ML20069C711
| ML20069C711 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/19/1982 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| SBN-293, NUDOCS 8207210188 | |
| Download: ML20069C711 (13) | |
Text
PUBLIC SEAVICE SEA 8KM STAM Engineedng Office:
Companyof New Hampsher e 1671 Worcester Road Framingham, Massachusetts 01701 (617) - 872-8100 July 19, 1982 SBN-293 T.F. B 7.1.2 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Mr. Frank J. Miraglia, Chief Licensing Franch No. 3 Division of Licensing
References:
(a) Construction Permit CPFR-135 and CPIR-136, Docket Nos. 50-443 and 50-444
Subject:
Corporate Peorganization, Public Service Company of New Hampshire
Dear Sir:
Public Service Company of New Hampshire (PSNH) has recently reorganized its corporate structure through the establishment of a Vice President of Nuclear Production. The Nuclear Production organization is managed by a Vice President, Mr. George S. Thomas, who previously held the position of Nuclear Production Superintendant. The duties, responsibilities, structure, and reporting relationships of the Nuclear Production organization are detailed in the attached revised Sections 13.1 and 13.4 of Final Safety Analysis Report (FSAR) Chapter 13.
These changes will be made to the FSAR as part of the next amendment.
PSNH is confident that this reorganization provides the net.essary effective lines of authority and communication between and among the organizational units involved in the management, technical support, and operation of Seabrook Station. The structure of the Nuclear Production organization minimizes any potential conflict with the application of resources to non-nuclear plants within PSNH. There exists a clearly established assignment of responsibility for the safe operation of Seabrook Station and for the attendant resources needed to implement this responsibility.
/ r 'ool M
Very truly yours, 4.. A 4 )
J. DeVincentis Project Manager Attachment cc:
Mr. Robert M. Gallo, U.S. Nuclear Regulatory Commission, Of fice of Inspection and Enforcement, Region I, 631 Park Avenue, King of Prussia, PA 19406 8207210188 820719 PDR ADOCK 05000443 A
PDR.
SB 1 & 2 FSAR CHAPTER 13 CONDUCT OF OPERATIONS 13.1 Organizational Structure This section describes the organizations of Public Service Company of New Hampshire (PSNH) and the Nuclear Services Division (YNSD) of Yankee Atomic Electric Company which are responsible for the operation and operational support of Seabrook Station. The qualifications of both organizations are offered as supporting evidence that the operational responsibilities for Seabrook Station can and will be discharged in a competent and efficient manner.
13.1.1 Management and Technical Support organization Public Service Company of New Hampshire is responsible for the operation of the nuclear-fueled generating station at Seabrook, New Hampshire to be known as Seabrook Station.
The overall responsibility for all activities associated with Seabrook Station rests in descending order with the PSNH Chairmoa and Chief Executive Officer, the President and Chief Operating Officer, and the Executive Vice President, who is designated as the management official in overall charge of nuclear power.
Reporting to the Executive Vice President are Vice Presidents of Production, Engineering and Nuclear Production. Also reporting to the Executive Vice President are Nuclear Projects, Energy Management and Research Department and -
the Fuel Procurement and Supply Department. The corporate organizational rela-tionships are shown in Figure 13.1-1.
The Vice President-Nuclear Production has full-time responsibility for the operation of Seabrook Station and maintains a Nuclear Production Staff for operational management and support of the station, a Station Staff for actual operation of the station, and a Training Center Staff for training of licensed station operators. PSNH has contracted with YNSD for l
a wide range of additional operation support services, and YNSD is responsible to the PSNH Executive Vice President for these activities. The organizational l
interfacing and responsibility reporting lines between PSNH and YNSD are shown j
in Figure 13.1-2.
l PSNH has contracted for certain operational services from YNSD and has retained l
certain operational activities for its PSNH staff. PSNH and YNSD have developed and enacted a document known as the "Second Memorandum of Agreement" which deli-neates the specific operational services supplied by YNSD for PSNH and the working relationships between the two organizations for the period of the operating license.
13.1-1
SB 1 & 2 FSAR There are two appendices to the Second Memorandum of Agreement. Appendix I to the Second Memorandum provides a detailed listing of support activities, the organizations responsible for the activity, and the degree of responsibility.
There are nine broad categories of activities.which are broken down into more precise sub-activities (see Table 13.1-1).
These nine broad categories are (1)
Environmental (Radiological and Non-radiological), (2) Engineering, (3)' Quality Assurance, (4) Nuclear Material, (5) Projects, (6) Operational Services, (7)
Licensing, (8) Nuclear Engineering, and (9) Information Services. A summary of the services provided by YNSD to Seabrook Station is given in Section 13.1.1.3.
For each designated sub-activity in Appendix I, one of five responsibility levels has been assigned to the organizations involved. These five levels are:
(1) Final approval and ultimate authority for the activity; (2) Chief responsibility for coordination and unplementation; (3) Mandatory participation in decision making (right of appeal, must be con-sulted and comments must be resolved);
(4) Maintains cognizance of activity through reviews (recommends changes but is not directly involved in decision making); and (5) No responsibility unless specifically requested.
All final approval authority, as defined in Appendix I, has been granted to the appropriate organizational entity within PSNH.
The responsibilities delineated in the agreement can be changed or added to with the mutual consent of PSNH and YNSD. Changes to the agreement must be approved by the YNSD President and the PSNH Executive Vice President.
Appendix II to the Second Memorandum of Agreement contains a detailed listing of Seabrook Station systems, components, and structures. Design changes for the items listed in Appendix II must be reviewed and approved by YNSD.
13.1.1.1 PSNH Nuclear Production Organization, Responsibilites and Authority The Nuclear Production organization is under the overall direction of the Vice President - Nuclear Production.
PSNH has recognized the unique aspects of the operation of a nuclear station and has fonned a highly qualified group of experienced nuclear personnel who, in concert with YNSD personnel, provide the operational support for Seabrook Station. There are three organizations within Nuclear Production responsible for l station operations and support. The Seabrook Station and the Training Center Staffs are two of the organizations and are located at the site. The other organization is the Nuclear Production Staff, portions of which are located l
13.1-2
4 SB 1 & 2 FSAR in Manchester and at the site. The responsibilities, training, organization, l
and qualifications of the Station and Training Center staffs are discussed in Subsections 13.1.2 and 13.1.1.2 respectively. The responsibilities of the Nuclear Production Staff are discussed in the following paragraphs.
The Vice President-Nuclear Production is responsible for the operation and operational support of Seabrook Station. To assist him in the accomplishment of these responsibilities, the Vice President-Nuclear Production has the Seabrook Station Manager, the Training Center Manager, and the Nuclear Production Staff reporting directly to him. The Vice President-Nuclear Production reports to the Executive Vice President and has the necessary qualifications and job position to qualify as " Engineer in Charge" as defined in ANSI /ANS 3.1 - 1978. The Vice President-Nuclear Production will be actively employed prior to the start of preoperational testing.
The Nuclear Production Staff contains the necessary expertise and authority to provide support for three basic functions. They are an operations function under the Nuclear Services Manager and associated support group, an engineering function under a Nuclear Engineering Manager and associated group, and a quality assurance function under the Nuclear Quality Manager and associated group. The staffing milestones for the Nuclear Production Staff are shown in Figure 13.1-3.
The Nuclear Services Group is located in the home office and is composed of a manager and a staff of at least two operations engineers. The Nuclear Services Manager will have a minimum of eight years of power plant experience with two years of the experience associated with start up or operational support. The staff engineers will have 3 to 5 years experience with at least one year of power plant experience. The group functions in direct support of the station in the areas of licensing, health physics, emergency planning, training, operations and operations assessment.
The group will also maintain communications with YNSD's Operations personnel on station activities. The Nuclear Services Manager will be actively employed prior to any significant pre-operational testing.
Additionally, an operations engineer will be assigned to the site to participate j
in initial startup testing to provide first hand experience to the Nuclear Services Group of operational problems encountered during start-up testing.
l The Nuclear Engineering Manager is responsible for a multi-disciplined group of 1
at least three staff engineers possessing expertise in the areas of systems engineering, electrical and instrumentation controls engineering, and reactor engineering.
The group has a wide range of responsibilities, including reviews of design changes, supervision of large backfit projects, and reactor core con-figurations. The group maintains close coordination with the YNSD Project and Licensing activities. The Nuclear Engineering Manager will have a minimum of eight years of power plant experience with five years of the experience in nuclear power engineering, a baccalaurate degree in an engineering or scientific j
field, and will be employed prior to any significant pre-operational testing.
)
The staff engineers will have 3 to 5 years experience with at least one year of power plant experience.
l The Nuclear Quality Manager has overall responsibility for assuring that the l
Seabrook Operational Quality Assurance Program is effectively implemented by all organizations performing work on safety-related systems and equipment at 13.1-3
l SB 1 & 2 FSAR Seabrook Station. The Nuclear Quality Manager reports to the Vice President-Nuclear Production. His staff consists of a minimum of three quality assurance engineers / engineering technicians.
The Nuclear Quality Group has the freedom and authority to perform independent reviews of quality related work rnd request work stoppages or remedial actions if conditions adverse to quality are encountered. Their authority extends over the Nuclear Production Staff, the Ceabrook Station Staff, the Training Center Staff, YNSD and any other organization performing quality-related work for Seabrook Station. The responsibilities of the Quality Assurance Group are described in Subsection 17.2.1.
The qualifications and experience of the Nuclear Quality Manager are as defined in ANSI /ANS 3.1 - 1978 for Professional-Technical.
The Nuclear Production Staff will receive the General Employee Training and the Training for Supervisors described in Section 13.2.
The Executive Vice President, Vice President - Nuclear Production, Nuclear Services Manager and Nuclear Engineering Manager will also receive a plant operations orientation course taught on the Seabrook simulator which includes training for mitigating core damage. The resumes of appropriate corporate management and Nuclear Production Staff personnel are contained in Appendix 13A.
The following is a compilation of the responsibilities of the Vice President-Nuclear Production and staff in various support areas:
a.
Environmental and Radiological 1.
Review and approval of the Environmental Radiation Monitoring Pro gram, Radiation Protection Program, Radiological Emergency Plan, Industrial Medical Plan, and Medical Emergency Plan.
2.
Participate in the selection of locations for offsite radiologi-cal monitors and in emergency plan drills.
3.
Cognizance of Seabrook Environmental Radiation Monitoring and Radiation Protection Programs.
l 4.
Provide liaison with state and local officials for environmental and radiological safety programs and plans.
5.
Approve and coordinate Unplementation of a corporate ALARA Program.
b.
Engineering and Design 1.
Coordinate activities between YNSD engineering and the Station Staff related to design changes, engineering consultants, engi-neering specifications and licensing activities.
2.
Provide project engineering assistance for Unplementation of cer-tain design changes at the station.
13.1-4
SB 1 & 2 FSAR 13.1.1.2 PSNH Training Center Organization, Responsibilities and Authority PSNH has recognized the importance of operator training by establishing a Training Center facility and organization which is independent of the station facilities and management, by providing a Seabrook site specific simulator, and by having the Training Center Manager report to the same level of home office management as the Station Manager. The Training Center is located on the Seabrook site outside of the protected area.
The Training Center facility contains classrooms, office space, a library, study areas, an instructor material preparation room, a computer room, administrative areas, and a simulated Seabroook control room with a full size main control board and various main control room panels. The simulator control board is manufactured by Link, a division of the Singer Company.
Link has had extensive experience with nuclear simulators and a myriad of simulators for military applications. Seabrook represents the eighteenth simulator built for the nuclear industry by Link. The simulator control room is not only similar to the actual control room in appearance, but is also operated under the same working conditions as the actual main control room to provide a realistic atmosphere for operator training. The Seabrook simulator meets the requirements of Regulatory Guide 1.149, 1981 except as noted in FSAR Section 1.8.
The Training Center Manager reports tc the Vice President-Nuclear Production in l
the home office as shown by Figure 13.1-2.
The Training Center organization is shown in Figure 13.1-4.
The organization is divided along two functional areas.
One area is the maintenance of the simulator hardware and sof tware under a staff which includes a supervisor, a software specialist and a technician. These per-sonnel undergo extensive training initially by Link in such areas as assembly language progranning, simulator software and hardware, mathematical modeling, and preventative maintenance. The second functional area is operator instruc-tion under a staff which includes a supervisor and four instructors. The Training Center Manager and Training Supervisor meet the ANSI /ANS 3.1 qualifica-tion requirements for Supervisors Requiring NRC Licenses.
The primary responsibility of the Training Center Staff is to provide the License Training and Requalification Training Programs for the Seabrook opera-tors. The staff also must maintain the instruction material and the simulator up-to-date with the current Unit I design. The resumes of the Training Center Staff are contained in Appendix 13B.
The Training Program for the instructors is identical in scope to the Seabrook operator training required for a senior reactor operator license, except that instructors are provided additional training on simulator control functions and to improve teaching skills. The training center staff instructors will be cer-tified under facility procedures to conduct specific courses of instruction.
Instructors will meet the qualification requirements of ANSI /ANS 3.1 - 1978 for licensed operators.
Initially, the instructors will participate in the cold license program of the Operator License Training Program. Replacement instruc-tors will participate in the hot license program. The Operator License Training Program is described in Section 13.2.
13.1-7
Recommend shutdown of the station to the Vice President-Nuclear Production if operational or engineering circumstances analyzed by YNSD dictate it.
10.
Review NSARC and Station Operation Review Committee minutes.
11.
Assist in the preparation of NRC information requests, preparation of Licensee Event Reports and resolution of NRC inspection findings.
c.
Plant Engineering The Plant Engineering Department is composed of an Instrumentation and Control Engineering Manager and group, an Electrical Engineering Manager and group, a Mechanical Engineering Manager and group, and a Systems Engineering Manager and group. The specific responsibilities of the Plant Engineering Department for Seabrook are:
1.
Initiate and prepare engineering design changes.
2.
Review and approve design changes initiated by the Station or Production for specified systems.
3.
Update or review specifications and system descriptions.
4.
Review station non-conformance reports for possible design deficiencies.
5.
Provide engineering information for NRC requests.
6.
Assist in the preparation of engineering technical specification changes.
7.
Prepare In-Service Inspection (ISI) Program, analyze ISI data, eva-luate repairs, and prepare ISI suenary reports.
8.
Assist in the preparation of ISI procedures and schedules and assist in the ISI interface with the Authorized Inspector and NRC inspectors.
9.
Prepare specifications for i[$adiation surveillance specimen removal, evaluate test data, prepare test reports and modify technical specifi-cations operating curves.
10.
Ass'ist in the evaluation and make corrective recommendations as a result of anomalous reading from the loose parts monitoring system.
d.
Licensing The Licensing Department is composed of a Licensing Manager, and a group of licensing engineers. The specific responsiblity of the Licensing Departmen. for Seabrook is to provide responses to industry standards and NRC guides and regulations which have been issued for comment.
e.
Nuclear Engineering 13.1-11
SB 1&2 FSAR The key supervisory positions for the station organization were filled in 1979, approxbnately five years prior to scheduled fuel loading of Unit 1.
Personnel to meet the operational requirements of Unit I will be hired on a phased basis consistent with the training and licensing requirements of the individual posi-tio ns. The station organization will be expanded beyond the normal needs of Unit 1 in order to meet the additional organizational requirements for Unit 2.
By the time of Unit 2 fuel loading, the Seabrook Station will have a staff of more than 255 employees. The schedule for this expansion is shown in Figure 13.1-6, which also shows the fuel loading and other key milestones for Unit 1.
The Units 1 and 2 on-duty operating shif t crews will be composed as shown in Technical Specification Table 6.2-1, and will meet the requirements outlined in Technical Specification Subsection 6.2.2 describing the plant organization.
Manpower necessary to staff five shif t crews will be provided. Each member of the station organization will meet, or exceed, the minimum qualifications recommended for comparable positions in Regulatory Guide 1.8, Revision 1-R, except ANSI /ANS 3.1 - 1978 will be used as the standard rather than ANS 3.1/ ANSI 18.1 -1971.
The employees assigned to the station organization will be trained as described in Section 13.2.
All personnel will be available for work on either unit.
13.1.2.2 Station Personnel Reaponsibilities and Authorities a.
Overall Station Management The Station Manager of the Seabrook facility is responsible for overall management of Units 1 and 2.
In his absence, the Assistant Station Manager assumes this responsibility.
In the event of unex-pected contingencies of a temporary nature occuring during the absence of these two managers, the Operations Manager will be respon-sible for overall station operations.
In his absence, the Assistant Operations Manager assumes this responsibility. The Shift Superintendent assumes the responsibility for overall management of Units 1 and 2 when the above station management is not within the sta-tion.
In addition, the Station Manager may designate in writing other qualified personnel to assume overall station responsibility in his absence.
The Station Manager reports to the Vice President-Nuclear Production l
of Public Service Company of New Hampshire (PSNH) for all activities related to the Station. Reporting to the Station Manager, or his assistant, are five managers:
1.
Operations Manager:
Responsible for the operation of Units 1 and 2
2.
Technical Services Manager: Responsible to provide support for i
the operation and refueling of Units 1 and 2:
13.1-18
3B 1 & 2 FSAR Technical Specification 6.5.2.8 defines the committee review requirements.
These are conducted through a combination of document summary reviews, presen-tations at regularly scheduled meetings and special meetings held to review pro-posed changes to the Operating License or Technical Specifications. The NSAR Committee will be required to review and approve all Operating License /
Technical Specification changes prior to their submittal to the NRC. Parti-cular document review assignments may be made by the NSARC to either individual NSARC members or to subcommittees with the appropriate expertise. Their reports or summary documents are reviewed by the full Committee at regularly scheduled meetings. Certain activities, such as In-Plant Audits, are performed under the cognizance of the NSARC. In such cases, written reports are issued to the Committee and the results discussed at regularly scheduled meetings.
13.4.2.4 Audit Program A program of quality assurance audits is described in the Seabrook operational Quality Assurance Program contained in Section 17.2.
13.4.3 Independent Safety Engineering Group An Independent Safety Engineering Group (ISEG) will perform reviews on plant operations, independent of those reviews performed by the Station Operation Review Committee (SORC) and the Nuclear Safety Audit and Review Committee (NSARC).
The ISEC will be composed of a committee of five, full-time, dedicated engineers who report their findings to the Nuclear Services Manager. Qualifications of the ISEC members will meet or exceed the requirements in Section 4.4 of ANS 3.1, ie., a bachelor's degree in engineering and two to four years experience in their field, including one to two years nuclear experience. The ISEG members will receive as a minimum the Training for Supervisors identified in Section 13.2.2.
The ISEG will be activated approximately three months prior to fuel-loading.
13.4.3.1 Duties and Responsibilities a.
The General review functions of the ISEC include:
1.
Examine plant operating characteristics, NRC issuances, Licensing Information Service advisories, and other appropriate sources of plant design and operating experience information that may indi-cate areas for. haproving plant safety.
2.
Maintain surveillance of plant operations and maintenance activi-ties to provide independent verification that these activities are performed correctly and that human errors are reduced as far as practicable.
3.
Perform independent reviews and audits of plant activities including maintenance, modifications, operational problems, and operational analysis, and aid in the establishment of programmatic requirements for plant activities.
13.4-4
_ _ _ _ _. - - _ _ _ _ - - - _ _ _. _ - _ _ _ _ - - - - -. _ _ - _.-. j
Where useful improvements can be achieved, this group will develop and present detailed recommendations to corporate management for such things as revised procedures or equipment modifications.
b.
The ISEG is not responsible for sign-off functions such that it becomes involved in the operating organization.
13.4.3.2 Reports The ISEG will prepare written summaries of reviews and evaluations performed as noted above. These summaries will include the results of, and recommendations resulting from such reviews and evaluations. Monthly reports containing a sum-mary of work completed and recommendations made will be forwarded to the Nuclear Services Manager, with information copies to the Vice President -
Nuclear Production and Executive Vice President.
13.4-5
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