ML20050A838
| ML20050A838 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/22/1982 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8204020319 | |
| Download: ML20050A838 (16) | |
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Ferry Nuclear Power Plant Docket IIos. 50-440; 50-441 Eesponse to Action Items -
l ISC "anagement Audit at i
PliPP, 1/25 - 1/29 r
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Dear "r. Schwencer:
1his letter transmits our responses to action items identifed isy the lac t'ar:25c ~nt Awilt Team during a site tisit at PHPP r
corrlueled from 1/29/02-1/29/02.
it.is our intention to revice Chapter 13 of the FSAR to in-e, ri orate any co::xi.tr ;nts I:ade in the attached recponses.
Very Truly Yours, t
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Lalwyn R. Eavidron Vice Fresident Eystem Engineering and Construction L
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Jay Gilberg John Stefano
- %x Gildner Eric redersen P
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Action Item 1:
Training Coordination at PNPP
Response
la). Training Section Description On February 15, 1982, the Nuclear Project Training Section was formed as a new Section in the Perry Project Services Department in response to the NRC Team's concerns about training,.
Mr. Cyril M. Shuster, General Super-vising Engineer, was transferred from System Planning Engineering to head the new Training Section.
Eight persons (6 professional, 2 clerical) are assigned to the Training Unit in Perry Plant Department with responsi-bility for Operations and Maintenance Training.
Ongoing training activities include the following:
CEI has entered into a lease / purchase agreement with GE for the Perry Simulator now located in Tulsa, Oklahoma; General Electric is being used to provide instructors for Operator Training on the Simulator; Ohio State University is under contract to develop a General Employee Training Program; and an arrangement is in effect with Ohio State University and Lakeland Community College wherein instructors from these institutions present college level courses in math and science on-site.
The objective of the newly established Section is to provide total site training coordination, so as to insure the Project is staf fed with trained, qualified individuals capable of supporting, maintaining, and operating the Perry Plant.
The Section organization chart has been established, as shown on attached Figure 1, with staf f size shown as of March 8, 1982.
As of March 8, Section manning was at five persons, with plans to enlarge to seven persons by the end of March.
The initial Nuclear Project Training Section organization design consists of a Program Developmental Activity, a General Nuclear Training Activity, and a Training Services and Support Activity.
Initially, this Section is responsible for consolidating all on going training in the Construction /
Support Departments and maintaining close coordination with the Perry Plant Department Training Unit in the communications of information, development of programs, development of procedures, and recordkeeping activities.
The ultimate assimilation of the Perry Plant Training Unit into the Nuclear Project Training Section is as shown on Figure 2.
The time frame for bringing the two elements together is currently projected as being 1
Action Item l_i (Page 2) at fuel load, so as not to cause any disturbances for the current operator training efforts. The estimated manning of the overall training organization will be approximately 20-22 persons plus consultants as needed. Approximately 75% of the staf f will be professional persons, th). HWR training for PPD staff Observation training will be scheduled for IIcalth Physics personnel. The llealth Physicist, whose prior experience has been chiefly in PWR plants, will spend at least four weeks at an operating BWR.
This will be accomplished prior to scheduled fuel load at the Perry Plant.
Selected health physics technicians, at least five, will participate in radiation protection activities at commercial BWR plants for at least four weeks each.
Observation training for the Operations and Maintenance Section General Supervisors will be supplemented with at least four weeks at an operating BWR plant prior to the scheduled fuel load at the Perry Plant.
Ic). Operator Qualifications Pipeline The operator qualification pipeline currently includes 35 persons with ten additional nuclear power plant experienced people to be hired during the first half of 1982 for training prior to fuel load. This number does not include upper management, training and technical staff engineers who also completing licensed operator training (12 of 17 to be trained are presently certified at the SRO level).
Expectations are that there will be 40 operator 11censeo candidates trained prior to fuel load to ultimately fill 12 SRO positions (six Shift Supervisors and six Unit Supervisors), and 12 RO positions (Supervising Operators). This allows for 16 additional license candidates to provide for last-minute attrition and examination failures. While the goal is to staff for six shift rotation, fewer licenses could suffice for a limited period of time to allow re-examination in case of unexpected failures.
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I Action Item 2:
Availability of Operating Nuclear Power Plant Experience in Plant Management in Operations Areas 1
Resoonse A person with operating nuclear power plant experience will be obtained in either an advisory capacity or integrated into the plant organization as l
Superintendent, Plant Operations for at least one year in advance of fuel load. This person will serve as a member of the Plant Operation Review Committee, and if not a permanent member of the Plant Staff, will remain in place at least for 12 me..ths following fuel load.
In addition, each operating shift will have assigned to it a person with commercial BWR start-up experience during the period from fuel load until 100%
power is attained or for one year, whichever comes first.
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Action Item 3:
Letter of Commitment on the Reorganization Plan for PNPP
Response
During a January 25, 1982, oral presentation to the NRC Management Audit Team, Managers of the PNPP Site Organization described current and future plans for the Site Organization. Described below are steps taken since the January i
audit as well as future plans to complete a full site reorganization to separate functions related to start-up and operation of Perry 1 from functions related to construction of Unit 2 six months prior to fuel load.
Two major changes have already occurred which respond to NRC and CEI concerns:
1.
On February 15, 1932, the Nuclear Project Training Section was formed as a new section within the Perry Project Services Department. The objec-tive of the newly established Section is to provide total site training coordination to insure that the PNPP Project is staffed with trained, qualified individuals capable of supporting, maintaining and operating the Perry Plant.
2.
As of March 12, 1982, the Nuclear Engineering Department's position of General Supervising Engineer (GSE), Nuclear Design and Analysis has been split to form two GSE positions:
GSE, Nuclear Construction Engineering section; and GSE, Nuclear Design and Analysis section. The attached organization chart shows the changes which have occurred.
The organizational changes described above are the first of several major changes which will occur between now and a date six months prior to fuel load.
The numerous organizational charts attached show the current site organization compared to the site organization expected to be in place six months prior to fuel load of Perry 1.
When these changes are initiated, an amended FSAR Chapter 13 will be transmitted to the NRC.
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Sheet 1 of 1 CHANGES TO THE NUCLEAR ENGINEERING DEPARTMENT SINCE THE JANUARY REVIEW:
DEPARTMENT ORGANIZATION AS OF MARCH 22, 1982 Nuclea r Engineer Depa rtment Manager M.
R.
Edelman I
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i Nuclea r Test Section Nuclear Construction Nuclea r Licensing and GSE Engineering Section fuels Management Section B.
L.
Barkley GSE CSE J.
M.
La s tov ka L.
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Beck Nuclear Construction Nuclea r Design and Administ rativn and Section CSE Analysis Section Special Projects J.
A.
Kline GSE Section GSL J.
H.
Bellack L.
E.
Hartline 197/G/3/kf
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Sheet 1 of 2 PNPP SITE ORGANIZATION: SIX MONTHS PRIOR TO FUEL LOAD OF PERRY 1 Nuclea r Group VP I
Nuclea r Engineering Nuclea r Construct ion Nucleah Quality Pe r ry P l a'n t Dept.
Pe rry Dept. Manager Dept. Manager Assurance Dept.
Manager P roj ec t Manager j
Se rv i ce s Manager Nuclea r Ana lysis and Records and Adh.in-Cdnstruction !
Ope ra t i'ona l Audit Design GSE i st ra t ion GSE Quality GSE Quality GSE Element 1
Nuclear Licensing T ra ining and Admini s-and fuels Manage-t ra t ion CSE ments GSE Superintendent Plant Operat ions l Constru6 tion Ou t a'g e Nuc l ea r Co'nst ruct i on Nucle 6r Test 3 Nuclea r Services Radi'aMon Engineering Engineering GSE GSE GSE Protection GSE GSE CSE TechnicaI'Section OpeFation Ma i n t'o r.a nce GSE Section Section GSE GSE 197/G/f/kr 4
a Sheet 2 of 2 PNPP SITE ORGANIZATION: SIX MONTHS PRIOR TO FUEL LOAD Of PERRY 1 (Cont'd)
Nuclea r Group VP Admini st ra t ive Se rvices i
Group VP s
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Perry Project
- Services Manager m
P rocu remerit Systems and' Procedures f ac i l i t i es' a nd T ra i di ng GSE GSE Services GSE GSE 197/G/5/kf
_A_c_ tion Item 4:
BWR-Operating Experience on Nuclear Safety Review Board
Response
The Nuclear Safety Review Board will have as members at least two senior individuals with commercial BWR operating and/or management experience.
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Action Item 5:
Adequancy of Plant Staffing Levels I
1
Response
The proposed plant staffing has been reviewed as a result of additional commitments made to provide on shift an Instrument and Control Technician, a Shift Technical Advisor, a goal of six operating shifts and the consolidation of training in a separate organizational element. Thus, the total staffing expected at fuel load for Unit 1, devoted exclusively to Unit 1 operation, is as follows:
Total Site Staffing For Unit 1 Operation Perry Plant Department 297 Nuclear Engineering Department (on site) 87 l
Project Services Department (Training) 20 l
Operational Quality Assurance (QA/QC) 25 i
Total Staff (Unit 1 Operation) 429
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Dased on these changes, the following is a tabulation of proposed staffing by section.
Perry Plant Department Units 1&2 Unit 1 r
Management 3
3 Maintenance 155 85 Operations 101 63 Technical 82 53 Radiation Protection 56 43 Services 52 42 Security 8
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Total 457 297 i
i-The training function, which at fuel load will report to the Manager, Project Services Department, will incorporate the licensed operator training as well as all the Perry Project personnel training. This function will require about 20-22 personnel. The Nuclear Engineering Department, including the Independent Safety Review Group, will be reorganized to support, on site, the I
operation of Unit 1.
A separate department, Nuclear Construction Department, will assume responsibility for completing Unit 2 including pre-operational testing. The Nuclear Engineering Department is proposed to be staffed with about 87 employees.
Operational Quality Assurance is also a separate
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reporting function with both QA and QC responsibility handled by a staff of 25 employees deveted exlcusively to the Unit 1 operation.
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(Page 2)
The above staffing does not include security personnel outside of the super-visory personnel.
The staffing described here provides for meeting all commitments for on-shift personnel without excessive reliance upon overtime in routino operation.
Extensive provision for training time is included, and adequate numbers of entry-level personnel will ensure fully trained skills will be available as required as construction progresses and Unit 1 is completed.
In addition to Unit I staffing for operation, there is located on site addi-tional Engineering, Quality Assurance, Construction and Project Services staff involved with the continuing construction of Unit 2 as outlined previously under Action Item 3.
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Action Item 6:
Engineering Support Staff for PSPP
Response
The Perry Nuclear Power Plant Site Organization will reorganize prior to fuel load for Perry 1 to separate the support functions for Perry 1 start-up and operation from the support functions for construction of Perry 2.
Six months prior to fuel load for Perry 1, the site organization will be as follows:
Nuclear Croup VP Administrative Services Group l
VP l
Nuclear l Quality 1
I Nuclear Engineering Perry Plant Perry Project Dept. Manager Assurance Dept.
Dept. Manager Services Dept.
Manager Manager Nuclear Construction Dept. Manager The new Nuclear Engineering Department will provide engineering support to Perry I during its start-up and operation:
the Department will have an initial staffing level at Perry 1 fuel load of about 87 employees.
The Nuclear Analysis and Design, Nuclear Licensing and Fuels Management, and the Records and Administration Sections will report to the Manager of the Nuclear Engineering Department.
Most of these individuals will be Cleveland Electric Illuminating Company employees.
However, CEI will continue to retain Gilbert Commonwealth Associates to provide additional engineering support where necessary. General Electric, as NSSS supplier, will also be retained on a consu1 ting basis where required.
The new Nuclear Construction Department will provide engineering support for Unit 2 construction. The Nuclear Construction, Nuclear Test, Construction Engineering and Outage Engineering Sections will report to the Manager of the Nuclear Construction Department.
CEI will continue to retain Gilbert Commonwealth Associates as the Architect / Engineer for Perry 2 construction.
Staffing levels for this department have not yet been projected.
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i Action Item 7:
FSAR Chapter on PNPP Compliance with NUREG 0737
Response
CEI will amend the PNPP/FSAR to include a new chapter describing the status of PNPP compliance with NUREG 0737.
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Action Item 8:
Shift Staffing
Response
The shift staffing described in the FSAR Section 13.1.2.3 for the Perry Plant Control room, with two units operating, provides for six licensed personnel for the two units; three SRO's and three RO's.
This staffing exceeds the NUREG 0737 interim guidance staffing level for Two Units, One Control Room configurat. ion by one SRO license and is less than the interim guidance staffing level for Two Units, TWo Control Rooms by one R0 license.
t The original Perry Plant control room design was arranged for optimizing the human factors impact for operators moving from one unit to the other while in the single control room.
This was the basis for arranging the two control boards side by side with identical positioning of all operating devices located on each control board. As a result of fire protection considerations, a partition was installed between the two control boards with a normally closed door at the partition and for more effective command and control during emergency operation, an SRO has been added to each shift crew.
For starting up or shutting down a generating unit, two R0 licensed operators are normally required. With three RO's available each shift, one RO will be regularly assigned to each unit with the third RO available for assignment to the unit which may be starting up or shutting down.
It is not normally expected that both units would be in that mode of operation at the same time.
If such would be the case, an additional RO will be provided by calling out or holding over an extra person if not available on shift. Thus, it does not represent the proper utilization of critically skilled manpower to require i
full time on shift the fourth R0 licensed operator for those rare instances when he or she would be needed. Therefore, exception is taken to the interim r
staffing guidance for Two Units, Two Control Rooms as tabulated in NUREG 0737 I.A.I.3-4.
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