ML20072S280
| ML20072S280 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/09/1991 |
| From: | Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-91056, TAC-79077, NUDOCS 9104150009 | |
| Download: ML20072S280 (12) | |
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lNew Hampshire; Yankee' --
Ted C. Feigenbovm
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Chief Executive Officer I
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NYN 91056 April 9,1991 United States Nuclear Regulatory Commission
- Washington, D.C, 20555
, Attention:
Document-Control Desk
References:
(a)
Facility Operating License No. NPF 86, Docket No. 50 443 i
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_(b)
NRC-letter dated March 7,1991, " Request for Additional Information on Application to Amend Facility Operating License to Authorize North Atlantic Energy Service Company (NAESCO) to Act as Managing Agent
- for Seabrook Station, Unit No.- 1 (TAC No. 79077)"
-(e)
A'pplication to Amend Facility Operating - License No. NPF 86 to y
Authorize North Atlantic Energy Service Company to Act as Managing Agent for Seabrook Station Unit % 1 dated November 13, 1990 (d)
^ NHY _ letters NYN 91008 dated Jatsaary 22, 1991, " Transmittal of Northeast Utilities' / plication to ' the Securities and Exchange Commission (SEC) Regarding the Organization'of No rth Atlantie Energy-
. Service Company (NAESCO)".
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Subject:
Request for Additional Information re: Transfer of Managing Agent
' Gentlemen:
Pleascifind enclosed the 'New Ha'mpshire Yankee response to the NRC's request' for -
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additional =information ~ [ Reference (b)). The information-referenced therein-is a-matter of public record and contained in'the Application (Reference (c)] and/or 'the Managing Agent
' Operating Agreement-between NAESCO and the Joint Owners, and the Service Agreements
- between NAESCOTand N~USCO and between NAESCO and YAEC that were submitted.to the NRC#with Northeast Utilities' SEC Application. transmittal [ Reference _(d)}.
If you have any questions, please contact'Mr. Terry L. Harpster, Director of Licensing i Services at (603) _474-9521, extension 2765.
Very -truly yours, ll Ted C. Felgenbaum TCF:JBlutad 9104150009 910409
-PDR ADOCK 05000443 p
PDR New Hampshire Yankee Division of Public Service Company of New Hampshire jyggj g P.O. Box 300 = Seabrook, NH 03874
- Telephone (603) 474-9517
United States Nuclear Regulatory Commission April 9,1991 Attention:
Document ('?: tent Desk Page two cc:
Mr. Thomas T. Martin
' Regional Ad!ainistrator United States Nuclear Regulatory Commission P. glon I 475 Allendale Road i
King of Prussia, PA 19406
- Mr. Gordon E. Edison, Sr. Project Manager Project Directorate-1-3 Division of Reactor Pre'3 cts U.S. Nuclear' Regulatory Commission Washington, DC 20555 Mr. Noel Dudley
.I NRC Senior Resident Inspector P.O. Box 114.>
Scabrook, NH. 03874 i
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New Hampshire Yankee April 9,1991 ENCLQ,9URE 1 TO NYN.01056 l'
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R Al 1:
The application to amend the Seabrook Station operating license does not include an organization chart that reflects the proposed No'th Atlantic Energy Service Company (NAESCO) and Northeast Utilities (NU) corporate structure and the specific working level or performance level organizational units that will provide technical support for operation of the Seabrook Station. Provide the appropriate organization charts that reflect the proposed organizational l
relationships.
Response
Figure 1 A. provides a schematic of the basic corporate relationships that NAESCO will have within NU, with the other NU subsidiaries, 3s well as with the Seabrook Joint Owners, the Yankee Atomic Electric Company (YAEC) and Public Service Company of New llampshire (PSN!!).
NU's organizational
,tructure for the operation of its nuclear units and NAESCO's place within it are shown on Figure 113.
NAESCO will be a wholly owned subsidiary of NU and will be designated as the managing agent for Seabrook Station with the same duties, responsibilities
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and relationships with the Seabrook Joint Owners as New flampshire Yankee l
has now (Application at 6).
Under the terms of the Managing Agent Operating Agreement (MAOA) that will be established between the Joint Owners and NAESCO, NAESCO 6 hall have complete and ultimate responsibility for day to day management and operation of Seabrook Station, The NAESCO Senior Site Officer will have final site authority and will be responsible for the overall safe operation of the Station. The MADA has been approved by the Joint Owners and was submitted to the NRC as a part of a supplement to the Application on January 22 (NYN 91008).
Northeast Utilities Service Company (NUSCO) is a wholly owned service company subsidiary of NU. _ As depicted in Figure 1 A, it provides engineering, l
operations, administrative and general services to other NU' affiliates including l
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the four nuclear units that NU currently operates. The relationship between
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NAESCO and NUSCO will be governed by the Service Agreement between them, a copy of which was submitted to the NRC in the January 22, 1991 supplement to the Application.
As stated in the Application (at 6) and in the Service Agreement (at 4),
NAESCO will, at all times, remain responsible for the management, operation
.and maintenance of Scabraok. Any services provided to NAESCO by NUSCO will be solely at NAboCO's request and discretion.
Such services when rendered will be subject at all times to the direction t.nd control of NAESCO and will be consistent with the MAOA, YAEC, which, through its Nuclear Ser< ices Division, has been providing certain services in support of Seabrook Station since 1972, will continue to provide almilar services to NAESCO. The relationship between NAESCO and YAEC will be governed by the Service Agreement submitted to the NRC with the supplement to the Appil. Hon dated January 22, 1991.
NAESCO will initially enter into a service agreement with PSNH for certain administrative, legal and other services la order to facilitate the transition.
The working level organizational units within NASSCO that will provide technical support for operation of Seabrook Station will be essentially the same as those providing it.to NHY before the Time of Effectiveness (TOE). The organizational groups that Figure 1 B indicates will report to the NAESCO Senior Site Officer are the same that currently report to the NHY President and CEO.
As stated in the Application (at 7), the staff of NHY will be ransferred to NAESCO at the TOE. The transition to NAESCO will therefore not create any perturbations in the safe operation of Seabrook.
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RAl2:
The application to amend the Seabrook Station operating license does not describe the qualificacions, including educational backgrou.ed and experience of the personnel that will be providing technical support for the operation of Seabrook Station. Provide the qualification desv8ption for these persons.
Response
The change in the corporate identity of the managing agent for Seabrook Station from NHY to NAESCO will not induce changes in the Seabrook Sittion technical support organization that was reviewed and licensed by the NRC.
As discussed in the response to RAl 1 and
- 4. NAESCO will operate Seabrook Station with essentially the s,.mc technical support organization as NHY. The changes brougnt about by the transfer will be to the Seabrook Station managing t
agent's relationships with external organizations.
After the transition, NAESCO, like any other licensee, may exercise its management responsibility and discretion and may ultimateiy make rnodifications to the orgaulzation after an evaluation of how its existing resources can best be integrated with other resources availabic, including those within the NU system. Any such changes, however, would be implemented consistent with existing regulations and commitments, including notification of the NRC Staff if required, as'well as with the other corporate agreements discussed above.
RAl 3:
The application to amend the Seabrook Station operating license states that the NAESCO operating organization will be able to draw on the resources of the Yankee Atomic Electric Company (YAEC) but does not state how this is to be accomplished.
Describe how YAEC 'is involved with the NAESCO organization. Will there be direct or indirect involvement from YAEC? Will requests for YAEC involvement in the operation of Seabrook Station come from NU, NAESCO, or from Seabrook Station? Is the relationship between YAEC, NAESCO, and NU reflected on the organization charts?
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Response
As stated in the response to RAl1 ubove, NAESCO will maintain the continuity of services with YAEC and the provision of such services shall be in conformance with the Service Agreemer.t between the two companies. All requests for YAEC support of the operatio0 of Seabrook Station will come from NAESCO.
T he relationship between NU NAESCO and YAEC is schematically depicted in Figure 1 A.
Through the Service Agreement, NAESCO will utilize YAEC's special expertise in certain technical areas, as NilY has done in the past. The Yankee Nuclear Service Division of YABC has also provided personnel at th& Dolton, Massachusetts office, and on site who are fully dedicated to support Seabrook Station.
It is anticipated that after the transition, some of these on site individuals will become NAESCO employees.
RAI 4
The application to amend the Seabrook Station operating license states that the technical support for the operation of Seabrook Station will be provided by NU. Given the support currently being provided to the other NU facilities, what assurance is provided that the current level of technict.1 support for the operation of Seabrook Station will be maintained at or above the current level and that this additional burden will not negatively impact the level of technical support to th. other NU operating facilities, s
Response
The overriding responsibility NAESCO will have under the requested amendment 16 to operate Seabrook Station safely and in accordance with all regulatory requirements, in order to fulfill this responsibility. the NilY onsite technical support,. corporate management and corporate technical support organizations will become part of NAESCO. In addition, NAESCO will have service agreements vilth NUSCO and YAEC which will enable it to draw upon
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the resources of NU and YAEC. As a result, NAESCO will operate Seabrook 4
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Initially, NUSCO is expected to provide NAESCO with certain services currently provided by NilY or YAEC, such as insurance program administration, external business audit functions, shared technical program development, training records support and data processing assistance. These services are not resource intensive and we have confirmed with ?"I that they would not be allowed to adversely impact the technical support provided to other NU facilities.
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-It is expected, and indeed it is one of the benefits of this amencer.t that NUSCO will also eventually provide technical support for the operation of Seabrook Station.
Under the terms of the Service Agreement that will be established between NUSCO and NAESCO, NAESCO shall, prior to contracting work to others, consider giving NUSCO the opportunity to provide such work.
NAESCO will, at all times, remain responsible for the management, ope ation, and maintenance of Seabrook and will, in al' cases, deelde who is to perform such worie.
NUSCO will be required, in each instance, to demonstrate to NAESCO's satisfaction whether it has the capability and resources to perform a requested service (NUSCO Service Agreement at 4).
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RAI 5
The application to amend the Scabrook Station operating Ilcense states that
- the Public Service Company of New flampshire (PSNH) is a licensee of the Seabrook Station. Given the NAESCO takeover of Seabrook, will PSN}l retain any responsibility for operation of the plant? Clarify this situation.
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Response
' Assuming the amendment authorizing the transfer of managing agent' to -
NAESCO is granted prior to the amendment authorizing the transfer of PSNH's ownership share to North Atlantic Energy Corporation (NAEC), PSNil will still be a Joint Owner and therefore a licensee of Seabrook Station when 5
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NAESCO becomes managing agent.
The proposed form of the license amendment (Application, Exhibit 2 at 2) retains PSNH as a licensee to reflect this situation. Once N AESCO becomes managing agent however, PSNil will not have any direct responsibility for the construction, operation or maintenance of Seabrook Station.
As stated in the response to R Al 1.
however, NAESCO will enter into a service agreement with PSNil for the perforroance of certain adruinistrative, legal and other services. This agreement will allow PSNil to provide NAESCO, upon request and on an interim basis, certain of these navices which will facilitate the transition.
RAI 6
The application to amend the Scabrook operating license states that there is uncertainty on the part of Seabrook Station personnel as to their future role.
We are concerned that the safe operation of Seabrook Station be maintained.
What assurances have been made to these personnel regarding their long term employment at the Seah.ook station? What plans have been formulated to replace those persons currently employed to operate and support Scabrook Station that do not desire to continue employment at Seabrook Station?
Respoese:
As indicated in the Application, there has been some uncertainty on the part of New llampshire Yankee employees during the extended bankruptcy proceedings of Public Service Company of New ilampshire.
Given the imminent resolution of the bankruptcy by the Joint Plan, that uncertainty has been reduced.
Although Seabrook Station has faced many challenges, the turnover in personnel has steadily dropped over the past four years. For the past two years the overall attrition rate has been nearly constant at 5.1% and 5.2%
For the opera; ions and technical support groups, the rates have been lower.
The turnover rate for the groups reporting to the Station Manager, for example, was 4.1% in 1990, while there were no control room operators or Engineering 6
e Department personnel lost to the company last year.
It is expected that the transition to NAESCO over the long term will not result in any abnormal amount of attrition. Any attrition that does occur will be handled as it is now.
Qualified candidates will be recruited, either from within NAESCO, NUSCO, YAEC or outside those organizations, hired and trained to perform the needed funetton. Therefore it is expected that any attrition that does occur will have no adverse impact on the safe operation of Seabrook Station.
In the near%ren (1991), all NilY employees will become NAESCO employees.
Eventually, the use of e ontractors will be tcJuced and other internal restructuring and conso18',ation may occur to improve the effectiveness of the NilY organization.
<e changes are normal as an operating organization matures.
New llampshire Yankee has atternpted to minimize any concern of its employees over their future. Employces and managers have been frequently briefed es to the schedule and scope of any expected change in organization.
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It has been explained that nearly all reiluctions in staffing will come from the i
existing contractor force and those NHY functions described as administrative and general. At the same time, some contractor employees (e.g. YAEC) will be hired as NAESCO staff thereby retaining their Seabrook specific experience, u
In the long term (19921996), therefore, the number of NAESCO employees is expected to remain nearly the same as the current 1991 NHY staffing level.
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CORPORATE INTERRELATIONSHIPS SEABROOK NU JOINT OWNERS Managing Agent Operating Agreement I
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