ML19344D145
| ML19344D145 | |
| Person / Time | |
|---|---|
| Site: | Millstone, 05000496, 05000497  |
| Issue date: | 03/01/1980 |
| From: | Counsil W NORTHEAST UTILITIES |
| To: | Skovholt D Office of Nuclear Reactor Regulation |
| References | |
| WGC-80-G-144, NUDOCS 8003110418 | |
| Download: ML19344D145 (7) | |
Text
i PEDEFTlEEJtBT LFFELFFEES we come<*euvienne m nema-P.o. Sox 270 l
%"_" "'***A*a",,",,,e,,,,,
MARTFo80. CONNECTICUT 06I01
.,.'17.L""'.O" ". c"e g
g J
wn.um o. couwst.
vce PassCENT mxuanm=womoucamunm.
March 1, 1980 i
WGC-80-G-144
)
Mr. Donald J.
Skovhclt Assistant Director Quality Assurance & Operations U. S. Nuclear Regulatory Commission.
Washington, D. C.
20555
Dear Mr. Skovholt:
Northeast Utilities has reviewed the " Criteria for Utility Man-agement and Technical Competence".
We understand that the purpose of this document is to promulgate criteria for nuclear plant staffing in accordance with the general recommendations of the various Three Mile Island investigative groups, and to describe an acceptable organizational structure and competence level for nuclear power. plant operation.
However, we find that the thrust of the document is to. address itself primarily to the qualifications and areas of expertise deemed necessary for operation and control-of a nuclear plant under both routine and accident conditions'.
We agree conceptually with the overall plan to define technical com-petence in normal and emergency operations and generally concur with the overall requirements.
A.
General Comments As a general comment, Northeast Utilities (NU) is in agreement with the key characteristics of the organizations depicted by the NRC as being acceptable.
However, we believe it is essential that the NRC define broad criteria and organizational structure to permit licensees adequate latitude to implement them as they believe most effective.
We urge that the NRC maintain a high degree of tiexi-bility in interpreting compliance of specific organizations in meeting che intent of these criteria.
It appears to us that the NRC may be attempting to ectablish definitive criteria too quickly.
We urge that caution be exercised lest the licensee be forced to spend huge sums of time and money meeting basic requirements which are still evolving.
In our view, the criteria should be firmly developed before inflexible dead-lines for implementation are set.
Irrespective of the above, we find that in most instances, NU meets the general objectives of the criteria.
- [*
P 800a11o M
u
We question the NRC's apparent preference for committees, i.e.,
On Site Safety Review Group, Senior Management Oversight Group, etc., as opposed to direct line management.
Although NU believes there is a need for certain committees, particularly when multi-discipline problems occur, it appears to us that some of the tasks assigned to these committees should be conducted by line management or supervisory functions.
As a final general comment, it has been our understanding that the Institute of Nuclear Power Operations (INPO) was to establish industry-wide benchmarks for excellence in nuclear operation and to conduct independent evaluations to determine if the benchmarks are being met.
The Institute was to review and analyze nuclear power operating experience, including that from other countries, and feedback in-fonnation to the utilities.
It was to utilize this inforaation in establishing educational and training requirements for operation and maintenance personnel.
Approved training programs were to be accredited and qualified instructors certified.
Also, seminars and generic training were to be provided to utility employees, includ-ing utility executives and upper management.
However, it appears to us that the requirements in this document are so specific that the " benchmarks for excellence" have been dictated by-the NRC without ' experienced operational review.
- Thus, we find that INPO's role in this ef fort has apparently been pre-empted.
B.
Specific Comments Northeast Utilities has many specific comments and they are provided below.
However, we wish to point out that most of these are directed towards what we believe to be a serious defect that pervaded the document.
That is, the document directs the licensee as to how particular criteria are to be met rather than permitting the licensee to develop and implement an acceptable program.
In many cases, the criteria or bases are not even presented.
Generally, the document merely lists specific requirements.
These range from specifying aducation, training and number of persons required for specific assignments, to designating acceptable numbers of hours worked.
It provides no flexibility to accommodate multiple unit sites nor does it permit a utility as NU with hundreds of man-years of nuclear experience to draw on this asset.
As a specific example of our concern, the proposed criteria describes an On Site Operational Support Center for the Site Support Manager who would be the interface between the Plant Manager (Station Super-intendent) and the Recovery Managar (Vice President for Nuclear l
[
Power).
The Site Support Manager, however, reports to the Technical Support Center (TSC) Supervisor (Plant Manager who _ is located in the TSC).
Based on our Millstone site, with multiple and different types of units, we would prefer to have the Plant Manager respond directly to the Recovery Manager, as presently exists.
Also, the Plant Manager should be located in the Site Emergency Operations Center (EOC) instead of the TSC.
A manager with a unit senior operator -license, designated the emergency duty officer, should be in charge at the TSC and provided with the necessary staff to place the unit in a safe condition.
The Plant Manager should be in the site EOC and should be concerned with minimizing the effects of the incident on the site, as well as the surrounding areas.
It appears that minimal concern has been directed towards the problems of personnel and resources control on-sito during an incident.
Additionally, there is a need for a Station Manager to not only properly support the task of placing the affected unit in a. safe condition, but also in minimizing the affects of the unit on the on-site staff as well as the surrounding populace.
Our specific comments are as follows:
1.
Shift Crew
" Shift staffing should be sufficient to assure that:
scheduled work periods do not exceed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> straight; at least a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> break is provided between work
. periods; no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of work is scheduled in any 7 day period; no more than 14 consecutive days are scheduled without having 2 consecutive days off."
NU Comment The NRC should provide criter.ia, not set explicit work rules.
This is a typical example of our concern about imposing detailed requirements.
In addition, this particular rula will be problem during refueling; NU may not have enough manpower.
Also, it can cause a general recurring problem due to attrition, vacations and periods of wide-spread illness.
2.
Management Resources "The management official in overall charge of nuclear
. power (e.g., Vice President Nuclear Power, Figure 1) shall be actively involved in nuclear plant operational activities.
Functions which should be performed (under-line added) by this official include:
~
"The, establishment and approval of the quali-fication requirements for all plant staff positions.
" Active overall managerennt of safety review groups that perform independent reviews of j
o important matters affecting safety.
"The establishment and supervision of functional units providing review of operational activities independent of the plant staff.
NU Comment F1nctions to be performed by the Vice President Nuclear Pus should not be specified.
We cannot agree that he shot i " supervise functional units", or provide "overall manas.oent of safety review groups" or " establish.
the qualification requirements for all plant staff positions".
If it is intended that he should be deeply involved in, and responsible for these functions, then we would agree.
If this is the case, we would strongly urge that the words be changed to reflect this intent.
3.
Senior Management Oversight Group "Each utility-owner shall establish a senior level over-sight group that provides a means for corporate management to be involved in nuclear power plant safety.
"The senior management oversight group should be com-posed of 3 to 4 persons at the Vice President level such as the vice president for power production, vice president for engineering and vice president for planning and research.
The group should meet monthly.
NU Comment We disagree with the need and logic to form such a review group.
The vice president for nuclear power is responsible for nuclear plant safety.
Vice presidents in other non-nuclear areas such as R&D, purchasing, etc. do not have the necessary training nor experience to centribute significantly_to plant safety.
This requirement would needlessly burden the vice president for nuclear power and we believe it should be deleted.
4.
Offsite Technical Staff Resources
" Provisions for this offsite technical support to the plant staff, as a minimum, shall be as follows:
" (1)
=
"(3) assignments shall be of a full-time nature to assure current knowledge of the nuclear unit's design and operation.
"(4) Qualifications of persons in the technical areas described above shall include a Bachelor's Degree in Engineering or the Physical Sciences and three years of profes-sional experience in the field for which they are providing technical support."
NU Comment Assignments of a full-time nature do not make good sense for a utility with multiple units.
In some circumstances it could reduce safety by precluding a more experienced person from working on a unit because it was required that he be assigned full-time to another unit.
In addition, we disagree with the requirement that all persons on the technical staff have three years of experience.
This appears to be another example of unjustifiably specifying details.
We believe that less experience may be acceptable in some areas, particularly if the work is properly reviewed and monitored.
5.
Off' site Resources - Training
" Training shall be provided to those personnel not reporting to the plant manager but who provide techni-L cal support to the plant staff.
training programs for technical support personnel shall train persons in the following areas:
"Information on LERs applicable to their facility;
" Current status of plant design changes and modifications; "Informatic.t on applicable codes and' standards;"
NU Comment In our view, technical support personnel do not need
-tr*.ining in status of all design changes, current codes or LERs -until they are to work on a particular system.
At that time, the procedures must specify checks and balances on their performance.
+
s a
w
6.
Offsite Recovery Staff Resources
" Technical Support Manager's Staff - the Technical Support Manager shall have available a staff with the expertise and qualifications listed in Table 2.
In addition, this staff shall include representatives from the NSS supplier, architect / engineer, and con-structor of the plant.
These representatives will act as liaison officers between their company and the licensee and may perform other technical tasks if time permits."
NU Comment Although we agree with the need to have support from the NSSS supplier, we see no justification to require represe.ntation from the architect / engineer or the constructor of the plant.
Generally, their involve-ment with the nuclear systems was minimal and in many instances they have not been associated with the plant since construction completion.
7.
Operational Support Center "b.
Near Term - The following personnel shall be available in the Operational Support Center-within one hour of the determination that an accident condition exists.
" (1)
" (3) Operating personnel - At least one full shift complement of licensed and non-licensed operators as specified in the Technical Specifications, in addition to the shift complement already on site.
" ( 5) Security Force - Sufficient personnel to man one additional shift."
NU Comment We cannot understand the need for an additional operating and security shift loitering in the operational support center (OSC) prior *to the time they report on duty.
We believe these additional personnel will over crowd the OSC and hinder the performance of on-going activities.
8.
Onsite Resource and Activities "The utility-owner shall provide for an onsite post-accident organization to cope with an accident situation.
Although the plant staff organization can reflect variations in company policy and procedures as established in Section II.A of these criteria, a representative organization is shown in Figure 3.
NU Comment We agree that there should be flexibility in estab-lishing the on-site (und also the off-site) organizational structure.
The conceptual organization present in Figure 3 of the document is quite different from that currently employed by NU.
We urge the NRC to emphasize that Figure 3 is a " representative organization" and that there are others which are equally acceptable.
It is intended that the preceding comments be constructive and provide guidance in your efforts towards draf ting the final regu-lations.
We are sincerely concerned with the safety aspects of our nuclear operation and believe that sound, rational regulations are a necessity.
Very truly yours,
/,. gf//)&
W. G. Counsil Vice President WGC/jmm ce; J. J. Kearney EEI C Walske AIF L