ML19296B867
| ML19296B867 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/11/1980 |
| From: | Allenspach F Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19296B831 | List: |
| References | |
| NUDOCS 8002220282 | |
| Download: ML19296B867 (11) | |
Text
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UNITED STATES OF A:'. ERICA f!UCLEAR REGULATORY COM:41SSION BEFORE THE ATOMIC SAFETY AflD LICENSING BOARD In the Matter of SACRAMENTO MUNICIPAL UTILITY
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Docket flo. 50-312 (SP)
DISTRICT
)
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(Rancho Seco fluclear Generating
)
Station)
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TESTIMONY OF FREDEP,ICK R. ALLEflSPACH RELATING TO MAf!AGEMENT AND TECHNICAL COMPETENCE (F0E III(d) and Board Question 32)
Q.
Please state your name and position with the flRC?
A.
My name is Frederick R..Allenspach.
I am employed by the fluclear Regulatory Commission, Division of Project Management, Quality Assurance Branch.
Q.
Have you prepared a copy of your professional qualifications statement?
A.
Yes.
It is attached to this testmony.
Q.
hhat is the purpose of this testimony?
A.
The purpose of this testimony is to set forth and discuss those criteria by which a licensee's management and technical competence is reviewed by the NRC and in particular, to respond to F0E Contention III(d) and Board Question 32, which state:
F0E III(d)
The NRC orders in issue do not-r.easonably assure adequate safety because no procedures have been taken to assure facility management competence.
8002220 1
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Board Question 32 Rancho Seco, being a Babcock and Wilcox designed reactor, is operated by personnel and management whose competence has not been adequately tested and evaluated, namely testing has not Deen Conducted as to whether such employees can act responsibly and appropriately to make judgment decisions during a loss of feedwater transient, personnel interviews have not been conducted to properly evaluate the test results with such employees and some employees have never been tested because of grandfathering, and there-fore is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public.
Q.
What present requirements or criteria does the f;RC have to assure personnel and facility management competence?
A.
An applicant for a construction permit or an operating license for a facility must fulfill certain regulatory requirements and acceptance criteria in the area of management and technical competence.
Q.
What are the regulatory requirements?
A.
An applicant i., required to submit information concerning organizational structure, personnel requirements, and technical qualifications to engage in the proposed activities in accordance with 10 C.F.R. 650.34.
Before a permit or license is issued, the fiRC is required to make a finding of technical competence of the applicant pursuant to 10 C.F.R. 150.40(b).
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. Q.
How does the IRC determine whether an applicant fulfills the management and technical competence requirements of the regulations?
A.
The information submitted in an applicant's Safety Analysis Report (SAR) with regard to management and technical corpetence is to be reviewed by the flRC against the standards and criteria set forth in the Standard Review Plan, Sections 13.1.1, 13.1.2 and 13.1.3 (l;UREG-75/087). The fiRC will review the management and technical organization of the applicant and its major contractors, including the nuclear steam supply system vendor, and architect engineer for the project.
Thus, the f1RC will review both onsite and offsite organizations with respect to their responsibilities and technical capability to engage in the activities proposed in the application.
Q.
What does the f1RC review to assure that onsite facility management and personnel are qualified to act responsibly'and competently in the event of an emergency or abnormal occurrence at the plant?
A.
With regard to the concerns expressed in the above contentions, the f;RC reviews the following critria set forth in the Standard Review Plan to assure that the licensee has an acceptable organization and adequate resources to provide the necessary technical support for the operation of the facility:
a) The licensee must have clear management control and effective lines of authority and communications among the organizational units involved in the management, operation, and technical support of its facility.
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- b) The licensee must have substantive breadth and level of experience and availability of manpower to provide technical support of its facility.
c) Qualifications of the " Engineer in Charge" should meet or exceed those given in Section 4.6.1 of Af1SI f118.1, as endorsed by Regulatory Guide 1.8, " Personnel Selection and Training."
Q.
What does the t1RC review to assure that clear management control and effecitve lines of communication exist between the organizational units involved in the management, operation, and technical support for the operation of the facility?
A.
The I;RC reviews management and technical support headquarters structure as demonstrated by the organizational charts and descriptions of functions and responsibilities. These charts and descriptions should be free of ambiguous assignments of primary responsibilities and assure that excessive workloads are not placed on certain individuals.
The Rancho Seco Final Safety Analysis Report (Section 12.2) described the licensee's organization and management responsibilities at the time of the submittal of application for an operating license. The present organization is described in the licensee's submittal dated July 30, 1979 (letter from Wm. C. Walbridge to H. R. Denton).
The fluclear Operations Department, under the Assistant General Manager and Chief Engineer, has primary responsibility for the operation of the Rancho Seco faci,lity.
The Generation Engineering
, Department, also under the Assistant General Manager and Chief Engineer, is responsible for licensing activities related to the Rancho Seco facility.
Q.
What does the liRC review to assure that the licensee has the necessary technical support for the operation of the facility?
A.
The NRC reviews the professional qualifications of both onsite and offsite technical personnel particularly in the areas of engineering, plant chemistry, health physics, fueling and refueling operations support, main-tenance support, and fire protection. Rancho Seco's present Technical Specifications require that e&ch member of the operating staff meet or exceed the minimum qualifications of ANSI 18.1 - 1971 for comparable positions. Further, the ehemical - Radiation Supervisor must meet or exceed the minimum qualifications of Regulatory Guide 1.8 of 1975.
Q.
Were the licensee's organizational structure, personnel requirements and technical qualifications reviewed by the NRC against the above criteria?
A.
Yes. With respect to SMUD, the Rancho Seco Final Safety Analysis Report (FSAR) was submitted on May 1, 1971, which described the SMUD organization and management responsibilities and quality assurance program for Rancho Seco. This information was submitted in accordance with requirements and guidelines in existence at the time. Questions were forwarded to SMUD in this area by the Atomic Energy Commission Regulatory Staff (the predecessor to the NRC staff), and responses are documented in Appendix 2 of the FSt.R.
, The SMUD organization, personnel qualifications, and quality assurance program were found acceptable to the Regulatory Staff as documented in a Safety Evaluaticn dated June 8, 1973, which was issued in support of the operating license granted for Rancho Seco.
Subsequent to the issuance of the operatine license for Rancho Seco, SMUD submitted a proposed amendment to its operating license that reflected a reorganization of its personnel and assignment of responsibilities (SMUD letter dated February 21,1978). This new organizational structure was again reviewed to ensure that f;RC requirements and guidelines were being met.
The flRC Staff found the reorganization acceptable and documented this acceptability in a safety evaluation forwarded with a license amendment in a letter dated fovember 14, 1978.
To date, no significant deficiencies in SMUD's capability to operate the Rancho Seco facility have been noted. However, as a result of the accident at Three Mile Island, the flRC has initiated. efforts to upgrade and more clearly define acceptance criteria in the area of management and technical support capability. These efforts are described in the Action Plan,*1UREG-0660 (DRAFT) dated December 10, 1979, as Task I.B l.
Although the schedule for Task I.B.1 states that acceptance criteria will be developed by January 1, 1980, the criteria are still under development. When fully developed and applied to operating reactor licensees, these criteria could result in an upgrading of SMUD with respect to its management and technical support capabilities.
In connection with this effort, operating reactor licensees were requested by letter dated June 29, 1979, to submit information regarding utility capabilities to respond to events such as the TMI-2 accident.
, Q.
What are the NRC plans for developing and applying upgraded requirements in the area of management and technical capabilities with respect to operating reactors?
A.
The new criteria now under consideration by the NRC fall into the following general areas:
1.
Shift manning requirements.
2.
Qualification and training requirements for plant staff personnel.
3.
Administrative controls for nuclear power plants.
4.
Management and technical capability of utilities that own and operate nuclear power plants.
Q.
With regard to shift manning, what is the NRC considering?
A.
The NRC is reevaluating the requirements for shift crew composition from the standpoint of both normal operation and er.ergency conditions. The revised shift crew composition will specify the required resources needed on shift in both numbers and technical expertive; and will require additional licensed personnel in the control room at all times beyond the number now required.
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, Q.
What revisions are being considered with respect to qualification and training requirements?
A.
Regulatory Guide 1.8, " Personnel Selection and Training" endorsing with several modifications, ANSI /Af1S 3.1, " Standard for Qualification and Training of Personnel for Nuclear Power Plants." ANS 3.1 is currently undergoing major revision.
This revision will, in general, increase the educational training and nuclear power plant experience required by the nuclear power plant staffs. The fiRC will subsequently issue for comment a revision to Regulatory Guide 1.8 that will state the NRC position relative to the acceptability o.' the revised standard.
Q.
What revisions are being considered with respect to standards and criteria relative to administrative controls?
A.
Regulatory Guide 1.33 endorsed, with several modifications, ANSI 18.7 - 1976,
" Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." This standard is currently undergoing revision.
These revisions, in general, should include clarification of responsibilities and authority of both onsite and offsite resources for the safe operation of the nuclear power plant; availability of persons to support the plant staff, increased controls of systems undergoing maintenance and modification; shift turnover responsibilities; and plant systems verification procedures.
The NRC will subsequently issue for comment, a revision to Regulatory Guide 1.33 that will state the NRC position relative to the acceptability of the revised standard.
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- Q.
What is the NRC staff considering with respect to the management and technical capability needs of operating reactors?
A.
The NRC is developing new criteria that will establish the management and technical capability needs of utilities with operating nuclear power plants.
These new criteria will establish the needs of the onsite plant staff and for offsite technical support to the plant staff for both routine and accident conditions. These criteria will establish minimum needs, in general, with respect to the numbers and qualification requirements of personnel; areas of expertive required; time frames for response to emergencies; and functional requirements for both onsite and offsite organizations. We expect these new criteria to be implemented through the use of NRC Regulatory Guides and revisions to the NRC standard Review Plan.
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A.
Will Rancho Seco be reviewed against any new criteria that are developed and instituted?
A.
Yes. As soon as new criteria are developed, all utilities will be reviewed by the NRC and be required to meet the requirements of the new criteria with respect to management and technical resources. Any necessary upgrading of personnel or resources will be required within an acceptable time frame.
The staff is of the opinion that these procedures will provide the manage-ment and technical capability needed to assure adequate safety of the Ranche Seco facility.
Frederick R. Allenspach Statement of Professional Qualifications June 1952
- Graduate - Polytechnic Institute of Brooklyn Degree in Bachelor of Mechanical Engineering July 1952 to August 1953
- flew York flaval Shipyard August 1953 to August 1954
- Republic Aviation Corporation August 1954 to August 1956
- Military Service September 1956 to June 1968
- Employed by the Brookhaven fiational Laboratory, Reactor Division. Approximately two years as operating shift supervisor in charge of an operating shift on the Brookhaven Graphite Research Reactor (BGRR).
Approximately three years as BGRR day shift supervisor respor.s.ible for various reactor support activities.
Approximately six years as BGRR Assistant Operations Group Leader primarily responsible for the temperature monitoring and reactor fuel management programs.
One year as BGRR Operations Group Leader responsible for all operational aspects of the reactor.
Included during this period at Brookhaven flational Laboratory were several short term supplemental assignments to Brookhaven fiational Laboratory review and audit committees assigned the responsibility to determine if other Brookhaven nuclear reactors were being operated in accordance with the applicable rules and regulations.
June 1968 to June 1974 Employed by the Atomic Energy Commission, Directorate of Licensing, Operational Safety Branch. My responsibilities included (as assigned); review and evaluation of applicants' organizational structure, and technical and administrative qualifications of applicants' proposed reactor operating organization, including emergency plans and industrial security plans; development of guides and codification of 6
. present and proposed practices with respect to administrative procedures for the operation of licensed reactors; the review of operating reports from licensed reactors for safety related items; and the preparation of reports relative to operating experiences at licensed reactors.
June 1974 to present
- Employed by the Atomic Energy Commission (now Nuclear Regulatory Commission), Division of Project Management, Quality Assurance Branch. My responsibilities include review and evaluation of applicants' organizational structure, and technical and administrative qualifications of applicants' proposed reactor operating organization; development of standards, codes and guides with respect to administrative procedures for the operation of licensed reactors; and the development of uniform acceptance criteria for subjects required to be addressed by license applicants relating to operatior,al safety matters.
Addit'ional Educational
Background:
- I have attended the MIT course on Light Water Reactor Safety, a course in Industrial Defense and Disaster Planning for Privately Operated Facilities sponsored by the Dept. of Army at the Military Police School in Fort Gordon, Georgia, and a Babcock and Wilcox Simulator training course.
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