ML20049J428
| ML20049J428 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/11/1982 |
| From: | Dewease J, Goldberg J HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20049J421 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8203180179 | |
| Download: ML20049J428 (42) | |
Text
, s 3 } Ill3 4 UNITED STATT!G OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: 5 i
HOUSTON LIGHTING & POWER $ Docket Nos. 50-4980L COMPANY, ET AL. 9 50-4990L (South Texas Project, S Units 1 & 2) $
5 TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
OF MR. JEROME H. GOLDBERG MR. JERROLD G. DEWEASE REGARDING THE OPERATION OF THE SOUTH TEXAS PROJECT l
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i 8203180179 PDR ADOCK 02031105000498 PDR T
. s 1
2 3
UNITED STATES OF AMERICA 4
NUCLEAR REGULATORY COMMISSION 5
6I 7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 8
9 .
10 11 In the Matter of: $
12 $
13 HOUSTON LIGHTING & POWER $ Docket Nos. 50-4980L 14 COMPANY, ET AL. 5 50-4990L 15 I I 16 l (South Texas Project, f 17 i Units 1 & 2) 5 18 ! 5 19 l 0i Testimony of Jerome H. Goldberg
}1,! and Jerrold G. Dewease Regarding the Operation of the South Texas Project 2} !
24 j 25 !
26 27 l Ql. State your names and current employment.
28 A1. (JHG): Jerome H. Goldberg, Vice President, Nuclear 29 3C l Engineering and Construction, for Houston Lighting & Power 31 32 Company (HL&P).
33 34 (JGD): Jerrold G. Dewease, Vice President, Nuclear 35 36 Plant Operations, for HL&P.
37 38 Q2. Mr. Goldberg, describe your professional experience 39 40 and educational background.
l 41 42 A2. (JHG): That information is presented in my testi-43 44 m ny regarding HL&P's management of the STP.
Q3. Mr. Dewease, describe your professional experience 47 and educational background.
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3 A3. (JGD): I received the degree of bachelor of 4
5 science in electrical engineering from the Christian Brothers 6l 7j College in Memphis, Tennessee in 1960. I am a registered 8
9 professional engineer in Tennessee.
10 11 From 1960 to 1965 I was employed by Memphis Light, 12 13 Gas and Water at its T. H. Allen Electric Generating Station, 14 15 a fossil fueled steam plant near Memphis. I was initially 16 17 employed as an Electrical Engineer, providing engineering support and technical guidance to the electrical maintenance f8 20 section and was subsequently. promoted to Assistant Electrical 22 Maintenance Supervisor. In 1965, the power plant was leased 24 to the Tennessee Valley Authority (TVA) and I became an 25 l 26 l employee of the TVA.
27 '
28 In 1968 I became an Instrument Engineer at TVA's 29 !
30 ' Browns Ferry Nuclear Plant near Athens, Alabama, which 31 32 consists of three 1098 MWe BWR units. There I initially 33 34 worked on the establishment of the instrument program and 35 '
36 Technical Specifications for the plant. I was promoted to 37 38 Assistant Engineering Supervisor in 1971, and given supervisory 39 40 responsibility over the Reactor Engineering, Radio-chemistry, 4f 4
Testing and Instrumentation and Control groups. In this 43 position I supervised the establishment of the initial 4
45 surveillance program which implemented the Technical Specifica-46 47 tions and participated in the initial startup of units 1 and 48 49 50 i 51 l i l
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1 1 2 l 3 2. In 1974 I was promoted to QA Supervisor at Browns Ferry 4
5 and in 1976 I was promoted to Assistant Plant Superintendent.
6 7 I was responsible for plant QA during the recovery from the ,
8 9 March 1975 fire, the restart of units 1 and 2 after the fire 10 l 11 i and the initial startup of unit 3. From 1977 to 1979 I was 12 13 Plant Superintendent at Browns Ferry.
14 15 In 1979 I was made Assistant Director of Nuclear 16 17 Operations at TVA. I had responsibility for the plant 18 operations staffs of four TVA nuclear plants: Browns Ferry; 20 i Sequoyah, which consists of two Westinghouse 1148 MWe PWR 21 l 22 I units now in operation; Watts Bar, which consists of two 23 l 24 i Westinghouse 1177 MWe PWR units now under construction; and 25 I 26 ! Bellefonte, which consists of two Babcock & Wilcox 1213 MWe 27 '
28 PWR units now under construction. I was also respons'ible 29 !
30 { for the TVA training center, which provides classroom and i 31 I
32 simulator training for reactor operators for all of TVA's j 33
! 34 I nuclear plants.
35 l 36 l In July 1981, I joined HL&P as Vice President, 37 3g Nuclear Plant Operations.
39 40 l Q4. Mr. Goldberg and Mr. Dewease, what is the purpose 41 4
of your testimony.
43 A4. (JHG, JGD): The purpose of our testimony is to 4
45 describe HL&P's current management organization and plans l
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3 4 for the operation of STP; to show that HL&P will have the 5
6 necessary technical competence to operate STP safely and has 7
8 already taken important steps in that direction; and to show 9
10 .that HL&P's planned staffing and organization meet applicable lf y NRC requirements.
13 Describe HL&P's management organization for the QS.
15 operation of STP.
16 17 AS. (JHG, JGD): The Executive Vice President has 18 19 l 20 ultimate responsibility for nuclear operations, including 21 STP. The nuclear plant operations staff reports to him 22 23 through Mr. Dewease, the Vice President, Nuclear Plant 24 25 l Operations. Mr. Dewease will be responsible for operation 76 27 of both the Allens Creek and STP plants. The organization 28 l for management of STP is shown on the attached chart (figure 1).
29 i 3
Also reporting directly to the Executive Vice 31 3
President are the Manager of the QA Department and the 33 34 Director, Nuclear Fuels.
35 36 There will be a technical support group which will 37 38 be a part of the Nuclear Engineering and Construction organi-39 40 ! zation that reports to Mr. Goldberg.
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42 In addition to the staff working full time in the 43 44 nuclear area, there are other HL&P staffs that will be 45 46 Providing support services for STP. Our Fossil Plant Engineer-47 43 ing and Construction organization represents a resource of 49 50 51 '
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2 3 engineering expertise that will be utilized as needed.
4 5 Although assistance from other HL&P groups and from outside 6
7 consultants will be available to supplement our full time 8i 9l staff on the STP, we plan to make HL&P essentially self 10 l 11 i sufficient in regard to the conduct of our nuclear opera-12 !
13 tions.
14 There is also a committee of executives and managers, 15 16 l called the Nuclear Safety Review Board (NSRB) that will be 17 18 f 19 reviewing the performance of Plant operations. This committee 2
is described in Section 13.4.of the Final Safety Analysis 21 22 Report (FSAR) and is discussed below.
23 24 Mr. Dewease, describe the organization of the Q.6 25 26 ! Plant Operations staff.
27 '
28 A.6 (JGD): HL&P's plan for the organization and 29 :
30 ' staffing for plant operations has been developed on the 31 32 basis of NRC guidance and industry experience and will 33 .
34 I continue to evolve as that guidance and experience dictate.
35 36 At present, we have underway a review of the organizational 37 38 structure which may result in additional changes; however, 1 39 l 40 the present organization is basically representative of the l
41 42 eventual plant organization.
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' 43 Figure 13.1-2 of FSAR Section 13.1 shows the 44 5
current organization for the operation of the two STP units, 47 including the number of personnel per our current plans.
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3 As described in Section 13.1, the organization includes four 4
5 major Sections: Operating; Technical; Maintenance; and 6
7 Training, each headed by a General Supervisor. The two 8
9 other groups shown, the Radiation Protection Group and the 10 11 Administrative Group, will also have senior level Supervisors.
12 13 Section 13.1 of the FSAR summarizes the responsibilities of 14 15 each group as well as the qualifications of key personnel.
16 17 In my answers to the next few questions I describe 18 the functions of each of these organizations, their proposed 19 f 20 staffing levels, and their staffing levels as of March 1, 22 ' 1982. It should be understood that the total staffing levels 23 24 identified for each organization are approximate. Although 25 l 26 l actual staffing levels may vary in specific instances, at a 27 28 minimum NRC requirements will be satisfied.
29 i 30 ' Q.7 Describe the Operating Section.
31 32 A.7 (JGD): The Operating Section includes personnel 33 34 licensed to operate the reactor and Auxiliary Operators.
35 36 The Operating General Supervisor is in overall charge of 37 38 reactor operations and will hold a Senior Reactor Operator 39 40 (GRO) license on each unit.
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2 3 The organization chart shows six Shift Supervisor 4
5 positions in the Operating Section. shift Supervisors will 6 J 7 hold an SRO license on each unit. A corporate management ,
8 9 directive will be issued prior to fuel load, clearly estab-10 11 lishing the command duties of the Shift Supervisor and 12 13 emphasizing his primary responsibility for safe operation of 14 15 l the Plant. Plant procedures will clearly define the duties, 16 I 17 responsibilities and authority of the Shift Supervisor and other licensed personnel.
f8 20 The Unit Supervisors, reporting to Shift Supervisors, 22 1 will be licensed SRO's and will be responsible for reactor 23 l 24 { operations command in the control room. Each one will -
25 1 26 l receive supervisory training designed to optimize his per-27 28 formance as a Unit Supervisor.
29 .
30 ' We currently have one Shift Supervisor, three Unit 31 32 Supervisors and 17 other personnel in the Operating Section.
33 34 The Shift Supervisor and one Unit Supervisor were previously 35 36 licensed SRO's on operating commercial nuclear power plants.
37 3g We are preparing all 21 personnel to be eligible for cold 39 40 licensing on Unit 1. At present 20 of them either have the f required nuclear experience or have been certified in the 43 44 45 46 47 48 l 49 50 51 l 1
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Westinghouse Reactor Operator Training Program, and training 5 for the other one is in progress. l 6l 7 We will have 24 Reactor Operators (RO's) and 8
9 approximately 30 Auxiliary Operators for two unit operation.
10 11 The Reactor Operations personnel are currently 12 13 involved in writing system descriptions and/or operating 14 15 procedures. As systems are turned over to HL&P these people 16 17 I will be participating in preoperational testing.
18 l Q.8 Describe the Technical Section.
19 l 2
A.8 (JGD): The Technical Section is made up of four 21 22 ' groups: Reactor Engineering, Chemical Analysis, Chemical 24 Operations, and Results Engineering.
25 26 ! The Reactor Engineering Group will consist of a 27 28 Lead Reactor Engineer and two Reactor Engineers, one for 29 !
30 ' each unit. These three positions are currently filled. The 31 32 Lead Reactor Engineer joined HL&P upon receipt of a Bachelor 33 -
34 of Science degree in Nuclear Engineering from Texas A&M in 35 36 1977. He has completed the 30-week Westinghouse Reactor 37 38 Operator Training Program, certifying at the SRO l'evel, and 39 40 the Westinghouse Station Nuclear Engineers Course. He is 41 42 currently on a six-month assignment with the Reactor Engi-43 44 neering staff at the Joseph M. Farley Nuclear Plant. One 5
Reactor Engineer has had extensive nuclear experience, 47 including several years as a Navy Reactor Operator and 4
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3 Reactor Technician and 12 years as a licensed SRO at the l 4
5 Research Reactor at the Texas A&M Nuclear Science Center.
6 7 He has also completed the 30-week Westinghouse Reactor 8
9 Operator Training Program, certifying at the SRO level, and 10 11 the Westinghouse Station Nuclear Engineers Course. In 12 13 addition, he has served as a qualified startup test engineer-14 15 while on assignment at the North Anna and McGuire Nuclear 16 17 Stations. The other Reactor Engineer joined HL&P upon 18 receipt of his Bachelor of Science degree in Nuclear Engi-20 neering from Mississippi State in 1981.
22 The Reactor Engineers are currently developing the 24 core p'hysics and thermal hydraulic testing programs to 25 26 } monitor core performance. They are developing the Initial 27 28 Startup Test Program, the onsite Special Nuclear Materials 29 30 Accountability Program, and the New Fuel Receipt, Inspection 31 32 and Storage Procedures. Their responsibilities during Plant 33 i 34 operation will include operational planning to determine l 35 36 plant loading and stretchout or coastdown capability to 37 38 ensure that refueling periods correspond to the proper core 39 40 burnup and system load demand. The Reactor Engineers will l 41 42 also implement the Special Nuclear Materials Accountability 43 l 44 Program for control and accountability of all special nuclear 45 46 material at the Plant site. They ensure that the receipt, 47 48 49 i 50 l 51 l
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3 inspection, and storage of fuel is conducted in accordance 4
5 with applicable criteria.
6 7 The Chemical Operations Group will consist of 42 8
9 personnel, including a Supervisor, 6 Foremen, 15 Chemical 10 11 Operators and 20 Operator Trainees and Auxiliary Operators.
12 13 The number of Chemical Operations Foremen has been increased 14 15 to provide supervision on each shift. We have one Chemical 16 17 Operations Foreman, three Chemical Operators, and four 18 Chemical Operator Trainees on board at this time. Six of 19 20 these chemical Operators and. Operator Trainees have nuclear 1
22 navy backgrounds. The other has experience at a commercial 24 nu 1 ar power plant.
5 26 The Chemical Operations Group is responsible for 27 28 the operation of Chemical Process Systems, Demineralizer 29 30 Systems, Radioactive Waste Processing Systems, and Non-31 32 Radioactive Waste Processing Systems. They are currently 33 34 writing procedures and developing training materials.
35 36 The Chemical Analysis Group will consist of 23 37 38 personnel, including a Supervisor, 2 Lead Technicians, a 39 40 Nuclear Plant Chemist, and 19 chemical technicians and 41 42 monitors. The Chemical Analysis Group presently consists of 43 44 a Supervisor, Lead Technician, and six chemical technicians.
45 46 At the time HL&P reviewed its organization after TMI, it had 47 48 one Supervisor over both Chemical Analysis and Chemical 49 50 51
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2 3 Operations. HL&P review concluded that this job was more 4
5 than one man could properly handle, so it was split into 6
7 two. A Nuclear Chemist also has been added on the current 8 ,
9 chart.
10 I 11 The Chemical Analysis Group is responsible for 12 13 P l ant chemistry and radiochemistry. Chemical Analysis 14 15 Personnel perform laboratory analyses on samples as con-16 17 trasted with Chemical Operations personnel who operate 18 19 systems supporting reactor operation. Currently Chemical 20 1
Analysis personnel are writing procedures, developing train-22 ing materials, conducting the preoperational environmental 3
24 sampling program, and providing chemical analysis support 26 l for hydrostatic tests.
27 28 The Results Engineering Group will consist of a 29 30 Lead Results Engineer and approximately eleven Results 31 32 Engineers. We have the Lead Results Engineer and six Plant 33 34 Results Engineers at this time, all of whom have engineering 35 l 36 degrees. The Lead Engineer has had nuclear experience as a~
37 38 Navy Electrical Division Officer, Reactor Controls Division l 39 40 Officer, Engineering Officer of the Watch, and Engineer 41 42 Officer and has attended an eight-week Westinghouse training 43 44 Program at Zion. One of the Results Engineers has also had 45 46 nuclear experience as a Navy Propulsion Plant Watch Officer.
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2 3 In addition, two of the Results Engineers have completed the 4
5 30-week Westinghouse Reactor Operator Training Course.
6 7 The Plant Results Engineers prepare test procedures, 8
9 Perform tests, and prepare test reports for initial startup, 10 11 Post-maintenance, and performance testing of Plant systems.
12 13 They implement programs for In-service Testing of Pumps and 14 15 Valves, HEPA Filter Testing, Containment Integrated Leak 16 Rate Testing, and Technical Specification Surveillance 17 18 Testing. One of these Engineers will have lead responsibility 20 for implementation of the Plant Fire Protection Program.
22 Results Engineers develop solutions to problems and analyze 23 24 equipment malfunctions in various Plant systems. The Results 25 26 Engineers are currently developing the programs discussed 27 ,
28 above, writing procedures, and coordinating the Plant staff 29 30 review of documents. The two Engineers developing the Fire 31 32 Protection Program have each attended several schools and 33 34 seminars on fire protection. In addition, we expect to 35 36 utilize the services of a consultant to review our Fire 37 38 Protection Program.
I 39 40 Q.9 Describe the Maintenance Section.
41
! 42 A.9 (JGD): The Maintenance Section is divided into I
43 44 four Groups; Electrical, Mechanical, Instruments & Controls 45 46 .
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and Maintenance support, each headed by a Supervisor.
5f Electrical and Mechanical Maintenance were originally headed 6i 7i by a single Supervisor, but this position was split so that 8l 9! each Group will have its own Supervisor.. This was done 10 l 11 because of the magnitude of the workload. With the excep-12 13 tion of the I&C and Electrical Maintenance Groups, the 14 15 i Supervisor positions have been filled.
16 I 17 The Maintenance Support Group will consi~st of 16 18 19 j personnel, including a Supervisor, a Planning Scheduler, 9 2
Specialists, 3 Parts Technicians and 2 Clerk-Typists. The 2 l 22 Supervisor, 3 of the Specialists and one Parts Technician 24 I positions are now filled.
25 l 26 : The Electrical Maintenance Group will consist of 27 '
28 21 personnel, including a Supervisor, 2 Foremen and 18 29 !
30 ' Electricians, Apprentices and Helpers. One Foreman, 5 31 32 Electricians and 3 Apprentice positions are now filled.
i 33 34 1 The Mechanical Maintenance Group will consist of
( 35 36 44 personnel, including a Supervisor, a Welding Specialist, 37 38 5 Foremen and 37 Mechanics, Apprentices and Helpers. The 39 40 Supervisor, 2 Foremen, 10 Mechanics and one of the Apprentice 41 42 I positions are now filled.
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3 The Instrumentation & Control (I&C) Group will 5' ' consist of 51 personnel, including a Supervisor, 2 Engineers, 6
7 4 Foremen and 44 I&C Technicians and Apprentices. An Engineer, 8
9 a Foreman and 9 Technician positions are now filled.
10 11 ! Maintenance personnel are currently performing 12 '
13 preventative and corrective maintenance'on the Reservoir 14 15 Makeup Pumping Facility and Meteorological Tower equipment.
16 , ~
17 ; They will assume maintenance responsibility for Plant equip-I ment as it is released for Preoparational Testing. Main-18 19 l .
tenance personnel will provide support, both manpower and 20 21 l procedural,,for initial wire che'cks and functional checks, 24 '
5 instrument and relay cali,bration,' initial motor checks, 26 ! initial pump checks, checkout of valves, electrical con-27 28 tinuity, meggar and hi-potential test's and final coupling 29 . /
30 alignment. The/ Maintenance Section will also provide support 31 / ,
32 for test calibration and. assistance in leak testing, flushing 33 i '- -
34 of piping systems, and the preoperational testing. All I
35 36 Maintenance Groups are currently writing procedures, developing 37 .
38 spare parts requirements,pnd developing the Preventive 39 40 Maintenance Program.
41 42 Q.10 DescribN the Training Section.
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A.10 (JGD): The Training Section is responsible for 4;
5 Plant staff training activities. We plan a large Training 6l i 7l Section, consisting.of three Groups: Operator Training, 8I 9{ Simulator Training and General Training. The Simulator 10 l 11 Training Group will utilize a plant specific simulator which 12 13 is now on order and is scheduled to be installed on the site 14 15 by mid-1983.
16 17 The Training General Supervisor has 20 years Navy 18 experience, 15 in the nuclear area. He has attended an 19 l
'2 8-week training course at the training center in Zion and is 2L, 2 participating in the INPO Instructor Qualification and 24 i Certification Workshops.
25 !
26 : The Operator Training Group will consist of.the 27 i Operator Training Supervisor and 3 Training Instructors, all 28 29 l 30 of whom will be licensed SRO's. This group will be respon-31 32 sible for all operator licence training, except that utilizing 33
, 34 i the simulator.
I 35 l l 36 l The simulator Training Group will consist of a 37 38 Supervisor, 3 Instructors, 2 Software Specialists, 2 Tech-39 40 nicians, and a Clerk. This Group will utilize the plant 41 r 42- specific simulator to train Reactor Operators and a number 43 f ther personnel, including members of the Technical 44 45 6
S PPort Staff.
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3 The General Training Group will consi.st of a 4
5 Supervisor and 7 Instructors. This Group will provide 6
7' technical and general employee training.
8 9 The three Instructor positions in the Operator 10 11 ' Training Group have been filled. The Instructors each have 12 13 about 7 years of nuclear Navy experience. All three have 14 15 attended the 30-week Westinghouse Reactor Operator Training 16 17 Program, and each is certified at the SRO level.
18 Q.11 Describe the Radiation Protection Group.
19 l yl A.11 (JGD): The Radiation Protection Supervisor is 22 assigned to the Plant staff from the corporate Health Physics 24 organization. The Supervisor receives technical direction 26 ! from the corporate Health Physics organization but receives 27 i 28 ! direction on scheduling from the Plant Superintendent. The 29 :
30 ' Group is responsible for radiation protection of personnel 31 32 , on site.
33 l 34 i The Radiation Protection Group will consist of 33 35 36 Personnel, including a Supervisor, two Health Physicists and 37 38 30 Radiation Protection Technicians, Monitors and Trainees.
39
- 40 We currently have a Supervisor and one Health Physicist.
41 l 42 The Supervisor has 30 years experience in applied radiation 43 44 Protection including both Navy and commercial nuclear power 5
plant experience.
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3 Q.12 Describe the Administrative Group.
5 6
A.12 (JGD): The Administrative Group will consist of 7 15-20 personnel, including a Supervisor. Its function will 8
9 be to provide clerical and administrative support to the 10 11 Plant organization.
12 13 Q.13 Mr. Goldberg, is HL&P planning how to provide 14 15 technical support for Plant operation?
16 17 ! A.13 (JHG): Yes. In 1979, a study was completed 18 1 19 I recommending that HL&P develop its own capability to perform 20 n n-LOCA transient analysis. We are now developing that 21 l 22 capability. HL&P personnel have visited nuclear facilities 24 I of Public Services of Colorado, Sacramento Municipal Utilities 25 l 26 ! District, Southern California Edison, Virginia Electric and 27 i 28 l Power Company, Arizona Public Services, and Florida Power &
29 I 30 ' Light to review various organizational structures used for 31 32 technical support of Plant operations. Findings from these 33 ,
34 I trips have been factored into our plans.
35 36 In January, 1960, Nuclear Services Corporation 37 38 .(NSC) completed a study which evaluated in light of TMI, the 39 40 HL&P staff expertise needed to provide technical support 41 42 during Plant operation. Numbers, skill type and skill 43 44 levels of personnel as well as technical review areas were 5
identified.
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Q.14 What are HL&P's current plans for providing technical 5 support for Plant operations?
6li 7l A.14 (JHG): The present Site Engineering Group will 8
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9 form the nucleus for the technical group supporting Plant 10 11 i operation. We plan to have a technical group on-site, 12 !
13 close to the activities it will support, to aid in developing 14 15 a close relationship with the operating staff. Although 16 17 formal procedures will govern such matters as requested 18 19 design changes, a close relationship will be an aid to i
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21 communications and mutual understanding. Additional tech-nical support will also be available from the headquarters 22 l 24 I office.
25 l 26 l Our goal is to have an on-site staff technically 27 28 capable of performing the design or design verification for 29 !
30 l all technical areas, especially those that are uniquely 31 32 nuclear. For very specialized and complex areas, such as 33 34 soil-structure. interaction, we will most likely continue to 35 l 36 employ outside consulting assistance. We believe that a 37 38 utility should have an in-depth knowledge and involvement in 39 40 technical matters affecting Plant operation and we are l 41 42 directing our recruiting and training efforts to that end.
43 44 As we move into the operations phase, our technical activities will shift from the headquarters to the site to 47 48 49 50 51 l l
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3 perform, in support of the Plant Operations staff, such 4 ,
5 functions as:
6 7 1) Provide a program and procedures for control 8
9 of Plant design.
10 l 11 2) Review proposed changes to operating procedures.*
12 13 3) Review and evaluate operating experience and 14 15 Performance of selected systems and components.
16 17 4) Review activities such as maintenance, outages, 18 and surveillance testing and the associated I
19 20 procedures.* .
22 - 5) Provide engineering design for Plant modifica-23 1 24 { tions (in-house and/or through contractors).
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26 ! 6) Participate in the resolution of noncon-27 '
28 formances.
29 1 30 l 7) Participate in procurement of engineered 31 32 equipment, including spare parts.
33 34 8) Interface with the Plant technical staff.
35 36 Q.15 Mr. Dewease, please summarize the current staffing 37 38 level of the STP Operations Division.
39 40 A.15 (JGD): Staffing the Plant organization began when 41 a Plant Superintendent and Assistant Plant Superintendent 42 43 44 45
- If requested by Plant operations staff.
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3 were named to their respective positions in February of l 4
5 1977. (Currently the Plant Superintendent position is 6
7 vacant.) Since 1977 we have grown to a staff of over 100 8
9 persons. We expect to build up to a staff of approximately 10 11 450 for two unit operation. To plan an orderly development 12 13 of the operations staff we have identified the tasks which 14 15 must be accomplished by the Plant staff up through commercial 16 17 operation of Unit No. 2.
18 19 We have been hiring personnel with nuclear exper-20 ence in the military services. We plan to continue to do 21 22 this, realizing, however, that the demand for these personnel 24 has greatly increased since TMI. We also plan to fill some 5
26 ' key positions with personnel with commercial nuclear power 28 plant operating experience.
29 30 Q.16 What are Plant Operations personnel doing during 31 32 the construction phase?
33 34 A.16 (JGD): Major pre-operational activities include 35 36 procedure development, training and experience visits to 37 l 38 commercial nuclear power plants, spare parts evaluations and 39 40 development of training materials.
41 j 42 Another major activity in which Plant personnel t 43 l
44 will be involved in the future is pre-operational testing.
l 45 46 Operators, Electricians, Mechanics, and I&C Technicians will 47 l 48 be assigned. to the "est Engineers as needed. Very valuable
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3 experience will be gained by our personnel in this way.
4 5 Present personnel are giving emphasis to development of 6
7 procedures that will be utilized for pre-operational testing.
8 9 In addition to working on plans for Plant opera-10 11 tion, the staff is reviewing and commenting on the Plant 12 13 design. Their review has resulted in suggested changes to 14 15 the design to improve system operability and maintenance.
16 17 Q.17 Please describe the transition from construction 18 19 to Plant operation.
21 A.17 (JGD): Before fuel is loaded in the Plant, HL&P 2
will conduct tests of the-Plant equipment and systems. A 3
24 separate HL&P organization, called the Startup Group, has 26 been established to conduct these tests. The Startup Manager, 28 Barry Duncan, is also Assistant Plant Superintendent and his 29 30 qualifications are described in Section 13.1 of the FSAR.
31 32 The Startup Organization is described in Section 14.2 of the 33 l 34 FSAR. It includes a number of experienced engineers working 35 36 on STP under a contract with Westinghouse. Plant Operations 37 38 personnel, including Operators, Chemical Technicians, and 39 40 I&C Technicians will be assigned to the Startup Group to 41 42 assist in the performance testing. The Startup Group is now 43 44 writing the Startup test procedures utilizing, where practi-45 46 cal, Plant precedures.
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3 4 As each Plant system nears completion the HL&P 5
6 Startup Group, HL&P Plant QA, Bechtel Power Corporation 7
8 (Bechtel) QA, and Bechtel Engineering will jointly review 9
10 .the status of the system to determine what must be done for 11 '
12 the system to be ready for testing. This activity includes 13
" walk-downs" of the system to identify hardware exceptions 15 or deficiencies.
16 17 When nonconforming conditions are identified by-18 19 l 20 HL&P Plant QA or Startup an NCR will be generated. The NCR 21 will be dispositioned by the ' organization that has design 22 :
23 responsibility at the time the nonconforming condition is 24 25 l identified. Depending on the scope of work necessary to 26 !
27 l disposition the NCR, either HL&P Maintenance or the Con-28 29 i structor will implement the disposition of the NCR.
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31 Once a system is tested and the test results approved, it will be turned over to Operations.
3 34 Q.18 Mr. Goldberg, has HL&P hired the personnel who 35 36 will provide technical support for Plant operations?
37 38 A.18 (JHG): As I mentioned before, the current design 39 40 and construction technical staff will form the nucleus for 41 42 the technical staff during operations. Technical activities 43 44 on the Project are under the direction of the Project Engi-45 46 neering Manager. The experience and qualifications of that 47 48 49 50 51 l 1
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4 staff were described in my previous testimony in this pro-5 6 ceeding, and will be updated in testimony on HL&P's rela-7 8 ti nship with Bechtel and Ebasco Corporations.
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NUREG-0731 identifies technical support skills 11 required for both normal and emergency operations.
12 We 13 already have on staff individuals that meet or will meet 14 15 most of the qualifications outlined in that document. We 16 17 plan to acquire or train additional individuals so that all 18 19 the requirements are satisfied. For instance, in 1981 we 20 21 recruited specialized skills in the areas of weld engineer-22 ,
23 i ing, ASME Division III pipe stress analysis, transient 24 j 25 l analysis, metallurgy, system engineering, and stronger 96 !l
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~7 1 engineering and licensing management.
2 Q.19 Mr. Dewease, describe the program for training STP 30 Plant operations stafi.
31 32 33 A.19 (JGD): An important element of our training 34 I program will be the use of the plant specific simulator 35 36 which we have ordered in accordance with one of the recom-37 38 mendations made after review of the lessons learned from 39 40 TMI.
41 42 We have formed a project organization to follow 43 44 the design, manufacture, installation, and testing of our 45 46 simulator. It is expected that the nucleus of our Simulator 47 4g Training Group will come from this project organization.
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4 The operator Training Group will be responsible 5
6 f r all operator license training except that utilizing the 7
g simulator. The objective of HL&P's operator training is to 9
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.e< quip the operator to assess any postulated situation and to 11 use the available information to evaluate the Plant parameters 12 13 displayed in the control room. The key to the operator's 14 15 ability to do this is understanding such factors as the 16 17 physical laws that govern the operation of Plant systems and 18 19 ! how those systems function.
20 '
21 Our on-site operator license training program 22 i 23 l consists of three parts: the Nuclear Steam Supply System
'4 l 25 ! (NSSS) Training Package, a Balance of Plant Package, and a f07 Procedures Package. The NSSS Training Package consists of 28 l 43 lessons including health physics, chemistry, reactor 30 ' theory, systems, accidents, transient and instrument failure 31 32 analysis. It includes system descriptions, lesson plans, 33 34 and training aids. This Package is completed. The Balance 35 36 of Plant Package is being developed by our Operator Training 37 38 Group. It will consist of 62 lessons on the remainder of 39 40 I the Plant systems. Each lesson will include system descrip-41 42 tions, lesson plans, and training aids. The approximate 43 44 current status is:
45 46 47 48 49 ,
50 51 '
1 2
3 4 System Descriptions: 47 completed, 5 in draft 5
6 Lesson Plans: 34 completed 7
8 Training Aids: 8 completed, 22 in Graphic y Arts 11 The Procedures Package h;s not yet been developed. It will 12 l 13 I consist of approximately 12 lessons covering operating 14 15 procedures, including normal, abnormal, emergency, and 16 17 annunciator response.
18 The General Training Group will provide the other 19 l 20 21 training for the Plant staff including General Employee 29 23 Training (Security, QA, health physics, etc.). Technical 24 Training will also be provided for six of the Plant groups:
25 l 267
! Chemical Analysis, chemical Operations, Radiation Protection, 28 Mechanical Maintenance, Electrical Maintenance, and Instru-30 ' mentation and Controls.
31 32 Q.20 Describe the training completed to date.
- 33 34 A.20 (JGD)
- Since 1977, we have sent three groups of 35 36 trainees through the Westinghouse Phase I, Phase II, and 37 38 Phase III programs at Zion, Illinois.
39 40 l These groups consisted of RO's, Supervisors, Plant I
41 42 management personnel and Engineers. Through this program we 43 44 have 15 individuals certified at the SRO level and 8 indivi-45 46 duals certified at the RO level. In addition to that program, 47 48 we have nine individuals who were already cold licensable i
l 49 50 51 l l
l l
i 1I 2
3 4 that have completed a Westinghouse 8-week intensive course 5
6 to familiarize them with Westinghouse commercial PWR's.
7 8 We think it is important to periodically provide 9
0
. refresher training to those individuals who have been through 11 the Westinghouse programs. Accordingly, we have contracted 12 13 with Westinghouse for 4-day Requalification programs on 14 15 their simulator. To meet current retraining requirements we 16 17 intend to send our licensed operators to Zion on an annual 19 l basis for the 4-day Requalification program.
18 20 l In late 1979, we sent 24 personnel to the 21 j 22 ,
23 ' Westinghouse 4-day Requalification program at Zion. In 24 25 ! early 1981 we returned 33 personnel to Zion for that program.
96 !
Q.21 How will the training program be utilized to 27 l f8 f prepare for initial Plant operation?
30 '
31 A.21 (JGD): Prior to cold license exams and in addition 32 to the on-site lecture series and periodic refresher training 33 34 i such as the 4-day requalification program at Zion, we plan 35 l 36 two weeks of simulator training. When that is completed we 37 38 will have the Westinghouse Pre-License Review Series and 39 i 40 i Audit before our personnel take the license examination.
I 41 42 Our plan is to put enough people into the start of this 43 44 program to man both Units 1 and 2. Although we do not 45 46 expect a 100% pass rate, we are confident that this approach 47 48 49 50 51 l -
- \
l I
1 '
2 l 3
4 will ensure that we have enough licensed personnel for 5
Unit 1.
Q.22 How will the training program be utilized once the
.9 Plant begins operation?
10 11 .
A.22 (JGD): After Unit 1 fuel load, our program will be 12 13 structured to bring people in at the entry level and train 14 15 them to qualify for the SRO license by means of three programs.
16 17 The first is the Auxiliary Operator Training Program.
Annually, we intend to have one class which will include the 18 19 l 20 21 following: 2 weeks indoctrination, 7 weeks Nuclear Power 2'
23 Plant fundamentals, 8 weeks of systems, 8 months of on-the-job 24 training, and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of simulator training.
25 !
After an Auxiliary Operator has been with us for 27 28 18 months, he will be eligible to go into hot license training 29l: i 30 at the RO level. That is the second of the three programs.
31 32 We intend annually to have one class which will include: 10 33 34 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 i
35 36 weeks of standing watch in the control room under the direc-37 38 tion of a licensed RO. Finally, candidates for RO and SRO l 39 40 l certificates will take the Westinghouse Pre-License Review I
i 41 i 42 Series and Audit, followed by the license examination.
43 44 The third program is the RO to SRO upgrade.
45 46 Annually, we will conduct one class which will include: 13 l
l 47 weeks of standing watch at the SRO level under the direction 4
49 50 l
51 !
I 1
l 1
2 3
4 f a licensed SRO, 40 class room hours of supervisory leader-5 6 ship 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 7
g level, and 4 weeks of advanced theory.
9 All Auxiliary Operators, RO's, and SRO's will 10ll 11 undergo retraining on a continuous basis. We plan to utilize 12 13 a six shift rotation which provides that five days in each 14 -
15 , 42 are used exclusively for training. Another four days'in 16 l 17 ! 42 are available for relief duty. When relief operators are 18 !
19 not standing relief watches in the plant, they will be 20 21 involved in additional training activities on an as-needed 22 , .
basis.
23 l 24 i The retraining program will include lectures, 25 !
26 simulator exercises, examinations, general employee training, 28 29 Licensee Event Report (LER) review, respiratory training, 30 fire brigade training, procedures review, and supervisory 31 32 training.
33 -
34 I Our plant specific simulator for STP will be 35 36 located at the site. We plan to have the simulator opera-37 38 tional in time to utilize it during the cold license training
, 39 l 40 of our first group of Operators. Of the simulator training 41 l 42 that I mentioned previously, that which is done before we 43 44 have our simulator operational will be conducted at Zion.
l 45 l 46 Q.23 Mr. Goldberg, will there also be training programs 4
for technical support personnel?
4 49 50 51 '
l 1
2 3
4 A.23 (JHG): Yes. Training of the technical support 5
6 groups is planned to cover each technical discipline.
7 8 Included in this planned training will be the use of the STP 9
10 . simulator.
11 12 Q.24 Mr. Dewease,- describe the organization for each 13 shift during reactor operation.
15' 16 A.24 (JGD): The shift organization is shown in Figure 2.
17 A Shift Supervisor with an SRO license will be on site 18 19 l anytime a unit is loaded with fuel. All personnel on shift 2 0
are responsible to him.
21 22 }
23 Reporting directly to him is an organization for 24 25 l each reactor unit headed by a Unit Supervisor with an SRO 26 i 27 { license and a chemical operations Foreman with associated 28 l staff. Each unit will also have two operators with RO 29 i 30 '
31 licenses, a Radiation Protection Technician / Monitor and a 32 Chemical Technician / Monitor.
34 Chemical operations personnel working on a unit 5
36 will keep the Unit Supervisor informed of their activities, 37 38 but will receive direction on priorities for scheduling work 39 40 activities from the Shift Supervisor.
41 42 We have added administrative aides on shift as a 43 44 result of TMI lessons learned. Administrative functions 45 46 that detract from or are subordinate to the Shift Supervisor's 47 48 49 50 51 l l
. . l l
l l
1 2 ,
3 1 4 management responsibility for the safe operations of the 1 5
6 Plant will be delegated to these personnel.
7 8 Our current plans call for the fire brigade to be 9
10 . headed up by the Chemical Operations Foreman. The other 11 four members will be made up of Chemical Technicians, Chemical 13 Operators and/or maintenance personnel.
14 15 Q.25 Does HL&P plan to include a Shift Technical Advisor 16 17 (STA) in its shift organization?
18 19 A.25 (JGD): Our present plan is to provide the expertise 20 21 of the STA through increased training of our shift Supervisors.
22 i 23 The STA position was recommended as a lesson learned from 94 h5 l TMI in NUREG-0578. The purpose was to provide an individual 26 I on-shift, with training in nuclear engineering or a related 27 l 28 l science and training in plant design and transient response, 29 iI 30 to complement the functions of other shift operations per-32 sonnel. The STA would be available in the control room 33 34 within 10 minutes of being summoned to diagnose off-normal 35 36 events and advise the shift supervisor. STA's are serving 37 38 now at currently operating commercial nuclear power plants.
39 40 I In NUREG-0731, " Guidelines for Utility Management 41 I 42 Structure and Technical Resources", the NRC Staff took the 43 44 position that "the long-term need for a shift technical 45 46 advisor to provide advice to the control room supervisor may 47 48 be eliminated when upgraded qualifications for the control 49 .
50 51 1
2 3
4 room supervisor ... and improved control rooms ... have been 5
6 attained." We believe that the long-term approach discussed 7
g in NUREG-0731 is preferable. The person making the decisions
,about reactor operation should have the nacessary experience 11 and education to perform properly.
12 13 However, if the NRC continues to require STA's as 14 15 separate advisors, HL&P will add qualified STA's in accordance 16 ~
17 with the NRC requirement.
18 l 19 Q.26 Will there be procedures to control access to the 20 21 control room? -
22 '
23 A.26 (JGD): Yes. Plant procedures will imit normal 24 access to the Control Room to those individuals casponsible 25 l 26 for direct operation of the Plant, technical advisors, and 28 specified NRC personnel, and will establish a clear line of 9 l I
30 authority, responsibility, and succession in the control 31 32 room. Limited special access to the control room may be 33 34 approved by the Unit Supervisor for specified purposes.
35 36 Q.27 Will there be shift turnover procedures?
37 30 A.27 (JGD): Yes. Plant procedures for shift relief and 39 40 I turnover will require signed check-lists and logs to assure 41 I 42 that the operating staff (including Auxiliary Operators and 43 44 maintenance personnel) possess adequate knowledge of critical 45 46 plant parameter status, system status, availability and 4
alignment.
48 49 50 51 '
I l
1 1
1 2
3 Q.28 Mr. Goldberg, how does HL&P plan to control design 5
changes during plant operation?
6 7
8 A.28 (JHG): All changes affecting basic engineering 9 design (equipment, structures, sizing and arrangement) or 10 11 Plant operability will be reviewed and approved by the 12 13 technical staff. Changes will also require the con-14 15 l currence of the PORC and the NERB. In addition to the 16 (
17 normal review for technical adequacy or desirability, these 18 19 requests for design changes will be reviewed with close 2
21 attention to the impact on FSAR commitments, any affected 22 analyses and whether or not an unreviewed safety question is 24 involved. Once the request is approved, implementation of 25 3 26 the design change will be directed by the site technical 27 l i 28 l group through the normal engineering process.
29 30 Q.29 Does HL&P have a system for learning from the 31 {
32 operating experience of other utilities?
33 -
34 A.29 (JHG): Yes, that type of information is available 35 36 in documents such as NRC I&E Bulletins and LER's. At present, 37 38 NRC generated' input, including I&E Bulletins, Notices, new 39 40 l regulations, and Regulatory Guides are screened by our l2 Nuclear Licensing Department for applicability and importance 43 4 and then sent for action to the appropriate management and 45 46 technical personnel, including those in Operations. The 47 publication, Nuclear Power Experience Reports, is used as 48 t 49 50 51 l l
1 2
3 4 another source of input to the technical support and Operations 5
3 staffs. The reports are reviewed by the cognizant discipline 7
8 and factored into the Plant design, construction and/or 9
10 . planned operation as appropriate along with other inputs.
ff In addition, Dr. . James Sumpter, of my staff, is a 13 member of the EEI Nuclear Operations Subcommittee.
14 This 15 group is composed of the chief technical support and opera-16 l 17 tions personnel from many utilities in the U.S. They meet 18 19 l tri-annually and exchange information concerning operational 20 21 experiences.
22 i 23 l Through the efforts of Nuclear Safety Analysis 24 l 25 l Center and the Institute of Nuclear Power Operations, the 26 !
27 many hundreds of LER's are now being screened and distri-28 29 . buted to interested parties, through a service known as 3
NOTEPAD. We are a user of that service.
31 3
Q.30 Mr. Dewease, please describe the FORC.
3 34 The PORC is a committee established in A.30 (JGD):
35 l 36 l accordance with the Technical Specifications. Its members 37 38 include the Assistant Plant Superintendent, the Operating l
39 40 I General Supervisor, the Technical General Supervisor, the
! 41 I 42 Maintenance General Supervisor, the Lead Reactor Engineer, 43 44 the Radiation Protection Supervisor, and the Plant QA Super-
, 45 l 46 visor. The PORC advises the Plant Superintendent on matters 47 48 important to safety.
t 49 50 51 l I
1 2
3 4
The PORC reviews procedures, tests, changes to 5
6 Technical Specifications and safety-related systems, Tech-7 8
nical Specification violations, 24-hour notification items, 9
. Plant operations, and the Security and Emergency plans.
10 11 We have built safeguards into this mechanism to 13 minimize the possibility of suppression of dissenting opinions 14 15 regarding safety matters. In the event of a disagreement 16 17 between a PORC member and the Plant Superintendent, the 18 19 ; member may request that the disagreement be documented in 20 21 the meeting minutes. PORC meeting minutes go to the Chairman 22 ,
23 l of the NSRB, which is discussed below. If a majority of 24 l 25 l PORC members disagree with the Plant Superintendent, the 26 !
27 [ NSRB Chairman and the Executive Vice President must be 28 { n tified in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
29 !
0l The PORC has been meeting monthly since July 1978.
32 The Committee's primary function to date has been the review 34 f saf ty-related procedures.
5 36 Q.31 Mr. Goldberg, describe the NSRB.
37 38 A.31 (JHG): The NSRB is a corporate headquarters 39 40 committee that is chaired by me as Vice President, Nuclear 41 42 Engineering and Construction. Its members include the 43
! 44 Manager, QA; the Manager, Nuclear Services; the Director, 45 46 Nuclear Fuel; and the Manager, Nuclear Licensing.
47 48 l 49 50 51 ;
I t
1 2
3 4 The NSRB reviews such matters as proposed changes 5
6 to procedures, equipment, systems, Technical Specifications 7
8 and the operating licenses. It reviews reports and meeting 9
0
. minutes of the PORC and significant operating abnormalities, 11 including violations of license requirements or internal 12 13 procedures having nuclear safety significance.
14 15 In addition, it conducts periodic audits of the 16 17 following areas:
18 19 l 1. The conformance of facility operation to provi-20 21 sions contained within the Technical Specifica-22 23 ( tions and applicable license conditions.
24 l
- 2. The performance, training, and qualifications of 25 l
'6
' f 7
I the entire facility staff.
28 { 3. The results of actions taken to correct deficien-I 30 cies occurring in facility equipment, stractures, 31 32 systems or method of operation that affect nuclear 33 34 safety.
35 36 4. The performance of activities required by the 37 38 Operations QA Plan to meet the criteria of Appendix 39 40 I B to 10 CFR 50.
I 41 42 5. The facility Emergency Plan and implementing 43 44 procedures.
45 46 6. The facility security Plan and implementing pro-47 43 cedures.
49 50 51 ' -
. e 1
2 1 3 l 4 Q.32 Will there also be a dedicated engineering staff f at the site, without operational responsibilities, which 7
will perform independent safety reviews?
9 10 A.32 (JHG): Yes, as a result of our review of the NRC 11 proposed post-TMI requirements, HL&P is committed to having l 12 13 an effective Independent Safety Engineering Group (ISEG) and 14 15 we have under study the details of its operation. Our 16 17 current plan is that the ISEG will report to me and will be 18 19 l composed of a small staff of on-site, full-time engineering personnel. Its responsibilities will include those speci-20ll 21 22 ' fied in NUREG-0737, " Clarification of TMI Action Plan Re-23 24 quirements." -
5l 26 l Q.33 Mr. Goldberg and Mr. Dewease, does the FSAR des-28 cribe how HL&P will conduct the operation of STP?
29 1 I
30 A.33 (JHG, JGD): Yes, Chapter 13 of the FSAR is entitled 31 32 Conduct of operations. It describes the HL&P organization 33 34 I for Plant operations, the personnel training program, certain l 35 l 36 Plant operating procedures and the review and audit program.
37 30 Section 13.3 references the separate volume containing the 39
( 40 l Emergency Plan which is now being revised to meet post-TMI
! 41 I 42 requirements, and Section 13.6 references the Security Plan.
43 44 Q.34 How were Sections 13.0, 13.1, 13.2, 13.4 and 13.5 5
6 f the FSAR prepared?
47 48 49 50 51 8
1 2
3 4 A.34 (JHG, JGD): The Plant operations staff was respon-5 6 sible for drafting major portions of those sections. The 7
8 Nuclear Licensing Section then coordinated an internal l0
. review f the drafts. These sections were reviewed and 11 updated earlier this year and we both personally reviewed 13 and approved these FSAR sections as revised through 14 l 15 amendment 24.
16 17 Q.35 Are the contents of FSAR Section 13.0, 13.1, 13.2, 18 19 l 20 13.4 and 13.5 as revised through amendment 24 true and 21 correct to the best of your knowledge and belief?
22 23 l A.35 (JHG, JGD): Yes.
24 1 25 l 26 1 27 I TH:13:A 28 29 30
- 31 32 33 34 35 36 37 38 39 40 I I
41 l 42 43 44 45 46 47 48 49 50 51 '
~
PRESIDENT I
EXECUTIVE VICE PRESIDENT VICE PRESID.ENT NUCLEAR PLANT OPERATIONS SOOTH TEXAS PROJECT I ALLENS CREEK
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1 i i l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
HOUSTON LIGHTING AND POWER )
COMPANY, ET AL. ) Docket Nos. 50-4980L
) 50-4990L (South Texas Project, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of Testimony of Jerome H.
Goldberg and Jerrold G. Dewease Regarding the Operation of the South Texas Project have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid on this //44 day of March,1982.
Charles Bechhoefer, Esq. Brian Berwick, Esq.
Chairman, Administrative Judge Assistant Attorney General Atomic Safety and Licensing for the State of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Commission . Division Washington, D.C. 20555 P. O. Box 12548, Capitol Station Austin, Texas 78711 Dr. James C. Lamb, III Administrative Judge William S. Jordan, III, Esq.
313 Woodhaven Road Harmon & Weiss Chapel Hill, North Carolina 27514 1725 I Street, N.W.
Washington, D.C. 20006 Ernest E. Hill Administrative Judge Kim Eastman, Co-coordinator
- Lawrence Livermore Laboratory Barbara A. Miller University of California Pat Coy P. O. Box 808, L-46 Citizens Concerned About Livermore, California 94550 Nuclear Power 5106 Casa Oro Mrs. Peggy Buchorn San Antonio, Texas 78233 Executive Director l Citizens for Equitable Lanny Sinkin Utilities, Inc. 2207-D Nueces Route 1, Box 1684 Austin, Texas 78705 Brazoria, Texas 77422 l
t - .
, a l
1 l
Jay M. Gutierrez, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 s -
Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
\
Atomic Safety and Licensing Board '
U.S. Nuclear Regulatory Commission .
Washington, D.C. 20555 ;,
Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -
l l- -
~
Thomas B. Hudson, Jr. j/'
s 1
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- - - ~ -