ML20040B083

Forwards Draft Input for Supplemental Ser,Identifying Outstanding Issues Re Staffing & Procedures.Info to Minimize Potential License Impact Re Shift Supervisor Duties Requested

ML20040B083
Person / Time
Site:	Grand Gulf
Issue date:	01/08/1982
From:	Schwencer A Office of Nuclear Reactor Regulation
To:	Mcgaughy J MISSISSIPPI POWER & LIGHT CO.
References
NUDOCS 8201250120
Download: ML20040B083 (29)

Text

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Dear Mr. McGauqhy:

Subjoct: Resolution of Outstanding Issues - Licensee Qualifications - Potential Adverse Licensing Impact In the performance of the Grand Gulf licensing review, the staff has identified many nutstandinq istues in regard to staffing and procedures. These outstanding issons are identified in the enclosure ani all >f these nust be resolved before issu.ince of an operatinq license. Considerable time was spent by the staff and the AC?.S connittee in discussing these sane or sinilar issues during the Septnnbor and October meetinqs. Since the issues arn still open, we would anticipate that this lack of proaress will advorsely affect the Grand Gulf ifcensino schedule. Therefore, we reonest that you provide the information as soon as possible to nininize the potential license impact. If you require any clarification of this request, olease contact it. D. Houston, Project Manar;er, ( 301 ) a'Q R4 30. s Sincerely, Unginal signed by A. Schwencer, Chief Licensinq Hrarch P's. 2 Division of Licensing

Enclosure:

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1 o DISTRlBUTION: Docket File 50-416/417 LB#2 File EKetchen, OEl.D / RBenedict DEisenhut/RPurple RTedesco Docket flos. 50-416 1 ASchwencer and 50 417 DHouston LB#2 LA' I&E (3) N.. Janes P. McGaughy, J r. i Assistant Vice President Mississippi Power & Licht Company P. O. Box 16e3 Jackson, Mississippi 39205

Dear Mr. McGaughy:

Subjact: Resolution of Outstanding Issues - Licens Oualifications - I 4 Potential Adverse Licensing Inpact i In the perfarnnce of the Grand Gulf licensin. review, the staff as identified nany sutstandina issues in ri: gard to staffi _ and procedures. nese outstanding issues are identified in the enclosure and ill of these nust e resolved before issuance of an operating license. Consi rable time wae s by the staff and the ACRS committee in discussing these.me or similar issues during the Septenber and October noetings. Sinc the issues are still open, we would anticipate that this lack of progre will adversely affect the Grand Gulf licensing schecule. Therefore, we request that you provide the infornation 4 as soon as possible to rininize to notential license irpact. If you require any clarification of this reque t, please contact fl. D. Houston, Project flanager, 4 (301) 40?-8430. i i Sincerel3, i / 4 8 Robert L.-TedescorATsistant Director .for-L icunsina -, Division of Licensing

Enclosure:

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Mr. J. P. McGaughy JAN 8 '082 Assistant Vice President Nuclear Production Mississippf Power & Light Company P. O. Box 1640 Jackson, Mississippi 39205 cc: Robert B. McGehee, Esquire Wise, Carter, Child, Steen and Caraway P. O. Box 651 Jackson, Mississippi 39205 Troy B. Conner, Jr., Esquire Conner and Wetterhahn 1747 Pennsylvania Avenue, N. W. Washington, D. C. 20006 Dr. D. C. Gibbs, Vice President Middle South Energy, Inc. 225 Baronne Street P. O. Box 6100 New Orleans, Louisiana 70161 Mr. John RicharQson Mississippi Power L Light Company P. O. Box 1640 Jackson, Mississippi 39205 Mr. R. Trickovic, Project 2ngineer Grand Gulf Nuclear Station Bechtel Power Corporation Gaithersburg, Maryland 20760 Mr. Alan G. Wagner Resident Inspector Route 2, Box 150 Port Gibson, Mississippi 38150 W 4

ENCLOSURE 1 DRAFT INPUT FOR NEXT GRAND GULF SUPPLEMCNTAL SER i Note preface sheet identifies where outstanding items requiring resolution are located in this draft SSER material,

l Outstanding Items i Grand Gulf a i p.1 Nuclear Plant Engineering group is inadequately staffed for support of plant operation.

p. 3 Advisors must remain for one year, not just to 100% power.

p. 4 MP&L must correct one administrative procedure.

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p. 5 We need documentatien about individuals on shift having BWR operating.

experience. Furthermore, we will condition the operating license to require one qualified advisor on each shift during startup testing until attainment of the nominal 100% power level,

p. 7 We need " pipeline" information on operator license candidates.

p. 9 We need FSAR Section 13.2.4 revision on fire brigade training.

] p. 13 Experience of ISEG members must be improved. i p. 14 PSRC conference call meetings should be held only for emergencies. p. 16 SRC must maintain cognizance over audits. Conference call meetings should be held only for emergencies, p. 16 We need resumes of additional SRC members. p. 18 The minimizing cf shift superintendent administrative duties has not been confirmed because administrative procedures do not address this i matter. 9 )

p. 21 They must provide procedure for I.C.S.

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p. 21 They should change independent verifier's qualifications.

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l SER SUPPLEMENT GRAND GULF NUCLEAR STATION i 13.1.1 "anaaement and Technical Sunnart Organizations In our SER we noted that we needed additional information concerning the staffing of the corporat? technical support groups (Nuclear Plant Engineering and Nuclear Services). See Figure 13.1-la. In a letter dated August 26, 1981, the applicants provided the following, information. The Nuclear Plant Engineering group is budgeted for 88 engineering and technical personnel. As of September 1981, there were 28 people in this group, including three contract personnel. Seven are in the mechanical group, three in the electrical group, six in the civil /str;ctural group, three in the operational analysis groep, and five in the angineering services group. Of the five Principal Engineers, who head up these five groups, only two are on board. The applicants have told us orally that the other three groups are being supervised by " acting" l supervisory personnel. However, based upon the cuntinuing lack of the Manager I of Nuclear Plant Engineering and the three Principal Engineers (and their resumes i that we can review to check their qualifications), we conclude that the Nuclear Plant Engineering group is not yet adequately staffed up for support of plant operation. It is our position that the position of Manager of Nuclear Plant Engineering and all five Principal Engineer positions be filled prior to a decision on issuance of an operating license, j The Nuclear Services group is presently staffed with 27 MP&L employees and 12 contract personnel. Of these, 21 are technical personnel. The applicants have stated that, at Unit i fuel load, they expect a total of about 45 people to be in the Nuclear Services group. The applicants have also provided resumes of key I people in the Nuclear Services group, including that of the Manager. Based on l --s..-

SENIOR VICE PRESIDENT, NUCLEAR { ASSISTANT VICE PRE SIDENT huCLE AR PH000CTiON SITE MANAGER ~ l 1 I i NUCLF AR PLANT, MANAGER MANAGEROF A AGLA0F MANAGER OF STARTUP MAN AGER OF L'ANAGER NUCLE AR PLANT GUALITY ASSURANCE NUCLE AR SERVICES 'AGER C0rdSTRUCTION [M IFIG.13.12) ' EhGIN EERING (SECTION Ill EN Gif.E E RIN G g ( w I ffECHANICAL ELECTRICAL CIVIL /STRUCTU R ALI OPE R ATION AL ENGINEERING STARTUP SCliEDULING C.T.O. ENVIRONMENTAL AN ALYSIS SERVICES GR0dP GROUP SUPT. SUPE RVISO R SUPE RVISO R GROUP GROUP [ GROUP r 1 %(I. I' ~~~~~~~r~~~T~~~~T~~~ n ~ i i NANAGE' OF R CONTRACT NUCLEAR ~ NUCLEAR MAN AGER OF BECHTEL OTHER CONTRACIOR/ RECORDS SAFETY GE PROJECT PROJECT MiOOLE SOUTH g.a.g t A021NIST R ATOR FUELS ADMINISTR ATO R & ilCEhSING MANAGER MANAGER SE RVICES IN C. OEPTS pg ;y l l l_ l M AN AGE RS MISSISSIPPI POWER & LdGHT COMPANY c l GRAND GULF NUCLEAR STATION UNITS 1 & 2 SUPERVISOR SUPERVISOR CORPORATE FINAL SAFETY ANALYSIS REPORT T OF SAFETY OF LICErdSING HE ALTH PHYSIClST H MP&L MANAGEMENT AND TECitNICAL SUPPORT ORGANIZATION FOR GRAND GULF NUCLE AR STATION FIGURE 13.1 la

l our review of these resunes and on individual interviews wiu some or' these people, we conclude that the 'luclear Services group will be supervised by people having adequate experience in the fields of their appointments. ihe applicants have also stated, in their August 26, 1981 letter, that the fluclear Servicas group will' be responsible for eupporting the plant staff for fueling and refueling ;perations. This satisfies our concern, noted in our SER, about there having been no mention in the FSAR about such expertise. We had also noted in our SER that, because of an apparent lack of BWR operating experience in corporate management, the applicants should provide one or more additional staff members reporting directly to the Senior Vice President - tiuclear, who have substantial commercial nuclear power plant, preferably BWR, operating and management experience and who will act as advisors to the Senior Vice President - fluclear on all decisions affecting operation of the plant. The additional s'.a ff membr s may be permanert employees or contracted coi.sultants, but they should be retained in this advisory position for a ueriod of at least one year starting from fuel load and extending through the first year of operation following fuel load. In their August 26, 1981 letter, the applicants responded to our concern as follows : "MPal intends to obtain the services of an additional staff member with sub-stantial BWR power plant operating and management experience. This staff member will report to the Assistant Vice President - fluclear Production and function as an advisor to the Safety Review Committee and to higher MP&L

{jgg;- utm management concerning SWR plant operations. This position will remain filled througn 100" power operation." We accept the applicants' proposal to have the advisor report to the Assistant Vice President - Nuclear Production rather than tc the Senior Vice President because the Assistant Vice President is the highest level of management intimately involved in the day-to-day operation of the plant. We believe that the advisor can be most effective if his attention is concentrated on such operations.

However, we do not believe that enough experience can be gained by MP&L management in the time it might take to conduct startup testing leading to attainment of full power.

Therefore, the advisory position must remain fillec for at least one year of opera tion. We will condition the operating license to require that the advisor remain for one year of operation following fuel load. 13.1.2 Coerating Organization In our SER we noted that we needed additional information to evaluate the plant staff shown on the organization charts in the FSAR. During our management audit meeting with MP&L in September 1981, we obtained clarification on the numbers of people that will be in each group for Unit 1 operation. See Figure 13.1-2. These numbers are acceptable because they fall within the range of staffing levels that we have accepted f or similar ap>.licaticns. In a letter dated October 12, 1981, the applicants providad revised Figure 13.1-3 which shows the plant operations department staffing for Unit 1 operat']n. The pre /ious Figure 13.1-3 did not identify thal the staffing was for one unit. This clears up the former inconsistencies in the FSAP., 4

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DMil -4 In our SER we noted that we were also concerned.about the applicants' statement 4 in FSAR Section 13.1.3.1 to the effect'that the ANSI fil8.1-1971 qualification requirements need not be applied to " additional personnel [are] used by MP&L to supplement the normal Nuclear Plant Staff." We did not understand the rationale behind that statement. During our September 1981 audit meeting itP&L noted that such additional personnel i would be consultants working under the supervision of MP&L employees who do meet the ANSI qualification requirements. !!P&L also stated that each consultant's r resume is reviewed and the consultant in individually interviewed aRd is con-trac *.ed for by name. This is an acceptable method of acquiring consultants P because it goes beyond the A'lSI requirements. We had noted in our SER that we wished to review the administrative procedures - that 1init the plant operating shift worki,g hours. With its 'etter of August 19, 1981, MP&L submitted cerhin administrative procedures for our review. Included t was Revision 1 of procedure 02-5-01-4 " Shift Relief and Turnover." Section 6.3.1 of this procedure sets forth the shift working hours limitation, including i an out-dated requirement that "An individual shall not be pemitted to work more l than 24 F)urs in any 48 hour period." This requirement hcs been superseded, as is correctly required in Section 6.1.4'c) of Revision 3 of procedure 01-S-06-2 4 " Conduct of Operations," by inclusion of the statement that "There should be at r least a 12-hour break between all work periods." The applicant has agreed to r revise procedure 02-S-01-4 accordingly, which will then bring the working hours limitations into conformance with the NRC requirements given in Action Item I.A.l.3.of NUREG-0737. Subject to confirmation that the required procedure l revision has beu accomplished, we consider this matter to be resolved. I i e -__..-.-_~,-.,_.--___#-..--

i We also noted in our SER that the applicant should submit the station staffing i for our approval in considering an operating license for U*it 2. However, the J licensing of Unit is several years in the future. The Technical Specifications I forming a part of the operating license for Unit I will, when issued, treat shift staffing of Unit 1 as a single unit plant. When Unit 2 is also licensed, the i Technical Specifications for both units will be written to conform to our require-ments at that time for a two-unit station. We consider this matter to be resolved. Because of the lack of BWR operating experience for licensed shift personnel, we noted in the SER that we require at least one individual on each operating shift who has substantive previous BWR operating experience, including startup and shutdown i j of a BWR and under conditions that one might expect to encounter during the initial

tartup and power escalation at the Grand Gulf plant.

During our September 1981 [ management audit meeting, MP&L committed orally to meeting this requirement. We i require documentation of this commitant. The documentation must also include a description of the qualifications (resumes) of each of the individuals on whom it will rely for this experience and of the details regarding the physical location of Wese individuals during shift and how they will interact with the shift organi-l zation. This matter is stin outstanding. We will conditic i the operating license to require one qualified advisor on each shift during startup testing until attain-ment of the nominal 100% power level. I i l t l

$2 . We were also concerned with whether or not there are enough R0 and SR0 candidates in the training " pipeline" to assure that there will be adequate shift staffing to accommodate license examination failures, attrition, retraining, and vacations ar' illness. In response to our concern, the applicants provided the following statement in thW letter of August 26, 1981. "MP&L intends to reconmend enough license candidates for both SR0 and R0 licenses to allow for 50% license exam failure. Should a high failure rate be experienced a minimum of 8 SR0s and 8 R0s could provide adequate coverage while th other candide., are preparing to retake the examination approxi-mately two months later. In addition to the initial group of license candida'tes, MP&L expects to license approximately ;5 additional operators and instructors during the first years of operation. An ongoing operator training program i:, in progress and will provide sufficient license candi-dates for attrition during op.' ration." This statement does not adequately address our concerns, Although four-shift operation can be accomplished with eight SR0s and eight R0s on shift, such thin staffing is inadequate to accommodate attrition, retraining, vacations and illness, which may well reduce significantly the number of licensed people available, potentially causing reliance on excessive overtime to fill in the gaps. We are also concerned that there may be inadequate plars #1r adding to the cadre of licensed operators during the initial one-to-twc years of operation. The applicants' statement that they expect to license "approximately 15 additional operators and instructors during the first years of operation" does not adequately describe a " pipeline". We require the applicants to provide summary detai$s f

i ) the program intended to add licensed shift personnel (not instructors, who li should not be assicned to the operating shift crews), including numbers of candidates, how they will be prepared experientially for license training, j when their training will take place, and approximately when they will be ready to take their fiRC license examinations. I We discussed this matter with MPf;L during our audit meeting in September 1981, and asked the r iplicants to provide informatior. concerning the " pipeline." We i have not received this information. Therefore, this matter is still outstanding. l j We had noted in our SER a lack of information in the ESAR about the Startup organization and the numoer of people involved. The applicants' letter of August 26, 1981 cleared up our concerns about the Startup Supervisor's respon- ) sibilities, which do include both the preoperational/ acceptance test program f and the startup test program. During our audit meeting, MP&L explained the I differences in organization apper.rt g in the FSAR organization narts as ceing related to the differences in function of tne group during the preoptrational ] phase and the startup phase. The preoperational/accepta' ice phase tests out I components and systems ready to be turned over to MP&L's plant operating organi-i zation. Different testing is performed in this phase in comparison to that i performed during startup, which tests the plant systems in more integrated fashion. 1, I The Startup Supervisor has Group Leaders reporting to him. The Group Leaders supervise 53 Test Supervisors who are responsible for conducting the tests. l Their nualifications are acceptable as noted in our Safety Evaluation Report. i i ~..-. - In its October 12, 1981 letter, MP&L provided a more detailed resume of the Startup Supervisor than had been given before. He had had startup test exper-ience at the Hatch nuclear plant of Georgia Power Company and four years as Radio'ogical Engineer at Ingalls Shipbuilding Company involved in the refueling and overhaul of nuclear submarines. Since 1978 he has been involved, at increasing levels of responsibility, in the preoperational and startup test programs at Grand Gul f. Based upon our revicw of the above information, we conclude that PPAL has made adequate prc/isions for staffing their preoperational and startt.p testing programs.

.) 13.2.1 Training for Non-Licensed Plant Staff In our SER we noted that the training program for the fire brigade, as described in the FSAR, did not include training in toxic and corrosive characteristics of products of combastion and in fires involving hazardous process chemicals. In its letter of August 27, 1981, f!P&L stated that training of the fire brigade will meet the requirements of Appendix R to 10 CFR Part 50 and that the FSAR Section 13.2.4 would be revised accordingly. Subject to our confirmation of the revised Section 13.2.4, we conclude that the fire brigade training meets th] requirements of Aopendix R and is acceptable.

l 13.4 Review and Audit f In our SER we noted that the FSAR had not addressed completely all the functions i of the independent safety engineering group (ISEG) that are included in the f1RC i position for Action Plan Item I.B.l.2 of flVREG-0737. In response to our concerns, the applicants submitted, in their letter of October 12, 1981, a more complete description of the Operational Analysis Group, (which will serve as an ISEG), its functions, and the technical qualifications of ils~mem bers. ~~~ I The activities of the Operational Analysis Group are directed by the Principal Engineer, Operational Analysis. The Operational Analysis Group, lo;ated at the plant site but reporting off-site, is. responsible for performing integrated system operational analysis and safety review in the following areas: (1) Perform evaluations of system off-normai thermal-hydraulic conditions and plant transients; (2) Investigate and evaluate system operational anomalies; (3) Perform independent safety reviews of equipment deficiencies, repetitive equipment malfunctions and plant systems performance; (4) Provide technical support to the plant staff in the event of an emergency; (5) Review and evaluate the applicability of industry and flRC informational bulletins and orders and provide appropriate responses; i (6) Provide recommendations to plant and corporate management on matters affecting safety and plant operation. i The safety review functions of the Operational Analysis Group wil' include, but not be limited to, the following: (1) Evaluation for technical adequacy and j chrity of operations procedural changes important to safety; (2) Independent l safety assessment and evaluation of plant performance; (3) Review and analysis I } of operating anomalies; (4) Perform reviews and safety related assessments of l l a-

I _) ), \\ plant organizational activities as assigned by the off-site Safety Review Committee. 4 l ihermal-hydraulic and transient analytical models incorporating specific plant I unique parameters will te utilized by Operational Analysis Group to identify and quantify operating safety margins during transient or off-normal plant operating and emergency conditions. The analytical and computer capabilities of Middle South Services is utilized to provide support for performing plant specific i transient analyses and to respond to requests for assistance. i Scenarios which could affect the sadcty of plant operations or which could lead 4 to degradation of the integrity of the fuel or c adding will be developed for i the purposes of training of staff personnel. The Operational Analyses Group may also utilize other qualified off-site' vendors, nuclear steam system suppliers, consultants, or national laboratcry staff personnel for safety related analyses and/or consultation as deemed appropriate. Based upon cur review we conclude that the functions and activities of the ISEG [ have been adequately described and meet the requirements of Action Plan Item I.B.l.2 i j of NUREG-0737. 1l I j N t d I l 1 ..a

f As stated in the applicants' letter of October 12, 1981, the Operations Analysis Group will consi;' of a minimum of five dedicated personnel with responsibilities and training in the following areas: Area of Capabil_i_ty Training _(Minimum) t Thermal-Hydraulics B.S. in itechanical, Nuclear or Chemical Engineer ing Core Physics and Control B.S. in Nuclear Engineering Plant Transients B.S. in Mechanical or fluclear Engineering Reactor Systen Behavior B.S. in Engineering and either SRO or equivalent experience Qualifications of people in Operational Analysis in the first three areac (thermal-hydraulics, core neutronics and plant transients) shall Sclude a Bachelors degree in engineering or the physical sciences. The qualifications of personnc' in the fourth area (reactor systems behavior) shall include a Bachelors degree 11 engineering with SR0 license or equivalent professional experience. Regarding the qualifications of the personnel intended to staff the ISEG, we note that the Principal Engineer is well-qualified for the position, having been involved-in reactor analysis and operation for the past 18 years, including approximately 12 years of broad experience at the Lacrosse Boiling Water Reactor, and having BS and MS degrees in mechanical engineering.

{}f(kff The education requirements for the other staff members are acceptable.

However, no experience requirements have been established by MP&L except for the. reactor systems behavior position.

4 Because of the functions of the ISEG, we do not believe it prudent to staff the grcup with inexperienced people. It is our position that each of the technical i members of the ISEG have one to two years professional level nuclear experience 4 in their discipline. We will pursue this matter further with the applicants and report our conclusions in a future supplement to the SER. We had elen noted in the SER that we had not completed our review of the Plant Safety Review Commit'ee (PSRC) and the corporate Safety Review Committee (SRC). J We have now reviewed those portions of the proposed Technical Specifications I that address these two committees. MPL_ has proposed to establish a PSRC to advise the Plant Manager on all matters r related to nuclear safety. The PSRC will be composed of: Chairman: Assistant Plant Manager Vice Chairman: Nuclear Support Manager Member: Operations Superintendent fiember: Technical Support Superintendent Member: idality Superintendent Member: Chemistry and Radiation Protection Superintendent Member: Paintenance Superintendent [ i I

. The PSRC will review plant procedures, tests, and modifications, and other matters related to plant safety. It will provide written recommendations of approval or disapproval and other determinations to the Plant Manager or, as necessary, to the Assistant Vice-President, Nuclear Production. It will maintain written minutes of each meeting, and meetings will be held at least monthly. The composition and functions of the PSRC are similar to or the same as those that we have found acceptable for other plants. MP&L has proposed that PSRC neetings be permitted to be conducted by telephone conference call. It is our position that meetings other than " face-to-face" generally be limited to emergency situations that require immediate PSRC review. We wil! pursue this matter further with MP&L and will report aur conclusions in a future supplement to the SER. MP&L has also established a corporate Safety Review Committee (SRC). It will provide independent review and audit of activities in the areas of: a. nuclear power plant operations b. nuclear engineering c. chemistry and radiochemistry d. metallurgy e. instrumentation and control f. radiological safety g. mechanical and electrical engineering

-lS-l h. quality assurance practices and will be composed of the following r,' embers: i Chairman: Assistant Vice President for Nuclear Production Member: Manager of Safety and Licensing i Member: Manager of Nuclear Plant Engineering Member : Manager of Quality Assurance Member: Manager of System Nuclear Operatinns, Middle South Services, Inc. Menber: Nuclear Plant Manager Member: Manager of Nuclear Services Member : Corporate Health Physicist The SRC will meet at least once per calendar quarter during the initial year of l unit operation following fuel loading and at least once per six months thereafter. A quorum will consist of the Chairman (or alternate) and four members. The SRC will review safety evaluations, unreviewed safety questions, proposed changes to the Technical Specifications or the license, violations of operating requirements, operating abnormalities, and other matters related to safety. It will also audit, periodically, operational activities, emergency and security plans, and other operational programs related to safety. Records of SRC activities will be prepared, approved, and distributed to plant and corporate managenent. The composition and functions of the SRC are similar to or the same as thosr-that we nave found acceptable for other plants. However, MP&L has proposed to delete the audit function of the SRC and, as with the PSRC, to permit " meetings" to be held bj conference call. S

It is our positica that the SRC shall maintain cognizance over the audits of plant activities although the audits themselves may be conducted by others. Also, as with the PSRC, it is our position meetings other than " face-to-face" 3enerally be limited to emergency situations that require immediate SRC review, i We will pursue these matters further with MP&L and will report our conclusions i in a future supplement to the SER. In its October 20, 1981 report to the Chairman of the NRC, the ACRS recommended that "the MP&L Nuclear Safety Review Board include two or more experienced voting members from outside MP&L having appropriate backgrounds." We understand that MP&L intends to add to the SRC two outsiders as voting members and the advisor to the Assistant Vice President - Nuclear Operations as a non-voting member. The applicants should document in the FSAR the commitment to include these additional people as members of the SRC. Subject to that documentation, we consider the applicant's commitment to be acceptable. We will report our cw - I clusions in a future supplement to the SER.

-16a-18.0 Advisory Committee on Reactor Safecuards ( ACRS) In its October 20, 1981 report to the Chairman of the f.RC, the ACRS recommended that "the MP&L fluclear Safety Review Board include two or more experienced voting members from outside MP&L having appropriate backgrounds." Our consideration of the ACRS recommendation is given at the end of Section 13.4 of this report.

, 22.2 TMI Action Plan Recuirements for Apoli ants for Operati ia Licenses In our SER we noted that we needed more information about the Shift Technical Advisors (STAS) (Action Plan Item I.A.l.1) and thz we needed certain adminis-t i trative procedures for our review. The administrative procedures related to Action Plan Items I. A.l.2 and I.C.2 through I.C.6.. We have received additional information about the STAS and have reviewed the applicants' procedures. Our evaluation of these matters is given below. I. A. I.1 Shift Te.:hnical Advisor We had noted in our SER evaluation of the STA program that we did rot understand how the STAS would be assigned to cover the operating shifts, nor the adequacy of the experience the STAS would bring to their positions. During our audit meeting, the applicant told us how the STAS would be assigned to cover the operating shifts. There will be six STAS: five for shift coverage and a sixth for relief. Shifts will rotate periodically. When an STA is not shift, he will help the Reactor Engineer in the analytical work necessary on for control of reactor transient; and maneuvers. The STA will cover the j operating shif's the rest of his duty time. We conclude that this is an acceptable way to assign STAS to the Operating shifts. We also received additional information concerning the experience qualifications of the STAS. iive of the six have extensive nuclear experience, ranging from two to 16 years. The sixth has significantly less nuclear exprience but appears to meet the qualification requirements. All have recently compieted the STA training program.

s With so many of the STAS having extensive experience, we expect that much of this experiential knowledge will " rub off" onto the less experienced individual, permitting him to " grow into the job" quickly. We conclude that the assigned STAS will provide u acceptable level of knowledge in their advisory function. I. A.l.2 Shif t' Surervisor Administrative Duties We noted in Section 1.A.l.2 of our SER that the applicant has committed to minimizing the administrative duties of the Shift Superint.c-ndent, but that we would review the plant administrative procedures to assure that the shift su]erintendent's administrative procedures have been minimized. We have reviewed the following procedures provided to us by MML: 01 -S-06-2 Rev. 3 Conduct of Operations 01-S-014 Rev. 4 GGNS Operations Organization 02-S-01 -3 Rev. O Responsibilities & Authorities of Operations Shift Personnel 01 01 A Re c. 1 Operations Section Although these procedures delineate various functions, responsibilities and authorities of operations personnel, the matters addressed are directed primarily to the safety of reactor operations. Administrative duties are not addressed, nor is there any mention of the operator trainee assigned to handle such duties. Therefore, we have not been able to confirm that the shift superintendent's administrative duties have, indeed, been minimized. This matter remains outstanding.

s -1 '- s 1 I.C.2 Shift Relief and Turnover Procedures 4 With regard to Action Plan Item I.C.2, we have reviewed procedure 02-5-01-4, Rev.1, " Shift Relief and Turnover." It presents the procedures used by the Shift Superintendents, the Shift Supervisors, s.J the licensed and r. n-licensed operators. It includes system status check-offs and requirements for sign-offs by the appropriate operators and supervisors, and specifies the reviews that must be made of logs and control panels. Based on our review of that procedure, we conclude that the applicant has fulfilled acceptably the requirements of Action Plan Item I.C.2. I.C 3 Shift Supervisor Responsibilities 4 Shift Superintendent responsibilities and authority are prescribed in several administrative procedures. The most specific is 02-S-01-3, Revision 0 "Cesponsibilities and Authorities of Operations Shift Personnel." It details the responsibilities and authorities of the Shift Superintendent, the Shift Superviser, the Control Room Cperator, the Assistant Control Room Operator, the Area / Building Operators (who are responsible for specified areas of the plant), and the Auxiliary Operators (who are responsible to the Area / Building Operators). Based on our review of procedure 02-S-01-3, we conclude that the applicant has fulfilled acceptably the requirements of Action Plan Item I.C.3 .w.., ~ - - - \\ i (

' L 4 i !.C.4 Control Room Access We have reviewed procedures 01-S-06 4, Revision 1, " Access and Conduct in the Control Room," and 01-S-06-2, Revision 3, " Conduct of Operations." he find that these procedures adequately prescribe the limitations on access to the control room and the line of authority, responsibility and succession inside and outside the control room and, therefore, fulfill the requirements of Action Plan Item I.C.4 I.C.5 Licensee Dissemination of Operatina E_xperience Concerning feedback of operating experience intermation, we do not believe that the applicant has adequately assured, through administrative pro-cedures, that important infomation is made available promptly to those that need it and that unimportant information is culled appropriately to prevent people from being burdened with information they do not need. We reviewed procedure 01-S-04-15, Revision 1, " Required Reading Program," to which the applicant had referred us as noted in our SER. Essentially, this procedure is directed only to distributing various items of informa-tion to plant staff members through their supervisors and to having individuals notify the Training Department that they have read the material so that this fact can be recorded in the individual's training

records, i

I 2 '.. J During our audit meeting, we noted to the applicant that there did not appear to exist a cohesive, encompassing administrative procedure that provided adequate direction to both plant and corporate personnel on the handling of operating experience informaticr. in a manner such that the thrust of Action Plan Item I.C.5 will be accomplished. The applicant cohmitted orally to developing such direction and confimed, in its October 12, 1981 letter, that a procedure to accomplish this direction will be implementad prior to fuel load. We require that this procedure be submitted for our review price to a decision on issuance of an operating license. I.C.6 Verifying Correct Performance of Operatino Activities We have reviewed the four procedures to which the applicant made reference, as noted in SER Section 22, Item I.C.6, concerning the verification of correct performance of operating activities. Based upon our review, we believe that these procedures provide adequate guidance for the purpose of meeting this Action Plan Item. The ?rotective Tagging System" procedure, especially, provides a detailed description of how equipment is tagged out for maintenance and returned to service and who permits such actions. It also requires that the " Independent fl Verifier shall be a knowledgeable individual as determined by the Shift Supervisor, prior to fuel load, and should hold a valid Reactor or Senior Reactor Operator's license after fuel load." Although we do not require the independent verifier to hold a valid R0 or SRG license, we consider that a holder of such a license would be a " qualified" person. Otherwise, it is our position that the independent verifier be knowledgeable in the system and equipment for which he is responsible for verification. We will i pursue this matter further with MP&L and report our conclusions in a future supplement to the SER. _ _ ~ __}}