ML19347F413

Forwards Response to NRC Concerns Raised at 810511 Meeting Re Mgt & Technical Capability

ML19347F413
Person / Time
Site:	Waterford
Issue date:	05/15/1981
From:	Wyatt J LOUISIANA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
W3P81-1282, NUDOCS 8105190214
Download: ML19347F413 (7)

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LOUISIANA 242 ceancNee srnser POWE A & LIGHT P O BOX 60C8

• NEW CnLEANS. LOUISIANA 70174 + (504) 366-2345 N SsvSb

.) M. WYATT Presodenc and May 15, 1981 cn,,e a , cue,v,arr,cer W3P81-1282 3-A1.01.04 c

A, l's S ..h Mr. H. Denton Director of Nuclear Reactor Regulation p [ /g U  ;/ ; p

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U.S. Nuclear Ragulatory Commission -

Li 't Washington, D.C. 20555 5 Ej u,,, knAl/;y2 8 g J

SUBJECT:

WATERFORD 3 SES / '8E;,%.,

DOCKET NO. 50-382 b".

MANAGEMENT AND TECHNICAL CAPABILITY ',Dw_ 3 , ' '

Dear Mr. Denton:

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At our meeting in your offices on May 11, 1981, we agreed to provide a response to your concerns in the subject area. The attached is our response to these concerns, and this information has been provided to your staff for consideration in the Safety Evaluation Report to be issued on May 30, 1981.

We will aggressively contin'te our efforts to improve our nuclear organization and will keep your staff informed as to our progress.

Yours very truly, I

J. M. Y att JMW:FJD:ver i

! Attacha nt cc: Mr. E. Blake Mr. W. M. Stevenson l

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Before the UNITED STATES NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-382 In the Matter of Louisiana Power & Light Company MANAGEMENT AND TECHNICAL CAPABILITY SUBMITTAL Louisiana Power & Light Company, Applicant in the above captioned proceeding, hereby files a Management and Technical Capability document to its Application for Licenses.

Wherefore, Applicant requests the licenses specified under Docket No. 50-382.

Respectfully submitted.

l LOUISIANA POWER & LIGHT COMPANY l

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M'. Wyat V President'& Chief Executive Officer DATE: f- I f-8/

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. STATE OF LOUISIANA)

) SS PARISH OF ORLEANS )

J. M. Wyatt, being duly sworn, states that he is President & Chief Executive Officer of Louisians Power & Light Company and that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission this document.

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7. M. att SUBSCRIBED AND SWORN to before me, a Notary Public in and for the Parish and State above named, this day of , 1981.

I Notary Public My Commission expires:

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May 15, 1981 RESPCNSE 'IO NFC MAMT AND TECHNICAL CAPABIIIfl CDNCERNS In discussion with members of the NRC Staff questions were expressed relating to the experience level and authority of LP&L persenml. In order to provide respenses to these expressions we will pose the questicns as we unde &=i.w i them followed by our respcnses.

NPC QCESTICN NO. 1:

l 'Ibe questicn was raised as to the apparent lack of counercial nuclear cperating l experience in LP&L's upper management organization. 'Ibe statement was made that there is no cne above the Plant Manager and the Offsite Support Manager who has cperating nuclear experience. 'Ihe Plant Manager and Offsite Support Manager have Navy experience, but the cnly significant wmau 2al nuclear experience in LP&L's managment frcm the level of Plant Manager and Offsite Su p Manager upward appears to be in the licensing and constructicn of a l nuclear power plant.

'Ibe NPC Staff believes that cmmercial nuclear opting expedence should be provided in LP&L's upper managment organization or be avmlable to LP&L's upper managemnt crganization en a full-time basis until such time as IP&L's upper managernent has the mquisite cmmercial operating nuclear experience.

1 RESPONSE 'IO QUESTICN NO.1:

LP&L er:phasizes, together with an appreciaticn of the technical subject, the managernent car *ilities of its upper management. Proper selection of middle managernent has resulted in middle managenent with sw technical and manage-nent credentials. Close working relationships have been developed between upper and iniddle mrmagement to ensure adequate and ccTetent decisica making.

l Both Mr. Iester, the Plant Manager, and Mr. Drumend, the Offsite Support Manager, are Navy veterans. In the Navy they acquired 6 years and 5 years rr.: clear experience respectively. Since joining LP&L they have accanulated l cm siderable experience with ca mercial nuclear power. Mr. Iester has 10 l years respcnsible experience en the Waterford 3 Project and Mr. Drumcrd 5 l years of simila experience. Mr. Drumend has also empleted the acadeic l portion of Cold License Training as well as having received 3 weeks of aesearch Beactor Training and 10 weeks of Cbservation Training at the St. Lucie Plant of Florida Power & Light Ompany. In the case of Mr. Iester, plant personnel i in his organizaticn and interfacing with him on a day by day basis will l have camercial War power plant experience. Mr. Dru:mond's staff will l have experien czmensurate with their duties. It is the intent to have l personnel within the Offsite Suw.um Staff who have operating nuclear exper-1 ience and/or experience in swding c.patai.l.rg nuclear facilities.

In addition to these experienced individuals IP&L will provide ccumercial nuclear operating experience within its uppez manecement organization. We will have en board or will enploy a censulunt with ccmnercial nuclear opting experience en a full-time basis to assist the Assistant 5

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Page 2 Vice President-Nuclear Operations. 'Ihis assistant will report directly to the Assistant Vice President-Nuclear Operations. He will be in place, if at all possible, prior to Octo,er 15, 1981 and it is anticipated that he will be available through the sta2.Zg rf the plant and as long thereafter as is required for the Assistant Vice President-Nuc: lear Operaticns to gain the requisite experience. 'Ihis individual will have a strcng background of nuclear operati m experience.

'Ibe assistance to be provided by this consultant will be as follows:

1. Act as a consultant to the Safety Review Ccmmittee.

2. Evaluate and pr: vide advice en the working rala*imships intemal to the 1-lant Staff and the Interfaces of the l plant staff with the Offsite Suppor- Organization.

3. Provide assistance and advice in the areas of operational '

staffing, trsuung, and crganizaticnal structure.

4. Provide assistance and advice in the area of NBC and Industry experience utilization within the Waterford 3 crganizations.

5. Overall assistance and advice an the startup and c p tion of Waterford 3.

NBC CCESTION NO. 2:

Describe LP&L's plans to ensure that both the plant managenent and each opting shift will have available adequa'a ccmercial nuclear power plant operating experience.

RESPotSE 'IO QUESTION NO. 2:

I2&L's plant manager has had six years of experience, including operaticos, in the nuclear Navy. Since leaving the Navy, he has had 10 years of respansible experience an the Waterford 3 Project, involved in design, ccnstructicn and startup. Repcrting imediately to the plant manager and interfacing with him on a day-by-day basis will be two assistant plant maragers. 'Ibe Plant Services Assistant Plant Manager has been involved in the design, ccnstruction and startup of Waterford 3 for 4 yem and has six nonths of ccmnercial nuclear power plant cpting experience on a PWR. 'Ibe Plant Services Assistant Plant Manager successfully ccrupleted 13 weeks of hot livanse schooling at Millstom 2.

He had 6 nonths of cn the jcb training at Arkansas Nuclear Caa. In conjun-

ction with fcrmal training for an SRO License he had 10 weeks of Observation

! Training at St. Lucie, 8 weeks of Simulator Training on the C. E. Sinulator in Windscr, Connecticut and 3 weeks of Research Reactor Training at the University of Florida.

t i 'Ibe Assistant Plant Manager Operations and Maintenance is presently being recruited by LP&L; eight carA1Mtes have been identified and LP&L expects to make an offer by June 1, 1981. LP&L ccmits to fillits this positicn with an individual who has a BS degree and a minimum of five years of operating nuclear experience of which at least three are en a ecmnercial PWR. Addit-

! ionally, LP&L is actively reen:iting an Optiens Superintendent and has '

l identified six candidates. An offer to fill this position is expec'ad to be .

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Page 3 made by June 1, 1981. IP&L otmrits to fill this position with an SRO-licensed indivia mi with at least three years operating PWR experience.

. Further details on personnel gulificaticns of vital personnel being recruited for the plant's operating and engineering staffs, which include as a prerequisite camercial operating experience, were provided in l I

Attachnent C of Mr. Wyatt's letter to Mr. Denton of April 20, 1981. 'Ibers plans provide that every operating shift at Waterford 3 will have an individual with cxxrmercial PWR nuclear power plant experience. IP&L ccmnits to meet that experienced criterion and expects to meet it by qualified IP&L shift personnel.

In the event, however, that IP&L's intensive recruit:nent efforts do not yield this result, then IP&L will meet this ccatu.tment by securing individuals with such operating experience to stand shifts with IP&L opting per-sonnel at least through Waterford 3's ccmnercial opting date while IP&L's shift auployees gain valuable hands cm experie.w .

'Io further assure that the plant staff and particularly the Waterford 3 Plant Manager have available at the time of initial plant operation sufficient ccmnerM nuclear power plant experience, IP&L ccmnits as well to have on board or ccntract for the services of an individual with a strong back-ground of nuclear cperating experience who will function en the i:rmediate staff of the Waterford 3 Plant Manager. 'Ihis indiv,6m1 will be available to the Plant Manager through startup of the plant and as 1cng thereafter as is required for the plant management to gain actual cperating experience an Waterford 3.

NRC C0w110N NO. 3:

, Fran the submissions received to date it is not clear to the NRC Staff that the Assistant Vice President-Nuclear Operations has the requisite authorities to effectively perform as the "managenent official in overall charge of nuclear power " IP&L shculd previde this assurance by clearly delineating the authorities of the Assistant Vice President-Nuclear Operations as related to: hiring and firing; the ability to get the necessary resources; the initiatien and executica of contracts; the ability to approve er d4 ==m decisions and requirements; the ability to approve and upgrade or downgrade plans and petw; and, the ability to es+ ahli=h and carry out plans and activities. Will his respmsibilities emphasize operations? In his role as " corporate centact with the regulatory agencies" will he sign papers?

Is he the designated officer handling affidavit h=nts to the NRC?

RESPCNSE 'IO CCESTICN NO. 3:

'Ihe Assistant Vice President-Nuclear Operations is rw m ni

• both within and outside of IP&L as IP&L's officer r==pm=ih1e for the Waterford 3 effort.

At present, that authority is generally w- %i with design, constructing and startup; ==c.ing with authorizaticn to operate Waterford 3, that i authority will be primarily to safely operate and maintain the plant. In this capacity he has ccuplete authority in matters pertaining to Waterford 3 so long as his actions and awwvals and ch-imicns are in cxmformity with the coupany Policy Manual. In this Manual are general Policy Bulletins, over 60 in nunber, which are used in cmducting Ccx:pany business and which are binding to all IP&L officers and suployees. His authcrities im1 +

a=roval and disapproval. In sane cases where tire and conditiens pe it, -

censultation with higher authority may be desirable. ,

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Page 4 aelating to the authority to fire individuals, the Assistant vi President-Nuclear Options, in acocM-a with written policy, has the right to sus-pend i=nad_iately and to renove frm Ccznpany prenises anyone under his supervision. Suspensions of this type are thereafter subject to typical erployee relations review.

In regard to hiring, DE's policy now requires that auployment of hourly rated and "entrr level" salaried enployees within the Power Production Departnent receive the approvals of the Director of P=.wud and the Vice President-Power Producticn. These approvals are also required for the hiring of other calaried and supervisory p=.,uual. 1?e hiring of other higher level salaried pmsuiuel and all supervisory personnel, requires the approval of the Senior Vice President.

Ite highest levels of DE's um%-mii. recognize the inportance of enploy-ment of highly capable individuals in the nuclear divisicn. Reccarmendations j for hiring will receive prcanot managenent acticn by all IPE senior management up to and including the President.

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The Assistant Vice President-Nuclear Operaticms has the authority to engage contract forces necessarf for the safe startup and operation of the plant.

Further, the Assistant Vice President-Nuclear Operaticms has the authority to engage without mcoetary limit those centract forces which may be required for the safe operation of the plant or to protect the health and safety of the er:ployees of Waterford 3 and the u=ams of the general public.

For sound corporate reasons the authority to execute centracts is limited to the Senior Vice President and the President. However, with Waterford 3, as with other areas of ooeraticns, IPE will have open ocntracts or purchase orders for services which might be required on an energency hacia. Further, the Assistant Vice President-Nuclear Operations has the authority to enploy contractors when necessary on an emergency basis to begin pathuig servies subject to a confirming purchase order and until such time as a formal m a= =it can be negotiated and executed.

The Assistant Vice President-Nuclear Operaticms has the authority to approve plans, programs and schedules and the authority to either puuici.a or downgrade the nuclear plant industrial security plan, fire protection s, u, and plant staff training s ug.au. As involves the OA Prosau, the Assistant Vice President-Nuclear Operations has no authcrity other than to reccmnend the gudion or downgrade of this plan.

In his role as "corocrate contact with the rs;ulatory gencies" the Assistant Vice President-Nuclear Operaticns will mally sign all cor-respera'r.me to the NRC with the exception of correspondence uniquely concerned with OA. He is the desigaated officer handling affidavit doc-unents to the NRC with the excepticn of u.u.2=spe-dence uniquely wamised l

l with OA.

D E is satisfied that with its Assistant Vice President-Nuclear Operations, l

it has met NRC guidance for a high level corpcrate official with exclusive nuclear respcnsibilities. Both the Vice President-Power Production and the Senior Vice President of DE understand the importance of nuclear matters and their involvenent in high level decisions is considered an asset rather than a detriment. In any event, as reflected in our April 20th filing, '

the Assistant Vice President-Nuclear Operations ha direct access to the ,

President when conditions in his view dictate that need.

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