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NUCLEAR REGULATORY COMMisstCN REGION n Mf. I 101 MARIETTA STREET.N.W.
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ATLANTA.GECRGIA 30303 j
s L3 739 l'EMORANDUM T0:
John A. Olshinski, Director Engineering and Operational Programs THRU:
Albert F. Gibson, Chief Operational Program Branch FR0!!:
Bruce A. Wilson, Chief Operator Licensing Section
SUBJECT:
AUDIT OF GRAND GULF SHIFT ADVISOR On February 23,198a, I observed memoers of the Grano Gulf staff acminister a board evaluation of a Shift Advisor who was amployed by tne Quadrex Corporaticr.
Ity reason for observing this evaluation was to gain first hand knowleage of tne retnod used by the MP&L Operator Training Evaluation Comittee (OTEC) in racertifying the competence of licensed personnel.
Since I die not have an opportunity to observe the recertification boards of licensed personnel anc tne procedures of botn boards were similar, I chose to take advantage of this opoor-tuni ty.
(' de Operations Training Supervisor, (SRO licensec); and the Tec
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e board was comprised of three membeps*
the Assistant Plant Manager-Suoport; to the Assistant Plant Manager-0perationr, (previously SR0 licenseci Orascen).
The board first reviewed the Advisor's background and experience records (without the Advisor present) to insure that he me't the minimum criteria imposed by MP'.L.
As explained to me, tnese criteria included:
3 years licensed experience at an coerating SWR 1 year SRG exoerience in a supervisory capacity They also reviewed records of training courses in which ali acvisors were raquirec to achieve an average grade of 80* on written examinations.
i Following tnis review, the Advisor was callec before the bcarc for a pericd of technical cuestioning whien lasted approximately li hours.
Ne Acvisor was inforcea that the nature of the questioning was to be "bruad :icture' ratner tnan olant scecifics.
The cuestioning was generally performec by one : card remoer at a time althougn other memoers were allowed to interruct for c'arificatter cr more in-ceptn incuiries as tney relt necessary.
The questioning covered a multitude of areas including systems, thecry, amer:ercy orocadures, tecnnical specifications anc radiolegical centrols.
n accition, several trans ien t scenarios were postulatec for tne Acvisor to evcluate.
In
'eral, I felt t.he tyce of cuestions were tecnnically acequate are de*anding.
bearc memoers tended to orcos soecific areas witn increastogly raccer cun-nons tc evaluate,tM Acvisor's extent of kncwledge.
Jchn A. 01shinski 2
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intent was to evaluate the board and not the canoidate, thus I kept nc notes scncerning the acequacy of his answers.
My recollection i s tr.a t overail r.is responses were very good with minor ceficiencies t'cted in several areas.
Althougn tne Advisor was questioned on at least three systems (ADS, ECCS, and Suppression Pool), the breadtt, or cepth of systems questioning was not equivalent to what a licerised candicate would have been askea.
The line cf questionir.g was consistent with what the Advisor was informed it would be at the beginning of the evaluation.
Also, the questions were often directed at him as an Advisor, e.g.,
what woulo be his recommendations to the shift supervisor and his course of
. action if the Supervisor chose not to follow his recommencations.
Following the questioning period, the board memoers discussed their findings in the absence of the advisor.
He was then recalled before the boacc where ne was informed of their positive results including a critique of his oral per#ormance.
Overall, I found the OTEC evaluation of the Shift Advisor to be cone in a comoetent anc conscientious manner.
All memoers were professitcal in tneir conduct of tne evaluation and cancid with me in the analysis of the Adviscr's performance and abilities.
I believe that MP&L's process of certifying tne Shif.
Aavisors is entirely adequate to ensus the Aavisors are capatie of fulfilifeg their intendeo function.
.W truce A. Wilson 4
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ATLANTA. GECICIA 303C3 e
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Mississippi Power and Light Company ATTh:
Mr. J. B. Richard Senior Vice President, Nuclear P. O. Box 1640 Jackson, MS 39205 Gentlemen:
SUBJECT:
REPORT NO.
50-416/84-12 On April 9 - April 13,1984, NRC inspected activities authorized by NRC License No. NPF-13 for your Grand Gulf facility.
At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.
Areas examined during the inspection are identified in the report.
Within these areas, the inspection consisted of ' selective examinations of procedures and representative records, interviews with personnel, anc observation of activiti" in progress.
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-'! thin the scope of the inspection,~.~no_ violations or deviations were identifiec In accordance with 10 CFR 2.790(a), a copy of this letter and tthe enclosure:
will be placed in NRC's Public Document P.ocm unless you notify this office by telephone within ten days of the date.of 'his letter and subrit written applits-c tion to withhold information contained therein within 30 days of the date cf the letter.
Such application must be consistent with the recuirements of 2.790(b)(1).
Should you have any questions concerning tMs letter, please contact us.
4 Sincerely,
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errelli, Crie'
- eactor rejects Branen dhr *i Division of Reactor Projects
Enclosure:
Inspection Reper No. 50 416/84-12 cc w/ encl:
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, E. Cross, Plsnt Manager
.alph T. Lally, Manager of Quality Micele South Seavices, Inc.
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A.DR 25 1964 Report No.:
50-416/84-12 Licensee:
Mississippi Power and Light Company Jackson, MS 39205 Docket No.:
50-416 License flo.:
NPF-13 Facility Name:
Grand Gulf Inspection at G a
'I site near Port Gibson, Mississippi I
Atw 2 3 @ A E' I Inspectors:
in g.,,D.Falcc fV Cate 11gnec 3 3 d[/2 b f 1%
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I Date Signec
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%lN 2'3 d[N 8Y N.
H. Krug, Acting 5ec:1.pACChief t Date 5tgnec Operational Programs Section~
Division of Reactor Safety-
SUMMARY
Inspection en April 9 - April 13,1964 Areas Inspected This routine, unannounced inspection involved 50 inspector-hours on site in t.5e area of the shif t advisor program.
Results in the area inspected, no violations or deviations were identified, ggs;43'Y w
7 REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. Cross, Plant Manager
- R. Rogers, Assistant Plant Manager
- L. Robertson, Operations Superintendent 4
- R.
Fron, Technical Assistant G. Lhamon, Operations Training Supervisor
- J. Bailey, Compliance Coordinator T. Mayfield, Simulator Instructor Other licensee employees contacted included shif t advisors, shift super-intendents, shift supervisors, and shift operators.
NRC Resident Inspector
- A. G. Wagner
' Attended exit interview on April fi,1984 (c'
) # Attended exit interview on Aprtt 11,.1984
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2.
Exit Interview The inspection scope and findings were sumarized on April 11, 1984 anc April 13,1984, with those persons indicated in paragraph 1 above.
The licensee ackncwledged the inspection findings.
3.
Licensee Action on Previous Enforcement Matters l
Not inspected.
4 Unresolved Items Unresolved items were not identified during this inscec:1on.
5.
Shif t Advisor Program Grand Gule linit 1, License NpF-13 condition 2.C.37 recuires that "at least one individual on each coerating shif t have substantive previous SW:
c;erating excerience, including startup and shutdown of a EkR and unce-coneitions that one might excect to encounter during the initial startu: 3rc power escalation at the Granc Gulf plant."
The recuirwent furthea states I
that the individual need not be licensed on the Grand Gulf ur4: and neec.:t be a licensee employee anc that the individual shall remair in : lace.rtt' the plant achieves and demenstrates full gewer cperation.
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2 To meet this requirement, the licensee has contracted personnel with V
previous BWR experience, trained them in Grand Gulf plant specifics and designated them as shift advisors.
Currently, five shif t advisors have been certified.
Procram Comoliance By letter -to the Office of Nuclear Regulatory Regulation (NRR) dated March 30,1984, the licensee provided information concerning shif t advisor certification, training and experience used to ensure that the requirements of license condition 2.C.37 have been met.
As stated, shif t advisors were required to have had at least three years of licensed operator experience with a minimum of one year of Senior Reactor Operator (SRO) experience.
Also, in addition to General Employee Training (GET) and Radiation Worker Training, shift advisors were required to successfully complete the following training program:
'One day of Emergency Assessment and Preparedness training.
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a.
b.
Three weeks of self study systems training designed to place an emchasis on Grand Gulf safety systems and the differences betweer a BWR 4 and SWR-6.
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c.
Seven days of shift advisor training covering the simulator, admints-trative procedures, technic _al specifications and mitigation of core damage.
d.
Two weeks of hands-on simulator training devoted to the areas of power ascension procedures and identification of, response to anc recovery f rom plant transients.
Finally, shift advisors were recuired to undergo an evaluation anc cral examination by the Operator Training Evaluation Cermittee (OTEC).
The OTEC evaluation consisted of exterience verification and training histor;.
review.
Deficient areas were identified and retested by written examina-tion.
The conclusion of the evaluation consisted of an oral examinatier by the committee to certify shif t aevisor cualification.
The inspector verified during the review of OTEC evaluation cocurer,ts and shift advisor resumes that the five shif t acvisors met the minimum exoerience requirements.
The insoector reviewed training records and comoieted examinations te ve-f e,
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that the five shif t advisors had succesfully comcleted the shif t acvisc-training program as described in tne Maren-30, 1984 letter.
The ins:e:::-
icentified one shi't advisor whe had not cce:1etec the desc-ibed tes'-i-:
prograr.
The inspector determined that for the pcrtion cf the shi't ac.'s':-
training not accomplished, the shift advisor had receivec ecuiva'er:
training as an instructor with the Grand Gulf training center.
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3 Furthermore, the inspector verified that each shif t advisor had successfully completec an OTEC evaluation and oral examination.
Within the area inspected no violations or deviations were identified.
Procram Evaluation The inspector performed an evaluation of the licensee's program for training of shift advisors and the methods which the licensee used to examine these advisors and determine the adequacy of their training and experience.
The specific job description for shift advisors was delineated in the licensee letter to NRP. dated February 20, 1984 The training given shift advisor:
and a description of the methods used to examine shif t advisors are containec in the licensee's March 30, 1984 letter.
During the conduct of this evalua-tion, the inspector reviewed training documentation and conductec interviews with plant management, shift aovisors, operating anc training personnel.
Baseo on these record reviews and interviews, the inspector determined that, considering the experience levels of the designated shift advisors, the training proviced appears adequate to support the envisionec advisory role.
A review of the licensee's program for maintairing the proficier.cy o' sh-advisors throughout the commitment period icentifiec the following poten;.al program deficiencies:
Shift advisors were not required to participate in tthe licensee's a.
requi red reading program.
The required reading program is the mechanism for ensuring that. licensed operators and senior operators are cogni: ant of system design changes, procedure changes and significant f acility and industry events.
Interviews with the shif t advisors determined that, although not a requirerrent, they generally reac the recuirec reading raterial.
Nevertheless, the absence of a prograr ati:
reouirement that the shift advisor participate in the recuirec reacirc program could potentially recuce their effectiveness.
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b.
Shif t advisors were not required to participate in the full "'if t" eek training" (recualifica tier training) with his assigned shif t.
~he licensee's "fif th week ' training" is periodic cperating shi't trainicc,
conducted every #if th week under current shi't rctat cr, 3rc is tre
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d licensee's vehicle for acministering the licensec ccerster recua"-
cation program.
Shift advisors were only recuirec to take tre simulator portion of this training.
Limiting tne snift advisor te eni, simulator portions of this training severely restricts the arourt a r c' scope of shift acvisor re#resher training anc could pctertia!'y rec ca their e#fectiveness.
The above 'incings were ciscussec with the licensee and en * :ri ' ' 2, *. H ',
a station re-crancum was issued to include shif t acvisors in the rec'.' e:
reacing program anc in tne fifth week rccualificatien training ;r:grar.
Within the areas inspected, no violations or cc'.iattens we e identi'ie:.
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Attechment to AECM-84/0267 e
c UTILITY ADVISOR EVALUATION TEM REPORT ON GRAND GULF NUCLEAR STATION SHIFT ADVISOR PROGRM April. 24-26, 1984
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TA8LE OF CONTENTS l
EXECUTIVE
SUMMARY
II.
08JECTIVE, SCOPE AND METHODOLOGY
!!I.
EVALUATION RESULTS 8Y SECTION A.
INTERVIEWS 8.
SHIFT 08SERVATION C.
SIMULATOR OBSERVATION 0.
RESUME REVIEW E.
ADVISOR DUTIES REVIEW F.
TRAINING LESSON PLAN REVIEW G.
EXM REVIEW H.
EVALUATION TEM RECOMMENDATIONS IV.
UTILITY ADVISOR EVALUATION' TEM MEM8ER EXPERIENCE s
V.
TEM END0RSEMENT OF REPORT 9
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EXECUTIVE
SUMMARY
Recent industry efforts have focused on identifying appropriate experience for NTOL plants as a part of a broader program to improve the managerial and technical experience of those involved in the operation of nuclear plants.
A special NTOL experience group chaired by H. B. Tucker, Vice President Nuclear -
Production, Duke Power Company, was asked by Mississippi Power & Light Company (MP&L) to assemble a team to evaluate the Grand Gulf Nuclear Station Shift Advisor Program.
l The six member Utility Advisor Evaluation Team (UAET) consisting of representatives from five major nuclear utilities, conducted a comprehensive evaluation of the Grand Gulf Advisor Program on April 24, 25 and 26,1984 l
The UAET evaluated all aspects of the program between the shift crews and the advisor, procedures and examinations.
The evaluation included documentation reviews, interviews with advisors and MP&L management and operations staff, and direct observation of shift operations and simulator instruction.
l The UAET concludes that MP&L has defined an effective Advisor program, has l
selected qualified individuals and has provided training appropriate for the l
shift advisors.
The MP&L Advisor program equals, and in may cases exceeds, the position presented to the NRC by the NTOL Utility Group on February 24, 1984.
Additionally, MP&L agreed to incorporate the UAET recomendations into their Advisor program which will further strengthen the effort.
The UAET also concludes that these advisors can rapidly anda effectively comunicate their experience to the MP&L shift crew.
It is the UAET's unanimous opinion that MP&L's Advisor program provides additional assurance that the Grand Gulf Nuclear Station can be started up and operated safely and in accordance with NRC regulatory requirements.
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OBJECTIVE. SCOPE AND METHODOLOGY o
The objective was to evaluate the effectiveness of the Grand Gulf Shift Advisor Program including the qualifications of each advisor on l
shift.
o The Scope of the evaluation consisted of a review of the following:
a)
The training provided the _ advisors, including the extent.of the training, the criteria for the training, the specific p)rocedures (administrative,
- normal, abnormal, and emergency,
Plant Technical Specifications, specific plant systems, and the scope, content, and grading of the examinations given.
b)
The standing orders and other connunications that define the specific duties and responsibilities of the Shift Advisor, the instruction provided to the shifts to ensure their understanding of the program, the advisor's functions, their limitations and access to plant management above the Shift Superintendent.
c)
The training records' ' review, observation of simulator trai.ning in-progress and observation of on-shift crews performing routine operation including shift turnovers.
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.V' including normal shift operations, shif t, turnovers, observation of o
The team divided into groups and conducted reviews of assigned areas the shift crews / advisor interface, the training program,' resumes of the individual
- advisors, interviews with most of the advisors, interviews with operations, training and plant management, and observation of simulator training in progress.
A post evaluation discussion was held with MP&L's management to*
review the team findings.
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EVALUATION RESULTS BY SECTION i
A.
INTERVIEWS i
l There were several types of interviews conducted with the MP&L Shift
- Advisors and operating staff.
These included a control room crew interview with all UAET members present, and interviews of three shift operating crews I
with two or more UAET members present.
The purpose of these interviews was threefold.
First_, to verify the adequacy of comunications relating to the duties and responsibilities of the Shift Advisor.
This verification was performed by comparing the responses obtained from the various advisors, control room RO's and SRO's to the responses obtained from plant management delineating the duties and responsibilities of these advisors.
Second, all the responses were compared to the duties and responsibilities stated in MP&L's standing orders and i
memos.
Third, to evaluate the Shift Advisors specific training needs relative to their duties and responsibilities.
This again was accomplished by comparing responses as described previously.
In sumary, the UAET members found that MP&L's advisors, shift crews and i
plant management generally agree on the function of the shif t advisor.
UAET members agree that the training provided meets or exceeds the requirements necessary to adequately function as Shift Advisors at MP&L's'. G, rand Gulf Nuclear Station.
t B.
SHIFT OBSERVATIONS l
One shif t turnover was observed by members of the UAET.
This review enabled the team to evaluate, in part, the Shif t Advisor's conformance to stated responsibilities and performance of duties.
These responsibilities and duties are defined by written standing orders and a related memo.
The advisor's turnover requirements are not described by procedure.
The advisors maintain their own special log.
They used this log and a control board walkdown to inform the oncoming advisor of significant activities accomplished during the previous shift or those in prngress.
It was stated that the Shif t Advisor attended the shif t turnover bet.seen the oncoming and offgoing Shift Superintendent.
This is an additional method for the advisor.
to maintain awareness of activities and was observed on one shift turnover.
The Shif t Advisor is norinally stationed in the main control room.
This location facilitates observation of unit status as well as communication with the Shift Supervisor and the control room operator.
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SIMULATOR OBSERVATION UAET members observed a portion of the simulator training provided the Shift Advisor.
The training provided was consistent with the training staff's course outline and objectives.
The Shift Advisor
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control room personnel in discussion of procedures and Technical Specifications and he made recommendations consistent with his position -
concerning equipment operations.
The pace of the class was appropriate for the student level of training and experience.
The program, as presented, I
represents SR0 level instruction and content.
D.
RESUME REVIEW 1
Each of the five current Shift Advisor's resumes were reviewed and the authenticity of previous NRC licenses was verified.
Verification of license l
was provided by the advisor contractor (Quadrex).
All candidates resumes indicated that they exceeded the industry requirements proposed for the Shift Advisor position.
In addition to the resume review and license verification, four of the five candidates were personally interviewed. Additional information about the advisor usefulness and their experience was obtained by direct interviews with the Shift Superintendents, Shif t Supervisors, Shif t Technical Advisors and Control Room Operators.
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E.
ADVISOR OUTIES REVIEW
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MP&L developed a memo with attached standing orders to cover the scope, responsibilities, duties and working relationships of the Shift Advisor.
The order covered all the important aspects of the Adviscr's role and specifically stated his key responsibilities:
"Specifically, the role of the Shift Advisor is to advise the Shift Superintendent on matters of plant operations which may have safety implications."
The UAET believes that MP&L's description of duties and responsibilities meet the current industry NTOL position.
The UAET made recommendations for improving these instructions and MP&L agreed to implement these recommendations.
F.
TRAINING LESSON PLAN REVIEW A training course for the Shift Advisors was developed by the station's i
training department.
The training staff performed a review of the duties of the ady'sor and developed a train < ng plan with elements specific to the needs of the advisors.
This course was seven weeks in duration and included Technical Specifications, plant procedure's, plant systems, simulator training and Mitigation of Core Damage.
The UAET reviewed the lesson plans for the i
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One week of power Ascension testing training and one week of Plant Transient Response and Recovery training were selected since these weeks included training in all areas within the scope of our program evaluation, i.e.,
plant procedures, Technical Specifications, and plant
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systems.
Evaluation of the examination is discussed below.
The lesson plans
- were considered satisfactory for the Shift Advisor position.
Emphasis was placed on the more significant operating and emergency procedures and plant systems.
The UAET considered the Shift Advisor's training plans to meet the requirements of the NTOL Utility Working Group.
G.
EXAMINATION REVIEW The UAET reviewed the content and grading of MP&L's oral, written and simulator examinations which were administered to the first group of Shift Advisors to complete training.
All examinations were representative of the Advisor Training Program.
The written examinations and the oral examinations given by the Operator Training Evaluation Committee had sufficient depth including plant specific and General Electric generic questions to assure that any Advisor who passed these examinations would be able to effectively relate and communicate their experience to the Grand Gulf operators.
The grading of the examinations was considered appropriate.
A majority of the questions on the examinations were considered to be at an SRO level, H.
EVALUATION TEAM RECOMMENDATIONS ~
s In order to enhance the existing Advisor Program, the UAET members recommended the following improvements:
o Develop a specific plant procedure delineating the advisors duties and responsibilities to replace the existing memos and standing orders.
o Discuss the new procedure with the shift crew, advisors and appropriate plant staff.
o Establish a structured Shif t Advisor Evaluation Program to ensure adequate advisor performance.
o Minimize administrative support assignments to the advisor during power operation and testing to enable maximum attention to the plant condition.
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c Page 6 IV. UTILITY ADVISOR TEAM MEMBER EXPERIENCE Nick S. Catron 8WR Simulator Training Supervisor Tennessee Valley Authority Mr. Catron has approximately sixteen years of nuclear experience including ten years of commercial experience. He is currently SRO licensed on Brown's Ferry 1, 2 and 3 with seven years SRO experience with duties including Assistant Shift Engineer and Shift Engineer and currently supervision of plant specific simulator and classroom instructions.
Specific plant experience includes plant construction and startup of Brown's Ferry Units 1 2 and 3 as Hot Licensed SRO Assistant Shift Engineer and Shift Engineer.
Training experience includes classroom and simulator training for both licensed and non-licensed training and currently as BWR Simulator Training Supervisor.
He served as a member of the Peer Advisory Panel to NRC on Operator Qualifications.
Max Manry Manager of Nuclear Performance Georgia Power Company Mr. Manry has thirty years of ciansnercial power plant experience of which
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sixteen years were in the area of fossil plant experience and fourteen years of nuclear experience.
The fossil experience consists of various engineering positions and a member of plant management.
The nuclear experience consists of eight years as Assistant Plant Manager and four years as Plant Manager during construction, preoperational testing, startup and operation of the Plant Hatch Nuclear Plant Units 1 and 2; one year experience as Plant Manager of Plant Vogtle during construction in preparation for startup;.one year experience in the Corporate Office as Manager of Nuclear Performance responsible for developing a program to improve the performance of Georgia Power Company's operating nuclear power plant.
He obtained a Cold SRO License on the Plant Hatch facility and now maintains a Georgia Power Company SRO certification requirement.
As Plant Manager of the Plant Hatch facility, he served as Chairman of the onsite Plant Review Board and as a member of the offsite Safety Review Board.
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r Page 7 J. Norman Pope Superintendent of Operations -
Oconee Nuclear Station
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Duke Power Company Mr. Pope has twenty-two years power plant experience, ten of these years have been comercial nuclear power plant experience.
He obtained an SRO license at Oconee, a 3 Unit 900 Mwe B&W power plant.
He has held the positions of Shif t Supervisor, Operating Engineer, and Superintendent of Operations at this plant.
In these line management positions, he has been responsible for portions of the initial testing programs, initial fuel loadings and initial startup testing on all three units, and the continued safe and efficient operation of Oconee.
E. L. Thomas Manager Nuclear Reliability Assurance Duke. Power Corapany Mr. Thomas has thirty-seven years power plant experience including thirteen years nuclear involvement.
Specific nuclear experience includes eight years in defining, developing and operating Duke Power Company's Nuclear Power Technical Training Program.
He served as Director of the T. raining and Education Division of the Institute of Nuclear Power Operations for 2.5 years.
Currently responsible for developing and implementing a program to improve the reliability / availability of Duke's nuclear generating units.
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Page 8 Jimmy D. Vandergrift Training Superintendent, Arkansas Nucl. ear One Arkansas Power & Light Company Mr. Vandergrift has twenty years training and experience in nuclear power.
He had six years experience in the nuclear Navy before joining AP&L in 1970 as an operator at Arkansas Nuclear One (ANO).
He has held SRO license on both the AN0 8&W and the CE Nuclear Units and served as Shif t Operating Supervisor from 1974 to 1978 during the initial startup of both units.
He has been in the ANO training organization since 1978 serving as the Training Supervisor and Superintendent.
He served on the Institute of Nuclear Power Operations' Training and Education Division Industry Review Group (IRG) from July 1981 until December 1984.
Jerald M. Waldorf Principal Engineer Nuclear Staff Support Section Carolina Power & Light Company Mr. Waldorf has over fourteen years of power plant experience with CP&L including over thirteen years of nuclear plant experience.
Mr. Waldorf received a Cold SRO License on 8runswick Plant in 1974.
He maintained the license until 1980.
He held the position of Senior Operations Engineer during
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the preoperational and startup test phases.
Duties includet fulfilling licensed engineer on shift commitments for significant testing and line supervision on all operating shift personnel.
Mr. Waldorf has also held the positions of Project Engineer with plant technical support staff Site TMI Manager and Resident Engineer responsible for onsite retrofit engineering activities.
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TEAM ENDORSEMENT OF REPORT This report reflects my observations and opinions.
tb NICK S. h TRON TENNESSEE VALLEY AUTHORITY f-I1// M I T T
MG MANRY ' b GEORGIAPOWERCON'ANY Ww w
J NOAMAN POPE
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