ML20113C440

Forwards Response to NRC 841031 Questions Re Amend 14 to Fsar.Info Will Be Incorporated Into Amend 15 to FSAR

ML20113C440
Person / Time
Site:	Perry
Issue date:	01/14/1985
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8501220324
Download: ML20113C440 (15)

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P.O. box 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING DLDG - 55 PUBLICSoUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE NtESIDENT NUCMAR January 14, 1985 PY-CEI/NRR-0161 L Mr. B. J. Youngblood, Chief Licensing Branch No. I Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to Additional Staf f Questions Pertaining to FSAR Amendment 14

Dear Mr. Youngblood:

This letter and its attachments are provided in response to your staff's questions (dated October 31, 1984) pertaining to FSAR Amendment 14 for the Perry Nuclear Power Plant (Units I and 2).

These responses are relative to changes and additions made to Chapter 13 of the FSAR.

The information provided in the attachments has been incorporated into FSAR Amendment 15.

If you have any questions, please feel free to call me.

Very truly yours, ydhs Murray R. Edelman Vice President Nuclear Group MRE:nje Attachments cc: Jay Silberg, Esq.

John Stefano (2)

J. Grobe

,i1f10l 8501220324 850114

),V i 1 PER ADOCK 05000440 i

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QUESTION 1.

Figure 13.1-3 shows seven positions entitled " shift supervisor training coordinator fire / safety," under the Supervisor of Security. What are the responsiblities of these positions? How will they interact with the Perry Training Section reporting directly to the Nuclear Operations Division, Vice President?

RESPONSE

The Security Unit is currently in the process of reorganization into the Nuclear Support Services Unit. The Unit, under the direction of the Security Supervisor will have five distinct operating activities headed by the following management personnel:

1.

The Security Operations Supervisor, responsible for ensuring that all uniformed security functions are performed to standards established in the Perry Physical Security Plan and the Perry Training and Qualification Plan.

2.

The Access Authorization Coordinator responsible for implementing the Perry Access Authorization Plan and for approving and auditing contractor and vendor Access Authorization Plans.

3.

The Security and Fire Systems Supervisor, responsible for ensuring that all required functional testing on the fire and security systems are completed and documented.

4.

The Security Training Coordinator, responsible for preparation and implementation of the Security Training Program according to standards established in the Perry Physical Security Plan and the Perry Training and Qualification Plan.

5.

The Fire Protection Cocrdinator, responsible for fire brigade training, fire inspections of plant faciltiies, conducting drills and practices and maintaining liason with local fire departments.

The Security training activity will interface with the Perry Training Section in terms of shared resources and expertise input. While our security instructors are security - intensive, training of security personnel in such areas as General Employee Training, BWR operations, radiological controls, respirator protection, etc. will be handled by the Perry Training Section. Assistance in the development of lesson plans, use of training equipment and facilities will also be provided by the Perry Training Section. Security-specific training records will be maintained by the Security Training Coordinator.

Under a reorganization effective October 1, both the Security Supervisor and the Perry Training Section General Supervisor will report to the Perry Plant Technical Department Manager. These changes in reporting relationships and responsibilities are shown in the attached Figure 13.1-4 and have been reflected in Amendment 15 to the FSAR.

9 QUESTION 2.

Figure 13.1-3 does not show any shift technical advisor positions.

Why have these positions been deleted from the plant's organization chart?

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RESPONSE

The position of Shif t Technical Advisor (STA) is not a defined CEI job title. Our intention is to assign qualified Technical Section personnel in the Operations Engineer job series to function as STA's.

The requirement to have STA's will be covered in the Perry Technical Specifications and plant procedures.

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QUESTION 3.

Table 13.1-3 does not provide sufficient qualifications information on operating crew members to ascertain compliance with Generic Letter 84-16.

Will this information be provided?

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RESPONSE

Two of the six required shift supervisors (resumes #32 and #35) have previous licensed operator experience and meet the requirements of Generic Letter 84-16.

There are presently four Associate Operations Engineers who will function as STA's and will fulfill the shift.

experience requirements of Generic Letter 84-16.

They have recently completed assignments of approximately one year on shift assisting in the startup testing phase at the Susquehanna Nuclear Station. These STA's are expected to be SRO licensed at fuel load and will meet the requirements of Generic Letter 84-16 based on the Susquehanna startup i

experience. Their resumes will be included in a future FSAR amendment.

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QUESTION 4.

Table 13.1-3 provides qualification information on three Supervisors, Chemistry Unit. However, Figure 13.1-3 shows that only two Supervisors, Chemistry Unit, will be required for Unit I and 2 operations. Which is correct?

RESPONSE

Figure 13.1-3 reflects minimum rather than maximum manning levels for the Perry Plant Organization. As indicated in resume #40, one of the Supervisors, Chemistry Unit, is currently on rotation to the Perry Training Section to develop chemistry training courses and serve as instructor.

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QUESTION 5.

Table 13.1-3 does not provide qualification information for Supervising Operators (RO) or Shift Technical Advisors (STA).

Will this information be provided?

RESPONSE

We currently have a number of people in the licensed training program.

-Those who will fill the Supervising Operator (RO) position will depend on the results of that licensing effort scheduled for mid 1985.

However, they will meet the requirements of ANSI /ANS 3.1-1978 and Generic Letter 84-16.

For STA information, see response to Question #3.

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QUESTION 6.

Table 13.1-1 shows Operation Engineers are equivalent to Professional-Technical, Instrumentation and Control. Figure 13.1-3 shows Operation Engineers being used in three different areas of plant operations: -Technical, Operations and Maintenance.

Are all of the Operations Engineers in these three areas to be considered under Instrumentatian and Control Requirements?

RESPONSE

'Not all of the Operations Engineers in the three areas are to be

. considered under Instrumentation and Control Requirements. At the Perry Plant, " Operations Engineer" is a generic job title reflecting the CEI engineer job series referenced in the response to question 2.

Personnel who occupy engineering positions (requiring a Bachelors Degree in Engineering or the Physical Sciences) in the Technical, Operations or Maintenance Sections of the plant organization will have capabilities in the specific areas assigned. Table 13.1-1 has beenF revised in FSAR Amendment 15 as shown in the attached.

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QUESTION 7.

Table 13.1-3 provides a resume (#56) for a Senior Nuclear Engineer in the Operations Section. Figure 13.1-3 does not show a Senior Nuclear Engineer position. Is this resume for an Operations Engineer in the Operations Section? If not, what position is it for?

RESPONSE

The resume for Senior Nuclear Engineer is for an Operations Engineer in the Operations Section. The Senior Nuclear Engineer was not considered a minimum required position in the Operations Section and, therefore, not reflected in Figure 13.1-3.

However, assigning the Senior Nuclear Engineer to the Operations Section has facilitated reporting requirements during the procedure / instruction / technical specification development effort.

It has also provided the necessary supervisory backup support to the Operations Section General Supervisor during license training and experience training assignments.

QUESTION 8.

Figure 13.1-2 shows Superintendent, Test, reporting directly to Nuclear Operations Divison, Vice President. Section 13.1.1.1.2.2, paragraph 5, indicates that the Start-up Test Organization reports to the GSE, Technical Section. Are these two organizations different? If so, what are their various responsibilities associated with starr-up testing?

RESPONSE

The Nuclear Test and Start-up Test organizations are different as discussed in the attached revised Section 13.1.1.1.2.2.

The Nuclear Test Section is only responsible for initial preoperational and acceptance testing of systems and subsystems turned over from construction. The Start-up Test Program commences with fuel load and will be the responsibility of the GSE, Technical Section.

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QUESTION 9.

Table 13.1-3, resume #8 states that the Nuclear Test Section is in the Nuclear Engineering Department. Figure 13.1-2 shows the Nuclear Test Section under the Superintendent, Test, presently being directed be the Superintendent, Plant Operations. Which is correct?

RESPONSE

Resume #8 of Table 13.1-3 is no longer correct. A reorganization ef fective Octobqr 1,1984 divided the existing Perry Plant Department into two departments: the Perry Plant Operations Department and the Perry Plant Technical Department. This new organizational structure, shown in the attached revised Figure 13.1-2, brings the responsiblity for the Nuclear Test Section activities under the Perry Plant Operations Department. The position of Superintendent, Test, is no longer reflected on the organization charts. A revised resume #23 (formerly resume #8) is also attached.

All changes in reporting relationships and responsibilities resulting from the reorganization have been reflected in Amendment 15 to the Perry FSAR.

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TABLE 13.1-1 PNPP STAFF TITLES AND ANSI /ANS 3.1 - 1978 EQUIVALENT PNPP Position or Title ANSI /ANS 3.1 - 1978 Equivalent Plant Manager Plant Manager Superintendent, Plant Operations Plant Manager Alternate General Supervisor, Operations Section Operations Manager General Supervisor, Maintenance Section Maintenance Manager General Supervising Engineer, Technical Manager Technical-Section General Supervising Engineer, Professional-Technical Radiation Protection Section Radiation Protection Chemistry and Radiochemistry Plant Health Physicist (RPM)

Professional-Technical Radiation Protection Supervisor, Health Physics Professional-Technical Radiation Protection

-Supervisor, Chemistry Professional-Technical Chemistry and Radiochemistry Reactor Engineer Professional-Technical Reactor Engineering Operations Engineers Professional-Technical Operations, Maintenance, Instru-mentation & Control Shift Supervisor Supervisor requiring NRC License Unit Supervisor Supervisor requiring NRC License Supervising Operators Operator 13.1-21 Am. 10 (11/29/82) t

13.1.1.1.2 Preoperational Activities 13.1.1.1.2.1 Development of Human Engineering Design Objectives and Design Phase Review of Proposed Control Room Layouts.

The design and layout of the Perry Control Room was developed by CEI/CAI after much consideration of such factors as space, layout, access, color, lighting, audio vs. visual alarms, viewing angles and instrumentation labeling. Also, the BWR Owners Group Survey Team conducted a survey in September, 1981 to identify any human factor design deficiencies in the plant panels. CEI is utilizing the Survey Report to identify those deficiencies requiring improvement.

The Nuclear Engineering Department will be responsible for implementing all corrections and improvements.

13.1.1.1.2.2 Development and Implementation of Staff Recruiting and Training Program 7

l lThe Nuclear Test Section of the Perry Plant Operations Department has been assigned the responsibility for preoperational and acceptance testing of systems turned over from construction. The Test Section has developed procedures detailing the methods and requirements for indoct'inating, training and r

certifying test personnel. These procedures are incorporated in the Nuclear Test Section's Administrative Procedure matrix and are separate from the Training Program developed for the PNPP operating organization and described in Section 13.2 of this FSAR.

Recruiting of qualified personnel for staffing the Nuclear Test Section has been accomplished with a combination of CEI and consultant personnel. Selection of operating personnel is in process with attention directed toward manning with a combination of qualified employees from within CEI and outside hires, particularly from among those with previous nuclear experience.

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t TABLE 13.1-3 (Continued) l RESUME No. 23

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Name:

Barry L. Barkley, General Supervising Engineer, Nuclear Test Section Formal Education and Training:

. B.S. Education (Physics), Indiana University of Pennsylvania, 1964 j

Graduate Physics (1 year) University of Maryland,1965 M.S. Nuclear Engineering, Catholic University of America, 1967 f

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Experience:

1975 - Present:

The Cleveland Electric Illuminating Company i

Joined CEI in 1975 as Operations Engineer in the Perry Plant Depart-ment and later appointed Senior Staf f Engineer responsible for design and specification review for plant operability and initial work on the Plant Operations Ihnual.

In 1979, was named to General Supervising Engineer Nuclear Design and Analysis Section in the Nuclear Engineering Department and was-responsible for the design engineering of the Perry Plant.

i In 1982, was named to present position of General Supervising Engineer,.

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Nuclear. Test Section and is responsible for the. initial check-out and run-in, acceptance testing, and preoperational testing of the Perry Plant. Reports to the Ihnager, Perry Plant Operations Department.

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'1970 - 1975:

General Electric Company As Start-Up Test Design and Analysis (STD&A) Engineer conducted start-up testing of GE-BWR's at Fukushima- (Japan) and KKM (Switzer-land) and as Lead STD&A Engineer organized and coordinated the sta'rt-up testing of the Fitzpatrick nuclear plant and performed l

supervisory dutie.s for CE test personnel on the plant site.

.1968 1969:

U.S. Army Served as Nuclear Ueapons Project Of ficer for the U.S. Army Material

. Command.

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