ML20010C377
| ML20010C377 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/14/1981 |
| From: | Dewease J, Goldberg J, Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20010C376 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8108200028 | |
| Download: ML20010C377 (50) | |
Text
_
1 . n .u.1 D C01'PI5PONDENCE fN7 )p[I'd}
' 7 ' '
l5 ($ '
- 1 l 1381 y k
y 8 g ,
)
9 0
UNITED STATES OF AMERICA h .
e/
NUCLEAR REGULATORY COMMISSION 1, dj/
12 l 3l 4
BEFORE THE ATCMIC SAFETY AND LICENSING BOARD 5
6 In the Matter of: 5 7 5 g HOUSTON LIGHTING & POWER S Docket Nos. 50-4980L 9 COMPANY, ET AL. 5 50-4990L 0 5 1 (S uth Texas Project, 5 22 Units 1 & 2) 5 4
TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
6 U
28
' "a oz "o" " ova"^ 3a-I30 MR. JEROME H. GOLDBERG .
31 MR. JERROLD G. DEWEASE 2 MR. ROBERT I. MOLES F33 MR. RICHARD A. FRAZAR 34 -
m35 REGARDING 536 37 THE OPERATION OF THE SOUTH TEXAS PROJECT 38 39 40 41 42 43 44 14546 47 48 49 l 50 51 '
8108200028 810814 PDR ADOCK 05000498 T PDR
...o 5
l l I1I 2 l
l 3 )
I4 5 6
I7l 8!
9I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Il0 11 l 12 13 , BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 14 !
15 In the Matter of: 5 l16 17 18 HOUSTON LIGHTING & POWER 5
5 Docket Nos. 50-4980L 19 COMPANY, ET AL. 5 50-4990L 5
1 21 20 (South Texas Project, 5 22 Units 1 & 2) 5 5
1 24 23 25 Testimony of Gcorge W. Oprea, Jr., Jerome H. Goldberg, 2o Jerrold G. Dewcase, Robert I. Moles and Richard A. Frazar 2 Regarding che Operation of the South Texas Project 29 30 -
31 Q1. State your names and current employment.
32 1 33 A1. George W. Oprea, Jr., Executive Vice President for 34 -
35 Houston Lighting & Power Company (HL&P).
1 36 37 Jerome H. Goldberg, Vice President, Nuclea'r Engi-38 39 neering and Construction, for HL&P.
l 40 l 41 Jerrold G. Dewease, Vice President, Nuclear Plant l 42 43 Operations, for HL&P.
44 Robert I. Moles, Plant Superintendent at the South I 45 46 i Texas Project (STP), for HL&P.
47 l 3 48 .
l u 49 i 50 1 51
'I
5.
V I1 2 ,
3 4
Richard A. Frazar, (QA) Manager, Quality Assurance 5
6 for HL&P.
'8i Q2. Mr. Oprea, describe your professional experience 9
10 'and educational backaround. ~
111 12 i A2. (GWO): That information is presented in my testimony 13 114li 15 regarding HL&P's experience in the construction of STP.
16 Q3. Mr. Goldberg, describe your professional experience 1 18 17 and educational background.
20 A3. (JHG): That information is presented in my testi-l19 21 22 mony regarding HL&P's management of design and construction 1 2423 f the STP.
25 26 Q3a. Mr. Dewease, describe your professional experience and educational background.
l931 A3a. (JGD): I received the degree of bachelor of science in electrical engineering from the Christian Brothers 132 33 College in Memphis, Tennessee in 1960. I am a registered 34 535 professional engiueer in Tennessee.
3 36 37 From 1960 to 1965 I was employed by Memphis Light, I
l38 39 40 Gas and Water at its T. E.. Allen Electric Generating Station, l 41 a fossil fueled steam plant near Memphis. I was initially 42 1
43 employed e.s an Electrical Engineer, providing engineering I 44 1 45 support and technical guidance to the electrical maintenance l
46 47 section and was subsequently promoted to Assistant Electrical 48 Maintenance Supervisor. In 1965, the power plant was leased 49 50 I"
l 1l 1 2 4 l 3 5 to the Tennessee Valley Authority (TVA) and I became an !
6 l 7j employee of the Authority. ;
In 1968 I became an Instrument Engineer at TVA's-Browns Ferry Nuclear Plant near Athens, Al'abama, which 12 ' consists of three 1098 MWe BWR units. There I initially 1 14 13' 15 worked on the establishment of the instrument program and 16 Technical Specifications for the plant. I was promoted to I 17 18 Assistant Engineering Supervisor in 1971, and given supervisory 20 l19 21 responsibility over the Reactor Engineering, Radio-chemistry, 22 Testing and Instrumentation and Control groups. In this 1 24 23 position I supervised the establishment of the initial 25 surveillatiuc pregram which implemented the Technical Specifica-1 27 26 28 tions and participated in the initial startup of units 1 and 1 30 29 2. In 1974 I was promoted to QA Supervi,sor at Browns Ferry and in 1976 I was promoted to Assistant Plant Superintendent.
I was responsible for plant QA during the recovery from the ,
March 1975 fire, the restart of units 1 and 2 after the fire 37 and the initial startup of unit 3. From 1977 to 197'9 I was 38 I 39 40 Plant Superintendent at Browns Ferry.
41 In 1979 I was made Assistant Director of Nuclear 42 43 operations at TVA. I had responsibility for the plant 44 operations staffs of four TVA nuclear plants: Browns Ferry; I 45 46 47 Sequoyah, which consists of two Westinghouse 1148 MWe PWR I 48 49 units now in operati6n; Watts Bar, which consists of two 50 Westinghouse 1177 MWe PWR units ncy under construction; and g 51
=
'\
.. . _ _ _ - . _ _ =- -
e 2 .
l 3 l 4 Bellefonte, which consists of twc, Babcock & Wilcox 1213 MWe l 5
6 PWR units now under construction. I was also responsibic for I7}
- 8! r.he TVA training center, which provides classroom and simulator i 9$
' training for reactor operators for all of TVA's nuclear 1 1110 '
12 plants.
I 1 1413I In July 1981, I joined Houston Lighting and Power 15 16 Company as Vice President, Nuclear Plant Operations.
17 18 Q4. Mr. Moles, describe your professional experience 19 20 and' educational background.
21 22 A4. (RIM): I, received the degtee of bachelor of 4
science in Electrical Engineering from the University of 25 Texas in 1965.
g2627 I joined nr.AP in 1965 as a Junior Engineer in the 28 Energy Production Department. As a Junior Engineer, I 1 30 29 31 performed testing on the 481 MWe P. H. Robinson Unit 1, and 1 3332 participated in the installation and startup of 12 gas 34 35 turbine generating units. In 1968 I was promoted to Assistant 1 36 37 Electrical Engineer in the Electrical Maintenance Section, 38 which is responsible for maintenance of various electrical l
1 40 39
! 41 and electronic equipment in ten generating plants. In 1971 1
42 43 I became Assistant Superintendent at the H. O. Clarke Generating 44 Station and in 1972 I was transferred to a similar position I 4566 l 47 at the Cedar Bayou Generating Station, where I supervised 40 g the operation and maintenance of three 750 MWe gas-fired 50 51
- a lE .
112 .
1 3 l l units. I was appointed to my present position in 1977. I 6'
7 am a Registered Professional Engineer in the State of Texas.
Since becoming Plant Superintendent at STP I have attended the Westinghouse 30 week Reactor' Operator Training 12 Course, certifying at the Senior Reactor Operator (SRO) 13 1 14 i; level. I have also attended reqc.alification training on the 15 l6 Zion simulator in 1979 and 1981.
IL7 18 QS. Mr. Frazar, describe your professional experience 19 20 and educational background.
21 ,
22 AS. (RAF): That information is presented in my testi-123 24 mony on HL&P's current QA program for the design and construc-25 tion of STP.
126 27 gg Q6. Panel, describe the purpose of your testimony.
9 0
A6. (Panel): The purpose of our testimony is to describe the HL&P management organization and plans for the 33 operation of STP; to show that HL&P will have the nece ary 34 -
E35 technical competence to operate STP safely and has already 336
, 37 taken important steps in that direction; that nr M 's planned m38 g39 staffing and organization meet applicable NRC requirements; 40 41 and to demonstrate that HL&P's QA program for Plant operations 42 43 will meet applicable NRC requirements.
44 Q7. Mr. Oprea, describe HL&P's management organization l 1 46 45 i 47 for the operation of STP. ;
48 , l I 49 l 50 !
51 1 I i
L I1 2 s 3
4 '
A7. (GWO): As Executive Vice President I have ultimate 5
6 responsibility for nuclear operations, including STP. The 0l 9
nuclear operations staff will report to me through Mr.
'Dewease, our Vice President, Nuclear Plant Operations. Mr.
110 f Dewease 11 i will be responsible for operation of both the Allens 12 !
13 ;
I 14 ' Creek and STP plants. The organization for management of 15 16 STP is shown on the attached chart (figure 1).
17 18 Also reporting directly to me will be the Manager 19 of the QA Department. Our QA Manager will have under him I20 21 22 Separate staffs for. nuclear operations, nuclear and fossil 1 24 23 design and construction, and supporting services. Our QA 25 Manager, Mr. Frazar has recently relocated his office from 26 2
the Plant site back to Houston. Mr. James Geiger, the new 29 STP QA Manager reported to work on June 22, 1981. ,
31 In addition to the nuclear operations and QA 1 33 32 personnel there will be a technical support group. This 34 -
35 group is a part of the Nuclear Engineering and Construction 1 37 36 organization that reports t: Mr. Goldberg.
38 39 HL&P has a Nuclear Fuel group that is responsible 40 41 for nuclear fuel support activities. The Director, Nuclear 1 43 42 Fuel reports to me. -
- 44 l 45 In addition to the staff working. full time in the i
' 46 nuclear area, there are other HL&P staffs that will be 47 l E 48 providing support ser'/ ices for STP. Our Fossil Plant Engineer-g 49 50 51' I _ -
w l
I1 2 '
3 4 ing and con.atruction organization represents a resource of 5
6 engineering expertise that will be utilized as needed.
[7! 8 9,
Although assistance from other HL&P groups and from cutside 10 ' consultants will be available to supplement our full time 111l!
12 staff on the STP, we plan to make HL&P essentially self 1 1413 sufficient in regard to the conduct of our nuclear operations.
15 16 There are also two committees of executives and l17 18 , managers that will be reviewing the performance of Plant 19 '
CPerations and QA. These are the Nuclear Safety Review l20 21 22 Board (NSRB) and the QA Program Evaldation Committee. These E23 24 two committees are described in FSAR Sections 13.4 and 17.2, respectively, and are discussed below.
2 Q.8 Mr. Dewease and Mr. Moles, dcscribe the organiza-tion of the Plant Operations staff.
1 30 29 31 A.8 (JGD, RIM): Figure 13.1-2 of Section 13.1 of the 1 33 32 Final Safety Analysis Report (FSAR) shows the organization 34 for the operation of the two STP units, including the number 1 36 35 37 of personnel per our current plans. While the details may 38 1 39 vary as our planning progresses, I do not expect any major 40
! 41 changes.
42 -
l 43 As shown in figure 13.1-2 and described in Section 44 13.1 of the FSAR, the organization includes four major l
I 45 46 47 Sections: Operating; Technical; Maintenance; and Training, each headed by a General Supervisor. The two other groups 50 51 I
I1 2 3
5 shown, tue Radiation Protection Group and the Administrative 6
Group, will also have senior level Supervisors. Section 7i 0 13.1 of the FSAR summarizes the responsibilities of each j group as well as the qualifications of key' personnel. In my 1 1110t 12 answers to the next few questions I describe the functions 13 ;
I 14 ' of each of these organizations, their ultimate staffing 15 16 levels, and their staffing levels as of August 10, 1981.
1 1817 Q.9 Describe the Operat: Lng Section.
20 A.9 (JGD, RIM): The' Operating Section includes personnel l19 21 ' ,
22 licensed to operate.the reactor and Auxiliary Operators.
1 ;423 The Operating General Supervisor is in overall charge of 25 reactor operations and will hold a Senior Reactor Operator 1 2726 28 (SRO) license on each unit.
The organization chart shows six Operating Supervisor positions in the Operating Section, our equivalent of the 33 Shift Supervisor required by the NRC. Operating Supervisors 34 35 will hold"an SRO license on each unit. A corporate management I 36 37 directive will be issued p.rior tc fuel load, clearly' establishing 38 l39 40 the command duties of the Operating Supervisor and emphasizing 41 his primary responsibility for safe operation of the Plant.
42 13 Plant procedures will clearly define the duties, responsibilities 44 and authority of the Operating Supervisor and other licensed I 4546 47 personnel.
48 1 49 50 51 l
lI l
i E__________._
ll . . . . . . . . - -___
I1 2 s .
3 The Watch Supervisors, reporting to Operating ll 4 6 Supervisors, will be licensed SRO's and will be responsible I7 {
1 3, for reactor operations command in the control room. Each 9j l0 i 'one will receive supervisory training designed to optimize I11 12 his performance as a Watch Supervisor.
13 !I 1 1514 We currently have one Operating Supervisor, two 16 watch Supervisors and 22 other personnel in the Operating 1 1317 Section. The three Supervisors were previously licensed l9 SRO's on operating commercial nuclear power plants. We are I2021 22 preparing all 25 personnel to be eligible for cold licensing 23 on Unit 1. At present 23 of them either have the required 25 nuclear experience or have been certified in the Westinghouse 1 27 Reactor Operator Training Program, and training for the 28 other.two is in progress.
1 3029 31 We will have 22 Reactor Operators and approximately 32 5 33 30 Auxiliary Operators for two unit operation.
34 35 The Reactor Operations personnel are currently 1 3736 involved in writing system descriptions and/or operating procedures. As systems are turned over to HL&P these people l3839 40 41 will be participating in preoperational testing.
I 42 43 Q.10 Describe the Technical Section.
44 A.10 (JGD, RIM): The Technical Section is made up of I 45 46 four groups: Reactor Engineering, Chemical Analysis, Chemical 47 40 Operations, and Results Engineering.
9 50 II'
! ll -e-
6 I
I1 2 .
3 4 Th Reactor Engineering Group will consist of a 5
6 Lead Reactor Engineer and two Reactor Engineers, one ~ for I7 8 9
each unit. The two Reactor Engineer positions are filled.
0 'One of the Engineers has had extensive nuclear experience, 12 including several years as a Navy Reactor Operator and 13 I14 Reactor Technician and 12 years working on the Research 15 16 f Reactor at the Texas A&M Nuclear Science Center. The other 17 l18 joined HL&P upon receipt of a Bachelor of Science degree in 1.9 Nuclear Engineering from Texas A&M in 1977. Both have I2021 22 attended the 30 week Westinghouse Redctor Operator Training Program, certifying at the SRO level and have attended the Westinghouse Nuclear Engineers Course.
27 The Reactor Engineers are currently developing the 28 core physics and thermal hydraulic testing programs to 52930 31 monitor core performance. They are developing the Initial 13233 Startup Test Program, the onsite Special Nuclear Materials 34 -
35 Accountability Program, and the New Fuel Receipt, Inspection 136 and Storage Procedures. Their responsibilities during Plant 37 38 39 operation will include operational planning to determine 40 41 plant loading and stretchout or coastdown capability to l I42 i
43 44 ensure that refueling periods correspond to the proper core
! 45 burnup and system load demand. The Reactor Engineers will I 46 i also implement the Special Nuclear Materials Accountability 47 l Program for control and accountability of all special nuclear 50 51
1 1
I2 3 4
material at the Plant site. They ensure that the receipt, 5
6 inspection, and storage of fuel is conducted in accordance with applicable criteria.
10 ! The Chemical Operations Group will consist of 42 11 12 personnel, including a Supervisor, 6 Foremen, 15 Chemical 13 Operators and 20 Operator Trainees and Auxiliary Operators.
1 15 14 ;!
16 The numLer of Chemical Operations Foremen has been increased 17 118 to provide supervision on each shift. We have one Chemical '
19 Operations Foreman, three Chemical Operators, and five I20 21 Chemical Operator Trainees on board it this time. 'Seven of 22 23 these chemical Operators and Operator Traineen have nuclear 124 25 26 navy backgrounds. The other has experience at a commercial 127 28 nuclear power plant.
The Chemical Operations Group is responsible for 31 the operation of Chemical Process Systems, Demineralizer 32 5 34 33 Systems, Radioactive Waste Processing Systems, and Non-35 Radioactive Waste Processing Systems. They are currently 5 37 36 writing procedures and developing training materials.
- 38
- 3 39 The Chemical Analysis Group will consist of 23 5 40 41 personnel, including a Supervisor, 2 Foremen, a Nuclear I 42 43 Plant Chemist, and 19 chemical technicians and monitors.
44 45 The Chemical Analysis Group presently consists of a Supervisor, 46 47 Foreman, and six chemical technicians. At the time we l 48 49 reviewed our organization after TMI, we had one Supervisor l
50 51
..I . -- . . . . - - - .
l 1
I-2 N s , s.
3 4
ver b th Chemical Analysis and Chemical Operation 4. 'Our 5
6 review concluded that this job was more than one man'could 8 properly handle, so it was split into two. A Nuclear Chemist 9l ;
'also has been added on the current chart.
1 11 10 12 The Chemical Analysis Group is responsible for 13 ,
I14 r plant chemistry and radiochemistry. Chemical Analysis 13 16 personnel perform laboratory analyses on samples as contrasted 17 18 with Chemical Operations personnel who operate systems 19 supporti..g reactor operation. Currently Chemical Analysis 1 21 20 22 personnel are writing procedures, developing training materials, I 23 24 conducting the preoperational environmental sampling program, 25 26 and providing chemical analysis capport for hydrostatic 2
tests.
29 The Results Engineering Group will consis.t of a 31 Lead Results Engineer and approximately eleven Results 32 I 33 Engineers. We have the Lead Results Engineer and six Plant ,
34 ,
35 Results Engineers at this time, all of whom have engineering 5 37 36 degrees. Three of them have completed the 30-week Westin9nouse l38 39 40 Reactor Operator Training Course.
41 The Plant Results Engineers prepare test procedures, 1 43 42 perfcrm tests, and prepare test reports for initial startup, 44 post-maintenance, and performance testing of Plant systems.
I 45 46 47 They implcment programs for In-service Testing of Pumps and
! E 48 Valves, HEPA Filter Testing, Containment Integrated Leak
- g 49 50 l
I 51
.._I _ . . . __.
I1 2 3
~
Rate Testing, and Technical Specification Surveillance 6
Testing. One of these Engineers will have lead responsibility 7
8 for implementation of the Plrnt Fire Protection Program.
l0 ! 'Results Engineers develop solutions to problems and equipment I11 l 12 malfunctions in various Plant systems. The Results Engineers l3 I14;' are currently developing the programs discussed above, 15 16 writing procedures, and coordinhting the Plant staff review 17 18 of documents. The two Engineers developing the Fire Protec-19 tion Program have each attended several schools and seminars 1 21 20 22 on tire protection. In addition, we' expect to utilize the 1 24 23 services of a consultant to review our Fire Protection
! 25 Program.
1 27 26 Q.11 Describe the Maintenance Section.
28 9
A.ll (JGD, RIM): The Maintenance Section is divided l 0 31 into four Groups; Electrical, Mechan.4 cal, Instruments o g32 m 33 controls and Support, each headed by a Supervisor. Electrical 34 .
35 and Mechanical Maintenance were originally headed by a 1 37 36 single Supervisor, but thi.s position was split so that each 38 39 Group will have its own Supervisor. This was done because l
40 41 of the magnitude of the workload. With the exception'of the 1 43 42 Electrical Maintenance Group, the Supervisor positions have 44 ,
been filled. Two o# the Supervisors whose experience was in j 1 46 43 '
47 fossil plants were assigned to operating nuclear plants for 48 49 several months to gain experie'7e by participating in refueling 50 51 "t^988*
I 13-l
I1 2 3
4 The Maintenance Engineering Group will consist of 5
6 11 personnel, including a Supervisor, a Planning Sche Gler, 3
9j 7 Specialists and 2 Clerk-Typists. The Supervisor and'one of the Specialist positions are now filled.
11011 f 12 The Electrical Maintenance Group will consist of 13 1 14 { 21 personnel, including a Supervisor, 2 Foremen and 18 15 l6 Electricians, Apprentices and Helpers. One Foreman, 5 I 17 18 Electricians and 3 Apprentice positions are now filled.
19 The Mechanical Maintenance Group will consist of I 20 21 22 44 personnel, including a Supervisor,' a Welding specialist, 1 2423 5 Foremen and 37 Mechanics, Apprentices and Helpers. The 25 Supervisor, a Foreman, 12 Mechanics and one of the Apprentice 2G positions are now filled.
The Instrumentation & Control (I&C) Group will 31 consist of 51 personnel, including a Supervisor, 2 Engineers, 1 3332 4 Foremen and 44 I&C Technicians and Apprentices. The 34 -
35 Supervisor, an Engineer, a Foreman and 11 Technician positions 1 36 37 are now fillud.
38 39 Maintenance personnel are currently performing 40 41 preventative and corrective maintenance on the Reservoir 1 4342 Makeup Pumping Facility and Meteorological Tower equipment.
44 They will assume maintenance responsibility for Plant equipment I 45 46 47 as it is released for Preoperational Testing. Maintenance O
g personnel will provide support, both manpower and procedural, 50 1 51 _
'W v.
I i
I1 2 c' .
1 3
4 for initial wire checks and functional checks, instrument 6 and relay calibration, initial motor checks, initial' pump 7}
8 i checks, checkout of valves, elect-ical continuity, meggar 9i
'and hi-potential tests, and final coupling alignment. The 110 11 ! l 12 Maintenance section will also provide support for test 13 1 14 ; calibration and assistance in leak testing, flushing of 15 16 piping systems, and the preoperational testing. All Maintenance l17 18 Groups are currently writing procedurca and developing spare 19 .
20 parts requirements.
21 22 Q.12 Describe the Training Section.
1 24 23 A.12 (JGD, RIM): The Training Section is responsible for Plant staff training activities. Since one of the 2
recommendations resulting from a recent organizational review was an expanded training organ tation, we plan a 31 large Training Section. We have three Groups in our Training 1 33 32 Section: Operator Training, Simulator Training and General 34 -
t 35 Training. The Simulator Training Group will utilize a plant 36 37 specific simulator whicn is now on order and is sche'duled to 38 39 be installed on the site by mid-1983.
40 41 The Training General Supervisor has 20 years Navy l 42 43 experience, 15 in the nuclear area. He has attended at l
45 8-week training course at the training center in Zion and is l44 46 participating in the INPO Instructor Qualification and 47 Certification Workshops.
9 50 51
__q I1 2 3
. s.
The Operator Training Group will consist of the 6 Operato. Training Supervisor and 3 Training Instructors, all 7
8 of whom will be licensed SRO's. This group will be respon-9 :l 10 ! sible for all operator license training, except that utilizing 1 11 12 the simulator.
13 14 The Simulator Training Group will consist of a 15 16 Supervisor, 3 Instructors, 2 Programmer Technicians, a I 17 18 Draftsman and a clerk. This Group will utilize the plant 19 specific simulator to train Reactor Operators and a number 1 2120 22 f other personnel,. including members of the Technical 1 2423 Support Staff.
The General Training Group will consist of a Supervisor and 7 Instructors. This Group will provide 29 technics.1 and general employee training.
30 31 The tnree Instructor positions in the Operator 32 !
1 33 Training Group have been filled. The Instructors each have 34 -
25 about 7 years of nuclear Navy experience. All three have 36 37 attended the 30-week Westinghouse Reactor Cperator Training 38 39 Program, and each is certified at the ShO level.
40 41 Q.13 Describe the Radiation Protection Group.
42 l 43 A.13 (JGD, RIM): The Radiation Protection Supervisor 1 44 45 .
is assigned to the Plant staff from the corporate Health l 46 l 47 Physics organization. The Supervisor receives technical O
g direction from the corporate Health Physics organization but 50
, 51 i
\
m l
1 . I 2 . i 3
l4 receives direction on scheduling from me. The. Group is 6 responsible for a radiation exposure control program'to I78i 9i assure that exposure to the Plant staff and the public are I
g10 kept as low as reasonably achievable.
ull 12 The Radiation Protection Group will consist of 33 1 1413 jpersonnel, including a Supervisor, two Health Physicists and 15 30 Radiation Protection Technicians, Monitors, Junior Monitors l16 17 18 and Trainees. We currently have a Supervisor and one Health 20 Physicist. The Supervisor has 30 years experience in applied l19 21 22 radiation protection including both }(avy and commercial 23 24 nuclear power plant experience.
5 6
Q.14 Describe the Administrative Group.
A.14 (JGD, R*.M ) : The Administrative Group will consist of 15-20 personnel, including a Supervisor. Its function 31 will be to provide clerical and administrative support to 32 33 the Plant organization.
34 -
35 Q.15 Mr. Frazar, describe the QA program for operations.
1 36 37 A.15 (RAF): As described in Section l'.2 of the FSAR, i
l38 39 40 1 HL&P has a QA Manual that establishes the corporate QA i 41 policy and commitments. The QA Manual will be implemented i 42 l 43 for STP operations by an Operations QA Plan (OQAP), which l 44 l 45 contains general critoria and requirements for STP operations.
46 47 The OQAP is in turn implemented in accordance with procedures E 48 g 4g that provide detailed instructions to employees performing 50 51 1
I1 2 .
l 3
quality related work. ,
The HL&P QA Manual has been in use 6
7g for a number of years. The CQAP is currently under develop-8' gj ment, with a significant amount of the work already &ccom-i plished. Our plan shows a tentative _compl'etion of the OQAP ,
l?. f by the middle of 1982, with further refinements occurring as l3 g I 1415 we move toward the fuel load date. This will allow nore 16 than adequate time to continue development of the deta led 117 18 procedures and training programs.
20 Q.16 Describe the QA organization for operation of STP.
l19 21 .
22 A.16 (RAF): Our organization structure for operations 123 24 QA will parallel the CA organization for design and construction 25 described in my previous testimony.
The QA organization for 126 27 28 perations vill report to executive level management not directly responsible for power production. The Operations 129 30 .
31 rganizati n 32 QA nsists of a Quality Engineering Group, an 33 Auditing Group, a Surveillance Group, and a Quality Control t
35 (QC) Group. (See figure 2) The functions of these Groups 36 37 are set forth in Section 17.2 of the FSAR and are summarized 38 39 below. .
40 41 Q.17 What are the functions of the Quality Engineering 42 43 Group?
l 44 l 45 A.17 (RAF): Quality Engineering performs inspection l 46 47 planning; investigates nonconformance reports and corrective 48 ^
1 49 action requests; performs trending; reviews procedures, 50 1 51 I1 2 3
4 procurement documents, quality records, audit responses, 5
6 specifications and receiving documents; evaluates test data; 7
3 writas procedures and revisions to the OQAP; maintains the.
9:
working QA files; prepares various QA repo'rts; and provides 1 11 10 12 QA training.
13 I 14 Q.18 What are the functions of the QA Auditing Group?
15 16 A.18 (RAF): The QA Auditing Group schedules audits; 17 18 prepares audit plans; recommends auditor certification; 19 20 provides input to the training
- program; and reviews and 21 22 approves responses to the audit deficiency reports.
1 24 23 Results of auditing activities are reported to executive 25 26 management.as well as management responsible for the activities 2
which have been audited. This audit group does not, by 29 itself, perform all of the audits necessary to satisfy 31 criterion XVIII of Appendix B. HL&P has an additional 32 33 auditing group which la off-site and which provides broader-34 35 scoped program audits to ensure that all 18 criteria of 36 37 Appendix B are audited. Although there will be some' overlap 38 39 between these auditing functions, the purpose of the on-site
, 40 l 41 group is to provide frequent smaller-scope audits to inform j 42 43 Plant and QA management regarding the current status of the 44 45 program. The off-site audit group provides a macroscopic 46 47 view of the QA program implementation by the whole STP
- 48 .
organization.
i 49 I
50 51 1
1 2 .
3 4
Q.19 Will the QA functions in Houston that you described 5
6 in your earlier testimony continue during Plant operation?
O A.19 (RAF): Yes. The QA Department in Houston will 9 ,l 10 l ' continue to provide services to the Plant, including document 11 l 12 review, vendor surveillance and auditing.
13 3 1 14 ' Q.20 What are the functions of the QA surveillance 15 16 GLoup?
117 18 A.20 (RAF): The QA Surveillance Group performs sur-veillance on the document control center, the record manage-l19 20 21 22 ment system, general plant housekeeping, and activities 123 24 controlled by the technical specifications. Results of 25 surveillances are reported to Plant and QA management.
26 2
Q.21 What are the functions of the QC Group?
29 30 A.21 (RAF): The QC Group performs inspections to 31 verify that acceptance criteria have been met for work done 32 33 by operations and Maintenance personnel.
34 35 The Group reccamends approval of procedures and 36 37 checklists; develops QC procedures; inspects activities 38 39 during maintenance, repair, and modification; and initiates 40 41 nonconformance reports (NCR's).
42 43 Q.22 What is the current staffing level for the Operations 44 45 QA staff?
, 46
! 47 A.22 (RAF): We currently have six professional personnel S8 assigned to the Plant QA organization. Personnel will be 49 50 51 I . . - . _ - . . . .
. . - _ - . . . . - . . - . . - - . - - ~.-
1
- 2 3
4 added to support the Operations QA program according to a 6' staffing schedule based on Project schedule infGrmation.
7 8 Q.23 What qualifications will be required for QA personnel?
9l 10 A.23 (RAF): Quality Engineering personnel should 1il 12 preferably have a degree in a specific technical discipline 1 1413 (such as mechanical, electrical, or nuclear engineering) and 15 16 experience in QA. Our intent is to employ a mixture of 17 18 seasoned personnel with 5 to lo years experience in nuclear 19 20 QA, coupled with ' junior personnel to uork alongside the 21 22 senior people in a career development role.
I 23 24 Quality Surveillance personnel should have licensed 25 operations . experience in the commercial nuclear power industry 2
or have had experience in one of the military programs as a nuclear reactor operator or a senior person in charge of an 1 30 29 31 operating reactor, such as an Engineering Officer of the 34 33 Watch in the Navy nuclear program.
34 -
35 Auditing personnel should have previous experience 36 37 and certification as auditor or lead auditor and be' certified 38 1 39 in accordance with ANSI N45.2.23 requirements.
I 40 l 41 our QC personnel will be certifieu in accordance l 42 l 43 with ANSI N45.2.6 requirements as Level II in the discipline 44 45 to which they are aasigned. Level III support to the QC 46 47 organization will be provided from the QA Department.
48 ,
49 50 51 i
M
, v.c, v...
1 2 ,
3 Management 1: vel personnel directly responsible 6
for the operations QA functions must have QA experience and 8i preferably a degree in engineering or science, and must be.
9l
'knowledgable in nuclear power operations and maintenance.
12 Q.24 Mr. Oprea, does UL&P have an Operations QA Manager?
13 114 A.24 (GWO): No, we have been actively recruiting to 15 16 fill that position, and expect to have a qualified individual 17 18 on board by the fall of 1981.
19 20 Q.25 Mr. Goldberg, is HL&P planning how to provide l21 technical support for Plant operation.
22 1 24 23 A.25 (JHG): Yes. Studying and planning for technical suppor+ of. operations started in 1976 when. HL&P defined the 2
role of HL&P Engineering in pre-operational testing and 9 tart-up. In 1978 and early 1979, the scope of activities 0
31 and responsibilities of the Site Engineering group during 332 333 the design and construction stage was defined. Also, in 34 -
35 1979, a study was completed recommending that HL&P develop 136 37 its own capability to perform non-LOCA transient ana' lysis.
38 39 We are now developing that capability. In the last two 40 41 years, HL&P personnel have visited nuclear facilities of 42 43 Public Services of Colorado, Sacramento Municipal Utilities 44 District, Southern California Edison, Virginia Electric and I45 46 47 Power Company, Arizona Public Servicec, and Florida Power &
48 Light to review various organizational structures used for 49 50 51
y_ - . . . . - . - .
1 2 .
3 I4 5 technical support of Plant operations. Findings from these 6
7j trips have been factored i no our plans.
8 g
one of our most significant recent efforts was a-O study performed by Nuclear Services Corpodation (NSC),
12 completed in January 1980. A principal purpose of the NSC 113 14 study was to evaluate, in light of TMI, the HL&P staff 15 I 16 expertise needed to provide technical support during Plant 17 18 operation. Numbers, skill type and skill levels of personnel 19 20 as well as technical review areas were identified.
21 ,
22 Q.26 What are HL&P's current plans for providing technical 1 24 23 support for Plant operations.
25 A.26 (JHG): Most likely the present Site Engineering 126 27 gg Group will form the nucleus for the technical group supporting 29 '
?lant operata.on. We plan to have a technical group on-site, 30 close to the activities it will support, to aid in developing 33 a close relationship with the operating 7taff. Although 34 -
3 35 formal procedtu es will govern such matters as requested R36 37 design changes, a close relationship will be an aid'to 30 lE communications and mutual understanding. Some support will 3 39 40 41 also be available from the headquarters office.
l I42 43 our goal is to have an on-site staff technically l
l 45 capable of performing design verification for all technical l l44 46 I areas, especially those that are uniquely nuclear. For very 47 48 49 Specialized and complex areas; such as seismic analysis, we 50 51
l I1 2
3 5
will most likely continue to employ outside consulting 6
assistance. We believe that a utility must have in-depth 7 ,
3l knowledge and involvement in technical matters affecting
' Plant operation and we will direct our rec'ruiting and training 12 efforts to that end.
13 1 15 14 ' As we move into the operations phase, our technical 16 activities will shift from the headquarters to the site to 17 18 perform,' in support of the Plant Operations staff, such 19 functions as:
1 21 20 .
22 1) Provide a program and procedures for control g23 24 of Plant design.
25 26 2) Review proposed changes to operating procedures.*
27
- 28. 3) Review and evaluate operating experience and 29 performance of selected systems and components.
31
- 4) Review activities such as maintenance, outages, l 33 and surveillance testing and the associated
,' 34 -
l g 35 procedures.*
l 536 37 l 5) Provide engineering design for Plant' modifications l38 39 40
,(in-house ana/or through contractors).
41 6) Participate in the resolution of nonconformances. ,
l 142 43 7) Participate in procurement of engineered -
44 45 equipment, including spare parts.
46 47
- If requested by' Plant operations staff.
I 48 49 50 51 1
- . .I . ... . _ . ..
1 1
- 2 N, 3
l4 8) Interface with the Plant technical staff.
Q.27 Mr. Dewease and Mr. Moles, please summarize the 8I current staffing level of the STP Operations Division.
9 A.27 (JGD, RIM): Although Plant operation is still a 110 11 12 few years awa5, HL&P has a significant part of the Plant 13 14 operations staff on the job at STP.
15 16 Staffing the Plant organization began when the 17 18 Plant Juperintendent and the Assistant Plant Superintendent 19 were named to their r6spective positions in February of I20 21 22 1977. Since that time we have grown' to a staff of ~113 persons. We expect to build up to a staff of approximately 25 6
360 for two unit operation. To plan an orderly development 2
of the operations staff we have identified the tasks which must be accomplished by the Plant staff up through commercial 0
31 operation of Unit No. 2.
13233 We have been hiring personnel with nuclear experience 34 -
35 in the military services. We plan to continue to do this, 36 37 realizing, however, that the demand for these personnel has l3839 40 greatly increased since TMI. We also plan to fill some key 41 positions with personnel with commercial nuclear power plant 42 43 operating experience.
44 Q.28 What are Plant Operations personnel doing during I 45 46 47 the construction phase?
48 A.28 (JGD, RIM):
I 49 One of the major pre-operational activities we have identified is procedure development. We d l
I12* 3 4
have made significant progress in preparing our Plant l 5 ,
6 Procedures Manual. As of August 10, 1981, 116 procedures 7
8 nad been approved and approximately 400 others were in s'ome 9l 10 !
~ stage of sevelopment. The procedure index' identifies over 11112 1600 prc:edures which we plan to have in our Manual.
13 14 The Plant Operations Review Comm.ttee (PORC),
15 16 which is described below, has been meeting monthly since 1 1817 July 1978. The Committee's primary activity to date has 19 been the review of safety-related procedures. Other major 1 21 20 22 activities of Plant. personnel to datd have included spare 1 ;4 23 parts evaluations and development of training materials.
25 An ther major activity which Plant personnel will 1 2'g 26 be involved in is pre-operational testing. Operators, Elec-2 29 tricians, Mechanics, and I&C Technicians will be assigned to 31 the Test Engineers as needed. Very valuable experience will 32 1 34 33 be gained by our personnel in this way. Present personnel m 35 are giving emphasis in procedure development to procedures
( g36 37 that will be utilized for pre-operational testing.
i 38 In addition to working on plans for Plant operation, 1 40 39 41 my staff is undergoing training and is reviewing and commenting
, 1 42 43 on the Plant design. The experience of our operations staff l
44 l 45 in operating similar systems at other plants has been reflected 46 47 in suggested changes to the design to improve system operability I 48 49 and maintenance. -
50 51 I
===-s -
' * * ~ '
I1 2 N. .
3 l4 Q.29 Mr. Dewease, Mr. Moles and'Mr. Frazar, describe 6 the transition from construction to Plant oteration. '
7 8 A.29 (JGD, RIM, RAF): Before fuel is loaded in the 9
0 ' Plant, HL&P will conduct tests of the Plant equipment and 1
12 systems. A separate HL&P organization, called the Startup 13 114 Group, has been established to conduct these tests. The 15 16 Startup Manager, Barry Duncan, is also Assistant Plant 17 ig , Superintendent and his qualifications are described in Section 13.1 of the FSAR. The Startup Organization is l19 20 described in Section 14,2 of the FSAR.
2 It includes a number 23 of experienced engineers working on STP under a contract 4
25 with Westinghouse. Plant Operations personnel, including 126 27 Electricians, Mechanics, Chemical Operators, Chemical Technicians, 28 I&C Technicians and Reactor Operators will be assigned to 129 30 -
31 the Startup Group to assist in the performance of testing.
, 132 33 The Startup Group is now writing the Startup test procedures 34 -
335 utilizing, where practical, Plant procedures.
336 37 As each Plant system nears completion the HL&P 38 39 Startup Group, HL&P Plant QA, Brown & Root (B&R) QA and B&R ll40 Construction Systems Engineering will jointly review the 41 1 43 42 status of the system to determine what must be done for the l
44 45 system to be ready for testing. This activity includes 6
" walk-downs" of the system to identify hardware exceptions g48 or deficiencies. -
50 1 51 --
o.
k I1 2 ,
3 4
5 . When nonconforming conditions are identified by 6
HL&P Plant QA or Startup an NCR will be generated. The NCR g7 58 will be dispositioned by the organization that has design 9
responsibility at the time the aanconformi'ng condition is 1 identified. Depending on the scope of work necessary to 14 disposition tha NCR, HL&P maintenance or B&R construction 15 16 will implement the disposition of the NCR.
17 18 Once a system is tested and the test results approved, 20 l1921 it will be turned over to operations.
22 Q.30 Mr. Goldberg, has HL&P hired the 1,c.sonnel who 1 2423 will provide technical support for Plant operations?
25 A.30 (JHG): As I mentioned before, the current design 12627 28 and construction technical staff will forn the nucleus for 12930 the technical staff during operations. Technical activicies 31 32 n the Project are under the direction of the Project Engineering 33 Manager. The experience and qualifications of that staff 34 were described in my previous testimony in this proceeding.
37 NUREG-0731 identifies* technical support sliills l3839 40 required for both normal and emergency operations. We 41 already have on staff individuals that meet or will meet 42 43 most of the qualifications outlined in that document. We 44 plan to acquire or train additional indivitiuals so that all l I 45 46 47 the requirements are satisfied. For instance, this year we I 4849 recruited speciali=e'd skills in the areas of weld engineer.ng, 50 1 51 , !
l'y I1 2 3
f ASME Division III pipe stress analysis, and transient analysis.
6 Ve also plan to recruit a metallurgist.
7 0
Q.31 Mr. Dewease and Mr. Moles, describe the progrwn for 9
' training STP Plant operations staff. '
12 A.31 (JGD, RIM): An important element of our training 13 1 14 program will be the use of a plant specific simulater.
15 16 Early this year we placed an order for a simulator 1 18 17 for STP. The purchase of a simulator was one of the recom-20 mendations made after review of the lessons learned from l19 21 .
22 TMI.
i 1 24 23 We have formed a project organization to follow 25 the design, manufacture, installation, and testing of our 1 27 26 simulator. It is expected that the nucleus of our Simulator 28 Training Group will come from this Project organization.
31 The Operator Training Group will be responsible 32 33 for all operator license training except that utilizing the 34 35 simulator. The objective of HL&P's operator training is to l 1 36 t 37 equip the operator to assess any given situation and to use 38 1 40 39 the available information to evaluate the Plant parameters l
41 displayed in the control room. The key to the operator's l 42 43 ability to do this is understanding such factors as the 44 physical laws that govern the operation of Plant systems and l
I 45 46 47 how those systems function. We expect to have a staff of I4849 trained personnel who will be able to handle any situation 50 51 they may be confronted with in the control room.
I y
.. _ . __ - - - ~ - - . - . - __ _ _ _ ___ _ _
1 .
2 3
4 our on-site operator license training program 6 consists of three parts: the Nuclear Steam Supply System l '3 1\ (NSSS) Training Package developed by Westinghouse, a Balance 9i
'of Plant Package, and a Procedures Package. The NSSS Trainiry 12 Package consists of 43 lessons including health physics, I
chemistry, reactor theory, systems, accidents, transient and 15 6 instrument failure analysis. It includes system descriptions, 7
18 lesson plans, and training aids. The Balance of Plant 9
0 Package is being developed by our Operator Training Group.
1 2 It will consist of 62 lessons on Pladt systems. Each lesson 3
24 will include system descriptions, lesson plans, and training aids. The current status is:
"27 System Descriptions: 32 completed, 15 in draft 28 Lesson Plans: 20 completed 31 Training Aids: 20 in development 32 133 The Procedures Package has not yet been developed. It will 34 -
consist of 12 lessons covering operating procedures, including 37 normal, abnormal, emergency, and annunciator response.
38 13@ The General Training Group will provide the other ,
! 40 l 41 training for the Plant staff including General Employee
- 42 43 Training (Security, QA, health physics, etc.). Technical l
44 l 43 rraining will also be provided for six of the Plant groups:
46 Chemical Analysis, Chemical Operations, Radiation Protection, 47 Mechanical Maintenance, Electrical Maintenance, and Instru-9 50 mentation and controls.
51
9 I
n.----- -
+
E 2 -
e 3
f Q.32 Describe the training completed to date.
A.32 (JGD, RIM): Since 1977, we have sent three groups 8 of trainees through the Westinghouse Phase I, Phase II, and 9 1
' Phase III programs at Zion, Illinois. !
11011 I 12 These groups consisted of Reactor Operators, 13 ,
1 14 ' Supervisor' Plart management personnel and Engineers.
15 l6 Through this program we have certified 17 individuals at the I1718 SRO level and 8 individuals at the RO level. In addition to 20 that pro 7 tam, we have taken 14 individuals who were already l1921 22 cold licensable an6.put them through'a Westinghouse 8-week I 23 24 intensive course to familiarize them with Westinghouse 25 .
commercial.PWR's.
126 27 We think it is important to periodically provide 28 refreshe'- training to those individuals who have been through 31 the Westinghouse programs. Accordingly, we have contracted 132 33 with Westinghouse for 4-day Requalifj. cation programs on 34 -
their simulator. To meet current retraining requirements we 53536 37 intend to send our licensed operators to Zion on an' annual 38 39 basis for the 4-day Requalification program. ,
40 41 In September, October, and November of 1979, we 1 4342 sent 24 personnel to the Westinghouse 4-day Requalification 44 program at Zion. In January, February, and March of this I 45 46 l 47 year we returned 33 personnel to Zion for that program.
l 48 l 49
! 50 51 au I ~ ~ - ~ ~ ~
I1 2 N.. x l 3
f ,
Q.33 How will the training program be utilized to 6
prepare for initial Plant operauon?
7 Ol A.33 (JGD, RIM): This spring we are conducting an !
' abbreviated on-site lecture series. In edrly 1982 we intend 12 to send our people back to Zion for the 4-day Requalification 13 114,! program and in the spring begin a 15 week on-site lecture 15
,3 16 series. In early 1983, we plan two weeks of Simulator E1718 training. When that is completed we will have the Westinghouse 19 Pre-License Review Series and Audit and then personnel will l2021 22 be taking the license examination. 0ur plan is to put 1 24 23 enough people into the start of this program to man both 25 Units 1 and 2. Although we do not eitpect a 100% pass rate, 1 27 26 we are confident that this approach will ensure that we have 28 enough licensed personnel for Unit 1. We expect 40-50 31 people to be taking the license examination-,
32 1 33 Q.34 How will the training program be utilized once the 34 35 Plant begins operation?
5 36 37 A.34 (JGD, RIM): After Unit 1 fuel load, our program 38 39 will be structured to bring people in at the entry level and 40 train them to qualify for the SRO license by means of three 4 2 ,,
l4143 $
l programs. The first is the Auxiliary Operator Training 44 i I 45 Program. Annually, we intend to have one class which will 46 47 include the following: 2. weeks indoctrination, 7 weeks I 48 49 Nuclear Power Pltnt fundamentals, P, weeks of systems, 8 50 I 51
- . 2_ _ _ _ _ -_.. .
I1 2 3
-x.
5 months of on-the-job training, and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of. simulator 6
7j training.
8 g l' After cn Auxiliary Operator has been with us for 18 months, he is eligible to go into hot license training at the RO level. That is the second of the three programs. We 14 Intend annually to have one class which will include: 10 15 16 week lecture series, 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of simulator training, and 13 17 18 weeks of standing watch in the control room under the direction 19 of a licensed Reactor Operator. Finally, candidates for RO I20 21 .
22 and SRO certificates will take the Westinghouse Pre-License 1 24 23 Review Series and Audit, followed by the license examination.
25 The third program is the RO to SRO upgrade. Annually, 126 27 28 we will conduct one class which will include: 13 weeks of standing watch at the SRO level under the direction,of a 129 30.
31 32 licensed SRo, 40 class room hours of supervisory leadership training, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator training at the SRO level, 35 and 4 weeks of advanced theory'.
536 37 All Auxiliary Operators, Reactor Operators, and
- 38 l
39 Senior Reactor Operators will undergo retraining on a con-
! 40 l 41 tinuous basis. We plan to utilize a six shift rotation l 42 43- wh % h provides that five days in each 42 are used exclusively l
- 44 l g45 for retraining. Anothe; ?our days in 42 are availe.ble for l 5 46 i 47 relief duty. When relief operators are not standing relief
' E 48 g 49 watches in the plant', they will be involved in additionc1 50 51 retraining activities on an as-needed basis.
I _
v 1
I1 2
3 f The retraining program will include lectures, 6
simulator exercises, examinations, general employee training, 7
O Licensee Event Report (LER) seview, respiratory training,
' fire brigade training, procedures review, 'and supervisory 310 11 12 training.
13 1 15 14 Our plant specific simulntor for STP will be 16 loce.ted at the site. We hope to have the simulator operational 17 l18 in time to utilize it during the cold license training of 19 20 our tirs't group of Operators. of the simulator training 21 22 that I mentioned previously, that which is done before we 123 24 I have our aimulater operational will be conducted at Zion.
25 Q.35 Mr. Frazar, please describe how the training 526 27 program of the QA Department will be conducted during Plant 28 perations.
0 L'-
A.35 (RAF): The QA Department will perform indoctrination 32 133 and training for QA personnel as well as other HIIxP employees 34 -
35 whose duties and responsibilities will be governed by the QA 536 37
, program.
38
- 39 Indoctrination and training of QA and non-QA HL&P 40 41 employees will be conducted to familiarize new or transferred I42 43 employees with the Nuclear QA Program. The program will 44 l stress the importance and meaning of QA as it applies to the l 1 46 45 47 employee's new position. .It will include a discussion of 48 49 the philosophy and ubjectives of the QA Program; an explanation 50 I 51 _
i _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ - _ _ _
l ll - - - - -
I1 2 .
3 ll 45 f the QA Program and how it a fects the duties and respon-6 sibilities cf the employee; and the purpose, scope and 7g I
implementation of quality related manuals, instructions, 0 procedures, Regulatory Guides, standards a'nd codes, with 12 specific emphasis on the sections which most directly affect 13 ,
I 14 15 the employee's new position. Emphasis will be placed on the 16 fact that the QA Program has been endorsed by the President 17 18 of HL&P and that quality policies and the various plans and 19 procedures that make up the QA Program are mandatory require-I2021 22 ments which must he. implemented and 5nforced.
1 2423 In addition to the QA Department training and indoctrina- l 25 26 tion described above, each set of departmental procedures 127 and the Plant procedures will provide for training and 28 2'
certification, if required, of personnel who perform quality-0 31 related work.
33 Q.36 Mr. Goldberg, will there also be training programs 34 -
35 for technical suppdrt personnel?
I3637 A.36 (JHG): Yes. Training of the technical rup' port l3839 40 groups involves a number of considerations. First, a general 41 training program is planned for each technical discipline.
I 42 43 Included in this planned training will be the use of the STP 44 simulator. We believe it is important that the technical I 45 46 47 support staff understand plant operations from the reactor 48 1 49 Perator's viewpoint'.
50 1 51 I _ _ _____ - - _ - _ -_- - -
I1 2 3
N -
l4 6 Another important part of the technical support staff training is health physics training. We plan to I7 8 9
perform this function tetally in-house and to have on board
' the instructors and the appropriate r.ultimedia equipment to 1 11 10 12 accomplish this task.
13 3 15 14 Q.37 Mr. Dewease and Mr. Moles, describe the organiza-16 tion for each shift during reactor operation.
17 l18 A.37 (JGD, RIM): The shift organization is shown in 19 Figure 3. An Cperating Supervisor with an SRO license will I 20 21 22 be on site anytime a unit is loaded sith fuel. All personnel 1 24 23 n shift are responsible to him.
25 26 Reporting directly to him is an organization for 2
each reactor unit headed by a Watch Supervisor with an SRO 29 license and a chemical Operations Foreman with associated 30 31 staff. Each unit will also have two operators with RO 1 33 32 licenses, a Radiation Protection Technician / Monitor and a 34
. 3 35 Chemical Technician / Monitor.
l 5361 37 i Chemical Operations personnel working on a unit l38 39 40 will keep the Watch Supervisor informed af their activities, 41 but will receive direction on priorities for scheduling work I 42 43 activities from the Operating Supervi.sor.
44 We have added administrative aides on shift as a I 45 46 47 result of TMI lessons learned. Administrative functions 48 I 49 that detract from or are subordinate to the operating Super-50 I 51
\.
I1 2 3
4 visor's management responsibility for the safe. operations of 6 . the plant will be delegated to these personnel. Even before 8 n1I we had anticipated a PBX operator on shift to relieve i
9i ;
l0 ' 'the control room of telephone anrwering responsibilities.
I11 12 Our current plans call for the fire brigade to be 1 14 13 I headed up by the Chemical Operations Foreman. The other 15 16 four members will be made up of Chemical Technicians, 117 Chemical Operators and/or maintenance personnel.
18 19 ,
20 Q.38 Does HL&P plan to include c Shift Technical Advisor 21
- 22 (STA) in its shift organization?
E23 5 24 A.38 (JGD, RIM): Our present plan is to provide the expertise of the STA through increased training of our f'
2 Operating Fupervisors. The STA position was recommended as I29 a lesson . earned from TMI in NUREG 0578. The purpose was to 30 1 31 provide an individual on-shift, with training in nuclear 32 I33 engineering or a related science and training in plant 34 -
g35 design and transient response, to complement the functions 536 37 of other shift operations personriel.
The STA would be 38 139 available in the control room within 10 minutes of being 40 l 41 summoned to diagnose off-normal events and advise the shift l 42 .
43 supervisor. I understand that STA's are 3rving now at 44 45 currently operating commercial nuclear power plants.
46 47 In NUREG 0731, Guidelines for Utility Management Structure and Technical Resources", the NRC staff took the 50 51 I . . . . . _ - - - - . -
I1 2 N .
3 f position that "the long-term need for a shift technical 6 advisor to provide advice to the control room supervisor may 7
6 be eliminated when upgraded qualifications for the control 9
, 3 10 i room supervisor ... and improved control rooms ... have been
' 5 11 12 attained." We believe that the long term approach discussed 13 1 15 14 in NUREG 0731 is preferable. The person making the decisions 16 about reactor operation should have the necessary experience i
17 18 and education to perform properly.
19 However, if the NRC continues to require STA's as I 20 ,
21 '
22 separate adviscrs, HL&P will add qualified STA's in accordance l E23 with the NRC requirement.
i 324 25 l 26 Q.39 What will be the procedures for controlling access
- to the control room?
A.39 (JGD, RIM): Plant procedures will limit normal 31 access to the Cor. trol Room to those individuals responsible 1 33 32 for direct operation of the Plant, technical advisors, and 34 -
35 specified Nhc personnel, and will establish a clear line of 1 36 37 authority, responsibility, and succession in the coritrol i 38 l
39 room. Limited special access to the control room may be 40 41 approved by the Watch Supervisor for specified purposes.
I 42 43 Q.40 Will there be shift turnover procedures?
44 A.40 (JGD, RIM): Yes. Plant procedures for shift I 45 46 47 relief and turnover will require nigned check-lists and logs 4G 49 to ass,ure that the operating staff (including Auxiliary 50 E
I1 2 s. .
3 f Operators and maintenance personnel) possess adeauate knowledge' 6I of critical plant parameter status, system status, availa) .lity I79:
8 and alignment.
Q.41 Mr. Goldberg, how does HL&P plan to control design 12 enanges during plant operation?
A.41 (JHG): All changes affecting basic engineering 15
, 6 design (equipment, structures, sizing and arrangement) or 1 7 1 8 Plant operability will be reviewed and approved by the 9
0 technical staff. Procedures will also require the approval 1
22 f QA, the PORC and.the NSRB. In adilition to the normal review for technical adequacy or desirability, these requests 25 f r design changes will be reviewed with close attention to 6
the impact on FSAR commitments, any affected analyses and 28 whether or not an unreviewed safety question is involved.
31 once the request is approved, implementation of the design change will be directed by the site technical group through 3 /.
35 the normal engineering process.
6 37 Q.42 Does HL&P have a system for learning from'the l38 39 40 operating experience of other utilities?
l A.42 (JHG): Yes, that type of information is available 42 l41 43 in documents such as NRC I&E Bulletins and LER's. At present, 44 NRC generated input, including I&E Bulletins, Notices, new I45 46 47 regulations, and Regulatory Guides a.re screened by our I 48 49 Nuclear Licensing Department for applicability and importance 50 51 I
v
+
r-- - ~ - -
I1 2 3
4 and then sent for action to the appropriate management and 6 technical personnel, including those in operations. The 7
8{ publication, Nuclear Power Experience Reports, is used as 9,
l0 '. another source of input to the technical support and operations l I 11 12 staffs. The reports are reviewed by the cognizant discipline 13 1 14 and factored into the Plant design, construction and/or 15 16 planned operation as appropriate along with other inp'ts.
17 IS In addition, both Mr. Moles, STP Plant Superin-19 tendent and Dr. James Sumpter, of my staff, are members of I 20 21 22 the EEI Nuclear Operations Subcommittee. This group, is 23 24 composed of the chief technical support and operations 25 personne! from many utilities in the U.S. They meet tri-12'27 annually and exchange information concerning operational 28 experiences.
1 30 29 .
31 Through the efforts of Nuclear Safety Analysis I 32 33 center and the Institute of Nuclear Power Operations, the 34 -
35 many hundreds of LER's are now being screened and distri-1 36 37 buted to interested parties, through a service known as 38 39 NOTEPAD. We are a user of that service.
l' 40 41 g.43 Mr. Dewease and Mr. Moles, how will Plant operating l 42 -
l 43 procedures be controlled?
I 45 A.43 (JGD, RIM): Responsibility for preparation of l 44 46 each procedure is assigned to a supervisor in the Plant 47 O
g organization. After appropriate reviews, the procedure is 50 I51 -_
I I1 2 3
l4 6 su;oitted for approval to the Plant Superintendent. For safety-related procedures, the cycle includes review'by the I7 8 9
PORC, a group required by the Technical Specifications to 0 perform such reviews as well as other functions. Procedures 12 governing the activities of the PORC are included in the l1314 15 Plant Administrative Procedures.
16 Q,44 Describe the PORC.
11718 A.44 (JGD, RIM): The PORC is a committee established 19 ,
by the Plant Administrative Procedure Manual and requ. ired by 12021 22 the Technical Specifications. Its members include the Plant Superintendent, the Assistant Plant Superintendent, the 25 Operating General Supervisor, the Technical General Supervisor,
- 27 the Mainterance General Supervisor, a Reactor Engineer, the 28 Radiation Protection Supervisor, the P?. ant QA Supervisor and 12330 31 a Site Engineering Representative.
32 133 The PORC reviews procedures, tests, changes to 34 -
35 Technical Specifications and safety-related systems, Technical 13637 Specification violations,'24-hour notification items, Plant operations, and the Security and Emergency plans.
l3839 40 41 The PORC artvises the Plant Superintendent regarding I 42 43 these matters, and he makes his decisions after considering 44 45 their advice. We have built safeguards into this mechanism I46 to minimize the possibility of suppression of dissenting 47 O
g opinions regarding safety matters. In t'4e event of a disagree-50 1 51 I1 2 N 3
f ment between a FORC member and the Plant Superintendent, the member may request that the disagreement be documented in 0 the meeting minutes. PORC meeting minutes go to the Chairman 9
of the NSRB, which is discussed below. If a majority of 1 11 10 12 PORC members disagree with the Plant Superintendent, the 1 14 13 NSRB Chairman and the Executive Vice President must be 15 l6 notified in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
I 17 18 I The PORC has been meeting monthly since July 1978.
The Committee's primary function to date has been the review l19 20 21
- 22 of safety-related procedures.
1 24 23 Q.45 Mr. Goldberg, describe the NSRB.
25 A.45 (JHG): The NSRB is a corporate headquarters 1 27 26 committee that is chaired by me as Vice President, Nuclear 28 29 Engineering and Construction. Its members include the Vice 31 President, Nuclear Plant Operations; the Manager, QA; the 32 33 Manager, Nuclear Services; the Director, Nuclear Fuel; the 34 General Manager, Fossil Power Plant Engineering; the nuclear 1 36 35 37 plant Superintendents, and the Manager, Nuclear Licehsing.
38 39 The NRSB reviews such matters as proposed changes 40 41 to procedures, equipnent, systems, Technical Specifications I 42 43 and the operating licenses. It reviews reports tud meeting 44 45 minutes of the PORC and significant operating abnormalities, l46 including violations of license requirements or internal 47 I
48 procedures having nuclear safety significance.
49 50 l ~
\
l
-- l I1 2 3
f In addition, it conducts periodic audits of the 6 following areas:
8 1. The conformance of facility operation to provisi.ons 9
10 contained within the rechnical s'pecifications and 1 11 12 applicable license conditions.
13 I 14 15
- 2. The performance, training, and qualifications of 16 the entire facility staff.
17 18 3. The resnits of actions taken to correct deficien-19 20 cies occurring in facility equipment, structures, 21 22 systems or method of operation that affect nuclear 1 24 23 safety.
25
- 4. The performance of activities required by the OQAP 1 27 26 to meet the criteria of Appendix B to 10CFR50, 28
- 5. The facility Emergency Plan and implementing 31 procedures.
1 33 32 6. The facility Security Plan and implementing pro-34 -
5 cedures.
6 u 3:7 g.46 Will there also be a dedicated engineerincj staff 38 39 at the site, without operational responsibilities, which l 40 l 41 will perform independent safety reviews?
- 42 43 A.46 (JHG): Yes, as a result of our review of the NRC 44 45 proposed post-TMI requirements, HL&P is committed to having l 46 47 an effective Independent Safety Engineering Group (ISEG) and 48 l 49 we have under study the details of its operation. Our
! SO
' E 51 l3 1
!l lW
--l I1 2 N
3 f current pl.an is that the ISEG will report to me and will be
, l 6 1 7 ,
composed of a small staff of on-site, full-time engineering 8 '
personnel- Its responsibilities will include those specified 9
0 in NUREG 0737. " Clarification of TMI Actio'n Plan Requirements."
12 Q.47 Mr. Oprea, during P! ant operation will HL&P continue 13 1 15 14 to utilize the QA Program Evaluation Committee described in 16 your previous testimony?
117 18 A.47 (GWO): Yes. The QA Program Evaluation Comnittee 19 20 is a corp; rate level group that evaluates the performance of 21 22 QA activities on all EL&P projects. ' Review of the performance l
E23 524 of the STP Operations QA program will be an important function 25 6 f this Committee.
27 ~
gg Q.48 What is the composition of that committee?
A.48 (GWO): I will continue to chair the Committee.
3 The other members incl".de the Group Vice President, Fossil 33 Plant Engineering and Construction; the Vice President, 34 -
35 Nuclear Engineering and Construction; the Vice President, 136 37 Nuclear Plant Operations; .the Vice President, Purcha' sing and 38 39 Services; the Vice President, Fossil Power Plant C,onstruction; 40 41 the Manager, STP; the Manager, QA; and the Director, Nuclear 42 43 Fuels.
! 44 Q.49 What will be the functions of the QA Program I45 46 47 Evaluation Committee during plant operation?
48 .
49 50 I" ..
I 1
< - . _ . - _ _ . ~ _ .
. . -- - - .- 4 1
- 2 N. .
3 I4 5 A.49 (GWO): The QA Program Evaluation Committee will 6
continue to assess the effectiveness of the HL&P nuclear QA 8 program from the management viewpoint. It will review NRC.
9
' reports, trend analysis data, selected audit reports, and 1 11 10 12 management QA audits. It will also review major substantive 13 1 14 ;' changes to methods and systems being implemented as part of 15 16 the Nuclear QA program.
17 18 Q.50 Mr. Goldberg and Mr. Moles, does the FSAR describe 19 how HL&P will conduct the operation of STP?
I 20 21 22 A.50 (JHG, RIM): Yes, Chapter 13 of the FSAR is entitled 1 24 23 Conduct of Operations. It describes the HL&P organization 25 26 f r Plant operations, the personnel training program, certain 2
Plant operating procedures and the review and audit prcgram.
29 Section 13.3 references the separate volume containing the 31 Emergency Plan which is now being revised to meet post-TMI 32 33 requirements, and Section 13.6 references the Security Plan.
34 35 Q.51 How were Sections 13.0, 13.1, 13.2, 13.4 and 13,5 36 37 of the FSAR prepared?
38 39 A.51-(JHG, RIM): The Plant operations staff was responsible 40
, 41 for drafting major portions of those sections. The Nuclear 1 43 42 Licensing Section then coordinated an internal review of the 44 45 drafts. These sections were reviewed and updated earlier 46 l 47 this year and we both personally reviewed and approved these l 48 l 49 FSAR sections as revised.
1 50
. l l-I12 3 ;
4 Q.52 Are the contents of FSAR Section 13.0, 13.1, 13.2, l 5 1 6 13.4 and 13.5 true and correct to the best of your knowledge 7,
8I and Delief?
9 10 A.52 (JHG, RIM): An amendment is being prepared that 111 12 i will reflect the additions of Mr. Dewease and Mr. Geiger, a 1 13 i14 !
reorganization of STP project engineering that has changed 15 16 some job titles, and an updated description of the 17 18 operations training program. With those exceptions these FSAR sections are true and correct.
l19 20 21 22 Q.53 Mr. Frazar, is the Operatidns QA program described 4
in the FSAR?
25 26 A.53 (RAF): Yes, there is a description of the 27 operations QA prograa in Section 17.2 of the FSAR.
28 29 Q.54 How was Section 17.2 prepared?
30 31 A.54 (RAF): Section 17.2 was criginally submitted in 132 33 1978. In 1981 HL&P submitted a substantial revision. I l 34 -
i 35 reviewed Section 17.2 and its revisions in draft, as did 1 36 l
37 various other staffs of HL&P and their comments were 38 39 considered in the preparation of the final drafts that were 40 41 then provided to BL&P Licensing for final editing, printing 42 h and submittal to NRC.
l 43 l 44 l
45 Q.55 Are the contents of FSAR Section 17.2 true and 46 correct to the best of your knowledge and belief?
47 48 ,
49 50 51
\
1 2 -
3 A.55 (RAF):
I4 5 6
With the exception that it is being amended to reflect the addition of Mr. Dewease as Vice President, I7 g 9
Nuclear Plant Operations, yes.
Q.56 What guidelines were used in the preparation of 1 11 10 Section 17.2?
12 A.56 (RAF): We used the NRC's standard format Reg.
f Guide 1.70, Revision 1 and the Standard Review Plan, Nureg 75/087.
17 In addition we considered the applicable industry Standards 19 and Regulatory Guides, including Reg. Guide 1.33, " Quality ll2o 21 Assurance Program Requirements (Operation), Reg. Guide 1.58, 22
" Qualification of Nuclear Plant Inspection, Examination, and 1 2423 '
25 Testing Personnel", and the applicable ANSI N45 daughter 126 27 documents.
28 29 Q.57 Mr. Frazar, in your opinion will EL&P's Operations 30 31 QA Program as described in Section 17.2 of the FSAR comply 32 33 with Appendix B to 10 CFR Part 50, and applicable Regulatory 34 35 Guides and industry standards?
Il2e 37 A.57 (RAF): Yes. In my opinion the Operations QA program will comply with Appendix B, the relevant NRC guidance 40 and the industry standards mentioned in Answer 55 above.
41 i I 42 43 44 45 46 TH:13A 47 48 . l 49 50 51
I lI l
I L I PRESIDENT l D.D. JORDAN I
I l EXECUTIVE VICE PRESIDENT G. W. OPREA I
l VICE PRESIDENT
~~ NUCLEAR OPERATIONS I '
J. G. DBEASE
~~
SOUTH TEXAS PROJECT ALLENS CREEK PLANT SUPERINTENDENT PLANT SUPERINTENDENT I R. I. MOLES I
I -
I FIGURE 1
i b N..
- 3. . . N i 1*
1 E ===
w > LaJ i U... cc
- CE D
. L3
- v. i LA.
1 iv' I 6 w _
H ..
<?*r-W d.h
. .m D -
E < -
V. ..
w I
w W
Q<
A L- '.
r
.g -
2 O A -"S O c _
= . <
<, h...
-= . . = .
6 e < V.
...** W --
> =~~ ::'
- / lllll
~
,=g,
.de Pm
.H.D ,,.
- '=. =.
- =
a
.- M<
w m,.
==
W -
(
lw:
.r. .P. J.
ee , , -
M.
p
~ ...
E. >
~
m N
4 Sm i
' I.-
\ :::: <
1 M
=
W l
h
.e V. h
. u.s.e.
r'* -
l
~2.
I
=P.. =
W i
l d N.
M W "."m"g N em W
~ .-
em.
4-
[e .
-- b.
./
Se
-m
.Ws W
.6 w
h h **
==
=.. b. . .
f an e ee l.-
- U
-o e
= ~ ,
i M L*J CC D
LD
.m.
r J *
- G
- Vs 3 -
TG
-m w
n o o o ,
o m
,a = = ,
o I * -
- tI g<
~ :
kw.
a -
.c"
- a s
Ia = I a a 3.t so o *I r
T oE o =- e =
w
._ w$
- oo=
4 Ew
=
E bo
. = =
O = - aY: - 2z
- r. = -
_ 6 g 2 = .t b 3w a$5 53E w<o 4
N 2 . : 9
< I2A -
E e mes wI
- g w 2 .r s.
= _-. w -o =.-
E I o .t*
g
= ..
- E 6
- ...E a
Wo* w e G e=
L.
h_
- h T mES m JO 4eO re we e*
w
- r - Y-7 nT 5
..E m w.Io E .
t 1
2 l
a et f 4 G I
Y Tr 2 :
w Z m W s
rS o a .? r s o
a
- z, f - f, a. o _
wd g 8 maammma g im ", 4 w.= . = . -=
I*5
& Aa m
Eo E b $E e o
=
l ru F o se -
- o,Y
-r
- e. w E o3w e 3 ens E 6 m o
I I
. . - . . .