ML19340D561
| ML19340D561 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/24/1980 |
| From: | Allenspach F, Crocker L Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19340D550 | List: |
| References | |
| NUDOCS 8012310249 | |
| Download: ML19340D561 (21) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Three Mile Island Nuclear
)
(Restart)
Station, Unit No. 1)
)
TESTIMONY OF LAWRENCE P. CROCKER AND FREDERICK R. ALLENSPACH RELATING TO CONTENTION AAMODT #2 Q.
Mr. Crocker, Please state your name and position with the NRC.
i A.
f?y name is Lawrence P. Crocker. I am a Senior Management Engineer in the Licensee Qualifications Branch of the Division of Human Factors
.i Safety within the Office of Nuclear Reactor Regulation of the Nuclear Reg'ulatory Commission.
Q.
Have you prepared a copy of your professional qualifications?
A.
Yes. A copy of my professional qualifications is attached to this testimony.
Q.
Mr. Crocker, please describe your connection with the Three Mile Island Station following the March 28, 1979 accident.
A.
Following the accident, I was assigned to the NRC Special Inquiry Group (Rogovin group) which was formed to investigate the accident. My partici-pation in the group efforts was limited primarily to the general area of investigation of federal (other than NRC), state, and local agency response to the accident.
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2-Upon completion of the Special Inquiry Group effort, I returned to NRC duties and, since January 1980, I have been involved in matters relating to utility organization and staffing. Part of this activity has included an evaluation of the THI-1 plant and corporate organization.
Q.
Mr. A11enspach, please state your name and position with the NRC.
A.
My name is Frederick R. A11enspach. I am a Management Engineer in the Licensee Qualifications Branch of the Division of Human Factors Safety in the Office of Nuclear Reactor Regulation of the Nuclear Regulatory Commission.
Q.
Have you prepared a copy of your professional qualifications?
A.
Yes.
It is attached to this testimony.
Q.
Mr. A11enspach, please describe your connection with the Three Mile Island Station.
l A.
I performed the review for the NRC staff of Sections 13.1 and 13.4 of the Final Safety Analysis Report supporting the issuance of an operating license for Three Mile Island Unit 2.
This was during the 1977 time period.
I had nothing to do with the plant from then until July of 1980.
During July, I participated as a member of an NRC team which evaluated the management organization and technical resources of the Metropolitan
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Edison Company corporate organization and the TMI-1 plant organization.
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What is the purpose of this testimony?
A.
The purpose of this testimony is to respond to the contention identified as "Aamodt #2," with respect to personnel who do not require an NRC license.
The Aamodt #2 contention states:
"It is contended that THI-l should not open until the performance of licensee technicians and management can be demonstrated to be upgraded as certified by an independent engineering firm. This upgrading should include 100% test perfonnance of job description with provision for retraining and retest, or discharge of those who cannot consistently and confidently master all necessary information for safe conduct of their job descriptions under all anticipated critical situations as well as routine situations."
Q. What is your overall reaction to this contention?
i A.
We believe that the means that have been and are being used by the NRC staff are sufficient to provide assurance that the THI-1 plant can be h
operated safely. We see no need for testing and certification of licensee personnel by an independent engineering firm. Further, in our view, k
personnel qualifications are only a part of the provisions that are needed
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to assure safe plant operation.
Q.
Can you describe the means you referred to that the NRC uses to assure that non-licensed plant perscanel are qualified and that safety related activities are properly performed?
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'k' A.
We use a multi-faceted approach which provides acceptable assurance that needed tasks at the plant will be properly accomplished. This includes establishing
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requirements for a basic level of qualifications of plant personnel (includ-ing training), administrative controls over the work being performed to assure that it is done correctly, and operability testing of equipment after the work has been completed to assure tht it is functioning properly.
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Q.
Can you briefly desc ibe the basic level of qualifications that were in effect prior to the TMI-2 accident?
A.
Yes. The NRC position on the question of personnel qualifications prior to the THI-2 accident was set forth in Revision 1, dated September 1975, to Regulatory Guide 1.8, " Personnel Selection and Training." Revision 1 to Regulatory Guide 1.8 endorsed the requirements of the American National Standards Institute (ANSI)/American Nuclear Society (ANS) Standard N18.1-1971,
" Selection and Training of Nuclear Power Plant Personnel," as an adequate basis for the selection and training of nuclear power plant personnel. A copy of ANSI /ANS N18.1-1971 and a copy of Regulatory Guide 1.8, Revision 1, September 1975 will be filed as exhibits in this proceeding. Note that Regulatory Guide 1.8, Revision 1, actually is labeled Revision 1-R and dated May 1977. However, as explained in the guide, it is identical to the September 1975 version.
Q.
Did Met-Ed personnel meet these qualification requirements?
A.
At the time of licensing Tf11-2, the plant staff met these qualification requirements.
Q.
Have any changes been made to the standard or the Regulatory Guide since the Tt11-2 accident?
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i A.
Yes. A revision to ANSI /ANS N18.1-1971 was approved by the ANSI Board of Standards Review and designated ANSI /ANS 3.1-1978, " Standard for Selection and Training of Nuclear Power Plant Personnel." A copy of ANSI /ANS 3.1-1978 will be filed as an exhibit in this proceeding. In February 1979, shortly before the TitI-2 accident, a Proposed Revision 2 to Regulatory Guide 1.8, endorsing ANSI /ANS 3.1-1978, with qualifications, was issued for pubitc comment. A copy will be filed as an exhibit.
Q.
How does the TMI-1 plant staff measure up to these proposed new requirements?
A.
The licensee has committed to upgrade his qualification requirements for plant personnel to those described in ANSI /ANS 3.1-1978 We have reviewed the resumes submitted in the startup report and consider that all key plant personnel meet the qualification requirements described in ANSI /ANS 3.1-1978.
Q.
Are there any additional changes being made to the ndard or Regulatory Guide since the TMI-2 accident?
A.
Yes.
In May 1979, additional comments regarding personnel qualifications l
were requested on the Proposed Revision 2 to Regulatory Guide 1.8 in light of experience gained from the THI-2 accident. Copies of all comments re-ceived by the staff both on the February 1979 draft guide and as a result of the May 1979 request for comments were provided to the ANS-3 Subcommittee for their use during development of a revision to the ANSI /ANS 3.1-1978 standard. A Draft Revision of ANSI /ANS 3.1-1978, incorporating upgraded qualificatioas, was approved by the ANS-3 Subcommittee on December 6,1979, with the designation ANS 3.1 The Draft ANS 3.1 standard incorporates exten-4 sive revisions in most areas of the standard on which comments were receive Public comments are now being solicited on a Second Proposed Revision 2, r
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September 1980, to Regulatory Guide 1.8 which endorses, with qualifications, the December 1979 revised standard. Copies of the December 6,1979 draft ANS 3.1 and the Second Proposed Revision 2 to Regulatory Guide 1.8 will also be filed as exhibits in this proceeding.
Q.
Can you summarize the significant changes pertaining to non-licensed personn21
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that have been incorporated in the December 1979 draft of ANS 3.1 as compared to the 1971 version of the standard?
A.
The significant changes incorporated into the revised standard include (a) a reformating of Section 4 "Oualification," to separate the topics of educa'tfon, experience and training in order to more clearly define personnel qualification requirements; (b) an upgrading of a number of specific qualification requirements, particularly in the area of education and ex-perience requirements; (c) more definitive guidance on training and retrairing programs including requirements for the use of position task analyses to define required training and the use of simulators in training and retraining pro-grams, and (d) qualification requirements for individuals directing preopera-tional and startup tests.
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As an example of the upgrading, ANSI /ANS N18.1-1971 required that non-licensed operators have a high school diploma or equivalent and that they should possess a high degree of manual dexterity and mature judgement.
The standard recommended that interviews and examinations be used to determine the ability of these non-licensed operators to progress to higher levels of
l responsibility and eventual licensing. By comparison, the new draft ANS 3.1 would require that non-licensed operators have a high school diploma and one year of power plant experience and that they be qualified to perform various tasks at the nuclear power plant by demonstrating performance capability for the tasks assigned and operating knowledge of systems involved and their relationship to plant safety.
In a similar fashion, qualification and experience requirements for other plant personnel have been upgraded in ANS 3.1 from the requirements of ANSI /ANS N18.1-1971. Overall, the changes
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in requirements proposed in the new draft ANS 3.1 and endorsed by the Second Proposed Revision 2 to Regulatory Guide 1.8 should result in a marked increase in the capabilities of the persons on the plant staff.
Q.
Do you believe that the new standard and Regulatory Guide will provide an acceptable basis for operating personnel qualifications?
A.
Yes, we do.
We believe the new qualification requirements will provide an
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acceptable level of education and training for the plant staff. Obviously, the NRC's determination of licensee acceptability after the guide is issued will be based on the subjective judgements of many people.
Q.
What are the staff's plans for implementing the Second Proposed Revision 2 to Regulatory Guide 1.8?
A.
As stated in the Regulatory Guide:
"The NRC intends to apply the remaining parts of this Regulatory Guide to operating plants and plants under construc-tion in conjunction with implementation of Task I.B.1.1, ' Organization and
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. Management of Long-Term Improvements,' of NUREG-0660. Accordingly, it is the staff's intention that all operating reactor licensees will be required to submit a plan by May 1981 for implementation of criteria for qualifica-tion of staff personnel that are expected to be equivalent to the remaining positions of this guide." However, some of the new qualification require-ments described in the standard have already been applied to licensees and pending licensees by NRR letters dated September 13, 1979, September 27, 1979, October 30, 1979 and November 9,1979. In general, these deal with licensed operators and Shift Technical Advisors.
Q.
In addition to the upgrading activities represented by the draft of ANS 3.1 and the proposed revision of Regulatory Guide 1.8, are you aware of other activities that are aimed at upgrading of the plant staff and the support to the plant?
A.
Yes. There has been a significant effort underway by the staff to establish 5
a set of guidelines for the utility management structure and the technical resources that should be available to support the plant operation. This effort has resulted in the issuance, in September 1980, of a draft staff report, NUREG-0731, entitled " Guidelines for Utility Management Structure and Technical Resources." A copy of NUREG-0731 will be filed as an exhibit in this proceeding. This document sets forth guidelines for the plant staff and their training and qualifications.
It also establishes guidelines for the utility corporate organization to assure that responsibility for the safe operation of the nuclear plant is clearly established and that technical staff personnel are available to support the plant operation. The document
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addresses these needs for both routine operations and operation under accident conditions.
Q.
And could you tell us the current status of this document?
A.
NUREG-0731 has been issued in draft form for interim use and public coment.
As a matter of fact, however, earlier versions of the document have been used by the NRC staff since February 1980 to aid in evaluating the manage-ment structures and technical resources of a number of utilities who had applications pending for operating licenses for nuclear power plants. Our intent is to receive comments from all interested parties on the current version 'of the document, consider these comments, and then re-issue NUREG-0731, if necessary, for an additional round of comments by about i
the end of 1980 According to the present schedule, NUREG-0731 should be issued in final form during the Spring of 1981.
Q.
Has TMI-1 been evaluated against these guidelines?
i A.
Yes. A joint NRC team from the Office of Nuclear Reactor Regulation and I
the Office of Inspection and Enforcement inspected both the plant staff and the corporate offices during the period July 23-25, 1980. A copy of the report of the inspection, Inspection No. 50-289/80-19, will be filed as an exhibit in this proceeding.
In general, the inspection team concluded that the GPUNG and the THI-1 organizational structures and resources were in confonnance with the guidelines. There were minor exceptions as noted in the inspection report.
For the most part, these involve finalization and documentation of procedures, which will ~then be subject to IE inspection for acceptability.
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Q.
On the subject of procedural controls, can you briefly describe the controls in effect prior to the TMI-2 accident?
A.
Yes. The NRC position on the subject of administrative controls prior to the TMI-2 accident was set forth in Revision 2 to Regulatory Guide 1.33,
" Quality Assurance Program Requirements (Operation), February 1978. This Regulatory Guide endorsed the requirement of ANSI N18.7-1976/ANS 3.2
" Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," as an adequate basis for administrative controls for nuclear power plants. A copy of Regulatory Guide 1.33 will be filed as an exhibit in this proceeding.
Q.
Have any changes been made to this standard since the TMI-2 accident?
A.
Yes, ANS 3.2 is currently under revision with the latest document being Draft 5 dated August 1980. The NRC, in an effort to reduce the time to issuance of a completed package, has decided to endorse this Draft 5 of 3
ANS 3.2 with a second Proposed Revision 3 to Regulatory Guide 1.33.
A copy of the proposed revision to Regulatory Guide 1.33 has been filed as an exhibit.
Q.
What are NRC's plans for implementing this revised Regulatory Guide?
A.
The proposed implementation date is January 1,1981. The licensee will be required to describe how TMI-1 complies with the Regulatory Guide, i
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What new administrative controls do you find most significant in meeting the objectives of assuring that work at the plant is done correctly and that operating personnel are aware of the status of safety-related systems?
A.
There are three that we consider to be the most significant. These are:
(1) A requirement for documented shift turnover activities, using checklists to document systems' status and the status of maintenance and test activities.
(2)
- 4. requirement that only the on-duty shift supervisor is permitted to release plant systems for maintenance or surveillance tests.
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(3) A requirement that a qualified operator who holds a reactor operator i
license, and who is knowledgeable about the equipment in question and the affected safety systems, verify the correct implementation of equipment control measures and proper alignment prior to returning to service.
Q.
Will TMI-l be required to meet these new standards?
A.
Yes, they will, prior to a recommendation for restart authorization.
L Q.
In addition to the above, have there been any other upgradings relative to qualifications, training and administrative controls that would bear on the subject in question?
5 A.
Yes. We refer you to the staff testimony provided by Robert W. Reid in this proceeding in resnonse to Board Questions 1 and 5 relative to the staffs' position regarding implementation of NilREG-0594 and/or NUREG-0660 for TMI-l which we sent to the Board on October 14, 1980. In his testimony, Mr. Reid A.
' l stated that "The staff has taken the position that all of the recommendations of NUREG-0660 'NRC Action Plan Developed as a Result of the Tt11-2 Accident' which have been required to be implemented by Babcock and Wilcox designed reactors are required to be implemented by TMI-1."
In NUREG-0660, there are a number of tasks identified in the areas of operating personnel and staffing, management for operations, and operating procedures, that are all aimed at improving the capability of the plant staff to handle the plant during routine operations and to' cope with emergencies. Those tasks described in NUREG-0660 that are required to be j
implemented for new operating licenses are identified in NUREG-0694, "TMI-Related Requirements for New Operating 1.icenses."
In the category of Operating Personnel and Staffing:
Task I.A.l.1 requires that each nuclear plant have a shift technical advisor on duty who has engineering expertise and who has received special training in plant dynamic response. This individual is required to provide
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on-shift advice and assistance to the control room supervisor in the event of an accident and to assist in the evaluation of operating experience.
Each operating nuclear power plant has had shift technical advisors on duty since January of 1980. Ti1I-l will have shift technical advisors on duty at such time as it begins restart operations.
Task I.A.l.2 requires that shift supervisors be relieved of ancillary administrative duties such that they can devote their total attention to the safe operation of the plant. This has been implemented at operating plants and at TMI-1.
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Task I.A.1.3 requires an additional senior reactor operator to be stationed in the control room at each nuclear plant to increase the number of qualified individuals on shift and available in the control room. This task also re-quires that use of overtime be restricted so as to reduce the potential of having tired operators on shift. A letter to all licensees implementing these requirements was issued on July 31, 1980.
For operating plants, imple-mentation of the requirement for an additional senior reactor operator will not be required until mid-1982, although the overtime restrictions are being applied now. TMI-l will be required to be in conformance sith both of these requirements before we make any recommendation for startup.
In the category of management for operations, Task I.B.1.2 essentially pertains to the evaluation of the organization and management of pending operating license applications. As mentioned earlier, we have evaluated the organization and management of TMI-l and its corporate support structure in the same manner as we have evaluated applicants for pending operating licenses since the TMI-2 accident. We have concluded that the GPU Nuclear Group and the TMI-l organizational structures and resources are in conformance with the staff guidelines.
Tasks I.C.2 through I.C 5 have to do with administrative procedures for operation and are aimed at achieving an improvement in the quality of instruc-tions to provide greater assurance that operator and plant staff actions required by the procedures are technically correct, explicit and easily understood for normal, trarsient, and accident conditions.
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l Task I.C.2 - Shift Relief and Turnover Procedures This task requires revised plant procedures to require the use of signed checklists and logs to assure that the operating staff, including auxiliary operators and maintenance personnel, possess adequate knowledge of critical plant parameter status, system status, equipment availability and alignment.
As detailed in the Evaluation Report (ER) supplement, U4 licensee has established such shift relief turnover checklists.
Task I.C.3 - Shift Supervisor Responsibilities This task requires that proced; es be revised to clearly define the duties, responsibility and authority of the shift supervisor and control room i
operators, and that corporate management issue a directive that clearly establishes the command duties of the shift supervisor and emphasizes his primary management responsibility for safe operation of the plant. As detailed in the ER, the licensee has issued such a directive and has l
revised Administrative Procedure AP-1009 to clearly establish the line of command during both normal and off-normal conditions.
Task I.C.4 - Control Room Access This task requires plant procedures which limit access to the control room to those individuals responsible for direct operation of the plant, or who are needed for support of the plant operation, and which establish a clear line of authority, responsibility and succession in the control room. TMI-1 has revised the procedures to accomplish this task. As detailed in ER i
Section 2.2.2.a. we have accepted this revision.
. Task I.C.5 - Procedures for Feedback of Operating Experience to Plant Staff This task requires procedures to be in place that will assure that operating experience information is fed back to the plant staff.
For TMI-1, as detailed in Section III.C of the ER supplement, the licensee has established procedures which should adequately accomplish this feedback of information' to plant and corporate personnel who need it. However, one of the procedures was still in draft form at the time of our July inspection of the licensee.
We will complete our review in this area af ter the procedure has been fonnally issued, but before any recommendation to authoriz'e startup.
Q.
What is'your view then as to the adequacy of the new requirements?
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A. We believe that the new requirements as described in the revised standards and Regulatory Guides and as covered by NUREG-0694 provide an acceptable level of qualifications and administrative controls to assure that safety-related activities are properly performed.
j Q.
So you do not see a need for testing and certification of the performance of l
licensee technicians and management by an independent engineering firm?
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A.
No,we do not. Testing, of course, is a way of obtaining assurance that people can do their jobs properly.
It does not necessarily follow, however, that the work will be done correctly. Further, for something as complex as a nuclear plant,100% testing is probably not practical. We believe _that the NRC multi-faceted approach provides better assurance that needed tasks at the plant will be properly accomplished. This includes establishing a basic level of qualification of plant personnel (including training), improved
a procedural controls over the work being perfonned to assure that it is done correctly, and operability testing of equipment after the work has been completed to assure that it is functioning properly. In the case of THI-1, we believe that we have made acceptable provisions for this multi-faceted approach. There has been a significant increase in the qualification re-quirements and in the training to be provided to all plant personnel at TMI-1. In addition, we have made provisions for extra technical expertise
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to be readily available to provide on-shift advice. We now require an additional senior reactor operator to be on shift and avaliable in the control room. We require procedures for shift relief and turnover. We have required that administrative procedures for operation be reviewed and 4
revised where necessary to assure that they are correct, explicit and easily understood. We have examined the corporate management organization and have concluded that it is acceptably structured and staffed to provide adequate support to the THI-l plant and that there will be adequate attention paid to plant safety.
j Q.
So, in your view, can TMI-l be safely restarted without requiring testing by an independent engineering firm?
A.
Yes, based upon the improvements that have been made in the areas of organi-zational structure, technical resources and capability, administrative-controls, and procedures, as noted above.
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August 1980 o
LAWRENCE P. CROCKER PROFESSIONAL QUALIFICATIONS I am a Senior Management Engineer in the Licensee Qualifications Branch of the Division of Human Factors Safety, Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission.
I graduated from the U.S. Military Academy at West Point, New York in 1951 with a Bachelor of Science degree in military engineering. I was com-missioned a Second Lieutenant in the Corps of Engineers, U.S. Army.
I served on active duty in the Corps of Engineers from then through August of 1970, at which time I retired in the grade of Lieutenant Colonel. My military experience included assignments as platoon leader, company com-mander, and battalion commander of various engineer units; overseas duty in Korea, Japan, the Azores and Thailand; and service on the Army General Sta f f.
During my military service, I attended various Army schools in-cluding the Army Command and General Staff College.
In 1955, I entere Iowa State College, from which I graduated in 1956 witt.
a Master of Science degree in Nuclear Engineering. The following year was spent attending the Oak Ridge School of Reactor Technology (ORSORT) at the Oak Ridge National Laboratory (ORNL). Upon graduation from ORSORT, I re-mained at ORNL for an additional year as Technical Liaison Officer for the Army Nuclear Power Program with the responsibility of representing the Army's interests at ORNL. From 1958 to 1960 I was a Project Officer in the Army
2-Reactor Branch of the Atomic Energy Commission with responsibility for managing, coordinating and technically. supervising contractor activity on a z....
research and development project leading to design of a pressurized water nuclear power plant.
After a 3-year break for an overseas tour and' attendance at an Army school, I was assigned in 1963 to the Office of the Inspector General, Department of the Army, where I was responsible for inspecting the operations and safety of the Army's nuclear power plants and research reactor facilities.
- From 1964 to 1967, I was assigned to the Office of the Chief of Research
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anc Development where I served as the point of contact within the Army General Staff on all matters pertaining to research and development on the Army's nuclehr power plants and research reactor facilities.
From 1968 until retirement from the Army in 1970, I.was the Deputy Director of the U.S. Army Engineer Reactors Group, with responsibilities including operator training, nuclear power plant operation, engineering support to the operat-ing plants, and limited research and development activity.
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.j F-Upon retiring from the Army, I accepted employment with the U.S. Nuclear l
Regulatory Commission, (then the U.S. Atomic Energy Commission) as a Project Manager in what is now the Division of Licensing.
In this capacity I was responsible for the safety evaluation of the Kewaunee Nuclear Power Plant which was licensed for operation in December 1973 and for the Alvin W. Vogtle Nuclear Plant which was licensed for construction in June
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of 1974.
I had primary responsibility for the safety review of the
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Koshkonong Nuclear Plant.
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. From August of 1976 until January of 1980, I was the Technical Assistant to the Director of Project Management.
In this pos! tion, I was responsible for preparation of periodic reports to the Advisory Committee on Reactor Safeguards on the status of resolution of the ACRS generic items.
I served as the representative from the Division of Project Management on the Advisory Group to the Technical Activities Steering Committee from the time that group was formed in February of 1977, in which capacity I participated in the develop-ment of the NRR program to handle generic technical activities.
During the l
period from May of 1979 through December of 1979, I served as a member of the NRC Special Inquiry Group investigating the Three Mile Island accident.
In January 1980, I was detailed to lead a small group working on development i
of criteria describing acceptable utility management structures and technical resources necessary for safe nuclear power plant operation.
In May of 1980, this function was absorbed by the newly created Licensee Qualifications Branch of which I am now a member.
During the period January through July of 1980, I participated in management reviews of the corporate organizations and plant staffing for those utilities proposing to operate the Sequoyah, Salem Diablo Canyon, and McGuire nuclear plants. Similar reviews also were conducted for the Zion nuclear plant and for the Three Mile Island Unit I nuclear plant.
I am a Registered Professional Engineer in the District of Columbia.
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Frederick R. Allenspach June 1952
- Graduate - Polytechnic Institute of Brooklyn
- Degree in Bachelor of Mechanical Engineering July 1952 to August 1953
- New York Naval Shipyard August 1954 to August 1956
- Republic Aviation Corporation August 1954 to August 1956
- Military Service September 1956 to June 1968
- Employed by the Brookhaven National. 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 responsible 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 Le,ader responsible for all operational aspects of the reactor.
Included during this period at Brookhaven National Labor:. tory were several short term supplemental assignments to Brookhaven National 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 include (as assigned); review and evaluation of applicants organizational structure, technical and administrative qualifications of applicants proposed reactor operating organization, including emergency plans and industrial security plans; development of guides and codification of E
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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 May 1980 Employed by the AEC/NRC, Division of Project Management, Quality Assurance Branch. My responsibilities include review and evaluation of applicants organizational structure, 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
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licensed reactors; and the developne.nt of uniform acceptance criteria for subjects req'uired to be addressed by license applicants relating to operational safety matters.
I May 1980 to Present Bnpinyed by the NRC, Division of Human Facters Safety, Licensee Qualifications Branch. My responsibilities include establishing requirements and qualification standards for licensee management and plant personnel; review and evaluate the technical and managerial quali-fications of applicants and licensees; and the developnent and review of administrative controls for the operation of ifcensed reactors.
I have attended the MIT course on Light Water Reactor Safety, attended the POP 0 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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