ML20112H128

Testimony of Fg Dawe,Ja Notaro & Ej Youngling Re Suffolk County & State of Ny Contention on Tdi Diesel Generator Qualified Load.Related Correspondence

ML20112H128
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/15/1985
From:	Dawe G, Notaro J, Youngling E LONG ISLAND LIGHTING CO.
To:
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ML20112H126	List: ML20112H122 ML20112H128
References
OL, NUDOCS 8501160624
Download: ML20112H128 (46)

Text

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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board

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In the Matter of )

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-Q Docket No. 50-322(OL)

LONG ISLAND LIGHTING COMPANY )

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(Shoreham Nuclear Power Station, )

Unit 1)

.O DIESEL GENERATOR QUALIFIED LOAD TESTIMONY OF GEORGE F. DAWE,

Q JACK A. NOTARO AND EDWARD J. YOUNGLING ON BEHALF OF LONG ISLAND LIGHTING COMPANY Testimony and Attachment

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V 8501160624 850115 PDR ADOCK 05000322 T PM

O LILCO, January 15, 1985 UNITED STATES OF AMERICA

() - NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board O In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 (OL)

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(Shoreham Nuclear Power Station, )

Unit 1) )

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DIESEL GENERATOR QUALIFIED LOAD TESTIMONY OF GEORGE F. DAWE, JACK A. NOTARO AND EDWARD J. YOUNGLING O ON BEHALF OF LONG ISLAND LIGHTING COMPANY

1. Please state your names and business addresses.

A. (Dawe) My name is George F. Dawe. My business ad-o dress'is Stone & Webster Engineering Corp., 245 Summer Street, Boston, Massachusetts 02107.

(Notaro) My name is Jack A. Notaro. My business O address is Long Island Lighting Company, Shoreham Nuclear Power Station, North Country Road, Wading River, New York 11792.

(Youngling) My name is Edward J. Youngling. My O business address is Long Island Lighting Company, Shoreham Nu-clear Power Station, North Country Road, Wading River, New York 11792.

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2. Please identify your current position and describe your professional qualifications.

(y A. (Dawe) My current position, to which I was O

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() appointed in January 1980, is Supervisor of Project Licensing within the Licensing Division of Stone & Webster (SWEC). I am responsible for technical and administrative supervision of all

() project licensing personnel assigned to SWEC headquarters proj-ects, including field assignments. My duties include assuring project awareness of regulatory requirements and developments,

() assuring proper and consistent application of SWEC licensing policies, and consulting with projects and clients on licensing issues.

() I joined Stone & Webster in 1973 as an Engineer in the Licensing Group. In January 1974, I was assigned as Li-censing Engineer for the Shoreham Nuclear Power Station (SNPS) under construction, and was Lead Licensing Engineer from 1976

()

to 1980. In this capacity, I was responsible for all licensing related activities for SNPS including preparation of the Final Safety Analysis Report. I have had additional assignments at

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. Stone & Webster including development of-company positions for NRC Regulatory Guides and Lead Licensing Engineer-for the Spe-() cial~ Projects Group of the Operations Services Division. I am also_the Stone & Webster representative to, and participating member of, two subcommittees of the AIF Committee on Reactor-(j . Licensing and Safety.

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Prior to joining Stone & Webster, I served seven years as a commissioned officer in the U.S. Navy Nuclear Power Program. My duties included direct supervision of operation and maintenance of a submarine nuclear propulsion plant. I also served on the staff of the U.S. Navy Nuclear Power School as Director, Core Characteristics and Reactor Physics Division.

While on active duty, I was qualified for assignment as Chief Engineer on nuclear powered vessels.

I received a Bachelor of Science degree from the United States Naval Academy in 1966. I have 18 years experi-ence in the nuclear power field and hold a certificate as Engineer-in-Training in Massachusetts by 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> examination. A copy of my resume setting forth my professional qualifications has previously been submitted on the record in this case.

(Notaro) My current position, to which I was ap-pointed in May 1984, is Outage and Modification Manager for the

. Shoreham Nuclear Power Station. As such, I am responsible for the implementation of design changes to the plant systems or equipment as required by the regulatory agencies or for plant operational considerations. I supervise the Planning and Scheduling, Modification Engineering and Outage Planning Sec-tions of the plant staff. In my current position, I have been involved with LILCO's diesel generator recovery efforts,

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including the endurance test run of EDG 103 at the qualified load of 3300 KW. I hold NRC Senior Reactor Operator License SOP-4419 for Shoreham, which I obtained November 1982.

I have been employed by LILCO since 1970 and as-signed to the Shoreham Nuclear Power Station since 1973. I have held a number of plant staff positions prior to my current position, including Operating Quality Assurance Engineer, Op- -

erating Engineer and Chief Operating Engineer. In addition, I have been assigned for periods of time to the Vermont Yankee Nuclear Power Station, the Millstone Nuclear Power Station and the Dresden Nuclear Power Station for power operation training.

I have successfully completed numerous LILCO, Gener-al Electric Company and industry training programs. I received a Bachelors Degree in Mechanical Engineering from City College of New York, and a Master of Business Administration Degree from Adelphi University. A copy of my resume, setting forth my professional qualifications more fully, is attached to this testimony as Attachment A.

(Youngling) I am the Manager of the Nuclear Engi-neering Department at LILCO. In this capacity, I am responsi-ble for engineering support at Shoreham, including the three TDI diesel generators. From 1981 until 1984, I was the Start-up Manager for the Shoreham plant. In this position, I was

responsible for implementing the preoperational test program for Shoreham, including checkout, initial operation and subse-l quent preoperational testing of the TDI diesel generators.

After the failure of the EDG 102 crankshaft, I was designated as the Recovery Manager for the repair and requalification of the diesel engines. In my various capacities, I have super-a vised more than 3,350 hours0.00405 days <br />0.0972 hours <br />5.787037e-4 weeks <br />1.33175e-4 months <br /> of operation of Shoreham's TDI die-sel generators, the development of the program to define the qualified load for the Shoreham TDI diesel generators, and the development of the confirmatory test and inspection program to assess the adequacy of the diesel generators at this qualified i

load. A copy of my resume setting forth my professional quali-fications has previously.been submitted on the record in this

. case.

3. What is the purpose of your testimony?

A. (All) The purpose of th'is testimony is to respond to the contention of Suffolk County and the State of New York concerning qualified load for the Shoreham TDI emergency diesel-operators. That contention, as admitted by the Board, states as follows:

Contrary to the requirements of 10 C.F.R. Part 50, Appendix A, General Design Criterion 17 --

Electric Power Systems, the emergency diesel generators at Shoreham ("EDGs") with a maximum

" qualified load" of 3300 KW do not provide suf-ficient capacity and capability to assure that

the requirements of clauses (1) and (2) of the first paragraph of GDC 17 will be met, in that (a) LILCO's proposed " qualified load" of 3300 KW is the maximum load at which the EDG may be operated, but is inadequate to han-die the maximum load that may be imposed on the EDGs because:

(i) intermittent and cyclic loads are ex-cluded; (ii) diesel load meter instrument error was not considered; (iii) operators are permitted to maintain diesel load at 3300 KW +/- 100 KW; (iv) operators may erroneously start addi-tional equipment; (v) [ subsection not admitted]

(vi) [ subsection not admitted]

(b) (subsection not admitted]

(c) The EDG qualification test run performed by LILCO was inadequate to assure that the r

EDGs are capable of reliable operation at 3300 KW because:

(i) (subject matter to be covered in block testimony)

(ii) (subject matter to be covered in block testimony)

(iii) operators were permitted to control

the diesel generators at 3300 KW +/-

l 100 KW during the test; (iv) instrument accuracy was not consid-ered; and (v) (subsection not admitted).

4. Please summarize your testimony.

A. (All) (1) The qualified load of 3300 KW is ade-quate and appropriate. Three intermittent load groups (motor operated valves, diesel generator fuel oil transfer pumps and diesel generator air compressors) were excluded in establishing the maximum emergency service load for each EDG and thus the qualified load. This exclusion, concurred in by the NRC Staff, was appropriate and justified because these are short term, small magnitude loads.

(2) The accuracy of the diesel generator load in-struments to be used during operation does not affect the ade-quacy of the qualified load. These instruments do not intro-duce errors of sufficient magnitude to impair the ability of the diesel generators to perform their intended function.

(3) A control band of + 100 KW about the 3300 KW qualified load is permitted only during required surveillance testing at the qualified load. This is necessary, as a practi-cal matter, to conduct such tests. This testing is not per-formed for extended periods of time and therefore any variation of the load about 3300 KW will not affect the ability of the diesel generators to perform their intended function.

(4) As required by regulation, operator error has been considered in the design of the plant. The use of a

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qualified load for interim licensing does not alter the plant's ability to meet this design basis. Operator error remains an unlikely cause of a diesel generator failure, and failure of a diesel generator is within the design basis of the plant.

(5) The 10 7 loading cycle confirmatory test was ad-equate to establish the qualified load of 3300 KW. The opera-tors were directed to conduct the endurance run portion of the test on EDG-103 at 3300 KW + 100 KW. The load data obtained at 30 minute intervals throughout the endurance run demonstrate the adequacy of the test. The accuracy of the EDG-103 load meter was verified before and after the endurance run to be well within the specified calibration limits for the instru-ment. Any operation during the confirmatory test that may have been above or below 3300 KW due to instrument error was not substantial, did not affect the validity of the test and is representative of future operation utilizing the installed load meters.

5. Please define " maximum emergency service load" (MESL).

A. (All) The maximum emergency service load, as de-fined in Amendment 52 to the Shoreham License Application (Re-vision 34 to the FSAR) is the maximum load which would exist on an EDG during a loss of coolant accident in conjunction with a loss of offsite power (LOOP /LOCA).

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6. How is the MESL determined?

A. (All) The MESL is determined for each EDG by sum-ming the individual loads which will be simultaneously connect-ed to that EDG for more than short periods of time following initiation of a LOOP /LOCA event. These loads are generally en-gineered safety features (ESP) or ESF support equipment, and are powered automatically following diesel generator start in response to a LOOP /LOCA initiation signal. Component nameplate load values are used in the summation except where values mea-sured in the plant are available.

7. What is the MESL for each EDG?

A. (All) The MESL for each EDG is set forth in the Shoreham FSAR, Revision 34, Table 8.3.1 1.A. The MESL is 3253.3 KW for EDG-101, 3208.7 KW for EDG-102 and 3225.5 KW for EDG-103.

8. Please define " qualified load."

A. (All) The concept of a " qualified load" was intro-duced in the NRC Staff's Safety Evaluation Report on the Transamerica Delaval, Inc. Diesel Generator Owners Group Pro-gram Plait. The SER states that the Staff and its consultants

-have not completed their review of the Owners Group efforts.

However, the SER reflects that the Staff has established an

interim licensing basis for TDI diesel engines. The NRC Staff has concluded that engines operating below a BMEP of 185 psig could be licensed in the interim. In considering whether an engine meets the 185 psig BMEP criteria, the NRC Staff has stated they would consider excepting engines from the require-ment where the load exceeds the 185 psig BMEP criterion for brief periods of time. See Safety Evaluation Report, Transamerica Delaval, Inc. Diesel Generator Owners Group Pro-gram Plan, pp. 13-14.

For engines where emergency service load require-ments involve a BMEP greater than 185 psig, the NRC Staff has required utilities to demonstrate that certain key components of the engines had been operated successful-ly for at least 10 7 loading cycles at or above the maximum emergency service load for those engines. This load level at which 10 7 loading cycles could be demonstrated was called the " qualified load." For Shoreham's TDI diesel generators, the confirmatory testing was chiefly for the purpose of demonstrating the adequacy of the replacement crankshafts. See Tr. 26292-93 (Berlinger).

9. What is the qualified load for the Shoreham TDI emergency diesel generators?

A. (All) For Shoreham, the qualified load is 3300 KW.

This is an upper bound of the maximum emergency service loads for all three TDI diesel generators.

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10. Were intermittent or cyclic loads included in LILCO's determination of the 3300 KW qualified load?

A. (All) No. Intermittent or " cyclic loads are small loads that will operate only once or occasionally following a LOOP /LOCA event. In either case, operation is for a short pe-riod of time. Because this equipment does not impose a contin-uous load on the diesel engines but only small load increases for short periods of time, it was not included in LILCO's de-termination of the qualified load.

11. How did LILCO arrive at the conclusion that inter-mittent or cyclic loads should not be included in the determi-nation of the qualified load?

A. (Youngling) LILCO concluded that intermittent or cyclic loads should not be included in determining the quali-fied load from review of the Staff SER for the TDI Diesel Gen-erator Owners Group Program Plan, as well as subsequent discus-sions with the Staff. That SER establishes the concept of a qualified load for diesels which operate at a BMEP greater than 185 psig. Since this SER in addressing qualified loads dis-cussed long term (10 7 cycles) loading conditions, and also pro-vided for exceeding 185 psig BMEP for brief periods of time when applying the BMEP criterion, LILCO concluded that brief, intermittent loads need not be included in establishing the

maximum emergency service loads, and thus the qualified load.

Prior to establishing the qualified load and performing the re-quired testing, LILCO discussed this interpretation with the NRC Staff. The NRC Staff concurred with LILCO's conclusion that intermittent or cyclic loads should be excluded from the MESL and qualified load. Dr. Berlinger restated this position in his December 13, 1984 deposition at pp. 17-19.

12. Which loads were not included in the determination of the qualified load as being intermittent or cyclic loads?

A. (Youngling, Dawe) Only three load groups are ex-cluded as intermittent or cyclic loads. These are (i) automat-ically actuated motor operated valves (MOV), (ii) diesel gener-ator fuel oil transfer pumps and (iii) diesel generator air compressors. As explained more fully below, each group repre-sents a small number of components, a small KW load or both.

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13. Please explain why automatically actuated motor op-erated valves have been categorized as excludable intermittent or cyclic loads.

A. (Youngling, Dawe) The automatically actuated motor operated valves are all of those valves which both receive power from an EDG and have the ability to operate automatically in the event of a LOOP /LOCA. The connectable load associated

with these valves is included in FSAR Table 8.3.1-1 by the line item " Motor Operated Valves" and a portion of the line item "480 V M-G Set."

These valves are valves which may be called upon to reposition automatically following a LOOP /LOCA initiation sig-nal. They include such valves as containment isolation valves, emergency core cooling system injection valves, and various system valves used to isolate redundant trains, unnecessary system loads or unwanted flow paths. A number of factors jus-tify the exclusion of these valves as infarmittent loads. Not all of these valves would be expected to reposition following an accident and thus would not actually represent a load on an EDG. Although they all receive automatic actuation signals to ensure proper positioning, many will be in their desired post-accident position during normal operation, and thus will not operate even upon receipt of a signal. Those that do operate can generally be expected to operate only once. If subsequent operation is necessary or desirable, it will generally result only from operator action. The automatic operation will occur during the first several minutes after the diesel generators start.

The stroke times of the MOV's are short. Most will complete their stroke, open or close, in less than one minute.

The longest stroke times do not exceed three minutes. Further, not all valves which will automatically reposition do so simul-taneously. Inherent time delays in reaching various actuation and permissive set points, bus programming and actuation signal generation will result in sequencing of valve operations.

For all of these reasons, the automatically actuated motor operated valves represent short time, intermittent loads on the EDG's. Because they represent small load increases for short periods of time, they are properly excluded in estab-lishing the qualified load.

14. What load could the automatically actuated motor op-erated valves impose on the diesels?

A. (Youngling, Dawe) For the reasons we have just stated, it is incorrect to take a simple summation of the loads attributable to each individual valve to represent the load a given EDG will supply. Such a summation yields a load which exceeds any that could reasonably be expected. Even this sum-mation of loads, however, would not result in exceeding the qualified load except in the case of one of the diesel genera-tors and then by only 19 KW.

As can be seen from FSAR Table 8.3.1-1, the category

" Motor Operated Valves" provides a summation of nameplate valve loads of 19.7 KW for EDG-101, 18.3 KW for EDG-102 and 0.7 KW

for EDG-103. These totals include all automatically actuated motor operated valves except two sets of 4 valves associated with operation of each train of the Low Pressure Coolant Injec-tion (LPCI) System. These LPCI related valves are powered by 480 V motor generator (M-G) sets which are, in turn, powered by the EDG's. By design, no diesel generator will be called on to power more than one of these sets of 4 LPCI related valves.

The 480 V M-G sets are maintained operating, but unloaded, to be ready to power the associated valves. This places a load of 19 KW per M-G set on the associated diesel generators. This 19 KW load per MG set is not an intermittent load and was included in determining the qualified load as dem-onstrated by FSAR Table 8.3.1-1A. Based on the nameplate rat-ings for each of the 4 valves powered by a given 480 V M-G set, the maximum coincident demand for each set of valves is less than 46 KW. Since this intermittent 46 KW load could be as-signed to any of the three diesels, it can be summed with the previously listed valve loads to establish an upper bound on the valve load for each diesel. This yields a total connected valve load of 65.7 KW for EDG-101, 64.3 KW for EDG-102 and 46.7 KW for EDG-103. As previously stated, though, such coincident loading is unlikely to occur, nor could it occur for more than a very short period of time, particularly in the context of the

10 7 loading cycles for which the qualified load is demon-strated. Moreover, even if these coincident valve loads are added to the MESL of each EDG, the loads would be 3319.0 KW for EDG-101, 3273.0 KW for EDG-102 and 3272.2 KW for EDG-103.

Thus, there is no significant period of operation above the .

qualified load level, even assuming the coincident operation of '

all automatically actuated valves.

15. Please explain why the diesel generator fuel oil transfer pumps have been categorized as excludable intermittent or cyclic loads.

A. (All) The diesel generator fuel oil transfer pumps transfer fuel oil for the diesel generators from the storage tanks to the day tanks in the diesel generator rooms. Each diesel generator has two associated fuel oil transfer pumps, only one of which is called on to operate. The preferred pump only operates after the fuel oil level in the day tank has been lowered to a predetermined value by operation of the diesel.

Thereafter, the pump operates to refill the tank and then stops. The second pump will operate only if the first fails.

The pump will operate for approximately 12 minutes every half hour during the operation of the diesel to maintain level in f

the day tank. The diesel generator fuel oil transfer pump load is only 0.2 KW per pump. Because this load does not operate

immediately after the start of an accident when the peak load on the diesel generators would be experienced and because the load is both small and intermittently imposed, it was not in-cluded in the determination of the qualified load.

16. Please explain why the diesel generator air compres-sors have been categorized as excludable intermittent or cyclic loads.

A. (All) The diesel generator air compressors are used to recharge the air start receivers following the start of the diesel generators. Each diesel generator has two independent, redundant air starting systems with each, in turn, having one air compressor. Each air compressor will automatically operate one time following energizing of the emergency bus by its asso-ciated diesel generator. Following one successful start at-tempt, each compressor will operate for approximately 15 minutes. Each compressor can recharge its associated air sys-tem in 30 minutes following the design capability of five start attempts. The air compressor load is 12 KW per diesel genera-tor. Since this is a one time load of short duration, it was not included in determining the qualified load. This load, if summed with the MESL for each EDG shown on FSAR Table 8.3.1-1A, does not raise the load on any EDG to the qualified load.

17. What load would be predicted if all the intermittent or cyclic loads on one EDG operated simultaneously?

A. (Youngling, Dawe) As explained for motor operated valves, it is incorrect to postulate all intermittent or cyclic loads operating simultaneously. In addition to the position and timing questions for valves, the fuel oil transfer pumps will not operate until the day tank level has been lowered by diesel operation. The air compressors will operate only once ,

after a diesel starts; the length of operation depends on the number of start attempts required. As with the valve loads alone, only an upper bound on intermittent loads can be easily predicted and, as before, if it were to occur it would be for a very short period of time. If all the intermittent or cyclic loads above are simply summed and added to the MESL for each EDG, the predicted load would be 3331.4 KW, 3285.4 KW and 3284.6 KW for EDG 101, 102 and 103, respectively. Thus, it is possible to calculate a load greater than the qualified load for only one EDG, and even then by only a small amount (less than 1%) and for no more than a few minutes even assuming coin-cident operation of all intermittent or cyclic loads.

18. Given that answer, shouldn't the qualified load have been established above 3300 KW?

A. (All) No. As previously explained, intermittent loads need not be considered in determining the qualified load.

Moreover, the summation of loads to establish the MESL does not take into consideration the actual sequence of operation of, or operating conditions seen by, plant equipment. In summing the loads on FSAR Table 8.3.1-1A to obtain the MESL it is simply assumed that all equipment operates simultaneously at the name-plate or measured value shown. This is conservative.

The extent of this conservatism is indicated by the results of the integrated electrical test (IET). The IET is performed to ensure that each redundant onsite power source and its associated load group can function without dependence upon any other redundant load group or portion thereof. Each por-tion of the test is of sufficient duration to achieve stable operating conditions and thus permit the onset and detection of adverse conditions which could result from improper assignment of loads, such as lack of forced cooling to a vital piece of equipment. The tests include introduction of an accident sig-nal (LOCA), and isolation from offsite power (LOOP).

Although the IET cannot simulate exactly the condi-tions that will exist following a LOCA, it does result in the full sequencing of loads, particularly in the short term before an operator would be expected to start responding to particular

symptoms from a particular accident sequence. This is signifi-cant because it is during the initial stage of the LOOP /LOCA that predicted loads would be at their highest due to initial starting of equipment before operators secure unneeded equip-ment. Following a LOOP /LOCA, the major loads on the diesel generators are attributable to the emergency core cooling sys-tem (ECCS) pumps, air-conditioning equipment and the service water pumps. During the IET, expected post-LOCA flows are achieved for both the ECCS and service water pumps and the chilled water systems are preheated to simulate design loads on the water chillers. Thus, there is substantial assurance that the IET results are a reasonable approximation of post-LOCA loads.

The IET has been performed at Shoreham with the TDI diesel generators. The peak loads measured for each EDG were 2833.6 KW, 2806.9 KW and 3072.0 KW for EDG-101, 102 and 103, respectively. These loads are significantly lower than the predicted MESL, and the qualified load for each diesel genera-tor. Additionally, during the IET, both reactor building ser-vice water pumps powe.ed from EDG-103 were started automat-ically. Had they been operated then as they now will be during plant operation, only one of these pumps would have started au-tomatically, and the peak load on EDG-103 would have been up to

l 358 KW less than the recorded 3072.0 KW. Thus, the IET pro-vides confidence that the predicted MESL for each EDG is con-servative.

19. What assurance is there that the qualified load of 3300 KW will not be exceeded during plant operation?

A. (All) Diesel generator operation itself can occur in response to plant conditions or as a result of operator ac-tion for surveillance testing in accordance with technical specification requirements. Loads can be placed on the diesel generators in one of two ways: (i) automatically in response to signals generated during events which require operation of the diesels, e.a., LOOP /LOCA, or (ii) manually by the operator when the diesel generators are operating.

Automatic loading of the diesel generators will not result in exceeding the qualified load. As previously explained, all automatically connected loads, except the iden-tified short time, intermittent loads, are included in the MESL for each EDG. These loads are bounded by the qualified load.

Operator action will also not result in loads greater than the qualified load. There is no condition under which all of the loads shown in FSAR Table 8.3.1-1 are needed or expected to be operated simultaneously. The ability to con-nect manually various loads is provided to ensure the operator

, has sufficient procedural flexibility to utilize various plant capabilities in the event of a LOOP or LOOP /LOCA. Some are provided to protect the non-nuclear portions of the plant.

The plant is designed so that operators do not have to take manual action during the first ten minutes of the event. Since this is approximately the time when peak loads are likely to be experienced on the diesel generators, it is unlikely that operator action will result in loads exceeding the qualified load. Due to the redundancy and diversity of ac-cident mitigation equipment, there is initially more equipment in operation than is needed. Thus, the initial actions taken by the operator in stabilizing the plant are directed towards securing unneeded equipment, redirecting flows, or otherwise reducing flows in such ways as throttling of ECCS once reactor vessel water level is restored.

Those loads which can only be connected manually are not needed or used during the initial response to a LOOP /LOCA.

They are available for later use by the operator. In some cases, this is equipment which may be used in the long term to mitigate LOOP /LOCA consequences, such as the post-LOCA hydrogen recombiners for control of combustible gases in the primary containment atmosphere, or the main steam isolation valve leak-age control system. In other cases, it is equipment not used

for LOOP /LOCA mitigation such as, for example, turning gears and lube oil pumps for the main and reactor feed pump turbines.

In either case, at the time such equipment is considered for use, the loads on the EDGs will have been reduced substantially from the MESL. When manually loading the diesel generators, the operators are directed by procedures and training not to exceed 3300 KW.

The situation is the same for response to events other than a LOOP /LOCA. The automatic LOOP /LOCA loads bound the automatic loads for other events such as a LOOP. Subse-quent operator decisions are limited by the 3300 KW load re-striction, but in no case are cumulative loads in excess of 3300 KW required.

For surveillance tests which confirm the automatic load sequencing of the diesel generators, the load experienced during the test is bounded by the MESL, and thus the qualified load is not exceeded. For surveillance testing of load carry-ing capability at the qualified load, the operators are di-rected to conduct the test at 3300 + 100 KW.

Therefore, there is reasonable assurance that the qualified load will not be exceeded following events which ne-cessitate reliance on the diesel generators. To the extent it may be exceeded during surveillance testing, as is discussed

more fully below, this would not affect the ability of the die-sel generators to perform their intended function.

20. What assurance is there that the operators will not operate the diesel generators at loads in excess of 3300 KW?

A. (Notaro, Youngling) Procedures and training give ample assurance that the operators will not load the diesel generators above the qualified load of 3300 KW. In addition, the NRC Staff has included in the Supplemental Safety Evalua-tion Report for the Shoreham TDI diesel generators, dated December 18, 1984, a requirement for a 3300 KW limit in the technical specifications. Plant operators are required to be familiar with the technical specifications, and they are trained to maintain the plant so as not to violate those speci-fications. Thus, it is highly unlikely that an operator would manually operate a piece of equipment that would cause the load on a diesel generator to exceed 3300 KW.

21. Please describe the procedural guidance provided for the operator to ensure that the qualified load of 3300 KW is not exceeded on any EDG.

A. (Notaro, Youngling) A number of procedures have been developed or revised to provide the proper procedural guidance to the operator. Included among these are (i) SP

23.307.01, Revision 12, " Emergency Diesel Generators," (ii) SP 29.015.01, Revision 7, " Loss of Off-Site Power Emergency Proce-dure," (iii) SP 29.015.04, Revision 0, " Loss of Coolant Acci-dent Coincident With a Loss of Off-Site Power," and (iv) SP

b 29.023.01, Revision 4, " Level Control Emergency Procedure."

The emergency diesel generator procedure, SP 023.307.01, provides instructions for proper operation of the EDG's and their associated auxiliaries. This procedure, in Paragraph 6.2.1, establishes as an operating limit that the continuous loading of any EDG should not exceed 3300 KW. Dur-ing surveillance testing of the diesel generators' ability to carry a load of 3300 KW, operation will be permitted at 3300 +

100 KW.

The level control procedure, SP 29.023.01, and the LOOP /LOCA procedure, SP 29.015.04, are interrelated procedures.

Individually and together, they provide guidance for the opera-tor during the initial stages following a LOOP /LOCA. They re-quire the operator to verify proper actuation of automatic loads and, if necessary, to initiate manually actions which should have occurred automatically. They also require the op-erator to verify that diesel generator loads do not exceed 3300 KW. The loss of off-site power procedure, SP 29.015.01, is then used to provide the load management guidelines for the

f diesel generators. This procedure establishes an upper limit for loading on each diesel generator at 3300 KW, directs that non-safety related loads be controlled so as not to exceed this limit, and provides load values for the connectable loads for the operators' use in maintaining the load below this limit.

Since all of the automatic loads are considered in the MESL for each EDG, manual actuation of loads which could result in ex-ceeding the qualified load is unlikely. For subsequent ac-tions, sufficient direction, warnings and guidance are provided by the procedures to allow the operator to manage load without exceeding the qualified load.

In addition to these procedures, a number of other procedures have been, or will be, modified. SP 24.307.01 (Emergency Diesel Generators Start and Load Test), SP 24.307.02 (DG-Emergency AC Power Load Sequencing Test), and SP 24.307.03 (Emergency Diesel Generators Load Rejection Test) provide pro-cedural control for surveillance testing. These procedures will implement the technical specification testing requirements at 3300 KW, and provide for a control band during testing of 3300 + 100 KW. Minor revisions have been, or will be, made to operating procedures for the service water, core spray and re-sidual heat removal / low pressure coolant injection systems.

These revisions provide caution and action statements for these systems to ensure that the qualified load is not exceeded.

Thus, during all phases of operation except surveil-lance testing at the qualified load, operation of the diesel generators is limited to 3300 KW, only during surveillance testing will operation be conducted at 3300 1 100 KW. This 1 100 KW operating band is necessary because it is not practical to maintain a perfectly constant load throughout a test. This will not adversely affect the diesel generators given the length of the testing and the width of the control band.

22. What training vill be provided to the operators to en'sure that the qualified load of 3300 KW is not exceeded?

A. (Notaro) The procedures just discussed will be placed on the required reading list for senior reactor opera-tors and reactor operators. Beginning February 1, 1985, training on these procedures will be formally implemented through lesson plans. All licensed operators will receive this training.

23. How does the operator monitor load on the diesel generators to ensure it does not exceed 3300 KW?

A. (Notaro, Youngling) A diesel generator load meter, reading 0 to 5600 KW, is provided for each EDG on the main con-trol board in the control room. These meters are easily acces-sible to the operators.

24. What is the accuracy of the diesel generr. tor load meters?

A. (Youngling) Each diesel generator load meter is a Weston vattmeter which has a specified measurement accuracy of 2% of full scale. Each meter is used in an instrument loop with other components such that the entire loop has an accuracy of 2ht of full scale. Therefore, each load meter can measure the kilowatt load on the diesel generator to an accuracy of i 140 KW. This would be the maximum error that could be intro-duced by an in-calibration instrument. In fact, the instru-ments currently installed have been measured to perform with a higher degree of accuracy. For example, the wattmeter for EDG-103 has been. checked for calibration four times since October 1982. In all four calibration checks, only one data point, the maximum scale reading of 5600 KW during the October 1982 check, was found to be out of calibration, and then by only a very slight amount. In the range of operation corre-sponding to the 3300 KW qualified load, these last four calibration checks have shown the instrument to be well within tolerance. The largest deviations observed at 3000 KW or 4000 KW indicated have been approximately 1 100 KW. Significantly, however, in the calibrations performed just prior to and fol-lowing the endurance run, the instrument was found to be within

60-70 KW (1-1.25% of full scale) at 3000 KW and 4000 KW indi-cated.

25. What steps does LILCO take to ensure that the accu-racy of the load meters is maintained?

A. (Youngling, Notaro) As part of the Shoreham instru-ment calibration program, the diesel generator load meters and their associated instrument loops are required to be calibrated annually. This calibration is performed in accordance with ap-proved station calibration procedures.

26. What assurance is there that the loads on the diesel generators will not exceed the qualified load as a result of diesel generator load meter instrument error?

A. (All) A LOOP /LOCA event results in the maximum au-tomatic demand on the diesel generators and is therefore the event considered in establishing the MESL for each diesel gen-era, tor. Upon receipt of a LOOP /LOCA signal, the plant response is automatic. There is no initial operator action based on readings from these instruments other than verification that loads do not exceed 3300 KW on any EDG. Analysis of the loads to be accommodated during a LOOP /LOCA confirms that this auto-matic loading will not result in exceeding the qualified load.

The results of the IET provide further confidence that the

predicted loads included in the MESL for each EDG are conserva-tive. Thus, the accuracy of these instruments at the outset of the LOOP /LOCA, or the LOOP alone, has no effect on individual EDG loading.

Because the subsequent operator actions after a LOOP /LOCA event initially result in reduction of load on a die-sel generator, loads will be significantly reduced by the time the operator considers placing discretionary loads, in a proce-durally controlled manner, on the diesel generator. Although the technical specifications and plant procedures will allow loading an EDG to 3300 KW indicated, it is nevertheless unlike-ly that the operator will approach this level to within the ac-curacy of his instrumentation, and extremely unlikely that it would persist for any appreciable length of time. The load profile following a LOOP /LOCA is bounded by 3200 KW after 12 minutes into the event and by 2617 KW after one hour into the event. This profile includes expected manual loading of the diesel generator. Even if the diesel generator is loaded to 3300 KW indicated, as the testimony of Drs. Pischinger and Rau reflects, the possible additional load due to instrument accu-racy would have no adverse impact on the ability of the diesel to perform its intended function.

M

Similarly, during surveillance testing of the diesel generators at 3300 KW indicated, the actual load on a diesel generator could differ from that indicated by the amount of in-strument error. This does not invalidate the surveillance testing since the testing is representative of actual op-eration. To the extent the test load may be slightly below 3300 KW due to instrument error, the necessary load carrying capability of the EDG is adequately demonstrated because the long-term demands on the diesel are not expected to approach 3300 KW. To the extent the qualified load could be slightly exceeded during testing as a result of instrument error, the time duration of such loading is not 'long. The technical spec-ifications will require that the diesel generators be tested at this maximum load for only one hour per month. Once per 18 months, the diesel generators will be tested at this load for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. As reflected in the testimony of Drs. Pischinger and Rau, this will have no adverse effect on the ability of the diesel generators to perform their intended function. In ei-ther an operational or testing situation, the relationship of load limits to instrument accuracy is no different in the con-text of qualified load than in the context of rated load. For example, it is common practice, in performing EDG surveillance tests at design rated loads, to utilize control room instrumentation for conduct of the tests.

27. Is it possible for an operator to start additional equipment erroneously, resulting in a total load exceeding the qualified load?

A. Although it is possible, it is unlikely.

28. For each EDG, what is the single worst case load that could be started erroneously as a result of an operator error following a LOOP /LOCA?

A. (All) For EDG-101 and EDG-102, the largest load which could be manually started is a control red drive (CRD) pump with a load of 206.1 KW. This would result in loads of 3459.4 KW and 3414.8 KW on EDG-101 and EDG-102 respectively, if superimposed on each diesel generator's MESL. Significantly, the MESL itself is conservative. A more realistic assessment.

of the effect of these operator errors would be found by con-sidering the erroneously started load concurrent with the mea-sured IET loads. This would yield loads of 3039.7 KW and 3013.0 KW for EDG-101 and EDG-102 respectively. Thus, even with the operator error, it is unlikely that the qualified load would be exceeded. Moreover, the error itself is unlikely.

The CRD pumps are tripped automatically on a LOCA signal. They are not needed for the reactor scram. The CRD pumps cannot be restarted as long as a LOCA signal is present.

For EDG-103, the largest available load would be the service water pump which does not start automatically. This load of 358 KW, if superimposed on the MESL for EDG-103, would result in a total load of 3583.5 KW. In fact, however, the IET was run with the second service water pump starting automat-ically and the measured load was only 3072.0 KW, well below the qualified load. Starting of this pump is unlikely because only two service water pumps are needed to mitigate the LOOP /LOCA event. Given the procedural controls, the available indication of diesel generator load in the control room, and the fact that more than one operator is cognizant of plant conditions, there is reasonable assurance that operator action to correct-such errors would occur.in a matter of minutes.

29. For each EDG, what is the single worst case load that could be started erroneously as a result of an operator error following a LOOP?

A.- (All) For EDG-101 and EDG-102, the largest avail-able load would be a core spray pump at 998 KW. When added to the predicted automatic load for these diesels following a LOOP, the total load would be 3839.2 KW and 3627.6 KW for .

EDG-101 and EDG-102, respectively. This is an unlikely error since core spray is only required following a LOCA. Following a LOOP, reactor water level is maintained by the HPCI and/or e

RCIC systems. Moreover, the 998 KW load we have assumed f starting a core spray pump is the nameplate load at design flow. To achieve this load, in addition to the action required to start the pump, the operator would have to continue to take action to establish a flow path capable of design flow. Since the reactor remains pressurized following a LOOP, absent other equipment failures or operator actions, the only flow path available to the operator would be the test mode from the sup-pression pool returning to the suppression pool. There would be no purpose for establishing this flow path. If this flow path is not established, the core spray pump would operate in the minimum flow return mode which provides for a small amount of flow to protect the pump. With minimum flow, the core spray-pump load would be significantly less than 998 KW. Thus, it is very unlikely that total loads comparable to those stated above would be seen since multiple operator errors would be required to establish this plant configuration for which there is no need.

For EDG-103, the largest available load is the 1022 KW residual heat removal (RHR) pump which would result in a total load of 3867.3 KW. (This value is conservative because the pump load assumes runout flow which would not exist without a break in the injection path.) This error is also unlikely.

Following a LOOP, only two out of four RHR pumps are required.

EDG-103 can supply power to two of the four RHR pumps. Each of the other EDGs can provide power to one of the other two RHR pumps. The RHR pump assumed as the worst erroneous load for EDG-103 is the second RHR pump on that diesel generator's emer-gency bus. It would not be considered for operation unless both RHR pumps powered from sources other than EDG-103 were unavailable. This condition would only exist following multi-ple independent equipment failures beyond the design basis of the_ plant.

As is the case for an operator error following a LOOP /LOCA, and for the same reasons, there is reasonable assur-ance that operator action to correct these errors would occur in a matter of minutes.

30. Is the qualified load of 3300 KW adequate when oper-ator error is considered?

A. '(All) Yes. In addition to technical specificiation limits, procedural controls and operator training are used to minimize the potential for operator error. Further, the design of the plant and its automatic response to events requiring diesel generator operation greatly minimize the need for opera .

tor action during the time frame in which the diesel generators will be carrying their maximum loads. When operator action is

T initially directed, other than to verify proper operation of automatic equipment, it is to secure or reduce operating loads.

Consideration of additional loads occurs only after loads have been substantially reduced as a result of implementing the emergency response procedures.

In the unlikely event an operator erroneously added a worst case load to an EDG coincident with maximum intended demand, the design ratings of the EDG would not be exceeded.

Testing and analysis of the diesel generators have demonstrated the ability of these units to carry these loads without tripping or, as shown by the testimony of Dr. Pischinger and Dr. Rau, without adversely affecting the ability of the engines to reliably perform their function. Such an error would be of short duration. Diesel generator load is clearly indicated in the main control room. By procedure, the operator is trained and required to verify diesel generator loading does not to ex-ceed 3300 KW. Such an error would therefore be easily recog-nizable and promptly corrected.

Operator error affecting a diesel generator is not made more likely by the potential duration of a post-LOCA re-covery period. The necessary electrical loads in the plant de-crease substantially a short time following a LOCA. Thus, there is more capacity available on the EDGs to accept

l additional loads. Moreover, the diesel generators are only used so long as off-site power is unavailable. In the low power licensing proceeding, offsite power has been shown to be reliable, and restoration time following its loss is short.

Lono Island Lichtina Co. (Shoreham Nuclear Generating Plant, i

Unit 1), LBP-84-45, slip. op. at 40-46 and 82-83 (October 29, 1984). Thus, the diesel generators would be in use, if at all, for only a small portion of the potentially longer post-LOCA recovery time.

Even if an operator error resulting in loading greater than 3300 KW on an EDG were assumed to cause failure of that EDG, that failure would be within the design basis of the plant. There is no single operator error which can simulta-neously increase the load on two or more diesel generators.

The IET has demonstrated the independence between the various power sources and their associated load groups. Shoreham has three independent diesel generators, any two of which provide sufficient capacity to ensure safety'for any design basis event. The loss of more than one EDG due to operator error, or other failure mechanism, can be postulated only if multiple, independent failures are assumed. No such assumption is re-quired by NRC regulations. In implementing the single failure criterion embodied in 10 CFR Part 50, Appendix A, an operator error constitutes a single failure.

For all of these reasons, the potential for operator error does not call into question the adequacy of the 3300 KW qualified load.

31. What assurance is there that the allowed operating  ;

band of 3300 1 100 KW did not result in an inadequate con-firmatory test run?

A. (All) The confirmatory test to accumulate 10 7 load-ing cycles at or above 3300 KW on EDG 103 was comprised of two parts. First, the number of hours of operation accumulated at or above 3300 KW on EDG-103 (221 hours0.00256 days <br />0.0614 hours <br />3.654101e-4 weeks <br />8.40905e-5 months <br />) prior to the decision to establish a qualified load was determined. Then, the re--

maining required hours were accumulated during an endurance run conducted solely for this purpose. This endurance run was con-ducted for 525 hours0.00608 days <br />0.146 hours <br />8.680556e-4 weeks <br />1.997625e-4 months <br />, and it was during this test that an op-erating band of 3300 1 100 KW was established.

The 525 hour0.00608 days <br />0.146 hours <br />8.680556e-4 weeks <br />1.997625e-4 months <br /> endurance run was conducted under oper-ator control to maintain a load of 3300 KW 1 100 KW on EDG-103.

Readings were taken of the EDG-103 KW output every 30 minutes.

-Of the 525 hours0.00608 days <br />0.146 hours <br />8.680556e-4 weeks <br />1.997625e-4 months <br />, only 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> were recorded at loads below 3300 KW.- No load was recorded below 3250 KW. 81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br /> were recorded at loads above 3300 KW, with no load above 3400 KW.

This shows that only a short amount of time during the endur-ance run-was at loads below 3300 KW. More operation occurred at

l l

loads greater than 3300 KW than below it. As the testimony of Drs. Pischinger and Rau shows, this test, when combined with previous testing at or above 3300 KW, adequately demonstrates  !

l 10 7 loading cycles at the qualified load. Thus, the allowed j EDG load control band did not affect the adequacy of the con-firmatory test to demonstrate reliable operation at 3300 KW.

32. What assurance is there that the diesel generator load meter accuracy was adequate for purposes of the endurance run?

A. (All) We have previously testified to the accuracy of the EDG-103 load meter. The EDG-103 load meter was cali-brated on October 1, 1984, one week prior to the commencement of the EDG-103 endurance run, and calibration was rechecked January 4, 1985. It was found,'in the range of 3300 KW indi-cated, to be accurate to 1 60 to 70 KW during each of these calibration checks.

With respect to the instrumentation, the diesel gen-erator generator was operated during testing, just as it will be operated in the future. Thus, the test was representative of operating conditions and demonstrates that when run at an indicated load of 3300 KW, the diesel will operate reliably.

The qualified load of 3300 KW, as indicated during the test, is the same indicated load to which the diesel will be limited in

operation by technical specifications and procedures. Even if the actual load represented by that indicated load is slightly different, it is of no significance because the addition of manual loads will be procedurally restricted by the total load as indicated on the load meter, while the automatically con-nected loads, as demonstrated by the IET, will be well below the qualified load indicated during testing.

L

i ATTACIBfENT A

ATTACHMENT A JACK A. NOTARO Outage and Modifications Manager Lono Island Lichtino company Assigned as Outage and Modifications Manager in May 1984. Re-sponsible for the implementation of design changes to plant systems or equipment as required by the regulatory agencies or for plant operational / reliability considerations. Specific du-ties include supervision of the Planning and Scheduling, Modi-fication Engineering and Outage Planning sections to maximize station availability and to optimize the size of the modifica-tion related work forces.

Graduated from City College of New York in 1970 with a Bache-lors Degree in Mechanical Engineering. Received a Masters of Business Administration Degree in 1974 from Adelphi University.

Completed the General Electric Co. Boiling Water Reactor Si-mulator Program in July 1976, and obtained certification as a Senior Reactor Operator.

Obtained NRC Senior Reactor Operator License # SOP-4419 for Shoreham November 1982.

Completed the following industry seminars and training pro-grams:

(a) BWR Design Orientation - General Electric Co.

(b) BWR Technology - General Electric Co.

(c) Nuclear Power Plant Technology - General Physics Corp.

(d) BWR Observation Training - General Electric Co.

. (e) Degraded Core Conditions - General Electric Co.

(f) Refueling Activities - General Electric Co.

(g) Radiation Protection ~- LILCO Evening Institute (h) Basic Applied Health Physics - Brookhaven National Laboratory (i) Vibration Analysis 'IRD Mechanalysis, Inc.

(j) Statics, Strength of Materials & Dynamics - LILCO Evening Institute

I l

(k) Management of Maintenance Storekeeping & Inventories

- Management Dynamics Institute (1) QA for the Nuclear Industry - Stat-A-Matrix and Gen-eral Physics Corp.

(m) Inservice Inspection and QA During Operations -

Southwest Research Institute (b) Basic Radiography - Corvair Division of General Dy-namics (o) Magnetic Particle & Liquid Penetrant Testing - Mag-naflux Corp.

(p) Basic Ultrasonics - Automation Industries (q) Nuclear Power QA - Long Island Section of AQSC

'(r) Inservice Inspection Symposium - Mirror Insulation (s) Operations Quality Assurance - Stat-A-Matrix (t) Reactor Research Training - Brookhaven National Lab-oratory 1983 - 1984 I

Assigned as the Shoreham Chief Operating Engineer in April 1983. Responsibilities include the formulation and imple-mentation.of the training programs for all Station personnel; development and review of'the Operations, Training and Security Sections of the Station Operating Manual; and the overall man-

.agement of the Operati ons, Training and Security Sections of the Station.'

1978 --1983 l Assigned as Operating Engineer of the Shoreham Nuclear Power Station in July 1978. ' Responsible for the development and im-plementation of the Station's operational activities including the direction.of day-to-day operation of the unit; startup, op-eration and shutdown of all station equipment; implementation of initial, requalification and replacement training programs

'for licensed and unlicensed operators; the development, review and implementation of-the Operations Section of the Station Op-

-erating Manual.

/

l June 1981 - Auoust 1981 l Assigned to the Operations Section of the Millstone Nuclear Power Station. The scope of this assignment included power op-eration training at greater than 20% power. The assignment en-compassed three months of actual hands-on experience in a two-month calendar period.

Participated in weekly and monthly routine BOP and NSSS system surveillance testing. Participated in high risk I&C Operations equipment and system surveillance testing. Witnessed TIP traces and conducted heat balances, core flow calculations were conducted with and without main computer available. Partici-pated in power downs from 100% power to complete control rod repositioning and repairs to main condenser cross-over valving.

Assisted in maintaining power at less than 25%, as required by Tech Specs, as a result of main computer problems. Witnessed implementation of emergency notification procedures.

Manipulated controls for power downs, return to power, Tech Spec LCO's, control rod repositioning, and stuck control rod surveillance-testing. Witnessed and participated in half scram and full scram recoveries, subsequent investigations, evalua-tions and notifications.

In addition to the above, attended daily Plant Manager's Unit and Unit Superintendent's meetings, Operations Department meet-

ings, Plant Operations Review Committee meetings, shift staffing, planning and scheduling evaluations.

March 1981 - May 1981 Assigned to the Operations Section of the Millstone Nuclear Power Station for the completion of the Unit'l refueling out-age. The scope of this assignment included refueling, cold shutdown to greater than 20% power, and greater than 20% power E to. cold shutdown. The assignment encompassed three months of actual hands-on experience in a two-month calendar period.

Participated in all significant pre and post refueling outage surveillance testing and inspections. Actively-took part in refuel bridge operations including control rod removal and re-

-placement,' channeled and dechanneled fuel movements, core.in-

~

spections and verifications, dropped fuel bundle evaluations and recovery. Assisted in the evaluations and calibrations re-sulting from abnormal nuclear instrumentation indications.

Participated in integrated leakfrate testing, primary system

hydrostatic pressure testing and dryvell inspections, assessed system status and return to normal. Conducted portions of pre-criticality testing including control rod functional, subcritical checks and friction testing. Actively took part in returning the unit to survive from cold shutdown to greater than 20% power including manipulation of controls during plant heat-up.

In addition to the above, participated in daily outage coordination meetings, Operation Department staff meetings, Plant Operations Review Committee meetings, shift staffing and scheduling evaluations.

April 1979 - May 1979 Completed the 160 hour0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> General Electric Company Observation Training Program at Commonwealth Edison Company's Dresden Nu-clear Power Station. Modification of the standard observation training program was effected in this instance including direct assignment to Dresden Operations and Clearance for unescorted access.

Dresden Unit 2 was returning from a refueling outage and Unit 3 was returning from a forced outage to replace the main trans-former during this training assignment.

On Unit 2, observed significant pre and post refueling outage surveillance testing. Witnessed integrated leak rate testing.

Participated in the primary system hydrostatic pressure test and drywell inspections. Observed preparations for an accom-plishment of approach to criticality, plant heat-up, transfer

to run, placing the main turbine in service and power op-eration. Witnessed half and full scram recoveries. Manipu-lated controls to reduce power from 700 MW to 200 MW in prepa-ration for stator cooling system filter replacement.

August 1978 Assigned to the Vermont Yankee Nuclear Power Station to observe startup of the unit following a refueling outage. Witnessed the completion of the integrated leak rate test. Witnessed the primary system hydrostatic pressure test and took part in the drywell inspection. Observed preparations for and accomplish-ment of approach to criticality, plant heat-up and transfer to run. Witnessed half scram recovery during plant heat-up.

March 1973 - July 1978 Assigned to the Shoreham Nuclear Power Station in the Quality Assurance Section and subsequently promoted to Station Op-erating Quality Assurance Engineer responsible for the Section in July 1974.

Responsibility included initial development of the operational quality assurance program. Responsible for all aspects associ-ated with its implementation at the station including reviews, audits, surveillance, inspections, selection and training of personnel, development of procedures and instructions, and the utilization of consultants and contractors. Additional responsibilities included licensing and inspection activities associated with the U.S. Nuclear Regulatory Commission and interfacing with external and internal organizations required to implement the operational quality assurance program.

1970 - 1972 Assigned to the Maintenance Section in the Northpower Power Station. Assigned duties included assisting in outages of both a scheduled and forced nature as well as maintaining plant equipment and systems, and completing special projects.

Member of the American Society for Quality Control. Member, Edison Electric Institute - Quality Assurance Task Force (EEI-QATF) and the EEI-QATF Operations Subcommittee.

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