and metallurgical laboratory services at the Harris Energy & Environmental Center for all Company activities, especially as needed to support nuclear plant construction and operation. This includes the capability to analyze radioactive metallurgical samples.

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In addition to the internal resources discussed above, the Departments also have available other company support and outside assistance from vendor's, AE's or other consultants on a contractural basis. These contracts, which" are discussed in Section 2.7, are maintained in effect and permit rapid mobilization of very substantial technical resources, if needed.

The Emergency Preparedness Unit is responsible for directing and coordinating Corporate Emergency Planning to ensure regulatory compliance; assessing the readiness of all CP&L emergency plans and programs; serving as interface with regulatory agencies on emergency preparedness matters; providing emergency preparedness support for CP&L nuclear plants; maintaining training qualifications of plant personnel in emergency response; testing emergency preparedness; ensuring the availability and operational readiness of emergency facilities equipment and supplies; and for providing coordination with Federal, State, and local agencies.

2.4.2 Fuel Department Technical Staff Resources The Nuclear Fuel Section of the Fuel Department provides operations support to CP&L nuclear units by giving technical assistance in four key areas:

refueling support, startup support, analytical support, and fuel performance monitoring. This Department is presently staffed with 25 professionals with a total of 224 years of experience.

2.4.3 En ineerin & Construction Group Technical Staff Resources The Engineering & Construction Group supports nuclear operations in the areas listed on Figure 4.

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Engineerin Resources Engineering support of the Harris Project is provided by the Nuclear Plant Engineering Department which is organized into two sections: the Harris Plant Engineering Section and the Engineering Support, Nuclear Plants Section. This Department is presently staffed with 48 .professionals with a total of 640 years of experience.

The Harris Plant Engineering Section is responsible for providing the design and engineering for the Shearon Harris Nuclear Power Plant, including engineering support of site activities.

The Section is organized into three primary units: Mechanical, Electrical, and Civil. Each of these units is headed by a Principal Engineer.

The Engineering Support, Nuclear Plants Section is responsible for providing engineering support for CPGL's operating nuclear plants.

The Section is organized into three units: the Brunswick Engineering Support Unit, the Mechani'cal Unit, and the Electrical Unit. The Brunswick Unit is headed by a Resident Engineer and the other two units by Principal Engineers.

In addition, the Section has the capability and is experienced in adding contract engineers and designers to supplement its forces. These contract personnel work under Department supervision and to CPSL procedures.

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Construction Support Resources The Nuclear Plant Construction Department has the responsibility for construction of all nuclear generating facilities and associated systems required for the production of nuclear power by CP&L and for providing assistance as requested on operating plant modifications. There are three sections in the Department: the Harris Site Management Section, the Brunswick and Robinson Site Management Section, and the Construction Procurement and Contracting Section. This Department is presently staffed with 105 professionals with a total of 1236 years of experience.

The Site Manager Harris Plant has 14 years of experience in nuclear power plant construction management.

The Manager Engineering and Construction, Brunswick and Robinson plants, has 32 years of experience in construction, including 13 years of nuclear construction management. Site staffs have been established both at Brunswick and Robinson Plants to perform construction work assigned to the Nuclear Plant Construction Department. These staffs are termed the Brunswick and Robinson Site Management Units.

The Manager Construction Procurement and Contracting has 30 years of construction experience including 15 years of nuclear construction.

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, 2.4.4 Corporate Quality Assurance Department Resources Figure 5 shows the organization of the Corporate Quality Assurance Department.

This department provides on-site and off-site QA/QC support for operating plants and for Harris during construction. This Department is presently staffed with 54 professionals with a total of 1146 years of experience.

The Engineering and Construction Quality Assurance/Quality Contxol Section has the prime responsibility for the Harris Plant Quality Assurance/Quality Control in the engineering and construction phase and during start-up. Its purpose is to anticipate and preclude safety-related nonconformances.

A major advantage of the present Harris organization is that CP6L retains direct control over the QA/QC organization. Consequently, CP&L is intimately involved in all QA/QC-related activities and has assumed direct management responsibility for obtaining satisfactory results rather than delegating a major portion of this responsibility to the constructor. Along these lines, one of the lessons learned at Brunswick is that direct control of the quality assurance of the Harris Plant dictated that CPGL obtain the ASME "N" stamps in the Company's name rather than allowing the constructor to obtain the "N" stamps as was the practice previously. "N" stamps are required by North Carolina law to be applied to those components and systems of a nuclear power plant designated in 10CFR Part 50 as having to meet Section III of the ASME Boiler and Pressure Vessel Code. The preparation of the ASME "N" Stamp QA Manual was handled totally 'in-house'y CPGL personnel, and the manual was accepted and approved at its first ASME review.

The Operations Quality Assurance/Quality Control Section, under the direction of its Manager, has the responsibility for assuring proper application of quality standards, practices, and procedures associated with plant operation, maintenance, or modification.

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The Performance Evaluation Unit is responsible for conducting an independent corporate, audit program. Personnel in this unit are trained to prepare for audits, conduct and report audits, and follow-up, as necessary, to assure timely correction of conditions, practices, and items that could degrade plant quality.

The Training and Procedures Unit is responsible for implementation of a training program designed to qualify QA/QC personnel for maximum interchangeability among various QA/QC activities. In concert with

/ appropriate departments, it will also develop, modify, and determine control of standard procedures to be utilized at construction and operating sites.

The unit is responsible for preparation and maintenance of the Corporate QA Manual, the ASME "N" Stamp QA Manual, and QA/QC procedures for corporate and/or field use.

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2.5 Coordination of Interdepartmental Technical Staff Support Coordination of technical staff support for nuclear operations is the ultimate responsibility of the Vice President Nuclear Operations Department. Written memoranda define each department's functional responsibilities for support activities; however, ultimate responsibility for safe nuclear operations is assigned to the Vice President Nuclear Operations.

During routine operations, when the Nuclear Operations Department requires technical assistance, the appropriate manager initiates a written Task Assistance Request (TAR) to the department within the Company which is assigned responsibility for those activities. Typically, the Nuclear Plant Engineering Department is requested by the Nuclear Operations Department to provide engineering assistance to resolve a plant design problem by initiation of a TAR. The Nuclear Plant Engineering Department performs the necessary engineering and recommends a solution to the Nuclear Operations Department.

These modifications are designed to comply with the Corporate QA Program, the plant Technical Specifications, and to other appropriate design codes. The Nuclear Plant Construction Department may be requested by the Nuclear Operations Department to perform the installation, or the modification may be installed by the Nuclear Operations Department. All modifications to the operating plant are approved by the appropriate management in the Nuclear Operations Department prior to installation. Similar definitions of interdepartmental responsibilities exist between the Fuel Department, Technical Services Department, and Nuclear Operations Department to ensure that nuclear refuelings and spent fuel movements are coordinated properly, nuclear licensing interface with NRC is coordinated with the plants, and that meteorological, seismological, and environmental monitoring programs are carried out as required by each Plant Operating License.

Should situations arise at nuclear plants requiring immediate technical staff support, the Vice President - Nuclear Operations Department requests immediate assistance from appropriate department heads throughout the Company or from outside contractors and vendors, if necessary.

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2.6 OFF-SITE STAFF TRAINING Training for the off-site technical support personnel is primarily supplied in the course of routine operations. Written procedures for handling incoming NRC correspondence ensures that appproprite off-site support staff are aware of current NRC directives and issues. Plant events and modifications would routinely be discussed with appropriate off-site personnel by the plant staff, and this interaction is an excellent mechanism to keep the off-site personnel informed. Many of the off-site personnel who deal with the nuclear power plants have spent time at the plant sites and have therefore received plant-specific health physics and security indoctrinations. As new personnel goin the off-site support groups, they will also receive this training as their job assignments require it. Expertise in specific areas is maintained by continual on-the-)ob training as routine gob assignments are carried out.

Off-site support staff are active participants in many industry groups which deal with generic interests and problems of power plants such as the Edison Electric Institute, the Southeastern Electric Exchange, and the Atomic Industrial Forum. In addition, this staff routinely participates in utility owners groups in order to respond to hardware or 'regulatory concerns such as BWR Pipe Cracking or the PWR Steam Generator issues. New information is passed onto the others within the Company who could benefit by briefings by those who first come into contact with the new information.

The Nuclear Training Section provides a formal professional orientation program for all newly assigned operations departments'rofessional staff.

Depending on the new employee's experience, this program may'onsist of up to five phases. In addition, supervisor/management courses are presented by the Employee Relations Department in the area of Human Resources Development, and Organizational Development Speciality Training Courses are routinely identified for employee upgrading and specialization.

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4Rk 2.7 CONTRACT ASSISTANCE The Technical Services Department maintains a large number of active contracts for labor and services in order to ensure availability of qualified personnel when they are needed by the nuclear plants to augment the Company's resources.

These contracts provide the capability to obtain additional maintenance personnel, such as mechanics, electricians, I&C Technicians, and technical specialists, such as RC&T Technicians, on an expedited basis. CP&L also has contracts with engineering and consulting firms for the purpose of having immediate access to specialized technical expertise when it becomes necessary to supplement CP&L technical capabilities. For example, contracts are in effect with the NSSS vendors, Westinghouse and General Electric, as well as architect engineers, such as Ebasco and United Engineers. In general, contracts are written so that the General Managers of the nuclear plants are authorized to obtain and assign the services and resources provided by these contracts as he deems appropriate. This mechanism ensures that contractual assistance for nearly every conceivable task is available and ready when needed.

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EMERGENCY RESPONSE CAPABILITIES Carolina Power & Light Company has developed and implemented a Corporate Emergency Plan which, in conjunction with the Harris Plant Emergency Plan, will apply to on-site and off-site activities for the Harris Plant. The Plan will provide for the necessary management and technical resources to support the on-site staff in the event of an emergency at the plant.

3.1 ONSITE RESOURCES AND ACTIVITIES 3.1.1 Action Levels The Corporate Emergency Plan establishes four classes of Emergency Action Levels:

Unusual Event Alert Site Emergency General Emergency The responsibility for determining the status of the nuclear plant in regard to emergency action levels shall be assigned to the Operating Supervisor who shall have the authority and responsibility to immediately and unilaterally initiate any emergency actions. A clear line of succession to the Operating Supervisor is established in the Plant Emergency Plan.

Upon declaration of an emergency action level of an "Unusual Event," the Operating Supervisor shall cause the onsite personnel to be notified and shall begin notification of offsite resources as deemed necessary to assist in the response effort. Upon declaration of the "alert" action level, an accident is presumed to have occurred or to be in progress, and the response actions as detailed in the Emergency Plan shall be initiated.

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A "Site Emergency" is declared when events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. A "General Emergency" will be declared when events are in process or have occurred- which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity.

3.1.2 On-site Resources The Plant Emergency Plan will provide for an on-site post-accident organization to cope with an accident situation. This post-accident organization will utilize the existing on-site organizational structure to the greatest extent practical to take advantage of established lines of communication and responsibility. The organization provides for management personnel to be assigned responsibility for specific functions. The on-site accident organization, headed by the General Manager (Technical Support Center Supervisor), will be responsible for all site operations necessary to establish safe plant conditions. The Manager Technical Support, Director Planning 6 Scheduling, and Principal Engineer Operations will report to the General Manager at the Technical Support Center.

The on-site organization will include the following resources in the areas indicated:

1. Control Room Resources

a. Short Term During this period, it is assumed that only the minimum required shift personnel will be available. The Operating Supervisor will be in charge. The shift licensed operating staff shall consist of the personnel identified earlier in Section 2.1.1.1 (Operating Supervisor, Shift Foreman, Reactor Operators).

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b. Near Term Sufficient personnel will be available in the Operational Support Center during the initial hours following the determinati'on that an accident condition exists to ensure that on-shift personnel can all be relieved by properly qualified individuals.

c. Long Term Sufficient personnel will be available to ensure that the shift staffing can be maintained without exceeding applicable criteria on limitations of working hours for an extended period of time (at least one week).

2. Technical Support Center (TSC)

The on-site Technical Support Center (TSC) will be'nder the supervision of the General Manager or his designated alternate to control all site operations necessary to establish safe plant conditions. The TSC will be designed and function in accordance with appropriately approved NRC requirements as set forth in applicable versions of NUREG-0696 or successor documents. Personnel to staff the Technical Support Center may be from the plant staff, the off-site organization and/or through contract arrangements with other organizations. These personnel or their equivalent replacements will be available continuously for the duration of the accident condition.

a. Short Term No requirements.

b. Near Term Sufficient personnel to ensure that the Technical Support Center (TSC) can be fully manned within a short time following the determination that an accident condition exists.

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c. ~ion Term There will be sufficient personnel available to ensure that the Technical Support Center can be staffed on a 24-hour a day basis for an extended period.

3. Operational Support Center (OSC)

An on-site Operational Support Center (OSC) will be established. It will be separate from the control room and the Technical Support Center and is the place to which the operations support personnel will report in an emergency situation. Communications with the control room and the Technical Support Center will be provided.

3.1.3 Procedures Emergency and accident procedures will include:

a. A clearly established chain of command which identifies the individuals and their alternates, their responsibilities and authority, and lines of communication during all phases of the accident and recovery operations.

b. Detailed instructions for contacting the plant personnel necessary to meet the Emergency Plan and for contacting the applicable off-site personnel to implement off-site response plans.

C~ Control room access shall be limited to on-shift operators and personnel requested by the Emergency Coordinator. Access to the control room shall be designated by the Manager Plant Operations.

d. Clearly specified lines of authority and special training that may be required.

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~ ~ Training Training in the implementation of the emergency procedures is required for all on-site personnel in their initial and requalifiction training. Additionally, drills or exercises are held to ensure that all the personnel required during the initial hours of the accident can be available at the site within the required times.

3.1.5 Recovery Manager As provided in the Corporate Emergency Plan, the Vice President Nuclear Operations will act as the accident Recovery Manager. He will assemble the recovery organization and will coordinate and direct Corporate support for the plant. He will expedite procurement and deployment of any off-site support needed by the plant, and will serve as an interface between outside agencies and the plant operations staff.

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~ L l//4 OFF-SITE RESOURCES AND ACTIVITIES 3.2.1 Emer ency Operations Facilities The Corporate Emergency Plan requires the establishment of several centers in the vicinity of the plant for the continued evaluation and coordination of all activities related to an emergency having or potentially having environmental consequences. As an interim measure, CP&L has established a Recovery Center which has been set up on the plant site to house off-site Corporate, A-E, NSSS vendor personnel, and personnel who will provide emergency recovery support and long-term recovery support under the direction of the Recovery Manager.

The Emergency Operations Facility (EOF) will be established off-site and will provide working space, equipment and communications links for the functions currently performed in the on-site recovery center. Space will also be provided for the Plant Media Center (PMC) personnel in the EOF. The Plant Media Center portion of the EOF will be operated under the direction of the Site Public Information Coordinator. Center personnel will assist the various media representatives in obtaining accurate information regarding the emergency. The Corporate spokesman will work out of the Plant Media Center and participate in planned news conferences with representatives of the NRC and state and local governments. The Local Emergency Operations Center (LEOC) will house the necessary facilities for local, state, and federal agencies responsible for directing all off-site activities required for protection of the public health and safety. A company representative will be assigned to the center to provide liaison between Company management on-site and the outside agencies operating from the LEOC. The Plant Media Center will be established near the site to provide facilities for Company public information personnel designated in the Corporate Emergency Plan. The utilization of the EOF/PMC and LEOC with appropriate communications will meet the functional requirements for coordination of the various activities.

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3.~ 2.~ 2 Organization The recovery organization consists of the Recovery Manager, six managers of support functions responsible to the Recovery Manager, and supporting personnel as shown in Figure 11. This organization may be modified during an emergency to better respond to the conditions of that emergency. Upon activation of the Corporate Emergency Plan, the recovery organization will be established at the affected plant to provide for recovery of the facility.

After the emergency phase of the incident has passed, the recovery organization will develop and carry out plans for recovery of the facility.

3.2.3 Mana ement Resources Recovery Manager The Recovery Manager directs and controls the recovery organization to assist and support the plant during the emergency. He will activate the Corporate Emergency Plan and assist in ending the emergency.

Concurrently, the recovery organization will begin efforts to determine the cause of the incident, develop a recovery plan, and procure any company and outside services and equipment necessary to complete needed repairs.

Plant General Mana er The Plant General Manager will direct the activities of plant personnel from the on-site technical support center, including support required for the Operations personnel in the plant control room.

Through the Nuclear Safety Review Committee, he will approve and implement license change requests, engineering modifications, special procedures, experiments, and tests required to respond to the incident. He will coordinate on-site maintenance, emergency training, and health physics activities including on-site sampling programs.

Technical Analysis Manager The Technical Analysis Manager is responsible for analysis and the development of plans and procedures with the ob)ective of taking the plant to a safe shutdown condition. He will coordinate the receipt and assessment of technical information on-site and off-site related to plant systems and facility operations, and submit timely recommendations to the Recovery Manager for implementation.

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Engineering Manager The Engineering Manager is responsible for directing and administratively controlling the engineering staff while providing engineering and design support to meet requirements of the recovery operation.

Construction Mana er The Construction Manager coordinates the construction activities to meet the requirements of the recovery operation. He will develop a construction plan, including the allocation of construction personnel, to support completion of plant modifications required during the recovery process.

Administrative and Logistics Manager The Administrative and Logistics Manager provides administrative, logistics, communications, and personnel support for the recovery operation. He will provide assistance to the Recovery Manager in the short-term planning, scheduling, and expediting of recovery operations.

Radiological Control and Waste Mana er The Radiological Control and Waste Manager is responsible for providing radiation protection and waste disposal plans consistent with the recovery operation. He will assist the Recovery Manager by providing ALARA review of engineering modifications and tasks proposed by the recovery organization.

Corporate Spokesman The Corporate Spokesman for the Company will have primary responsibility for all public statements to the media at the site concerning the effect of the emergency on the Company, the specific details of the emergency, and steps the Company is taking to mitigate it.

3.2.4 Off-Site Recovery Staff Resources The Corporate Emergency Plan specifies the off-site recovery staff resources which will be available in the event of an emergency. The resources are organized into the following areas:

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Technical Analysis Engineering Construction Administrative and Logistics Radiological Control and Waste Site Public Information The implementation of the Corporate Emergency Plan will include the assignment of personnel to these organizations to provide the technical, administrative, radiological, and public information support required in an emergency. The details of these support functions are documented in procedures developed to fully implement the Corporate Emergency Plan.

3.2.5 Off-Site Contractual Assistance CPSL's ability to maintain contractual arrangements has been demonstrated and these arrangements are capable of accommodating the requirements under emergency conditions. The Corporate Emergency Plan explicitly addresses arrangements to be made to ensure that required personnel and logistics necessary to support the off-site recovery staff will be available when needed. 'The implementing procedures will specify the necessary contractual arrangements that have been made to assure required personnel and logistics necessary to support the off-site recovery staff.

3.2.6 Training and Re uglification Procedures have been developed which specify the training requirements for the off-site recovery staff members.

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~ ~ Procedures Procedures have been prepared which will fully implement the Corporate Emergency Plan. The procedures will specify activities required for activation of the recovery team, operation of the team, and for utilization of physical resources of the Company during the emergency.

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E 4.0 HARRIS UNIT 1 STARTUP 4.1 STARTUP ORGANIZATION The Harris Startup Organization, which will be responsible for the startup of all four Harris units, consists of thirty-three people, including a Startup Superintendent and four Startup Supervisors, each of whom supervise the efforts of five senior engineers and two engineering technicians. The responsibilities and authorities of each are as follows:

Startup Superintendent

1. Supervise the activities of the Startup Organization through the Startup Supervisors.

2. Prepare and update the startup schedule.

3. Assign overall test responsibility to the Startup Supervisors.

4. Review and approve requests for vendor assistance as recommended by the Startup Organization.

5. Review and approve/recommend approval of test procedures, test procedure modifications, and test data in accordance with the Startup Manual instructions.

6. Review and recommend approval of startup requests for construction and engineering modifications or changes required during the test program.

7. Issue periodic progress reports and work schedules for the Startup Organization.

8. Issue special reports concerning startup activities as deemed necessary.

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9. Review progress of startup activities with contractors, vendors, and company management.

10. Maintain liaison with the plant management, keeping them informed of the test program status, and coordinate with them the activities of plant personnel assigned to startup activities in conjunction with their training program.

ll. Represent the Startup Organization on interdepartmental and interorganizational committees associated with the test program.

12. Maintain liaison with contractors and vendors to coordinate their activities relating to the test program.

13. Responsible for the preparation and maintenance of the Startup Manual.

14. Accept Release For Tests from CPSL Construction.

Startup Supervisor

1. Assign a cognizant Startup Engineer for each test identified to be required on assigned systems, and periodically review test assignments to maintain an even distribution of work load.

2. Supervise the activities of and provide guidance to the Startup Engineers reporting to him and assure that their, operations are conducted in accordance with SHNPP Startup Manual instructions.

3. Supervise the preparation of test procedures as assigned to the individual Engineer.

4. Provide technical guidance and assistance in the preparation of test procedures.

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5. Recommend plant scheduling changes as necessary to support the testing effort.

6. Review and recommend approval of test procedures, test procedure modifications, and test data in accordance with the Startup Manual procedures.

7. Recommend approval of and schedule vendor representative assistance.

8. Recommend changes in plant design and/or construction to facilitate testing, operation, and maintenance.

9. Review periodic progress reports and work schedules.

10. Assist in the preparation of special reports concerning startup activities when required.

Startup En ineer

1. Conduct all work assignments in accordance with the Startup Manual and other Startup procedures/instructions.

2. Prepare and recommend for approval assigned test procedures.

3. Conduct all assigned tests and prepare test reports.

4. Review engineering drawings and documents and prepare requests for construction and engineering changes to facilitate both operation and maintenance.

5. Recommend approval of system Release For Tests.

6. Define system and subsystem Release For Test boundaries.

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7. Conduct an inspection of assigned systems prior to system Release For Test acceptance and recommend the acceptance of systems from construction for testing.

8. Coordinate and supervise activities of personnel assigned to support the test program.

Ebasco Services, Inc Ebasco Services is the architect/engineer for the SHNPP. As the design organization, Ebasco will provide the design bases to be used in the evaluation of appropriate safety related and balance-of-plant (BOP) preoperational test procedures and results. Ebasco will be consulted, as necessary, during the procedure development and evaluation of test results to ensure that the test program verifies plant design parameters.

Westin house Electric Corporation Westinghouse provides on-site technical assistance to CP&L during the installation, startup, testing, and initial operation of each nuclear steam supply system (NSSS). Westinghouse on-site personnel review and comment on NSSS preoperational test procedures to assure that test acceptance criteria and test objectives are appropriate and consistent with safe operation.

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Harris Pre-Startup Preparations As a result of the experience gained at Robinson and Brunswick, CP&L is aware of the value of early pre-startup planning for Harris Unit 1. Several management actions have been taken with the objective of effecting a smooth, orderly transition from construction through startup to operation:

1. The construction schedule reflects a consideration of plant startup requirements. A Release for Test (RFT) schedule has been developed jointly by Startup, Engineering, and Construction which defines the sequence and timing of each RFT turnover to the Startup organization to support an orderly testing process. The various buildings and piping systems have been scheduled in a manner that will allow early startup involvement. This will allow leveling the startup manpower requirements and will permit the startup and testing of the entire system to begin as early as practicable. As equipment and systems are completed, they are transferred to the CP&L Startup Organization, which implements the testing program. This jurisdictional transfer consists of a series of formal system/component and facility/structure Releases For Test until eventually all plant system/components and facility/structures have been formally released to the Startup Organization. This transfer (Release For Test RFT) only represents a transfer of jurisdiction and not a transfer of work responsibility that is normally performed by Nuclear Plant Construction Department (NPCD) (i.e., identified on plant design documents and punch lists). All work performed by NPCD after release to Startup will be performed in accordance with the Startup Manual.

A similar logic prevails with respect to the electrical portions of the plant. The construction schedule places emphasis on early completion of those portions of the common building which contain the control room and the cable spread rooms. The intent is to construct these facilities as soon as possible in order to allow

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installation of the relay racks and control boards in the cable spread room and the control room. Again, releasing startup and test work as early as possible will provide the maximum amount of time for an orderly transition to the operating phase.

2. Construction management action is being taken in a second area of scheduling in order to contribute to a smooth running RFT Program and startup of the plant. Facilities will be provided at the Harris site to permit the Startup Organization to move to the site and provide opportunity for the Startup Engineers to become involved in the day-to-day construction of the various systems for which they are responsible. This assignment of plant operating personnel will facilitate their becoming familiar with the plant and its systems while they write pre-operational and testing procedures and observe the construction in progress. The familiarity thus gained will simplify problems during turnover for startup.

3. Definition of the boundaries of the RFT packages started in 1979 so that construction could maintain a continuing cognizance of the boundaries of the startup systems and the sequence in which the systems would be required to be completed and turned over to plant operations. These boundaries allow construction to plan work on the C

systems needed first, and permits quality assurance personnel to collect, check, and package documentation in volumes that are grouped in anticipation of future RFTs.

4. The organization at the Harris site has been structured such that there are fewer organizations involved in the RFT as compared to our other nuclear plants. Therefore, the process of construction completion, construction checkout, QA checkout, and Release For Test to Startup flows through fewer organizations resulting in a better understanding and closer contact with the systems being completed.

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As individual systems or portions of systems are completed, the Site Engineering & Construction Quality Assurance/Quality Control Unit performs final system inspections. Any nonconforming or incomplete work is identified and documented for resolution. Subsequent inspections are performed to ensure proper resolution of nonconformances and incomplete work. Any outstanding work (i.e.,

incomplete work, nonconformances, etc.) is identified in the RFT package as exceptions. The RFT package is then forwarded to the Startup Group for acceptance. The Site Quality Assurance/Quality Control Unit will continue to provide Quality Assurance coverage for any further work (e.g., resolution of exceptions) performed by the Nuclear Plant Construction Department subsequent to RFT.

As an aid in developing complete turnover packages, a Material Tracking System has been initiated for pipe spool, hanger, and electrical cable installation. The purpose of this system is to track the completion status of these bulk items from the delivery phase through to installation and Release For Test to the Startup Group in a consistent and efficient manner. The objective of this system is to establish a common data base from which material status will be extracted by all functional groups, thus reducing the creation of duplicate files with their potential for inconsistent information.

Construction Control System The concept of this module of the Material Tracking System consists of a computerized system with common data base from which engineering, construction, quality assurance, and operations (startup) can extract pertinent data relative to the status of material during the erection, inspection, testing, and RFT phases of the project. One major component of the Construction Control System will be a RFT Tracking System which will indicate the status of systems for startup and testing. It is anticipated that most of the major components of the Construction Control System will be implemented during 1981. In the meantime, a 4-7

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number of the components of the Construction Control System have been, and are continuing to be, developed and implemented. Some of these components include:

1) Mechanical Status Reporting System This component of the Construction Control System was implemented in 1979. The system tracks the status of piping spools, hangers, restraints, and valves. It is currently a computerized system which relies on batch input and printout reports for the status of mechanical items.

2) Electrical Status Reporting System This component of the Construction Control System was approved and will be implemented in early 1981 as a computerized system which relies on batch input and printout reports. This system tracks the status of cables, cable trays, conduit, and terminations. It is also designed to interface with the A/E computerized Cable Routing System which produces raceway, cable pull, and cable termination cards.

3) Welder Qualification System - This system, a manually operated system for monitoring welder qualification, has been in operation since the Construction Permit was received, and was computerized in 1980. It tracks the qualification status and performance of each welder on the SHNPP project, and alerts project management when qualifications on each welding procedure is subject to expire.

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The Shearon Harris Nuclear Power Plant Startup Manual addresses the plant startup program. Startup includes the period from completion of construction (on a system or equipment basis) through the completion of the Power Test Program. There are two major periods of activity and two major areas of responsibility as follows:

Construction Phase/CP&L Nuclear Plant Construction Department Area of Jurisdiction: A period that begins with receipt of equipment on site and ends with system/component releases to CP&L Startup Group (SG).

Initial Test Phase/CP&L Startup Group Jurisdiction: A period that commences with system/component release to the SG and terminates with the completion of the Power Test Program.

The Startup Manual, Section 5, Construction Completion Activities, is used by the NPCD as a guide in performing necessary checks 'prior to releasing the equipment to CP&L Startup.

The Startup Manual, Section 6, Construction/Startup Interface, describes in detail the interface procedures and controls used from initiation of RFT (Release For Test) from the Nuclear Plant Construction Department until a system is placed on the Operational Systems List after completion of testing.

It should be understood that this transfer (Release For Test) only represents a transfer of jurisdiction and not a transfer of work responsibility that is normally performed by the Nuclear Plant Construction Department. The significant point is that although work will be processed through and controlled by the cognizant Startup Engineer or Supervisor after release to Startup, the RFT exception work and any required modifications will be performed by construction forces already on the site. This approach along with several significant factors related to craft labor will allow the construction startup group to be adequately staffed. The significant craft labor factors which will exist during the startup period are:

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1. The peak requirement for mechanical and electrical crafts for Unit 1 will have passed. Since work will be winding down and the number of craftsmen reduced, the constructor will be in a position to retain those with higher skill levels.

2. There will be a sizeable pool of workers from which to draw.

3. The craftsmen devoted to the effort will be those who made the initial installation. This familiarity of installation and site specific procedures, requirements, etc., will expedite the work.

4. The multi-unit site offers additional advantages:

(a) the pool of experienced manpower working on Unit 2 could be shifted to Unit 1 if unforeseen circumstances arise; (b) since Units 2, 3, and 4 offer continuous employment, the tendency for craftsmen to begin looking elsewhere as Unit 1 winds down will not be as great.

The startup of SHNPP Unit 1 will be the fourth nuclear unit on which CP&L professional and technical personnel have participated. As we progress

, through construction, the expertise level of existing employees will rise and the addition of new employees will add to that experience level.

Another advantage of the multi-unit plant is that the learning curve from Unit 1 to Unit 2 results in less demand on senior site personnel's time, allowing them to devote more of their time to startup support.

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Construction Plant Security During Unit 1 Operations Based on our experience during construction of Brunswick Unit 1 while Brunswick Unit 2 was operating, the SHNPP security plan has been formulated and is continuing to be reviewed and updated as necessary. Details of the plan are considered to be proprietary information as defined in paragraph 2.790 of 10CFR2, and are considered to be sensitive data which would be detrimental to plant security effectiveness if divulged publicly. For these reasons, the following information pertaining to construction support of plant security does not address specific details of the plant security plan. When nuclear fuel is received for the SHNPP Unit No. 1, a plant security system will have already been implemented to provide necessary security. This plan will be administered by the Nuclear Operations Department and will affect the Nuclear Plant Construction Department's activities directed toward completing final construction requirements and plant startup. The operating plant security plan will have a phased implementation process which covers the it initial security for startup with increasing requirements until meets the security needs for operating Unit No. 1.

While construction forces are completing the work required to start up Unit No. 1, and at the same time continuing work on Unit Nos. 2, 3, and 4, a construction security force will continue to be maintained on the plant site.

This construction security force will continue to control the entrance and exit of construction personnel, equipment, and materials to and from the plant site. Prior to receipt of the operating license for Unit 1, the operational plant security organization will be established in accordance with the provisions of the operating license, and will have the following general responsibilities: controlling all access to the Unit No. 1 areas, monitoring alarm and surveillance systems, and maintaining liaison with local law enforcement agencies. Construction forces will cooperate with plant security forces as necessary to provide security orientations, briefings, and training to craft, craft supervision, and construction management personnel.

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During the time when both construction security and plant security forces are on site, each force will have very specific security duties with necessary coordination achieved between them.

Construction forces will comply with applicable "Security Instructions" and "Security Procedures" which are adopted for the operating plant. Construction forces will also provide any necessary support for the "Safeguards Contingency Plans" which will be established to provide for specific actions in response to various contingency situations.

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ADDITIONAL INFORMATION 5.1 RECRUITING PROGRAM The overall proposed staff for SHNPP is now estimated to be 909 plant personnel by the end of 1992. The anticipated buildup of this organization will extend over a 10-year period, as shown on Figure 12.

The necessity of a well developed, detailed, and productive recruiting program to accomplish this type of hiring program has been recognized. In order to take advantage of the existing plants as training bases for the buildup of the Harris staff, beginning in 1979, personnel have been hired into the Harris organization but temporarily assigned to various operating plants for training purposes. At various times, these personnel or other trained personnel from those plants will be transferred to the Harris Plant organization on site.

Details of this proposed program are described below.

Carolina Power & Light Company has developed an aggressive recruiting program at colleges and universities. During the academic year 1980-1981, visits were conducted at thirty-two (32) colleges and universities. In the academic year 1981-1982, visits have been scheduled at twenty-four (24) four-year engineering institutions. In addition to visits at educational institutions, naval bases will be visited in 1981 to add to the complement of experienced nuclear personnel.

Carolina Power 6 Light is also seeking to recruit technician level personnel from technical schools and community colleges. In 1981, twenty-seven (27) community colleges and technical institutes were visited for recruiting purposes. COL actively participates in programs designed to enhance the Company's image on two-year campuses. For example, in 1980, personnel participated in "career days" at the community colleges and technical institutes and made presentations before placement officers from fifty-two (52) North Carolina community colleges and technical institutes.

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The Cooperative Education Program, established at ten (10) four-year and two (2) two-year institutions, and summer employment provide vocational training to students, and serves as a means of identifying potential employees.

Advertising on the local and national levels in newspapers and professional/technical publications provide emphasis on recruiting engineering and technical personnel.

Carolina Power & Light Company's Wage and Salary Program is competitive with other utilities and industries on the local and national levels, which attracts entry level and experienced personnel for operating plants. An annual review is made of the Salary Program in order to reflect changes in the cost of living and other factors to keep the program competitive. Entry level, professional and technical salaries are evaluated twice annually and adjustments made over the first two-year period.

A Recruitment Unit in the Employee Relations Department was established with the goal of developing and implementing a recruiting program designed to meet all levels of need within the Company. Harris recruitment takes place within this unit. Operating personnel from Harris and other generating plants assist in the recruiting program'to identify competent and experienced personnel in order to meet staff requirements.

College recruiting is an on-going program designed to attract qualified college graduates for entry level engineering, technical, and professional non-engineering positions. From September 1980 to April 1981, Company recruiters have visited the following colleges and universities: Mississippi State, Alabama, Kentucky, Pennsylvania State, North Carolina State, North Carolina, Virginia, Virginia Polytechnical, South Carolina, Clemson, South Carolina State, Duke, Florida, Central Florida, North Carolina Central, Auburn, Tuskegee, Georgia Tech., Tennessee, North Carolina A&T, Tennessee State, Vanderbilt, Howard, Old Dominion, Louisville, Tennessee Tech., East Carolina, St. Augustine, Winston-Salem State, Atlantic Christian, UNC at Wilmington, and UNC at Charlotte.

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Technical school and community college recruiting will assure the Company of a continuous supply of qualified technical graduates with at least two years of training. Schools in the following states are visited on a routine basis:

North Carolina, South Carolina, Virginia, Alabama, Florida, and Pennsylvania.

In addition, CPSL actively participates in programs designed to enhance the Company's image on two-year campuses. Some of these programs include:

Industrial Workshop, Career Day, Job Fair, and Workshops for high school guidance counselors on career opportunities for two-year graduates.

The Company is deeply involved in locating, screening, and recruiting experienced personnel. The advertising program includes publications such as Engineering News Record, Power Magazine, Nuclear News, IEEE Spectrum, ASME Publication, Navy Times, and other military newspapers. Local newspapers are used whenever a supply of qualified personnel is made available due to industrial layoffs or job changes. The Company continuously encourages referrals by employees. Particular emphasis is placed on engineering and technical personnel.

Carolina Power 6 Light Company is an equal opportunity/affirmative action employer and has a number of special programs designed to attract qualified minority, female, and handicapped personnel.

Staffing the Harris Plant Organization The planned staffing rate for the Harris Plant staff shown on Figure 12 is based on an evaluation of the staff needs in conjunction with the startup schedule. Recruiting of personnel for this plant is already active as previously discussed and will continue on a schedule designed to ensure that personnel can be placed in training classes, training positions, or other positions of responsibility far enough in advance to ensure that sufficient 5-3

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numbers of qualified personnel are available to staff the Harris organization when needed to perform the required startup functions; develop the required operating, maintenance, and administrative procedures; operate and maintain systems following acceptance by startup personnel; and provide for safe operation of the various units while other units are being completed or started up.

At the present time, several key positions in the Harris Plant organization have already been staffed and are currently performing their assigned tasks.

These include the Startup Superintendent, the four Startup Supervisors, and the Assistant'o the General Nanager. In addition, 30 of the non-supervisory positions in the Startup Unit have been staffed and are currently functioning in their role of planning for the startup activities. Additionally, 17 non-supervisory positions in the Administration and Engineering Units have been staffed and are in the process of developing document control, cost control, and other basic procedures.

As of May 1981, there were 233 people on board in this organization, of which 180 have been temporarily located at various operating plants for training purposes. These personnel are committed to the Harris Plant organization and have been placed at other plants to be involved in either the formalized operator training program discussed in Section 2.1.3 or to receive on-the-job.

training experience at the operating plants. These personnel will be transferred to the Harris Plant organization on site at an appropriate time to meet startup or operating personnel needs.

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'BHOR SENIOR VICE PRES IDENT B4IMEERING 6 CONSTRUCTION E. E. VTLEY VICE PRESIDENT POWER SUPPLY GROVP L. W. EVRY SENIOR VICE PRESIDENf FUEL 6 tATERIALS MtttAGBKNT GROUP J. H. DAVIS, JR.

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$ wwmwwamam tAtAGER MANAGER MANAGER DIRECTOR HAtAGER HAIAGER HANGER MANAGER ENGINEERING 6 CCttSTRVCT ION OPERATIONS AND ENVIRONMENTAL 6 t4JCLEAR TRAINING BKRGBICY BAII RDtfKNTAL HAINTENANCE ACHINISTRAT I ON LICENSING 6 QUALITY ASSURANCE/ RADIATIOM CONTROL PREPAREDtKSS TEOtlOLOGY SECTION SECTION PERMITS SECTION QUALITY CONTROL SECTION SECTION VNIT SECT ION HAtAGER tAICLEAR 6 WCLEAR OPERAT I ONS HEALTH PHYS I CS 5ECIRI TY 5 IWLATOR LICENSING QUALITY ASSURANCE/ VNIT VNIT TRAINING WIT QUALITY CONTROL VNI T CRAFT REGULATORY PRINCIPAL QA SPECIALIST ENVIROMKNTAL ADMINl STRATI ON f TEO II CAL COMP LIAIICE PERFORMAIICE EVALVATION WIT WIT TRAINING WIT VMI7 CVRR I CVLW PROJECT QA SPECIALIST OKHISTRY CONTRACTS DEVELOPtKNT METEOROLOGY TRAINING 6 PROCEDURES VNIT WIT WIT VNI T FIRE PROTECTION ~ PERMI TS VNIT UNIT SPECIAL PROJECTS WITS I.ICIND THREE HILE ISUIM) TEAM ADMINISTRATIVECHANNELS COITROL BOARD MNAN FACTORS l REV IEW r mr AVTNOIIIZED DIRECT POWER SUPPLY COORDIIATICtt COIDIUNICATION CNANNEL FI6.5 CAROLINA POWER AND LIGIlf COIIPANY QUALITY ASSURANCE, POIIER SUPPLY AND FUEL 6 HATERIALS ILVIAGEIIENf GROUPS OFF-SITE SUPPORT ORGANIZATION

CAROI ZNA PO~ 8c LZGHT COMPANY ENGZNEEHZNG 8c CONSTHUCTZON GROUP OFF-SZTE MANAGEMENT RESOURCES SENIOR VICE PRESIDENT ENGINEERING 8 CONSTRUCTION GROUP M. A. MCDUFFIE VICE PRESIDENT VICE PRESIDENT NUCLEAR PLANT NUCLEAR PLANT CONSTRUCTION ENGINEERING DEPARTMENT DEPARTMEiNT A. B. CUTTER SHELDON D. SMI TH MANAGER SITE MANAGER ENG INEER ING HARRIS PLANT HARRIS PLANT SECTION CONSTRUCTION MANAGER MANAGER ENGINEERING SUPPORT ENGINEERING 8 CONSTRUCTION NUCLEAR PLANTS SECTION BRUNSWICK 8 ROBINSON 0 I RECTOR MANAGER NUCLEAR ENGINEERING CONSTRUCTION PROCUREMENT SAFETY REVIEW AND CONTRACTS

CAROLINA POWER 6 LIGHT COMPANY INDEPENDENT SAFETY REVIEW GROUPS PPES IDENT'HIEF EXECUTIVE OFFICER AND CHAIRMAN SHERWOOD H. SMITHS'R.

VICE CHAIRMAN J ~ A. JONES EXECUTIVE VICE PRESIDENT POWER SUPPLY 8 ENGINEERING G CONSTRUCTION GROUPS E. E. UTLEY VICE PRESIDENT NUCLEAR SAFETY AND RESEARCH DEPARTMENT T. S. EL'LEMAN MANAGER CORPORATE DIRECTOR CORPORATE NUCLEAR SAFETY SECTION HEALTH PHYSICS SECTION CORPORATE NUCLEAR DIRECTOR-SAFETY UNIT ONS ITE NUCLEAR (OFFS ITE) SAFETY ONS ITE .NUCLEAR SAFETY BSEP ONS ITE NUCLEAR SAFETY HBR ONSITE NUCLEAR SAFETY SHNPP Fig.7

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BOARD OF DIRECTORS I

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LEGEND I PRES IDENT~ CHIEF EXECUTIVE ADIIINISTRATIVECHANNELS I OFF ICER AM) CHAIRMAN SMITHS'R.. W W W W W W W W W W W W 'W W W W w w W W W llew I

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w w w w aPae s I I I I I PROJECT QA MANAGER- PRINCIPAL QA SPEC. 044ER MANAGER- MANAGER- MANAGER- DIRECTOR MANAGER-SPECIALIST OP ERAT IONS PERFORMANCE ENGINEERING G ENVIR~4%NTAL AND, CORPORATE NUCLEAR CORPORATE CORPORATE TRAINING 8 QA/QC CONSTRUCT ION QA/QC RAD I AT ION CONTROL TRA I NING POWER PLANTS HEALTH PHYS ICS NUCLEAR SAFETY PROCEDURES Fig. 8

MANAGER ENGINEERING HARRIS PLANT ENG INEER ING ENGINEERING UNIT I START-UP 6 UNITS 2, 3, G 4 OPERATIONS MECHANICAL UNI T ELECTRICAL UN I T CIYIL UNIT MECHANICAL UNIT ELECTRICAL UNIT Fig.9 NUCLEAR PI.ANT ENCiINEERINC DEPARThlENT IIARRIS PLANT ENCiINEERINCi SECTION

GENERAL MANAGER-HARRI S PLANT MANAGERi DIRECTOR PR INC I PAL TECHNICAL PLANNING 8: ENG I NEER SUPPORT SCHEDUL ING OP ERAT IONS Fig. 10 IIARRIS TECllNICAL SUPPORT CENTER ORGANIZATION

CORPORATE t%NAGEMENT CORPORATE CORPORATE EMERGENCY HEADQUARTERS OPERATIONS AND PLANT MED IA CENTER MEDIA MANAGER TEAMS RECOVERY W M & W SR W SN RC SS W RR W IN REGULATORY MANAGER AGENCIES PLANT RAD IOLOG I CAL TECHNI CAL ADMIN I STRAT I VE OPERAT IONS CONSTRUCTION ENGINEERING CONTROL ANALYSI S AND AND HASTE LOGISTICS Fig.11 RECOVERY ORGANIZATION

1000 FUEL LO wtllT 3 Projected Harris Plant Staff 900 FUEL LOAD UNIT 4 COMME RC I A L OPERATION 3 800 COMMERCIAL 700 OPERATION 4 FUEL LOAD UNIT 2 FUEL LOAD UHIT 1 COMMERCIAL OPERATION 2 500 COMMERCIAL TOTAL OPERATION I PLANT STAFF 300 200 100 1980 81 82 '83 '84 85 'SG '87 '88 89 '90 '91 '92 '93 '94 YEAR Fig. 12

CORPORATE NUCLEAR SAFETY PROGIUN POLICY STATEMENT It is the policy of the Carolina Power & Light Company to design, construct, and operate nuclear power plants without jeopardy to its employees or to the public health and safety. Nuclear safety programs shall be developed, implemented, and updated as necessary to assure that the Company's nuclear generating units will be managed such that all plane systems used to treat, store,.or convey waste produced by the generation of nuclear steam will be designed, constructed, and operated in a safe manner. Deviations from these programs shall be permitted only upon written authority .from the corporate management position originally approving the program.

The design, construction, and operation of nuclear plants shall be accomplished in accordance with U. S. Nuclear Regulatory Commission (NRC) regulations specified in Title 10 of the U. S. Code of Federal Regulations. All commitments to the NRC Regulatory Guides and to engineering and construction cod'es shall be carried out.

The operation of the Company's nuclear power plants shall be in accordance with the terms and conditions of the facility operating license issued by the NRC.

Any changes in operating procedures, experiments at the facility, modifications to the plant hardware or systems, shall be made in accordance with the terms and conditions of the facility operating license; The corporate nuclear safety (CNS) section of the nuclear safety & research department shall monitor the Company's nuclear programs on a continuous basis to assure they are being carried out in an effective manner. The CNS section shall implement the nuclear safety functions as defined in ANSI N18..7 and as required by nuclear plant safety analysis reports, technical specifications, and NRC Regulatory Guide 1.33.

The vice president nuclear safety & research department and the manager CNS section shall review with the senior operating officer of the Company with the ultimate responsibility for the operation of all nuclear power plants on a regular periodic basis the overall effectiveness of the Companyb nuclear safety programs. They shall be expected to communicate directly with corporate manage-ment up to and including the chief executive officer and if appropriate with the board of directors to resolve any nuclear safety-related concerns if the concerns cannot be resolved satisfactorily at a lower management level.

Issued by- Date:

Sherwood H. Smith, Jr.

Chairman/President Chief Executive Officer EXHIBIT 1 .

CAROLINA POWER & LIGHT COMPANY CORPORATE QUALITY ASSURANCE PROGRAM

POLICY-'STATEMENT It is the policy of the Carolina Power & Light Company to design, construct, and operate nuclear power plants without jeopardy to its employees or to the public health and safety. The quality assurance programs shall be developed, implemented, and updated as necessary to assure that the Company's nuclear generating units will be managed such that all plant systems used to produce; convey, or use nuclear generated steam and all plant systems used to treat, store, or convey waste produced by the generation of nuclear steam will be designed, constructed, and operated in a safe manner. Deviations from these programs. shall be permitted only upon written authority from the corporate management position originally approving the program or implementing procedures.

The design, construction, and operation of nuclear plants shall be accomplished in accordance with U. S. Nuclear Regulatory Commission (NRC) regulations speci-fied in Title 10 of the U. S. Code of Federal Regulations. All commitments'o the NRC Regulatory Guides and to engineering and construction codes shall be carried out.

The operation of the Company's nuclear power plants shall be in accordance with the terms and conditions of the facility operating license issued by the NRC.

Any changes in operating procedures, experiments at the facility, modifications to the plant hardware or systems, shall be made in accordance with the terms and conditions of the facility operating license.

The corporate quality assurance department. shall monitor the Company's nuclear programson a continuous basis to assure they are being carried out in an effective manner. The corporate quality assurance department shall implement the quality assurance audit functions- as defined in 10CFR50, Appendix B, ANSI N18.7, and as required by nuclear plant safety analysis reports and techni-cal specifications, Company approved ASME programs, and NRC Regulatory Guide 1.33.

The manager corporate quality assurance department shall review with the senior operating officer of the Company with the ultimate responsibility for the opera-tion of all nuclear power plants on a regular periodic basis the overall effec-tiveness of the Company's quality assurance program. He shall be expected to communicate directly with corporate management up to and including the chief executive officer and if appropriate with the board of directors to resolve any quality assurance related concerns factorily at a lower management level.

if the concerns cannot be resolved satis-The engineering & construction quality assurance (E&CQA) section of the corporate quality assurance department shall implement the Corporate Quality Assurance Programs and the approved ASME QA Programs assuring effective implementation by surveillance of portions applicable to the engineering & construction group.

EXHIBIT 1A

The operations quality assurance (OQA) section of the corporate quality assurance department shall implement the Corporate Quality Assurance Programs assuring implementation by surveillance of portions applicable to the power supply group. The OQA section shall also implement the applicable portions of the Corporate QA Program as implemented by the engineering & construction group for nuclear plant modifications.

The managers of all functions involving nuclear fuel, engineering and construc-tion, and operations shall assure that their personnel are adequately trained for their jobs and they have the experience and education required to carry out their assigned responsibilities. Personnel who habitually or willfully disre-gard or violate the nuclear safety and quality assurance policies and procedures will be subject to disciplinary action.

Issued by:

Sherwoo , Smith, Jr, Date:/

Chairman/President Chief Executive Officer EXHIBIT 1A

Carolina Power & l.ight Company

~ wtl4tLN4PW'AM kk%N4 '%Aha~'I~a 'MAAWW P. O. 8ox 1551 ~ Raleigh, N. C. 27602 4 A. JONES Senior Executive Vice President Chief OPerating Oiiicer April 15, 1981 MEMORANDUM TO: Messrs. T. S. Elleman M. A. McDuffie E. E. Utley FROM: .

J. A. Jones Recent organizational changes make responsibilities of the Vice President it necessary I

to update the assigned Nuclear Safety & Research to meet periodically with Company personnel concerning nuclear safety and quality assurance. I This memorandum confirms our understanding that the Vice President Nuclear Safety & Research will meet periodically with the individuals occupying the positions listed later in t:his memorandum to review nuclear safety and quality assurance matters. These discussions will encompass matters outside of normal nuclear safety and quality assurance reports and could include (but not necessarily be limited to) such items as trends in quality assurance which could lead to safety problems, generic quality assurance and safety problems in the nuclear industry, long-term concerns requiring extended or intensive investigation affecting CP&L's quality assurance or nuclear programs, attitude problems which could adversely affect implementation of CP&Lts programs, or any personnel concerns related to potential safety problems.

These meetings will give the individuals whose total responsibility is nuclear safety and quality assurance an additional avenue to express concerns to the Chief Executive Officer of the Company satisfactorily resolved.

if necessary to get them It will be the responsibility of the Vice President Nuclear Safety &

Research to initiate these meetings on a frequency of no less than once each quarter. If, however, a meeting is essential to resolve any quality assurance or safety issues that require immediate attention, individuals occupying the positions listed in this memorandum are responsible for contacting the Vice President - Nuclear Safety & Research immediately.

In the event of his absence in these situations; or in the event the Vice President - Nuclear Safety & Research does not respond satisfactorily, the Chief Operating Officer or the Chief Executive Officer should be contacted.

EXHIBIT 2

This memorandum is applicable to the individuals occupying the following positions:

Manager Corporate Quality Assurance Manager Operations Quality Assurance/Quality Control Manager Engineering and Construction Quality Assurance/Quality Control Manager - Nuclear Training Manager Environmental and Radiation Control Manager H. B. Robinson Plant Manager Brunswick Steam Electric Plant In'addition, the Vice President for Nuclear Safety & Research may elect to meet with plant personnel having responsibilities for operations, maintenance, training and health physics as he deems necessary.

TSE/phT6 cc: Messrs. H. Banks J. D. E. Jeffries J. R. Bohannon C. H. Moseley A. L. Cutter S. D. Smith C. Dietz S. H. Smith, Jr.

L. W. Eury R. B. Starkey B. J. Furr B. H. Webster

p. W. Howe EXHIBIT 2

0 CIPRL Carolina Power 6 Light Company P. O. Box 1551 ~ Raleigh. N. C. 27602 SHERWOOD H. SMITH. JR Preseeht March 17, 1980 MEMORANDUM TO: Dr. Thomas S. Elleman, Vice President Nuclear Safety and Research PROM: Sherwood H. Smith, Jr.

SUBJECT:

. Nuclear Safety and Quality Assurance Matters This memorandum will confirm our understanding that you will meet periodically with me to discuss nuclear safety and quality assurance matters.

These discussions may encompass matters outside of routine nuclear safety and quality assurance audit and surveillance reports, as well as appropriate items in those reports. These reviews should

=

include, but not be limited to, such items as trends in quality assurance which could lead to safety concerns, generic quality assurance and safety problems in the nuclear industry, any tters requiring extended or intensive investigations affecting CP&L's quality assurance or nuclear safety programs,'.the attitudes and morale of personnel involved in the implementation of CPGLrs programs, or any other personnel concerns related to safety matters.

Since your total responsibility includes all aspects of nuclear safety from a corporate standpoint with no other assigned duties that might conflict with this interest, I am certain that your reviews will provide an objective evaluation of the effectiveness of nuclear safety, quality assurance, and MBA programs. I will also expect to be informed about the concerns of other person-nel working in areas of nuclear safety, quality assurance, and health physics, if there are any safety matters not being satisfactorily addressed by other levels of management.

Our conversations, of course, will not be intended to replace, or alter, the regular and routine written reports on nuclear safety matters, which are provided to me.

It will be your responsibility to initiate these meetings on a frequency of no less than semiannually. Of course, however, should situations arise that you feel should be brought to my attention immediately for satisfactory resolution, I will expect you to contact me promptly and make me aware of the urgency of the situation.

EXHIBIT 3

1KMORANDUM TO: Dr. Thomas S. Elleman -2<< March 17, l980 Iz, in your judgment, the response to your expressions of concern is not satisfactory from a safety standpoint, it will be your responsibility to make the Chairman of the Forecasting, System Development and Finance Committee of the Board of Directors aware of your concern, or in the absence of that individual you may contact any member of the Board.

Since the Directors oz our Company are vitally interested in the effec-tiveness of our nuclear safety programs, it will be your responsibility to appear before the Forecasting, System Development and Finance Committee of the Board annually to provide a professional evaluation of our programs. Arrange-ments will be made for you to meet with this Committee periodically during its regularly scheduled meetings, and when appropriate to appear also before the eqtire Board.

Sherwood H. Smith, Jr.

SHS,Jr.:pt CC: Board of Directors Senior Management Committee EWIBIT 3 (COhT)

April'2, 1981 HEfORANDVM TO: Mr. E. E. Utley Mr. J. M. Davis, Jr.

Dr. T. S. Elleman Mr. L. W. Eury Mr. M. A. McDuffie Mr. W. J. Ridout, Jr.

FROM: J. A. Jones

SUBJECT:

Corporate Health Physics Policy Attached is a revised copy of our Corporate Health Physics Policy. The Policy Statement is applicable to all health physics programs which are established to engineer, construct, and operate nuclear power plants on our system.

This Policy supersedes the Corporate Health Physics Policy attached to my memorandum dated January 11, 1980. Please take measures which you deem appropriate to disseminate the revised Policy Statement to appropriate personnel under your supervision to assure that they are fully aware of the Policy Statement and the comm'itments contained therein.

Jh J/dwj W2 Attachment

, cc: Mr. H. R. Banks Mr. R. L. Mayton, Jr.

Mr. Sherwood }i. Smith, Jr.

EXHIBIT 4

Cg+g, Carolina Power & Light Company CORPORATE HEALTH PHYSICS POLICY In line with the overall policy of Carolina Power 6 Light Company to engineer, construct, and operate nuclear power plants without jeopardy to public health and safety, it is the policy of the Company to develop, implement, and maintain sound health physics programs at each Company facility where radiation producing equipment and/or radioactive materials are used or stored. The health physics programs shall be structured to ensure that the exposure to radiation of Company personnel, contractor personnel, and the general public will be maintained at levels which are as low as reasonably achievable (ALARA) and consistent with United States Nuclear Regulatory Commission Regulations in Title 10 of the United states Code of Federal Regulations. The health physics programs associated with activities licensed by state regulatory agencies shall be developed to comply with applicable state regulations.

The health physics programs developed by the Company shall ensure that personnel, the general public and the off-site environs are protected, and procedures and records systems are established to meet all applicable federal or state regulations. Each Company employee and contractor personnel working in a facility where exposure to radiation might occur shall make every reasonable effort to maintain radiation exposures and releases of radioactive materials to unrestricted areas as far below specified limits as reasonably achievable.

Personnel who habitually or willfullydisregard or violate health physics procedures and practices will be subject to disciplinary action.

Health physics programs shall be developed which will be strictly adher'ed to by the Company and its contractors to limit occupational exposures at Company facilities in which exposure to radiation may occur to ALARA levels. The health physics programs shall be documented in writing and shall be reflected in written administrative procedures and instructions for operations involving potential exposures of personnel to radiation and for design activities associated with each facility. Instructions to designers, constructors, vendors, and facility personnel responsible for specifying or reviewing facility features, systems, or equipment shall reflect the health physics programs goals and objectives.

The goals and objectives of the health physics programs shall be to, maintain the annual dose to individual facility personnel to as low as reasonably

'achievable and to maintain the annual integrated dose to facility personnel; i.e.> the sum of annual doses (expressed in man-rem) to all facility personnel, as low as reasonably achievable. The health physics programs shall identify the organizations participating in the programs, the positions involved, and tile respo'nsibilities and functions of tltc various positions in conducting tile programs.

41 1 Fayettevttte Stteel ~ P O. Oox 1551 ~ 1tatetith. N C. 27602

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EXHIBIT,.4~

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The design of nuclear facilities shall be consistent with the goals and objectives of the health physics programs. Modif'ications to existing nuclear facilities shall be designed and implemented in compliance with the health physics programs to meet ALARA requiremens. Design review shall reflect consideration of the activities of facility personnel such as operations, maintenance, refueling in-service inspection, radioactive waste processing, and decontamination.

Adequate trained personnel shall be provided to develop and conduct all necessary health physics programs. The health physics personnel shall possess the necessary training and eXpertise to carry'ut the health physics programs in an efficient manner to assure that Company and regulatory requirements are met.

The director of corporate health physics will make himself available to all Company personnel for advice and consultation on matters relating to health physics.

All health physics programs shall require procedures, job planning, record keeping, special equipment, operating philosophy, and other support conducive to meet ALARA requirements. Proper preparation and planning shall be performed prior to entering radiation areas where significant doses could be received.

Adequate supervision and radiation protection surveillance shall be provided during operations in radiation areas to ensure that the appropriate procedures are followed, that planned precautions are observed, and that all potential radiation hazards which might develop during the operations are considered in a timely manner. Results of activities in radiation zones shall be analyzed to identify deficiencies in the program and to provide the basis for revising procedures, modifying facility features, or make other adjustments which may reduce exposures during subsequent activities.

1)ealth physics facilities, instrumentation, and protective equipment shall be adequate to permit the staffs to function effectively. The selection of instrumentation and equipment and the quantities provided shall be adequate to meet the anticipated needs of the facilities during normal operations, major outages, and accident conditions.

Appropriate training programs in the fundamentals of radiation protection and facility exposure control procedures shall be established to provide instructions to all facility personnel including contractors whose duties require working in radiation areas.'raining programs for health physics personnel shall be provided to improve their performance in the health physics programs.

Appropriate health physics programs shall be established for all Company operations which deal with radiation. The programs shall be consistent with the corporate health physics policy and all applicable regulations. The director of corporate health physics shall periodically evaluate the various health physics

.programs and other Company activities which have impacts on the programs and report to senior management regarding the effectiveness and adequacy of the programs. Thc director of corporate health physics shall make recommendations to senior management as necessary to maintain effective overall health physics programs.,

EXHIBIT'4

The director of corporate health physics shall review with the senior of the Company with the ultimate responsibility for the operation of operating'fficer all nuclear power plants on a regular periodic basis the overall effectiveness of the corporate health physics programs. He shall be expected to communicate directly with corporate management up to and including the chief executive officer to resolve any concern in the area of corporate health physics if the concern cannot be resolved satisfactorily at a lower management level.

Issued by~ ~Wc/'-- z Date:

Sherwood H. Smith, r.

ChairmanlPresident Orig.'. 6-17-77 Chief Executive Officer Rev. 1: 1-11-80 Rev. 2: 4-21-81 EXHIBIT 4.