ML20094J613

Advises of Decision to Organize & Implement Project Startup Organization.Transfer of Preoperational Testing Responsibilities Will Be Implemented Gradually.Fsar Chapters 13 & 14 Will Be Amended

ML20094J613
Person / Time
Site:	Braidwood
Issue date:	08/07/1984
From:	Swartz E COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
9059N, NUDOCS 8408140386
Download: ML20094J613 (20)

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('N; Commonwealth Edison

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) one First Nationti PLiza. Chicago. Illinois r-( !!? ~J Address Reply to: Post Othce Cox 767 (j/ Chicago, Illinois 60690 August 7, 1984 Mr..He>old R. Denton, Director O f fict; of Nuclear Reactor Regulation U.S. Nuclear. Regulatory Commission Washington, DC 20555

Subject:

Braidwood Station Units 1 and 2 FSAR Change Concerning Project Start-up Organization NRC Docket Mos. 50-456/457

Dear Mr. Denton:

The purpose of this letter is to advise NRR of the ommonwealth Edison Company decision to organize and implement a Project Start-up Organization at our Braidwood Station.

This decision was made as a result of the experience gaineo from our entire Nuclear program and most recently from the Star'.-up programs at our LaSalle County and Byron Stations.

As t.ne time of fuel loao of Braidwood Unit 1 approaches, preparation for operation including training, emergency planning, operating procedure preparation, etc., places great demands on out Braidwood Station personnel.

We have learned that the response to.these demands come at the expense of our preoperational testing schedule.

Therefore, in order to maintain this schedule, we have decided to organize and implement the Project Start-up Organization.

This approach has benefits over a total contract services approach in that it will serve to keep responsibility for, and direct control of the program within Commonwealth Edison's proven nuclear organization under a proven and fully accepted QA structure.

The transfer of the preoperational testing responsibilities will be implemented gradually.

It is anticipated that parallel organizations will exist between Braidwood Station and the Project Start-up Organization while duties and system responsibilities are being transferred.

Enclosed for your advance information are changes to the Byron /Braidwood FSAR that fully explain our new Braidwood Project Start-up Organization.

Our Byron /Braidwood FSAR Chapters 13 and 14 will be amended to include this information in the next Amendment.

$i B408140386 840807 8

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PDR ADOCK 05000456 i

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i H.R. Denton August 7, 1984 Please address any questions that you or your staff may have concerning this matter to this office.

One signed original and fifteen copies of this letter with Attachments are provided for your use.

Very truly yours, E. Douglas S z

Nuclear Licensing Administrator bs Attachments cc:

J.G. Keppler - RIII RIII Inspector - Braidwood 9059N

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Attachment

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On page 13.1-6, insert the'following note under the title:

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Site Operational' Analysis Lead Engineer"-

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. NOTE:

At the Braidwood Station, these responsibilities. fall.under the title of Prdject 0AD Supervisor.. See FSAR Section 13.1.5.2.

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. 13.1.5 Project Start-up Organization This subsection describes the structure, functions, and responsibilities of the Braidwood Project Start-up Organization.

This organization has been established to assume complete onsite responsibility for the Preoperational testing phase of the initial testing program.

The interaction of this organization with the Station organization and with Project Engineering is described in Section 14 of the FSAR and in the Commonwealth Edison Quality Assurance Program.

13.1.5.1 Project Start-up Organization An organization chart of the Project Start-up Organization is provided in Figure 13.1-3.

This chart indicates the title of each position and the anticipated number of persons assigned to common or duplicate positions at the time of peak activity.

A schedule for filling all indicated positions for each unit relative to fuel loading is provided as shown in Table 13.1-4.

This schedule represents the estimated manpcwer requirements and is subject to change as need dictates.

13.1.5.2 Project Start-up Personnel Responsibility and Authorities The functions, responsibilities, and authorities of various Project Start-up positions and organizations are as follows:

Project Start-up Superintendent The Project Start-up Superintendent has complete onsite responsibility for the preoperational testing phase af the initial testing.

He is responsible for completing the testing of systems to meet the required fuel load and commercial service dates while adhering to all quality requirements.

He will coordinate the activities of Project Construction, Project Operational Analysis Station, and Project Start-up to complete systems for fuel load and commercial service, as required by the technical specifications, and to turn these systems over to the Station staff.

He will also plan and schedule activities for the completion of construction, preparation for testing, testing, onsite evaluation, and onsi e approval of results and turnover of systems to operating.

He will provide schedules in a usable format.

In. carrying out these duties, he must establish priorities for Project Construction completion of system for Test and Turnover; establish priorities for Project Engineering Department and Project Field Engineering Department design to support Test and Turnover; establish need dates for the purchase and expediting of materials to support Test and Turnover; and establish priorities and support the testing of systems by the Project Start-up Organization.

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. Project.-Start-up-Testing Supervisor.

The _ Project L Start-upiTesting Supervisor. is. responsible for completing all

-preoperationalfand system demonstration test procedure writing, system turnoverofor test, test execution, and test completion.

His duties include following1 and completing systems for turnover for flush, test, and test completion; supervising the_ preparation of all preoperational and. system: demonstration test results for Test Review Board; controlling and completing testing. deficiencies identified during system preparation 7for test,: flush,: testing, and prior to release for operation; supervising testing and flushing activities

• resolving conflicts between PCD and

Project Production concerning flushing and testing;.and ensuring project

< implementation of the start-up manual.

Project Sche'duling

~

Project Scheduling.is responsible for development and maintenance of a Braidwood Project Schedule-and other supporting schedules within~the Braidwood' Project,0rganization; ongoing monitoring and. assessment of progress made in.the. Project' Schedule; incorporation of constraints into the schedule including budget and-manpower resources.-

' Project OAD Supervisor

' Project Operational Analysis Department' performs all~ electrical construction tests and will' assist both the_ Station'and the Project Start-up Organization when; requested'in the performancelof preoperational tests.

The Project OAD Supervisor has signoff authority for construction testing ~ tasks, and hefexecutes-the construction-test-plan as' coordinated:

-withfProject--Construction Department' personnel whoLare: responsible'to declare when plant equipment'is available'for construction test and

' calibration.

He'is also responsible for evaluating the adequacy ofl site

.specificLprograms usedsto. train and test, Project OAD personnel in electrical construction test procedures.

. Qualifications:

Fourcyear college graduation plus five _ years 1of. related experience inl equivalent inspection,. examination, or testing activities

.withlat least two years of this experience associated with nuclear.

facilities ortif not, at.least' sufficient' training to be acquainted with g

'the relevant quality assurance aspects of a nuclear' facility.

Technical ~

-competence to-supervise and work on electrical systems is attested by the

~ System OAD Generation Group Supervising Engineers:and reviewed by the i

System OAD Supervisory > Staff. Engineer 6

Project Material Coordinator The Project-Material' Coordinator will work with CECO Construction,_

Engineering, Quality Assurance, Land Purchasing Departments and S&L in

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obtaining all.necessary1 material, drawings, documentation, schedules, and anytrelated'information'necessary to complete the-testing and turnover.of each system demonstrationiand preoperational test within the. framework created by1the approved CECO Q.A. program.

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. Project Start-up Turnover Supervisor The primary-responsibilities of this position'are.the planning and

-completion of activities required for the turnover of systems to Operations.

Included as one of these activities is to coordinate the

-completion:and resolution of all deficiencies required for system turnover;toL0perations.

The direction for the maintenance and monitoring of the; deficiency program is also a responsibility of this position.

Project Start-up Staff Supervisor zThe Project' Start-up Staff Supervisor's primary responsibility is for the Start-up Organization's Test Review Board effort.

The Staff Supervisor is responsible for assigning participants to Test Review Boards consistent with the requirements of the Quality Assurance Manual.

He will also be a TestLReview Board participant.

In addition, Project Scheduling, the. Project Material Coordinator and Westinghouse's Site Engineering Team also' report to the Staff Supervisor.

- Succession-of Authority s

TheLBraidwood Project Start-up Superintendent will ultimately have

overall responsibility for the Braidwood Station preoperational test program onsite activities.

He designates, in writing, which of those

' direct reports will be responsible in his absence.

That person must,

- however, satisfy the requirements of ANSI 18.1-1971 for Plant Manager.

- 13.1. 5. 3 - Qualification-Requirements' The. Braidwood Project Start-up Management. follows the guidelines of ANSI-N18.1-1971'for' personnel selection-and: training.

Table:13.1-5 lists Project Start-upLstaffSpositions and designates ANSI-

-;N18.1 equivalent titles.:

.i 113.1.5.4 Qualifications'of Start-up Personnel

-The'qualifica'tionstof-the. initial 1 staff personnel-holding key managerialL

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and supervisory; positions in the'Braidwood Project 1 Start-up Organization aresprovidediin thefresumes-included 11n,AttachmentL13A.

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. BRAIDWOOD-FSAR TABLE;13.1-4 SCHEDULE FOR FILLING POSITIONS (BRAIDWOOD STATION PROJECT START-UP ORGANIZATION)

- MONTHS PRIOR

-POSITION TO CORE LOAD Project Start-up Superintendent In Place Project Start-up Testing Supervisor In Place Project-Start-up Staff Supervisor In Place ProjectLStart-up-Operation Specialists 12 - 16 Project Start-up Technical Specialists 12 - 16 Project Start-up Turnover Supervisor In Place Project 0AD: Supervisor In Place

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BRAIDWOOD FSAR TABLE 13.1-5 BRAIDWOOD PROJECTISTART-UP ORGANIZATIONAL TITLES AND ANSI N18.1 EQUIVALENT TITLES TYPE OF BRAIDWOOD PROJECT ANSI N18.1 TITLE LICENSE' REQUIRED START-UP TITLE Plant Manager None Start-up Superintendent Technical Manager None Proj. Start-up Testing Supv.

Proj. Start-up Staff Supv.

Supervisors-Not Requiring None Project Start-up Operation

.NRC Licenses Specialists Technical Support None Project Start-up Technical Specialists

-- Other Personnel

• None Project.0AD Supervisor Other Testing Personnel

• The qualifications of the Project OAD Supervisor are given in Section 13.1.5.2.

The qualifications of other testing personnel are.

described in Commonwealth Edison's response to FSAR Question 423.2.

13.1-24 t

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PRDJECT START M SUPERINTENDENT C. J. TO MSHEK i

PROJECT DAD PROJECT START-UP PROJECT START-UP PROJECT START-UP TEST SUPERVISOR TURNOVER SUPERVISOR STAFF SUPERVISOR N. P. I MIS J. J. GALLIGAN R. M. POKORN H. A. ZIMMERMN STAFF STAFF (33)

(4)

FLUSH TESTING MATERIAL COORDINATOR (2)

Ct)0RDINATOR (X)0RDINATOR OP SPECIALISTS (3)

SCHEDULING (3)

(2)

(2)

TECH SPECIALISTS (3)

W SITE ENGINEERING (4)

ASST SUPERVISOR (3)

ST I

COORDINATOR C)

TURNOVER E

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. B/B FSAR ATTACHMENT ~13A TABLE OF CONTENTS PAGE l'3.A.27-Project Start-up Testing Supervisor, Braidwood. Station 13A-35 (James J. Galligan) 13.A.28' Project Start-up Staff Supervisor, Braidwood Station 13A-36 (Henry A. Zimmerman)

13.A.29 Project Start-up Operational Analysis-Supervisor, Braidwood Station 13A-37 (Niccoli P. Tomis) 13.A.30 Project Start-up Turnover Supervisor, 13A-38

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.Braidwood Station (Robert M. Pokorn)

-13.A.31 Project Material Coordinator, 13A-40 Braidwood Station (Francis L. Wirkus) 4 13a-iii

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, B/B FSAR

'4 13.A.27 Ploject Start-up Test'ing Supervisor, Braidwood Station

.NAME:

James.~J. Galligan CITIZENSHIP:

United: States of America AGE: '

28 FORMAL EDUCATION:

B. S. University of Wisconsin - Applied Science and Tech.

' TRAINING:

USAF-One year Electronics and System Training.

Westinghouse-P-250 Computer School, EHC, 7300 Series Electronics, IPPO.

Other-EGC, Honeywell, Conitel (L&N), Response Time Measurement, Management:

Basic Supervisory, Kepner-Tregoe, MBO.

WORK EXPERIENCE:

1983-present.

Start-up Test Evaluation and System Preparation for Test ano Test Completion 1978-1983f Master Instrument' Mechanic, Instrumentation Installation, Testing, Calibratiin (Braidwood)

-1975-1978' Electrical Installation end Testing of Power Distribution Systems,' Modification Installation and Testing (Zion) 1970-1975 Computer and Electronics Maintenance, Electrical / Electronic Testing'(Zion) 1966-1970 USAF Missile System' Start-up,' Testing, and Maintenance 13A-35

. B/B FSAR 13.A.28' Project Start-up Staff Supervisor, Braidwood-Station

-NAME:-

HenryfA. Zimmerman CITIZENSHIP:

2 IUnite'd States of America-AGE:

33-

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FORMAL' EDUCATION:

BS, Nuclear Engineering - University of_ Wisconsin, August 1972 Master of Management - Northwestern University, 1982-

' TRAINING:

General = Electric --BWR; Technology, 1973

Commonwealth Edison - Introduction to Power ' Plant Operation, 1984 Commonwealth Edison --PWR-Systems Descriptions, 1984

^ eWORK: EXPERIENCE:

' Commonwealth-IEdison:.

.W-1983-Presenti : Project' Start-upLTestrand Test Results; Review Supervisor,j Braidwood 1982-19831 l

-Dresden Station Maintenance: Staff 11980-1982.

' Statistical Research' E1979-1980.

Fuel Buyer for: Zion, Byron /Braidwood-

[GeneraliElectric:-

197.4-1979c

~.. Project Application-Engineer:

Plant" Clinton;) Fuel T

Dresden,-QuadLCities, LaSalle. County.

1972-19741

, Field ' Engineer: ' Maintenance and; refueling.at Millstone,

{Dresden,oMonticello Start-upl Engineer:' Duane Arnold Energy Center; 113 A'-3 6 '

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1 B/B FSAR 13.A.29' Project Start-up Operational Analysis Supervisor, Braidwood Station NAME:-

Niccoli P. Tomis CITIZENSHIP:

United States of America AGE:

37 FORMAL EDUCATION:

~ Associate in Applied Science - Milwaukee School of Engineering.

BS in Applied Science and Technology - University of Wisconsin -

Parkside, 12/74-5/75.

TRAINING:

Management Coaching, 1982 Introduction to Power Plant Operations, 1981 Protective Relaying for Generating Station Equipment, 1977 Special Course conducted at Braidwood Station on Braidwood Plant Systems WORK EXPERIENCE:

Commonwealth Edison:

6/78-present Braidwood Station Project 0.A.D. - Supervising Engineer in

-charge of electrical testing.

10/76-6/78 LaSalle County Station S.O.A.D. - Tested equipment up to 345KV including aux power, fans, pumps, heaters, valves, instruments, and miscellaneous equipment; also acting LTE.

during LTE's absences.

6/75-10/76 Collins Station S.O.A.D. - Tested equipment up to 765KV including aux power, fans, pumps, heaters, valves, instruments, and miscellaneous equipment.

-9/71-11/73 Station Construction at Zion Station - Tested equipment up to 4KV including aux power, fans, pumps, heaters, valves, and miscellaneous equipment.

13A-37

. 8/B FSAR 13.A.30

. Project Start-up Turnover Supervisor, Braidwood Station NAME:

' Robert'M. Pokorn CITIZENSHIP:

United States of America AGE:

41' FORMAL-EDUCATION:

University of Illinois - Graduated 1965 BSEE TRAINING:

1984' Introduction to. Power Plant Operation; PWR Simulator -

Commonwealth Edison

-1978 Project /2 Basic Scheduling - Project Software & Development, Inc.

-1977 ASME Survey Member - Bechtel, Midland BWR Simulator Training - General Electric-Welding Training - Hobart 1976

.NDE' Training:-Radiography Interpretation - Magnaflux Magnetic Partical/ Liquid Penetrant - Magnaflux.

Ultrasonic Testing - Magnaflux Codes and-Standards --) Energy Incorporated 1971 Basic Supervision - Commonwealth. Edison WORK' EXPERIENCE:

-1983.-Present Braidwood Project Start-up, Braidwood Station, Lead

. Project Scheduler for Braidwood Station 1980-1983'

. Project Scheduling and Cost Control; General Office;ilead Project Scheduler.for Byron /Braidwood-Stations 1978-1980'

. Construction Scheduling and Cost: Control, General Office; Lead. Project'Schedulerifor Byron /BraidwoodLStations-

1976-1978-Quality Assurance,-LaSalle County Station; Lead-'of Electrical and Later LeadL of Structural. Section of Site Q.A.

1976-:

Quality Assurance, General Office 13A-38

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~-12-n JWORK EXPERIENCEr(continued)i>

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g 1975-1976; MDivision' Engine'ering, ChicagoiSouth Division;. Supervisor,

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~offthe Planning Section; L

L1973-1975.

Division: Engineering, Northern-Division; Supervisor;of the

' ;PlanningJSection.

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'1972-1973, 10f fice tof.the' 0perating Manager,, General Office;' Staf f l Assistant'

1971-1972T TDistrictJEngineering,fWaukegan; supervised fieldLengineers 7 n;the -designi.of distribution: facilities.

1

1968-1971

-

TDistribution-Engineering, General' Office; worked on the

.' design of-transmission.and distribution substations...

cAlso,;was'assignedito a~special studies section of the c *. _.

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-department dealing 11nfpower distribution related.

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problems.- Another> assignment was the planning of:

additional distribution facilities.

J1966-1968:

Division Engineering,--Chicago:. North Divis' ion; worked in

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field engineeringz.related:to'th'e design of distribution

facilities.

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1965-1966:

Assigned-to the GraduateiTraining Program-to-learn.about

'the activities _end; functions.of departments within

Commonwealth EdisonLCompany.

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. B/B FSAR 13.A.31 Project Material Coordinator, Braidwood Station NAME:

Francis L. Wirkus

CITIZENSHIP:

-United States of America

' AGE:

41 FORMAL EDUCATION:

' Bachelor'of Science in Business Administration - Loyola University-TRAINING:

WORK EXPERIENCE:

8/83-Present Project Material Coordinator-(Staff Assistant) - Braidwood~

~ Station

-8/82-Present Project Material Coordinator'-(Staff Assistant) - LaSalle

-County Station 5/81-8/82 Investment Recovery =(Salvage) 6/79-5/81 Project' Expediter-6/76-6/79 Senior Expediter 9/74-6/76

~ Expediter

~6/72-9/74 Supervisor Code Control 2/70-6/72 Order Analyst

-10/69-2/70 Order Analyst I 4/69-10/69 Equipment--Inspector

'9/58-4/69 Various bargaining unit positions-

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13A-40.

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14.2.2 Organization and Staf fing At Byron Station, the operating and technical staffs will manage and execute the initial test program in accordance with the Quality Assurance Program as outlined its the QA Topical Report referenced in Chapter 17.0.

The Technical Staff Supervisor is the senior participant of the Onsite Review-Group.

The. senior participant will choose the necessary participants for a particular review from designated individuals qualified in the disciplines listed in Technical Specification 6.1.G. l. f. - The-station technical staffs are responsible for writing and

conducting the initial test program.

The Test Review Board is responsible for the onsite review and approval of the test procedures and test ~results.

At Braidwood, two Commonwealth Edison organizations have been established to execute the initial testing program.

These two organizations are the Station and-the Project Start-up Organization.

For initial start-up testing, the Braidwoud Station's efforts will parallel those of the Byron Station's.

That is to say, the Braidwood Station's Operating and

-Technical Staffs will manage and execute the initial start-up test program in accordance with the Quality Assurance Program as outlined in the_QA Topical Report referenced in Chapter 17.0.

The Technical Staff Supervisor is the senior participant of the Onsite Review Group.

The

' senior participant will choose the necessary participants for a

-particular review from designated individuals qualified in the

' disciplines listed in Technical Specification 6.1.G.1.f.

The station technical staffs are. responsible for writing and conducting the initial start-up test program.

The Test Review Board is responsible for the

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review and the approval of the start-up test procedures and start-up test results.

After April, 1984, responsibility for preoperational testing at the Braidwood Station rests with the Project Start-up Organization.

The preoperational test program will be executed in accordance with the Quality-Assurance Program as outlined in the QA Topical Report referenced in Chapter 17.0.

For any tests performed during and after fucl load, the Technical Staff Supervisor is the senior participant of the Onsite Review Group.

The senior participant will choose the necessary participants for a particular review from designated individuals qualified in the disciplines listed in Technical Specification 6.1.G.1.f.

The Project Start-up Organization's Testing Staff (as and when applicable) will be responsible for writing and conducting the Preoperational Test program.

A Test Review Board, organized consistent with the Quality Assurance Manual ~~from the Station or from the Project Start-up organization (as and when appropriate), will be responsible for the onsite review and approval of the preoperational test procedures and test rosults.

The C6mmonwealth Edison Operational Analysis and Station Construction Departments will provide technical support or oarticipate in the test program as required.

The Project Engineering Department (PED) has

.overall responsibility for the successful review, approval, and completion of the initial test program.

PED conducts its review in accordance with an approved procedure (PED Procedure Q.19).

PED also provides the interface between the test personnel at the stations and the architect-engineer and the Nuclear Steam Supply Vendor.

The Nuclear Steam Supply System vendor (Westinghouse) and the architect-engineer (Sargent & Lundy) will, as required, provide technical assistance.during testing of systems.

The authority and responsibility

'of each organizational unit involved in the initial test = program is further specified in the. Quality Assurance Program, Quality Assurance

' Procedures; Manual, Section'll.

The. organizational' structure ~that will implement the test program is discussed in Section-13.1.

Personnel conducting'the testing.will be qualified by experience and training as described in Chapter 13.0.

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. 14.2.3 Test Procedures The initial test' program will be conducted using detailed written

- procedures forL each findividual test.

Tests of Safety-Related Systems and specially designated non-safety-related systems ( for purposes of initial plant start-up_only) are called Preoperational or Start-up Tests.

The Quality Assurance Program for the Commonwealth Edison Company (referred to in. Chapter.17.0)' describes the procedures for administration of Preoperational and Start-up Tests. 'All other tests will be called System Demonstrations or Operational. Demonstrations.-

Preoperational Tests and System Demonstrations will be. performed during the "preoperational test phase."

Start-up Tests and Operational Demonstrations will be performed during-the " start-up test phase."

SarGent'&.Lundy or Westinghouse, as appropriate, and as directed by Commonwealth Edison, will prepare rough draft test procedures.

The station staff (Project Start-up's Testing Staff as and when applicable for preoperational tests at the Braidwood Station) will pranare final draft test procedures based on the rough draft and on comments received

- from; appropriate Commonwealth Edison departments.

Sargent & Lundy and/or Westinghouse will' review the final draft procedures as directed by

' Project' Engineering.

The final draft of Preoperational Test and Start-up Test' procedures will be-reviewed and approved by the Project Engineering Department.

Revisions to Preoperational Tests or Start-up Tests will be

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prepared by the station staff '(or Project Start-up's -Testing Staff as -and when applicable-for preoperational tests at the Braidwood Station) and submittedoto the Project Er.gineering Department for review and approval.

System Demonstration and Operational Demonstration test ~ procedures will

_ be written, reviewed,and approved by; the station staff (or Project

- Start-up's Testing Staff as and when applicable for System Demonstration tests at the Braidwood Station) in accordance with station procedures.

Individual test procedures will specify prerequisites, data to be obtained, and requirements and acceptance criteria to be fulfilled..

Table 14.2-1' identifies'the information typically provided in the individual test procedures.

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.- 14.2.5 Review,: Evaluation, and Approval of Test Results

. Initial preoperational and start-up tests that fall within the scope of the Quality Assurance program will be subject to two stages of evaluation.- First, a detailed and comprehensive review by Station or Project Start-up personnel (as applicable) will be made.

The Project Engineering Department project personnel will perform a second and final

.' review-and. evaluation.

Modifications or rework of systems or equipment required to resolve deficiencies will be accomplished in accordance'with controlled procedures.

Retesting, if required Decause of modification or

- rework, will be documented and filed with the initial test record.

The initial core loading procedure will specify the start-up tests that must be completed prior to commencement of fuel load.

All testing identified as falling within the preoperational test phase will be completed and the results evaluated prior to core load.

. Modification and rework on systems that is required to resolve test deficiencies is controlled by the Test Review Board during post test review and by Project Engineering who has responsibility for final test-

.accep ance an :approva.

Project Engineerin ma specify additional test t

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requirements to resolve test deficiencies pr or o final test approval.

The power. ascension procedure will specify.those start-up tests or portions'of start-up tests that must be completed as a prerequisite for commencing each' phase.

The data obtained at each power test plateau will

. be evaluated and approved before increasing power level.

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-The:last paragraph of Section 14.2.9 revised to read:

' " Personnel from other facilities'make up.a significant portion'of the

- Station's Operating and Tech Staffs as well-es Project Start-up's Testing Sta f f 'at t'.e-Braidwood Station.

Their experience will be utilized in

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- both preparing and: implementation of.the test procedures."

1-A 5