ML20052E409
| ML20052E409 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/29/1982 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.2, TASK-1.B.1.2, TASK-1.C.2, TASK-1.C.3, TASK-1.C.5, TASK-1.C.6, TASK-TM NUDOCS 8205110085 | |
| Download: ML20052E409 (13) | |
Text
THE CLEVELAND ELECTRIC ILi.UMIN ATING COMPANY P o Box 5000 m CLEVE'L AND OHlo 44101 e TELEPHONE (216) 622-9800 m ILLUPAINATING BLDG e 55 PUOLIC SOUARE Semng The Bec g c i k,
+c Nation Datwyn R. Davidson o
c, m PRE S:Ot NT N
<,sn.s nuanu n'no Ano constsuction 7j p
April 29, 1982 y
JO\\., 7
-]
,N Mr. A. Schwencer c 3,
- 7.
Chief, Licensing Branch No. 2
)s s Division of Licensing A
/
(# )' 7 - -
U. S. Nuclear Regulatory Commission
/
Washington, D. C.
20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to Request for Additional Information -
Management Organization
Dear Mr. Schwencer:
This letter transmits revised responses to our March 22, 1982, letter regarding the questions posed by the NRC Licensee Qualification Branch on the Perry Nuclear Power Plant Site and CEI Corporate organization.
It is our intention to incorporate these revised responses in a subsequent amendment of Chapter 13 to our Final Safety Analysis Report. An amended Chapter 13 will be transmitted to you as soon as it is completed.
Very Truly Yours, Dalwyn. Davidson Vice President System Engineering and Construction DRD: mlb cc:
Jay Silberg John Stefano j
Max Gildner QpD1 Eric Pedersen
- 1) f i (
8205110005 820429 PDR ADOCK 05000440 A
Action Item 2:
(Revised)
Availability of Operating Nuclear Power Plant Dcperience in Plant Management in Operations Areas
'Besponse A person with operating nuclear power plant experience will be obtained in either an advisory capacity or integrated into the plant organization as 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 Co=ittee, and if not a permanent member of the Plant Staff, will remain in place at least for 12 months!following fuel load. This manag'ement advisor will meet ANSI 3 1-1978 qualifications 4for a technical section supervisor or operations supervisor.
The advisor will have had prior experience at a supervisory level at a cc:mercial, operating nuclear power plant in a position such as Lead'; tart-Up Engineer, Start-Up Manager, technical section supervisor or operations supervisor.
In addition, each operating shift will have a person with co=ercial-BWR start-up experience assigned to it for a' minimun period of one year following fuel load for Perry 1.
o m
D t
.t, s
k 5
1 w
b l
s
(*s
/ v.
3 s
9
-g
+
i
..r
\\
s s
Action Item 3:
(Revised)
[
3
[
^
- j Letter of Comaritment on the Reorganization Plan for PNPP
. p
\\
Response
r During a Januarv 25, 1982, oral presentation to the Isc Management Audit Team, Marlagers of the PNPP Site Organization described current and future plars foe the' Site Organizatio'1. Described below are steps taken since the7 anuary audit as well as' future plans to complete a full J
cite reorganizatfon tc separate functions related to, start-up and operation of Perry 1 from functions related to constraction of Unit 2 six months prior to fuel load.
{l
=
s Several cajor changes have" already,o:durred which respond to IEC and CEI concerns-
,l 1.
On February 15, 1982,'the Nuclear' Project Training Section was formed as a new section within'the Perr;,' Project Services Department. The objective 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 operatin6 the Perry Plant.
2.
As of, March 12, 1982, the Nuclear Erigineering Department's position of General; Supervising Engineer (GSE),' Nuclear Design and Analysis has been split to form two GSE, positions:
GSE, Nuclear Construction Engineerin6 section; and GSE, lhelear Design and Analysis section.
The attached organization chart'shows the changes which have occurred.
4 i
3 On,B.pril 21, 1982, additional changes were announced with the
{ recrganization effec 31ve on May 1, 1982:
The Nuclear Engineering and Construction Division and the Ngelear Construction Department in that Division were formed.
The Luclear Engineering Department was discontinued and the
. Nuclear Construction Section was renamed the Nuclear Construction Administration Section, Nuclear Construction Department.
Certain section reporting responsibilities changed as shown in the attached organization chart.
In summ ey, all proposed organizational changes discussed on January 25, 1982, have been implemented at PNPP with the exception of the l
co=mitment to provide a Vice President solely responsible for nuclear activities. This co=mitment will be implemented 6 months prior to fuel load for Unit 1.
I i
p y.
y CHANGES TO TIE HUCLEAR ENGIHEERING DEPARTMENT GINCE TIIE JANUARY REVIEU:
DEPAR' DEUT ORGAICZATION AS OF MAY 1,1982 VICE PRESIDENT, VICE PRESIDENT, I
SYSTEM ENGINEERING AND CONSTRUCTION ADMINSTRATIVE SERVICES j
4 I
DIVISION MANAGER, NUCLEAR ENGINEERING AND CONSIRUCTION
- MANAGER, MANAGER,
- MANAGER, MANAGER, CONSTRUCTION PERRY PLANT OA PERRY PROJECT DEPARTMENT DEPARTMENT DEPARTMENT SERVICES
/
GSE GSE GSE GSE GSE GSE Nuclear Nuclear Administration Nuclear Nuclear Nuclear Licensing and Design and and Special Construction Test Construction Fuels Management Analysis Projects Engineering Administration 9
Action Item 5:
(Revised)
Adequacy of Plant Staffing Levels
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, is as follows:
Perry Plant Department Units 1 and 2 Unit 1 Management 3
3 Maintenance 155 85 Operations 101 63 Technical 82 53 Radiation Protection 56 43 Services 52 42 Security 8
8 TOTAL 457 297 Other Pro;)ect Organization Department Staffing, Fuel Load, Unit 1 Nuclear Engineering Department 115 Quality Assurance Department Management 2
Training and Administration 42 Audit 10 Construction Quality Assurance 79 Operations Quality Assurance 17-TOTAL 150 Construction Department 400 Perry Project Services 100
a
- Action Item 5: (Con't)
Pg. 2 he Perry Plant Department Training unit win be consolidated under the Nuclear Project Training section at fuel load for Unit 1.
- Bus, the staffing level of the Perry Project Services Department, Nuclear Project Training Section will be about 20-22 personnel at fuel load for Unit 1.
The Nuclear Engineering Department, which includes the Independent Safety Engineering Group, has been recently reorganized (see revised response to Action Item 3) to funy support, on site, the operation of Unit 1.
The new Nuclear Construction Department (see ' revised response to Action Item 3) will assume responsibility for Construction Engineering, Construction Administration, and Pre-Operational Testing. Operational Quality Assurance will be a separate reporting function with both QA and QC responsibilities i
at fuel load of Unit 1; the projected staff of 17 will be devoted excittsively to support of Unit 1 operation.
The above staffing does not include aecurity personnel outside of the supervisory personnel.
B e staffing described here provides for meeting all commitments for j'
on-shift personnel without excessive reliance upon overtime in routine
^
operation. Extensive provision for training time is included, and adequate numbers ' of entry-level personnel will ensure fully trained l
skills will be available as required as construction progresses and Unit 1 is completed.
I l
t Ir 1-
l l
'630.13 Expand the description of the initial fire brigade (13 2 3) described in section 13 2.5.1.
(Revised)
Response
A fire brigade consisting of a licensed Senior Reactor Operator sto functions as the brigade leader, a Plant Operator (AO), an Instrument and Controls Technician, and two Security personnel will be available on all shifts. The fire brigade members will have no duties during a fire except those directly related to manual fire-fighting. Prior to assignnent to the fire brigade and annually thereafter, each member will receive a physical exnM nation that will ensure that no physical condition exists that would prevent proper performance of strenuous fire-fighting activities.
The fire brigade will be equipped with sufficient quantities of personal protective equipment, manual suppression equipment and other equipment necessary for effe_ctive fire-fighting. Equipment will meet criteria stipulated in 10CFR Part 50, Appendix R, Section h(1)(2)(3).
The fire brigade training program provides for classroom training, practice sessions and drills.
The fire brigade training program will meet criteria stipulated in 10CFR Part 50, Appendix R, Section.I.
A sufficient nu=ber of on-shift personnel will receive the same basic training and retraining as that received by the fire brigade. These on-shift personnel will be available and trained to assist or replace designated menbers of the fire brigade as necessary.
I l,
~
630.18' NUREG-o737 Section I.B.l.2 established the requirement (13.4) for an Independent Safety Engineering Group. Present (revised) your plans for complying with this requirement.
Response
The Perry Nuclear Power Plant win have an on-site Independent Safety Engineering Group (ISEG) which will meet the intent of NUREG 0737, I.B.1.2.
The ISEG will fom a part of the Nuclear Engineering Department. The group will be staffed by engineers and other technically oriented personnel, all of whom will have qualifications comparable to the requirements set forth in ANSI /AUS 3.1, Sections 4.1 and 4.2 (December 1981),
The staff will consist of 5 individuals from Mechanical, Electrical, Chemical /EnvironmentalandQualityAssurancedisciplines, one of who will be designated as chaiman. The chair =an of the ISEG will report directly to the Manager of Nuclear En&ineering Department.
The ISEG will be a full time dedicated organization. At any given time, five individuals will be assigned to the ISEG; however, the individuals will serve on a rotational basis with a minimum assignment of at least 3 months and nm4rmily for one year.
The charter of the ISEG will include the following scope:
1.
The priicipal function of the ISFG is to examine plant operating characteristics, NRC issuances, LIS advisories, and other functions of design and operating experience infomation that indicate areas for improving plant safety.
2.
The ISEG is to perform periodic, independent review of plant activities including maintenance modifications, operational problems and operational analyses.
As deemed necessary by the ISEG, detailed reco=mendations regarding improvements will be presented to management.
3 Periodic surveillance of operations and maintenance audits will be conducted to verify that these activities are perfomed correctly. These activities do not include detailed audits of plant operations; but rather, represent an overview function.
4.
The ISEG will evaluate the effectiveness of the operational Quality Assurance program independent of nomal functions of the Quality Assurance Department.
Nuclear Engineering Department procedures will be developed to assure that the requirements of the charter and the intents of NUREG 0737 are met.
Item No.
I.A.l.2 s
Shift Supervisor Administrative Duties 4
REQUIREMEITT Review the administrative duties of the shift supervisor and delegate functions that detract from or are subordinate to the management responsibility for assuring safe operation of the plant to other personnel not on duty in the control room.
RESPONSE
Administrative procedures will be clearly written to define the shift supervisor's command and control responsibilities and authorities and to emphasize his responsibility for safe opera-tion of the plant.
Those functions which clearly detract from the shift supervisor's responsibility for assuring safe opera-tion of the plant will be assigned to other personnel, not directly responsible for reactor operations.
O I
e e
i e
Item No.'I.C.2 ea vszc Shift Relief and Turnover Procedures REQUIREMENT
- The licensees shall review and revise as necessary the plant procedure for shift and relief turnover to assure the following:
1.
A checklist shall be provided for the oncoming and offgoing control r6cm operators and the oncoming shift supervisor to complete and sign.
The following items, as a minimum, shall be included in the checklist.
a.
Assurance that critical plant parameters are within allowable limits (parameters and allowable limits shall be listed on the checklist).
b.
Assurance of the availability and proper alignment of all systems essential to the prevention and mitigation of operational transients and accidents' by a check of the control console.
(what to check and criteria for acceptable status shall be included on the checklist);
c.
Identification of syAtems c6mponents that are in a degraded mode of operation permitted-by the Technical Specifications.
For such systems and components, the length of time in the degraded mode shall be compared with the Technical Specifi-cations action statement.(this shall be recorded as a separate entry on the checklist).
2.
Checklists or logs shall be provided for completion by the offgoing and ongoing auxiliary operators and techni-cians.
Such checklists or logs shall include any equipment under maintenance or test that by themselves could degrade a system critical to the prevention and
' mitigation of operational transients and accidents or initiate an operational transient (what to check and criteria for acceptable status shall be included on the checklist); and l
l 3.
A system shall be established to evaluate the effective-ness of the shift and relief turnover procedure (for example, periodic independent verification of system alignments).
- This " REQUIREMENT" is taken from D.
B.
Vassallo's letter dated 11/9/79 to all, licensees of plants under construction since it i _.
was not provided in detail in either NUREG-0660 or NUREG-0737.
f l
RESPONSE
LOJi Checklists and/or logs will be provided for the control room operators and shift supervisor.
The checklists and/or logs will include items such as critical parameters, control console checks for availability and proper alignment of systems essential to the prevention and mitigation of operational transients and accidents and the identification of degraded systems or components (including, time in~ degraded mode) that are addressed by Technical Specifications.-
Auxiliary operators will revi~ew plant status by log reviews.
An administrative procedure will address the conduct of shift turnover.
D O
s*
h i
l h
I N+
=
r
Item No. I.C.3 pn usy Shift Supervisor Responsibilities REQUIREMENT Issue a corporate management directive that clearly establishes the command duties'of the shift supervisor and emphasizes the primary management responsibility for safe operation of the plant.
Revise plant proced;ures to clearly define the duties, responsibilities and authority of the. shift supervisor and the control room operators.
RESPONSE
A corporate management directive will be issued establishing the command duties of the shift supervisor that emphasizes the pri-mary management responsibility for safe operation of the plant.
Plant administrative procedures vill define the duties, responsibilities and authority of the shift supervisor and control room operators.
W s
.,,l t
v e
'l ENel
'U.33
.o.
~
Item No.
I.'C.'5 T-
-'@E Procedures for Feedback of Operating Experience to Plant Staff REQUIREMENT Review administrative procedures to ensure that operating ex-perience from within and outside the organization is continually provided to operators and other operational personnel and is incorporated in training programs.
f.
RESPONSE
PNPP will participate in the INPO SEE-IN program.
Procedures will be implemented to ensure that all Significant operating Experience Reports (SOER's) and Significant Event Reports (SER's) are distributed for review, and recommendations for corrective actions appropriate to PNPP are provided to; plant staff personnel and incorporated into the training program."
G e
q 9
- e e
i f
I l
s
(~
l l
l f
i
- }
.,. (
. I.C.6 Item No.
Es WL:=
Guidance on Procedures for Verifying Correct Per'formance of Operating Activities REQUIREMENT It is required (from NUREG-0660) that licensees' procedures be reviewed and revised, as necessary, to assure that an effective system of verifying the correct performance of operating activi-ties is provided as a means 'of reducing human errors and improving the' quality of normal operations.
This will reduce the frequency of occurrence of situations that could result in or contribute to accidents.
Such a verification system may include automatic Lystem status monitoring, human verification of operations and maintenance activities independent cf the people performing the activity (see NUREG-0585, Recommendation 5), or both.
Implementation of automatic status denitoring if required will reduce the extent of human verification of operations and main-tenenace activities but will not eliminate the.need for such verification in all instances.
The procedures adopted by the licensees may consist of two phases--one before and one after installation of automatic status monitoring equipment, if required, in accordance with item 1.D.3.
RESPONSE
,, _ " n, The PNPP has committed to compliance with Reg. Guide 1.47,
" Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems."
In addition procedures will be developed which require the approval of the Unit Supervisor (SRO) to release any system or equipment important to safety for maintenance or surveillance.
The approval of the Unit Supervisor will also be required to return any equipment important to safety back into service.
Procedures will also be developed to verify and document the functional acceptability of any equipment returned to service which is important to safety.
For the return-tc-service of ECCS Systems, independent verification of proper systems alignment will be made unless functional testing can be pe7 ormed without compromising plant safety and can prove that f
all equipment, valves, and switches involved in the activity are correctly aligned.
J'.
-,v-