ML20058B467
| ML20058B467 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/25/1982 |
| From: | Kintner L Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20058A656 | List: |
| References | |
| NUDOCS 8207260025 | |
| Download: ML20058B467 (23) | |
Text
JUN 2 51982 Docket No.:
50-341 Applicant:
Detroit Edison Company Facili ty:
Femi 2
Subject:
MEETING
SUMMARY
OF JUNE 15, 1982, REGARDING THE FERMI 2 SAFETY AND PERFORMA!CE ENGINEERING GROUP The purpose of the meeting was to discuss applicant's proposed changes to the cora-position of the Fermi 2 independent safety engineering group. Enclosure 1 lists at-tendees. The present caposition for the group which has been accepted by the staff in its SER (July 1981) is provided in Enclosure 2.
Infomation regarding the proposed cmposition of the group provided during the neeting is given in Enclosure 3.
Notes on the meeting written by E. S. Pedersen, t.icensee Qualification Branch menter as-signed to the Femi 2 review, are provided in Enclosure 4.
The NRC - accepted independent safety engineering group is composed of five full-time engineers located at the site who will report to the of f-site Director of Nuclear Engineering (Enclosure 1).
The applicant has proposed to change the cmposition of the group to use its on-site engineering staff (about 85 persons) part-tine as required to perfom the functions of the group, with a full-time lead safety engineer to coordinate the wort and pre-pare reports. The lead safety engineer would report administrative 1y to the supervi-sor of one of the on-site engineering sections. A monthly sumary of safety actions and any significant plant safety matters would be reported directly to the Director of Nuclear Engineering.
The staff indicated that, stbject to consideration by applicant of the following coments, the proposed organization for the independent safety engineering group ap-pears to be satisfactory to the Licensee Qualification Branch. The staff's cements for consideration by the applicant in its amendment to the FSAR are:
1.
The independence of the lead safety engineer from the organization responsible for power production should be clearly expressed.
2.
A high-level priority for safety engineering tasks by engineering per-sonnel responsible for other tasks should be clearly expressed.
3.
The lead safety engineer should be on the same management level as su-pervisors in the on-site engineering organization.
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NRC FORM 318 (10-80) NRCM 024o OFFiClAL RECORD COPY usam wu-mm
- JUN 2 51982 The amendment to the FSAR describing this proposed change is scheduled to be filed July 15,1982. The staff plans to include its evaluation of the proposal in SER Supplement No. 3, scheduled to be issued in Septect>er,1982.
Drfsinal SIsned By:
LeSter L. xin tuer L. L. Kintner, Project Manager Licensing Branch No.1 Division of Licensing Encl osure:
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Mr. Harry Tauber Vice President Engineering & Construction Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 cc:
Mr. Harry H. Voigt, Esq.
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LeBocuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.
Washington, D. C.
20036 Peter A. Marquardt, Esq.
Co-Counsel The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Mr. William J. Fahrner Project Manager - Fermi 2 The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Mr. Larry E. Schuerman Detroit Edison Company 3331 West Big Beaver Rcad Troy, Michigan 48084 David E. Howell, Esq.
3239 Woodward Avenue Berkley, Michigan 48072 Mr. Bruce Little U. S. Nuclear Regulatory Commission Resident Inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Dr. Wayne Jens Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Mr. James G. Keppler Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 es
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June 15,1982 Meeting Detroit Edison - NRC Naine Affiliation L. L. Kintner LB-1, Licensing Project Manager for Fermi 2 Timothy Okeefe Detroit Edison - Nuclear Engineer Larry E. Schuerman Detroit Edison - Supervisor - Licensing William F. Colbert Detroit Edison - Assistant Director, Nuclear Engineering John A. Zwolinski NRR - DHFS - LQB, Branch Chief Lawrence P. Crocker NRR - DHFS - LQB, Section Head Eric Pedersen NRR - DHFS - LQB, Reviewer for Fermi 2 9
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i Infomation regarding the NRC-Accepted Femi 2 Indepen-dent Safety Engineering Group (TMI Requirement I.B.I. 2)
Exerpt from Femi 2 SER (July 1981)
Exerpt from Femi 2 Draft Technical Specifications
'i (February 5,1982) l 1
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u I.B Support Personnel I. B.1. 2 Organization and Management Position Corporate management of the utility-owner of a nuclear power plant shall be sufficiently involved in the operational phase activities, including plant modi-I fications, to assure a continual understanding of plant conditions and safety considerations.
Corporate management shall establish safety standards for the operation and maintenance of the nuclear power plant.
To these ends, each utility-owner shall establish an organization, parts of which shall be located perform independent revior cnd audits of plant activities; provide onsite, to:
technical support to the plant staff for maintenance, modifications, operational problems, and operational analysis; and aid in the establishment of programmatic I
requirements for plant activities.
1 The licensee shall establish an integrated organizational arrangement to provide for the overall management of nuclear power plant operations.
This organization shall provide for clear management control and effective lines of authority anti communication between the organizational units involved in the management, technical support, and operation of the nuclear unit.
The key characteristics
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of a typical organization arrangement are:
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(1) Integration of all necessary functional responsibilities under a single
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responsible head.
i (2) The assignment of responsibility for the safe operation of the nuclear i
power plant (s) to an upper-level executive position.
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Utility management shall establish a group, independent of the plant staff, 3
but assigned onsite, to perform independent reviews of plant operational activi-ties.
The main functions of this group will be to evaluate the technical
,j adequacy of all procedures and changes important to the safe operation of the J
facility and to provide continuing evaluation and assessment of the plant's operating experience and performance.
Discussion and Conclusion 4
Our evaluation of the applicant's response to this position is provided in detail in Section 13 of this report, and summarized below.
The applicant provided its response to this item in Amendments 33 and 35 to the FSAR and several letters to NRC.
The staff reviewed this submittal, met with the applicant, and visited the corps.' ate office of Detroit Edison Company to evaluate the proposed organization for operati'on of Fermi 2, including the i
senior corporate officer who will be 'in overall charge of nuclear operations, corporate personnel who will support plant operations, and the operating person-for the plant.
The Vice-President, Nuclear Operations, will have responsibilit; for operation, maintenance, modification and quality assurance of Fermi 2.
Many personnel now working in engineering, design, and construction will transf to nuclear operations as construction is completed.
Corporate technical suppor will be provided principally by three groups; Nuclear Safety and Plant Engineer 22-14
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Nuc1sar Technology, and Nuclear Fuel, under the Director for Nuclear Engineering.
The Superintendent, Nuclear Production, is responsible for operation and main-tsnance of the plant.
The Radiation Protection Manager will have direct access to the Superintendent on radiation protection matters.
The applicant has provided a schedule for filling key positions in the corporate and plant organizations and for training and licensing plant personnel that is censistent with the scheduled fuel loading target date of November 1982.
The applicant has included in its organization, an onsite-independent safety engineering group consisting of five engineers, that will report to the offsite Dirsctor of Nuclear Engineering.
Bas 2d upon our review of information given in FSAR Amendments 33 and 35, in cur review team meeting with the applicant in May 1981, and in several letters from the applicant, we conclude that:
1.
The corporate and plant organizational structures for operation and total number of personnel planned to staff the organizations are acceptable.
2.
The phased transition of personnel from construction activities to operation will provide valuable continuity and carryover of knowled e to the operations 0
phase.
However, the applicant should effect this transition in a manner that does not compromise quality of construction or safety of operation.
3.
The qualification, education, and experience requirements for the corporate technical staff supporting the nuclear plant operations and the resumes of key personnel filling those positions have been acceptable.
I 4.
The applicant has made acceptable provisions for manning the plant operating shifts.
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5.
The plant management and staff will be provided with individuals having sufficient operating experience to safely operate the plant.
We therefore conclude that the requirements of this item have been met.
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.M.1 Tit ADMINISTRATIVE CONTROLS _
6.2.3 SAFETY AND PERFORMANCE ENGINEERING GROUP (SPEG)
FUNCTION 6.2.3.1 The SPEG shall function to examine unit operating characteristics, l
NRC issuances, industry advisories,' Licensee Event Reports, and other sources of plant design and operating experience information, including plants of similar design, which may indi,cate areas for improving unit safety.
COMPOSITION 6.2.3.2 The SPEG shall be composed of at least five dedicated, full-time engineers located onsite, each with a bachelor's degree in engineering or related
, science and at least two years professional level experience in his field.
RESPONSIBILITIES 6.2.3.3 The SPEG shall be responsible for maintaining surveillance of unit l
activities to provide independent verification
- that these actis.ities are performed correctly and that human errors are reduced as much as practical.
AUTHORITY 6.2.3.4 The SPEG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activities, operations activities or other means of improving unit safety to the Director of Nuclear Engineering.
6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall provide technical support to the Nuclear Shift Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to safe operation of the unit.
6.3 UNIT STAFF OUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualificatieris of ( ANSI N18.1-1971).
6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the (position title), shall meet or exceed the requirements and recommendations of Section ( ) of ANSI N18.1-1971 and l
Appendix "A" of 10 CFR Part 55 and the supplemental requirements specified in Section A and C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees, and shall include familiarization with relevant industry cperational experience identified by the SPEG.
- Not responsiDie for sign-off function.
5W FERMI - UNIT 2 6-6
Infonnation provided by Applicant in June 15, 1982 meeting regarding proposed change to camposition of Fenni 2 Inde-pendent Safety Engineering Group to meet the requirements of TMI Item No. I. B. 1.2.
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DEIPOIT EDISON
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NUCLEAR DGINEERING-NUCLEAR OPERATIONS FERMI 2 MEETING AGENDA JUNE 15, 1982 A.
Introduction and Purpose of Meeting, i.e., Performance of " Independent Safety Evaluations" by Detroit Edison's NSPE Group B.
Detroit Edison's Organization
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Nuclear Operations
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Nuclear Engineering
\\ Nuclear Safe \\
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l NSPE's Mission and Functions, including discussion on ccr:plement - skill and experience levels C.
Detroit Edison's Proposed Changes to FSAR and Technical Specifications D.
Discuss Basis for Proposed Change E.
Discuss Methods on the Conduct of the ISE Functions F.
Sunmary Written by:
T. J. O'Keefe
/czm Attachments:
1,2,3,4,5 1.
- Nuclear Operaticos Organizatica Charts N-1, 4 & 5;
- Nuclear Engineering Mission Statenent; j
- NSPE Organization and Index of Major Functions 2.
FSAR H.I.Be1.2.3 - Edison Position on ISEG 3.
Technical Specification 6.2.3 - Camitment on NSPE (ISEG) 4.
Nuclear Engineering Procedures Related to Safety Evaluations
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5.
Specific Statement on Reporting and Authority
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NUCLEAR ENGINEERING-NUCLEAR OPERATIONS ORGANIZATION Nuclear Engineering reports to the Assistant Vice President and Manager-Nuclear Operations, and its role as part of the Nuclear Operation's Organization is illustrated in Chart 6.
The mission of Nuclear Engineering is to provide engineering, fuel sanagement, scientific technology, and technical ser-vices to the Nuclear Operations organization in support of Fermi 2.
At present, approximately 80 complement positions have been identified for Nuclear Engineering.
The Nuclear Safety and Plant Engineering Division (NSPED) of Nuclear Engineering has as its mission to provide engineering support and services to the plant, including licensing responsibilities, safety, transient and system analysis, in-house engineering assurance, system configuration and modifi-cation responsibility.
Chart 6A provides the organizational overview of NSPED.
The Nuclear Technology (NT) Division of Nuclear Engineering has as its mission to provide technical support to Nuclear Operations in specialized engineering and scientific disciplines.
These responsibilities include materials-related properties associated with plant construction and operation (material tests, codes, practices, regulations, research), radiological technology associated with plant operations, and emergency planning activities.
Nuclear Technology will support both Nuclear Engineering and Nuclear Production on a day-to-day basis, with actual functions such as radiological services remaining within Nuclear Production, operating under criteria set by Nuclear Technology.
Chart 6B provides the organizational overview of NT.
The Nuclear Fuel (NF) Division of Nuclear Engineering has as its mission to provide nuclear fuel management, including design and licensing analyses, nuclear fuel procurement planning and contract administration, rate case support and financial studies for nuclear fuel, and operational reactor engineering.
Chart 6C provides the organizational overview of NF.
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I Attachment i P. 5 of 5 Chart 6A GEN. SUPER.
Matrixed NSPED from W.F.COLBERT
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SUPERVISOR SUPERVISOR SUPERVISOR SUPERVISOR SAFETY &
SYSTEM &
LICENSING ENGINEERING PERFORMANCE PLANT ASSURANCE
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I ANALYSIS ENGINEERING W.W.HODGES E. LUSIS L.E.SCHUERMAIJ Shift Technical
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Licensing audits &
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Activiths surveillances administer, configuration j
Interface and train engineering
_ Single point with other contact w/NRC
_[ETITY,y andIresponsi- _ Special studies 6 Washington QA groups ISEG or pre-eng.
accountability evaluations other groups to
_ Represent Interface with eng. during
_ Experience
_ Design review accomplish above external analysis support audit Refueling &
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_ Machine driven
_ Licensing special analysis support licensing
_ Interface with
_ Task Eng.
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plant on performance and
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_ Design and Technical Engineering Support Group Proposed 3/22/82 N
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l H.I.B.1.2 Evaluation of Organization and Managenent H.I.B.1.2.1 Statement of Concern As a result of the lessons learned frtrn the accident at 'IMI-2, a need has been recognized for improving the safety performance and for improving the ability to respond to accidents of the organizations involved in the production of nuclear power. In order to improve these areas, the management of these organizations must beccme nore aware of and pay particular attention to matters of nuclear safety.
One method of inproving the safety perfonnance of these organizations would be the establishment of an onsite safety engineering staff and the establishment of an integrated program for the systematic review of operating experience with concurrent dissanination of information to plant personnel. This would increase the available technical expertise located on site and would provide continuous, systematic, and independent assessment of plant activities.
H.I.B.1.2.2 NRC Position Each applicant for an operating license shall establish an ensite Independent Safety Engineering Group (ISEG) to perform independent reviews of plant operaticns.
The principal function of the ISEG is to examine plant operating characteristics, NRC issuances, Licensing Information Service advisories, and other appropriate information sources of plant design and operating experience that may indicate areas for improving plant safety. '1he ISB3 is to perform independent review and audits of plant activities including maintenance, modifications, operational problems, opera-l ticmal analysis, and aid in the establishment of prwummatic requirements for plant i
activities. Where useful improvements can be achieved, it is expected that this group will develop and present detailed reccmmendations to corporation management i
for such things as revised procedures and equipment modifications.
1 I
P. 2 of 4 H.I.B.1.2.2 NRC Position (Continued)
Another function of the ISEG is to maintain surveillance of plant operations and maintenance activities to provide independent verification that these activities are'perfomed cxtrrectly and that human errors are reduced as far as practicable.
ISH3 will then be in a position to advise utility management on the overall quality and safety of operations. ISEG need not perform detailed audits of plant operations and shall not be responsible for signoff functions such that it bectrnes involved in the operating organization (Reference 1).
- p. 3 of 4 H.I.B.l.2.3 Detr61t Edison Position e
A Nuclear Safety and Plant Engineering group, as part of a larger Nuclear Engineering Department, will be established within the Detroit Edison Nuclear Operations Organi-
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zation.
Nuclear Safety and Plant Engineering (NSPE) will, as part of its duties, have the responsibility for the perforrance of the onsite independent safety engineering function. NSPE will be located at the site, and will be available to and in close proximity to the operating personnel and will have continued access to the plant facilities and records. The NSPE group will provide a lead engineer who will be responsible for the performance and accountability of the independent safety engineering function; he will have available to him the engineers necessary to effectively conduct these reviews or activities.
Nuclear Safety and Plant Engineering will report through the General Supervisor, Nuclear Safety and Plant Engineering, to the onsite Director of Nuclear Engineering.
The Director of Nuclear Engineering is not in the direct management chain for power production; he is independent of the plant superintendent.
Nuclear Safety and Plant Engineering will have as part of its responsibilities the requirement to examine unit operating characteristics, NRC issuances, Licensee Event Reports, and other sources that may indicate areas for improving unit safety.
This group, augmented as required, will perform the independent safety engineering reviews of plant activities, including maintenance, modifications, operational problems, and operational analyses; it will also aid in the establishment of program-matic requirements for plant activities.
In addition, NSPE will maintain surveillance of the plant operations and maintenance activities to provide independent verification that these activities are performed correctly and that human errors are reduced as much as practicable. This group will not perform detailed audits of plant operations and will not be responsible for signoff functions such that it beccmes involved in the operating organization.
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- p. 4 of 4 H.I.B.1.2.3 Detroit Edison Position (Continued)
Nuclear Safety and Plant Engineering will make detailed recmmendations for revised procedures, equignent nodifications, and other means of inproving unit safety to the Director of Nuclear Engineering. Although this group will interface with the Quality Assurance (OA) organization, it will not be part of the OA organization.
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'Ihe responsibilities and authority of the Nuclear Safety and Plant Engineering group will be described in the applicable engineering procedures, hf p,
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6.2.3 NUCLEAR SAFE 1Y AND PIANT DK;INEERING (NSPE)
FUNCTION 6.2.;3.1 NSPE shall, as one of its functicns, examine unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other scurces'of plant design and operating experience information, including plants of similar design, which may indicate areas fo~ r improving unit safety.
CO@OSITICN 6.2.3.2 NSPE will provide a lead engineer who will be responsible for the perfonnance and accountability of the independent safety engineering function; he will have available to him the engineers necessary to effectively conduct these activities.
Engineers, conducting these activities, will be located on-site, each with a Bachelor's Degree in Engineering or related science and at least two years professional level experience in his field.
RESPONSIBILITIES 6.2.3.3 NSPE will, as part of its duties, be responsible for maintaining surveillance of unit activities to provide independent verification that these activities are performed correctly and that hean errors are reduced as much as practical.
AUINORITY 6.2.3.4 NSPE shall make detailed reccumendations for revised procedures, equignent nodifications, maintenance activities, cperations activities or other means of 1.Tproving unit safety to the Director of Nuclear Engineering.
6/10/82
p.1 cf 1 NUCLEAR OPERATIONS NUCLEAR ENGINEERDU PROCEDURES
- SPECIFICALLY REIATED TO SAFETY REVIIHS/EVALUATICNS (EXCERPIED FRCH NUCLEAR DGINEERDE PROCEDURES MANUAL DEEX) 1.9 Action Itms Iog and Tracking System 1.10 IRAG, OSRO and ISB3 Support Activities 2.1 Licensing and Regulatory Activities 2.3 Engineering Review and Evaluations 2.4 Review and Evaluation of Proposed Operating Procedure Changes 2.7 Non-Conformance Reporting 3.1 Independent Safety Evaluations (10 CFR 50.59) 3.2 Shift Technical Advisor (s) Program 3.3 ISEG Activities, Reports, and Authority 3.5 Specill::ed Engineering Analysis 3.6 Engineering Assurance 5.11 Radiological Monitoring and Radiation Protection 5.15 Radwaste Program 6.1 RERP Plan Maintenance and Administration
- These procedures, as is the entire manual, are in the process of being developed.
6/10/82
p.1 of 1 NK EXCERPT FROM PROCEDURE No. 3.3 ISEG ACTIVITIES REPCRTS AND AUNCRITY AUm3tr1Y:
'1he lead ISEG Engineer receives, through the Director of Nuclear Engineering, adequate personnel frun the Nuclear Safety and Plant Engineering group to accanplish the assigned ISEG activities. Consultant support and the necessary logistical support will also be provided the Director of Nuclear Engineering.
Ic:.1GdHG:
As required or warranted, the lead ISEG Engineer or any
'at-large' ISEG mernber shall report any significant condition or concern to the Director of Nuclear Engineer-ing iarbally, followed by a written report.
Additionally, the lead ISEG Engineer will issue a monthly sunnary report of the ISEG activities to the Director of Nuclear Engineering.
6/10/82 i
Notes by Erik Pedersen, LQB member, on the June 15, 1982 meeting regarding the proposed changes to the Femi 2 Independent Safety Engineering Group.
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