ML20213E007
| ML20213E007 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/12/1982 |
| From: | John Kramer Office of Nuclear Reactor Regulation |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0461, CON-WNP-461, TASK-1.A.1.1, TASK-1.A.1.2, TASK-1.A.1.3, TASK-1.B.1.2, TASK-1.C.3, TASK-1.C.4, TASK-1.C.5, TASK-1.C.6, TASK-TM NUDOCS 8203030248 | |
| Download: ML20213E007 (31) | |
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Robert L Tedesco, Assistant Director for Licen[ sing. "i
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Joel J. Kramer Deputy Director i
Division of Human Factors Safety
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SUBJECT:
LQS INPt!T FOR WASilINGT0!! NUCLEAR PROJECT 2 (Wi!P-2)
WASilINGTON PUBLIC P0'lER SUPPLY SYSTEM PLANT flAf1E: Washington Nuclear Project flo. 2 l
LICEf!SIf!G STAGE: CL DOCV.ET NU!'SER: 50-397 PISPO!!SIBLE BRANDI AND PROJECT MANAGEP.:
LD-2, R. Auluck l
REVIDI STATUS: Complete, except as noted in report The Licensee Qualifications Branch has completed, except for open items, its review of Sections 13.1, 13.2 with respect to unlicensed personnel,13.4, and 13.5 with respect to Administrative Procedures of the FSAR for the !!NP-2 Our evaluation is based on the infomation contained in the FSAR, on infomation received in our inter-office (NRR/ Region V) review of the applicant January 12, i
13, and 14 it Richland, Washington, and at the plant site, and discussions with l
nunerous individuals in the Washington Public Powcr Supply System (UPPSS) organization. Since sone of our evaluation is based on infomation furnished during our visit to UPPSS, we will require that this infomation be fomally placed in the WMP-2 docket.
He have incorporated the Action Plan items in the SER in accordance with the Standard Review Plan as follows:
Shift Technical Advisor (Section 13.1)
Item I.A.1.1 Itens I.A.l.2 - Shift Supervisor Administrative Duties l
I.C.3 Shift Supervisor Responsibilities (Section 13.1) l Item I.A.l.3 Shift Manning (Section 13.1) i Item I.B.l.2 Independent Safety Engineering Group (Section 13.4)
Shift and Relief Turnover Procedures (Section 13.5.1)
Item I.C.2 l
Item I.C.4 Control Room Access (Sedtion 13.5.1) l Item I.C.5 Procedures for Feedback of Operating Experience to Plant l
Staff (Section 13.5.1) l Iten I.C.6 Guidance on Procedures for Verifying Correct Perfomance of Operating Activities (Section 13.5.1)
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We consider the following items open:
1.
_ Training - The applicant has not described the training program for the Shift Support Supervisors, nor has he listed to our satisfaction those individuals required to receive training in the mitigation of core damage. We will pursue these matters with the applicant and report the resolution in a supplement to this report.
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l 2.
Administrative Procedures - In respect to limitation on working hours, it is our position that this plan be expanded to include health physicists i
and key maintenance personnel performing safety related functions. We I
will pursue these matters with the applicant and report the resolution j
in a supplement to this report.
3 Condition on License - We will condition the license to require that at least one person who has commercial RWR startup or licensed operating experience be provided on each operating shift, at least up to attain-j ment of a nominal 100% power operation. This condition can be satisfied by assigning either appropriately qualified UNP-2 personnel or contractor i
i personr.el.
This review was perfomed by F. Allenspach, l',anagement Systems Engineer, x28356.
There are no dissenting views within DHFS to the conduct or conclusions of this i
review.
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I Joel J. Kramer, Deputy Director l
Division of Human Factors Safety Office of Nuclear Reactor Regulation l
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Enclosure:
UNP-2 SER i
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H. Thompson J. Zwolinski A. Schwencer i
R. Auluck DISTRIBUTION:
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N SAFETY EVALUATION REPORT WASHINGTON NUCLEAR PROJECT 2 13 CONDUCT OF OPERATIONS 13.1.1 Management and Technical Support Orcanization A.
General During the period January 12, 13, and 14, 1982, a USNRC review team visited the Washington Public Power Supply System (WPPSS) corporate office in Richland, Washington, and the Washington Nuclear Project No. 2 (WNP-2) near Richland, Washington. The purpose of the visit was to review the proposed organization for the operation of the WNP-2 from the level of senior corporate officer, down to and including the proposed operating staff at the WNP-2 plant. WPPSS is a municipal corporation whose function is the construction and operation of nuclear power plants.
Except for one small hydroelectric generating facility, the entire WPPSS organization is dedicated to the construction and operation of nuclear power generation facilities. The team visit consisted of reviewing the organizational structure for operation and for technical support of the plant staff, the levels of staffing, the experience level of principal persons of bcth the corporate and the plant staff and the interfaces between the plant staff and its corporate support structure. The review team consisted of individuals from the Office of Nuclear Reactor Regulation and personnel from the Region V Regional Administrator's Office.
Beginning with a meeting at WPPSS's corporate office in Richland, the applicant provided the review team with a thorough briefing on its organization for the operation and technical support of the WNP-2.
This briefing was followeo by discussions with numerous corporate personnel sufficient for the review team to gain a feeling for the responsibilities and attitudes of the individuals, an understanding of now they fit into the organization, and how they interface 13-1
~
with other onsite and offsite organizational units. Discussions with plant personnel were held at the site to obtain the same type of information.
The following description and evaluation are based on information in the Final Safety Analysis Report and supplemental information obtained during the visit some of which will require confirmatory documentation by the applicants.
This Section 13.1.1 was reviewed against subsection 13.1.1 of NUREG-080D I
(Standard Review Plan), Revision 2 July 1981.
B.
Oroanizational Structure The current organizational structure for WPPSS, including the WNP-2 project is shown in Figure 1.
The senior corporate officer in charge of the applicant's nuclear program is Mr. R. L. Ferguson, the Managing Director, WPPSS.
Mr. Ferguson has over 20 years of nuclear experience.
He is assisted by a Deputy Manager Director, Mr. A. Squire.
Mr. A. Squire also has many years of nuclear experience. The Managing Director and Deputy Managing Director will have overall responsibility for the operation of the WNP-2.
In addition, they have overall responsibility for the design and construction of the other WPPSS nuclear generating facilities.
Reporting directly to the Office of the Managing Director are the Directors of Safety and Security, Quality Assurance, WNP-1/4 Program, WNP-2 Program, WNP-3/5 I
i Program, Power Generation, Technology, Public Affairs and Information, Admin-istration, Business Programs, and Treasurer. A brief description of the WNP-2 program, Power Generation, Technology, Safety and Security, and Quality Assurance Directorates are presented below.
l 1.
WNP-2 Program The WNP-2 Program Director has responsibility for the completion of the project through the startup test program until attainment of commercial operation, at which time responsibility for the facility is turned over to the Power j
Generation Directorate. The WNP-2 Program Director is Mr. Robert G. Matlock who has approximately 25 years of nuclear experience.
Figure 2 shows the 13-2
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f WASHINGTON PUBLIC POWER SUPPLY SYSTEM 4
MANAGING DIRECTOR DEPUTY MANAGING DIRECTOR EXECUTIVE ASSISTANT L
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PUBLIC AFFAIRS OUALITY Pil0G R AM S T ECif NOLOGY TREASURER SLCUlllTY
& INFORM ATION ASSURANCE I
CORPORATE LEVEL ORGANIZATION figure 1 6
WASHINGTON PUBLIC POWER SUPPLY SYSTEM WNP-2 PROGRAM PROGRAM DIAECTOR DEPUTY PilOGRAM OfRECTOA STARTUP &
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OUAllTY OUSINESS PROGRAM SITE AShUllANCE CONTROL ADMINISTRATION M Ai4A(,8 H M ANAGE R MANAC(H MANAG(H WNP-2 PROGRAft DIRECTORATE t
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organization reporting to Mr. Matlock. Within the Directorate is a Deputy Program Director for Startup and Operations to whom the Test and Startup Manager, and the Plant Manager report. At the time of commercial operation, the WNP-2 Directorate will be dissolved and the Plant Manager will report to the Director, Power Generation. The current manning of the WNP-2 Program Directorate is about 295 individuals, with a projected staff of about 461 individuals (including plant staff) at the time of fuel load.
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2.
Power Generation The Power Generation Director is responsible for the safe and efficient opera-tion of the plant after commercial operation is achieved. He is also responsible for providing plant support in the areas of maintenance, inservice inspection, and training. An organization chart for the Power Generation Directorate is shown in Figure 3.
Mr. Arthur 0. Kohler, Jr., the Director of Power Generation, has about 16 years of nuclear experience. The current manning of the Power Generation Directorate is about 169 individuals, with a projected staffing of about 211 individuals at the time of WNP-2 fuel load, exclusive of the WNP-2 plant staff.
3.
Technology The Technology Director is responsible for design control of all authorized plant modifications; technical expertise in the fundamental engineering disci-plines such as Mechanical, Electrical, Civil, Chemical, etc.; as well as specialty areas such as materials, welding and inservice inspection engineering.
As each system is completed and turned over to the WNP-2 Test and Startup Group, responsibility for design control will be assumed by the Technology Directorate.
The Technology Director is also responsible for providing tech-nology support in the areas of nuclear fuel management and environmental programs. An organization chart for the Technology Directorate is shown in Figure 4.
It is planned that the WNP-2 Program Project Engineering group shown in Figure 2 will be transferred to the Generation Engineering group in the Technology Directorate at the time WNP-2 reaches commercial operation.
13-5
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM TECHNOLOGY DIRECTOR DEPUTY DIRECTOR i
TECHNICAL &
INFO. SYS TEMS SYSTEMS GENERATION NUCLEAR ENGRG.
FUEL &
ENGINEEltING ENGtNEERING SERVICES ENVIHONMENT A551 cent CION f tCHNOLLGi A551 DeHEC10n f tCHNotOGv A551 DeptCIOn llCHNOLOG, A555 DiNECf0RftCHNOLOGv, SYSTEMS TECHNICAL PLANT PRFM.
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& SIMULATION MANAGtM M AN A6t M TECHNOLOGY DIRECTORATE Figure 4 E
e The Director of the Technology Directorate is Dr. Peter S. Sken, who has about, 12 years of nuclear experience. The current staffing of the Techpology Direc-torate is about 151 individuals, with a projected staffing of 227 at the time of WNP-2 fuel load.
4.
Safety and Security The Safety and Security Director is responsible for health, safety and'3ecurity, licensing programs and regulatory interfaces.
Technical support to the plant from this directorship is provided in the form of health physics and radiolog-ical support, plant security programs, emergency preparedness planning, fire protection program, licensing coordination and NRC interface, and safety evaluation of the plant through the Nuclear Safety Assurance group. This Directorate is shown in Figure 5.
The Director of Safety and Security is Mr. J. W. Shannon who has about 28 years of nuclear experiance.
The current staffing of this Directorate is about 139 individuals, not including the security force, with a projected staffing of about 206 at the time of WNP-2 fuel load.
5.
Quality Assurance The quality assurance organization is responsible for the development and implementation of the operational quality assurance program. This organiza-tion and program are described in detail in Section 17 of this report.
l C.
Test Prooram The WNP-2 Project, through the Deputy Program Director, Startup and Operations has responsibility for the Test and Startup Program.
Reporting to the Deputy Program Director for Startup and Operations is the Manager, Test and Startup, who is responsible for the program up until the time of fuel load, at which time the responsibility transfers to the WNP-2 Plant Manager. The current manning of the Test and Startup group is about 100 WPPSS personnel with a projected maximum of about 130 WPPSS personnel. They are currently augmented by two Bechtel Test Engineers and six GE test engineers. This augmentation is 13-8 y
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM l
SAFETY & SECURITY DIRECTOR DEPUTY DIRECTOR WNP 2 HEALTH Pi t VSf CS / Cit EM.
MANAGtn WNP.1/4 HEALTH NUCLEAR SAFETY Pe t VSICS/CitL M ASSURANCE MANAtelN M ANALL M WNP 3/5 HEALTH PetvStCS/CitLM MAN ALL M SECURITY PROGRAMS HEALTH & SAFETY LICENSING PROGRAMS PROGRAMS MANAGER M AN AGt R MANAGER SAFETY AND SECURITY DIRECTORATE Figure 5 l
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m projected to reach a maximum of about 23 individuals supplemented as necessary.
by individuals from Burns and Roe.
D.
Summation l
In the course of our visit to the WPPSS headquarters and the site, we met with many of the key individuals noted above and some of their first-line super-visors. We discussed the staffing of their groups, their backgrounds a'nd I
qualifications, and the present and projected interactions between the various groups that will support the operaticn of the WNP-2.
We found that the appli-cant had been successful in obtaining nuclear-experienced individuals for key positions in the organizational groups that will supp;rt the operation of the plant.
The Technology Directorate plans to provide within its department the capability to do all baseload engineering. We consider that their projected staffing is adequate to perform this function.
Plant design changes and modification engineering will be performed by this group. Engineers from this group also provide backup to their counterparts on the plant technical staff. Our dis-cussions with key personnel in other areas lead us to believe that the organizational arrangement will provide good management control and adequate resources to support the operation of the WNP-2.
E.
Conciusion We conclude that the applicant meets the acceptance criteria of subsection 13.1.1 of the Standard Review Plan, NUREG-0800.
13.1.2 Plant Staff A.
Organization l
The organization of the WNP-2 plant staff is shown in Figure 6.
The Plant Manager has direct responsibility and authority for all plant activities.
The Plant Manager reports directly to the WNP-2 Program Director prior to commercial I
13-10
m PLANT OPERATING ORGANIZATION 9
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operation. After commercial operation begins, the Plant Manager reports directly to the Power Generation Director who is resident in the WPPSS main office.
The Plant Manager has the responsibility for management of the following plant departments:
Plant Operations under the direction of the Operations Manager; Plant Maintenance under the direction of the Maintenance Manager; Plant Chemistry /
Health Physics under the direction of the HP/ Chemistry Manager; Technit'al support under the direction of the Technical Manager; Training under the direction of the Training Supervisor; and Administrative support under the direction of an Administrative Supervisor. The plant staff on board as of December 1981 is 164 individuals with a projected manning at fuel load of 219 individuals. This organization was reviewed against s;bsection 13.1.2 of NUREG-0800 (Standard Review Plan), Revision 2 - July 1981.
1.
Plant Operations The Operations Department is responsible for all plant operations and is under the direction of the Operations Manager who will hold a Senior Reactor Operator License (SRO).
He reports to the Plant Manager. The Operations Manager is responsible for the day to day routine as well as the abnormal or emergency operational situations that may arise.
He is responsible to see that all operations are carried out in a safe, efficient manner and that the plant is operated in strict conformance to the Operating License, Technical Specifica-tions and in accordance with approved written procedures. The Assistant Operations Manager will hold a Senior Reactor Operator License and is respons-ible to the Operations Manager.
The applicant plans to operate with six shift crews.
Each shift crew will be under the direction of a Shift Manager.
He is in charge of all plant opera-tion on shift and is directly in charge of and responsible for the shift crew assigned to his specific shift. The shift crew under the Shift Manager is divided into two sections:
one section under the Centrol Room Supervisor and one section under the Shift Support Supervisor.
13-12
The Control Room Supervisor assists the Shift Manager in the performance of his duties and assumes those duties during periods when the Shift Manager is unavailable The Control Room Supervisor is responsible for supervising the activities of the Control Room Operators and other assigned personnel.
Report-ing to the Control Room Supervisor will be two Reactor Operators, three equip-ment operators, and one or more instrument and control technicians.
The Shift Manager and Control Room Supervisor will each hold a Senior Reactor Operator License, and the Reactor Operators will each hold a Reactor Operator Lttense.
The Shift Support Supervisor assists the Shift Manager in the performance of his duties. He is responsible for the supervision and direction of personnel assigned to perform balance-of plant operating functions such as operations of make-up water treatment systems, radwaste processing systems, and other plant support systems.
He is responsible for performing administrative duties as delegated by the Operations Manager and other shift-related administrative duties as assigned.
Reporting to the Shift Support Supervisor will be one or more equipment operators, HP/ chemistry technicians, and one or more maintenance support personnel.
The projected manning of the Operations Department is 71 individuals.
In addition to those reporting to the Shift Manager, there will be a Shift Technical Advisor (STA) assigned to each operating shift to provide technical advice to the Shift Manager.
The STA's will assigned from the Technical Department.
We require and the applicant has agreed that each operating shift during initial operation of the plant shall have an individual with previous startup or licensed operating experience on a comparable BWR. The applicant believes he can fulfill this requirement inhouse.
If not, he plans to use GE personnel.
l 2.
Plant Maintenance l
The Maintenance Department is responsible for all plant maintenance and is under the direction of the Maintenance Manager. The Maintenance Manager reports to the Plant Manager.
Reporting to the Maintenance Manager, are the Mechanical Supervisor and the Instrument and Electrical Supervisor.
13-13
8 This Department is responsible for all mechanical, instrument and electrical repairs and preventive maintenance work in the plant.
This includes scheduling and conducting surveillance tests assigned to this section as required by the Technical Specifications. Offsite support for this section is provided by the Generation Services organization and includes Inservice Inspection, Training, Calibration Laboratory, and Planning and Scheduling. Other offsite support is provided when needed in the form of vendor representatives for technical guidance on maintenance of major components of the plant. Contracted Rblp will be needed for major outage maintenance. This has not been contracted for at this time.
The projected manning of this department is 65 individuals.
3.
Plant Chemistry / Health Physics The Health Physics / Chemistry Manager functions as the Radiation Protection Manager (RPM) and is responsible for managing the plant radiation protection and chemistry control programs. The Health Physics / Chemistry Manager func-tionally reports to the Plant Manager. He administrative 1y reports to and operates under corporate policy provided by the Safety and Security Director.
The Health Physics / Chemistry Manager is assisted by the Health Physics Supervisor, Chemistry Supervisor, and Radiochemist.
The Chemistry Supervisor supervises the activities of the Chemistry / Radiochemistry section. The Chemistry Supervisor is responsible for activities in the Chemistry Laboratory, Radiochemistry Laboratory, and radiological Counting Room. The Chemistry Supervisor is also responsible for the development and implementation of plant chemistry, radioch'mistry, and appropriate programs that provide e
monitoring of plant processes and discharges.
The projected manning of this department is 30 individuals.
Section 12 of this report describes in detail the health physics organization.
4.
Technical Group The Technical Manager reports to the Plant Manager and is responsible for performing onsite technical functions in the areas of plant engineering, 13-14 r
instrumentation and control engineering, electrical engineering, reactor engineering, computer engineering, chemical process engineering, power ascension test engineering, plant performance engineering, and regulatory compliance.
He is responsible to approve the application of those design changes and modifications to the plant and for developing and implementing programs and procedures which provide proper management control in the above areas.
Reporting to the Technical Manager are the Plant Engineering Superviso? and the Nuclear Engineering Supervisor, who provide continuous support of plant operations and maintenance to assure plant reliability, maximum efficiency, and proper plant safety. The Plant Engineering and Nuclear Engineering Super-visor supervise the activities of the technical staff in the functional areas of nuclear / reactor engineering, plant performance engineering, instrumentation and control engineering, computer engineering, chemical process engineering, mechanical engineering, electrical engineering, and regulatory compliance.
The projected manning of this department is 28 individuals. The STAS come from the complement of engineers in this department.
5.
Training Department The Training Supervisor reports directly to the Plant Manager and has been delegated the responsibility for ensuring all plant personnel are fully trained and qualified in accordance with applicable federal guidelines and regulations.
This group budgets, schedules, conducts, or arranges for appropriate training for operations, technical, maintenance, startup and and health physics / chemistry personnel.
6.
Administrative Department The Administrative Supervisor reports directly to the Plant Manager and provides administrative support for the plant staff.
7.
Shift Fire Brigade l
A Shift Fire Brigade, consisting of a minimum of five (5) members will be established on each operating shift. The fire brigade will be comprised of 13-15
the Shift Support Supervisor (Brigade Leader), two Plant Equipment Operators, one shift Health / Physical Chemistry Technician and one maintenance support individual.
C.
Qualifications The applicant has stated that the minimum education and experience qualifications
~
for the onsite plant personnel are based on Revision 1-1977 of Regulatory Guide 1.8, " Personnel Selection and Training." In Section 13.13.1 of the FSAR the applicant has described the minimum qualification requirements for plant positions. We find the described qualification requirements acceptable as they meet those described in Revision 1 to Regulatory Guide 1.8.
In addition, we have reviewed the qualifications of individuals assigned to key management and supervisory positions and find them acceptable.
However, the positions of Assistant Plant Manager and Assistant Operations Supervisor are not currently filled. We will review the qualifications of these individuals when these positions are filled.
D.
Conclusion We conclude that the applicant meets the acceptance criteria of subsection 13.1.2 of the Standard Review Plan, NUREG-0800.
Summary and Conclusion Based on our review of information received in a rewrite of Section 13 of the FSAR, dated December 29, 1981, and information received in our meeting with the applicant on January 12,13, and 141981, we conclude the following:
1.
The corporate structure provides for clear lines of authority and communi-cation between the plant staf f and the corporate entities that will provide technical support for the operation of the plant. We find this proposed structure and the numbers of persons projected for assignment within this structure, and their qualifications, acceptable.
13-16
2.
The plant staff structure provides for clear lines of authority and communication from the technical groups to the Plant Manager. We find the overall structure to be acceptable.
The health physics and chemical technicians are a common group and are trained in both disciplines. The Radiological Assessment Branch is reviewing this area in depth to assure clear lines of authority and adequate qualification of the HP technicians. TheirevaluationoIthe y
acceptability of the Health Physics organization is contained in Section 12 of this report.
3.
We have reviewed the qualification requirements established by the licensee for plant staff personnel and consider them acceptable since they meet the position described in Revision 1 to Regulatory Guide 1.8, " Personnel Selection and Training " In addition, our review of resumes currently in hand indicate the individuals in key supervisory positions meet our
. position.
We will continue to review the resumes of other individuals of the plant staff as they are submitted to us.
4.
Shift Crew Composition
~
We have reviewed the shift crew composition and conclude that it meets our position described in the July 31, 1980 letter to all licensees and applicants.
In addition, the applicant's proposals to staff for six shift rotation provides for adequate personnel so that there should be no need for routine use of overtime on shift. The applicant currently has 49 individuals in their training program for cold licenses.
This includes 8 individuals who will be STAS, 3 individuals from their training department, and 8 individuals in management and nonshift supervisory positions; leaving 30 individuals they plan to license for staff positions. All 30 are planned to be SR0 candidates. We consider that this is an adequate number to meet our shift staffing requirements at fuel load.
5.
Test Program We have reviewed the organizational structure, qualification requirements, and number of individuals assigned or to be assigned to the test program 13-17
and we find the applicant has provided for clear lines of authority and an adequate number of testing personnel; accordingly, we find these are acceptable.
1 6.
Fire Brigade We have reviewed assignment of responsibilities for fire protection and
^
the composition of the fire brigade and find they are in accordanc'e with BTP CMEB 9.5-1.
i 7.
Summary These findings contribute to the staff's collective judgment that the applicant complies with the requirements of $50.40(b) (that the applicant is technically qualified to operate a nuclear power plant), and that the applicant will have the necessary managerial and technical resources to provide assistance to the plant staff in the event of an emergency, as specified in Section 13.1 of the Standard Review Plan, NUREG-0800.
13.2.2 Training for Non-Licensed Perso1nel The applicant has presented its training program for nonlicensed operators in the FSAR. The Plant Manager is responsible for overall conduct and administration of the WNP-2 training program.
He has delegated this reponsibility to the Training Supervisor.
However, the development and implementation of parts of this program may be delegated to other members of the plant and to the home office.
In conjunction with the plant staff training group, the Training Division under the Director of Generation is responsible for providing general employee training and some specific reactor fundamentals training. Other home l
office departments provide specific training in their areas of responsibility, e.g., the Safety and Security Directorate provides training in the areas of i
security, fire protection and health physics.
l This subsection was reviewed against subsection 13.2.2 of NUREG-0800 (Standard Review Plan).
Revision 2 - July 1981.
13-18
General Employee Training All permanent plant personnel granted unescorted access to the station will be i
trained in the following areas:
a.
Appropriate Plant Security and Emergency Procedures b.
General Radiological Protection c.
Industrial Safety d.
Quality Assurance e.
First Aid & CPR f.
Fire Protection Program Selected supervisors, engineers, technicians, and craftsmen are provided training and other specialized courses to satisfy the applicable requirements of their particular positions.
Examples of some of these specialized courses are:
Specialized Courses i
1.
BWR Station Nuclear Engineering 2.
BWR Nuclear Instrumentation 3.
BWR Process Computer 4.
GE Rod Drive Control System 5.
BWR Process Instrumentation and Control 6.
Westinghouse Electro.-Hydraulic Control System 7.
BWR Chemistry 8.
Radiological Engineering i
9.
BWR Radiochemistry for Technicians i
- 10. Health Physics / Chemistry Technician Training j
Fire Brigade Training l
1.
Instruction Each assigned member of the fire brigade will complete a basic fire brigade training course.
The training will be conducted by knowledgeable 13-19 I
.i
and experienced personnel. The scope of the course will include the following:
a.
Identification of the hazards and types of fires that could occur.
b.
Identification, location, and operating features of manual, automatic, and portable fire protection equipment.
c.
Indoctrination on the plant's fire fighting plan and responsibilities.
d.
Proper use of all fire fighting equipment and proper procedures for postulated fires and conditions.
e.
Access and egress routes to the plant.
f.
Proper methods of fire control in confined areas, such as buildings and tunnels.
g.
Changes in fire fighting plans, plant modifications which affect fire fighting, and familiarization with new fire fighting equipment.
One individual per shift will be designated responsible for directing the actual fire fighting forces. These individuals will receive training as necessary to carry out that function.
2.
Practice Each brigade member will attend a practice session at least once per year.
Practice sessions will include:
a.
Practice in extinguishing actual fires.
b.
The use and wearing of self-contained breathing apparatus, t
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3.
Drills At least four (4) times per year, per shift, fire brigade drills will be conducted.
Each brigade member must participate in at least two (2) of the four (4) drills each year. At least one (1) drill per year shall be unannounced.
The drills may, or may not, be held in conjunction with other fire brigade practice and/or classroom training.
STA Training The applicant's STAS will be degreed engineers from the plant Technical Department.
They are presently enrolled in the cold license training program and will receive the same training as all cold license candidates.
In addition, tney will participate in Phase II of an " academic upgrace program" being given to Shift Managers. This Phase II training includes:
BWR Nuclear Engineering BWR Materials i
Abnormal Event Analysis Control Room Management BWR Chemistry / Radiological Occurrences BWR Corrosion (IGSCC) dWR Nuclear / Process Instruments Communication / Motivation Mitigating Core Damage All license candidates will attend a one week training session on use of systems designed to detect and mitigate core damage.
This class will be c
conducted and will generally follow the guidelines provided in the INPO Training Document STG-01. The applicant plans also for the Heactor Engineering l
Supervisor, Nuclear Engineer, Performance Engineer, and Assistant Plant Manager to receive this training.
l j
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Summary and Conclusions The applicant has described, in accordance with the requirements of 10 CFR Part 50, 950.34(b)(7), the training given to nonlicensed personnel and a schedule for that training as related to the applicant's presently scheduled fuel load date.
Training and retraining of nonlicensed personnel meets the requirements of ANSI /ANS 3.1 as endorsed by Regulatory Guide 1.8; fire brigade personnel will undergo classroom instruction, fire-fighting practice alEd periodic fire drills; shift technical advisers will receive training in the areas of mathematics, reactor physics, thermodynamics, controls, reactor operations, and transient and accident response; and shift technical advisers and other operating personnel will receive training in the mitigation of core damage.
We have reviewed these training plans and conclude that the training for nonlicensed plant staff personnel at WNP-2 is acceptable and iunts the require-ments of 10 CFR 50 sections 50.34(a and b); and the acceptance criteria of subsection 13.2.2 of the Standard Review Plan (NUREG-0800) except for the following items that reed further review:
i 1.
The training program for the Shift Support Supervisors which has not been described.
2.
The applicability of training for mitigating core damage to all plant personnel who may provide management support in the event of an emergency.
13.4 Onerational Review i
The applicant has established a program for the review and evaluation of operating phase activities that are important to safety.
This program focuses primicily on the provisions the applicant will use to review and evaluate proposed changes, tests and experiments; the review of unplanned events, such as licer.re event reports; and the provisions for the evaluation of plant t
operatic.;.
This section was reviewed against Section 13,4 of NUREG-0800 (Standard Review Plan), Revision 2 - July 1981.
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e e a
L 1.
Plant Staff Review The applicant will establish a Plant Operations Committee (POC) prior to fuel lead to perform reviews of operating phase activities. The POC will be composed of the Pla'nt Manager, Assistant Plant Manager, Operations Manager, Technical Manager, Maintenance Manager, Health Physics / Chemistry Manager, Administrative Manager (nonvoting), and Plant QA Manager.
It will meet at least once each month following fuel load.
A record of all POC meetings will be retained. The assigned responsibilities of the POC include those described for such committees in the Standard Technical Specifications.
It will be advisory to the Plant Manager.
2.
Independent Review The applicant has established a Corporate Nuclear Safety Review Beard (CNSRB) to provide for the independent review of operational phase acti-vities on a periodic basis. The CNSRB will consist of a manager and at least four engineers. The CNSRB membership is by appointment by the Managing Director regarding operational safety matters. Membership is required to meet or exceed the minimum qualification requirements specified by ANSI N18.1-1971 and ANSI N18.7-1976. The current membership that has been established by the Managing Director is listed below:
j 1.
Deputy Director, Safety and Security (Chairman) 2.
Director, Quality Assurance (Alternate Chairman) 3.
Acting Director, Power Generation 4.
Director, Technology 5.
Director, Project 1/4 6.
Director, Project 2 7.
Director, Project 3/5 8.
Mesber-at-Large 9.
Open (Member-at-Large) l
- 10. Member and Executive Secretary i
t I
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Meetings will be held at least once per calendar quarter during the initial year of unit operation and at least once per six months thereafter.
It will function to provide an independent offsite review of activities as described in Section 6.5.2 of the Standard Technical Specifications.
Results of the independent reviews will be documented and forwarded to appropriate members of management.
3.
Safety Engineering Group (SEG)
The applicant has established an onsite Safety Engineering Group for WNP-2 consisting of a minimum one manager and three full-time engineers at the site plus about 2 engineers at the home office. This group will be part of the Nuclear Safety Assurance group shown in Figure 5 above and will report directly to the Manager Nuclear Safety Assurance. The Nuclear Safety Assurance group is chartered with ensuring and improving overall nuclear safety of WPPSS nuclear facilities and has no direct responsibility for day-to-day power production. The onsite safety engineers will be supported by offsite independent engineering and safety expertise as required to accomplish their functions.
The general functions of the WNP-2 Safety Engineering Group will include the following:
a.
Evaluation of procedures important to safe operation of WNP-2 for technical adequacy and clarity.
I b.
Evaluation of plant operations and operational data.
c.
Evaluation of the operating experience of WNP-2 to provide recommendations on safety-related concerns; and responsibility for the feedback of operating experience of other plants.
I I
j d.
Overall assessment of WNP-2 staff performance regarding conformance l
to safety requirements.
l l
13-24 L
1 O (
l e.
Other matters relating to safe operation of WNP-2 that the SEG deems-appropriate for consideration.
f.
Assessment of plant safety programs.
The qualification and training of the SEG manager will be comparable to that described in Section 4.2 of ANS 3.1, Draft Revision, dated March 13,
^
1981. Other SEG member qualifications and training will meet ANS 3.1, I
Draft Revision, dated March 13, 1981, Section 4.2 or 4.4 or equivalent as described in Section 4.1.
Summary and Conclusion The applicant's program for the review of plant operations is in conformance with staff guidance described in Regulatory Guide 1.33 and applicable industry standards (ANSI N18.7), and is acceptable.
The applicant has desc-ibed the program for the review of operational activities.
The program includes reviews by the plant staff organization, reviews of safety related activities independent of the operating organization, and independent reviews and assessments of plant activities by an independent group located onsite. We have reviewed the provisions far these reviews in respect to organizational provisions, qualifi-cation requirements of those performing the review, and the subject matter to be reviewed. We find that the applicant's program for the review of operational activities is in conformance with staff guidance described in Regulatory Guide 1.33 and the applicable industry standard (ANSI N18.7); the qualifica-tion levels for plant staff personnel performing reviews meets the guidelines of Regulatory Guide 1.8 and applicable industry standard ANSI N18.1, Section 4.4; the provisions for an independent review meets the guidelines of Regulatory Guide 1.33 and applicable industry standard ANSI N18.7 (ANSI 3.2),
Section 4.3 and ANSI /ANS 3.1, Section 4.7; and the applicant's Safety Engineering Group meets the guidelines of Section I.B.1.2 of NUREG-0737; and meets the acceptance criteria of Section 13.4 of NUREG-0800, Standard Review Plan.
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p.
>r 13.5.1 Administrative Procedures This subsection was reviewed against subsection 13.5.1 of NUREG-0800 (Standard Review Plan), Revision 2 - 1981.
All activities affecting nuclear safety will be conducted by written and approved procedures. The preparation and initial review of the procedures will be the responsibility of various plant staff personnel. These procedures I
will be reviewed by the Plant Operations Committee and approved by the Plant Manager prior to implementation.
Procedures will be provided that meet our position described in Revision 2 to Regulatory Guide 1.33.
The applicant is developing a Plant Procedures Manual.
Volume 1 will contain the administrative procedures. These procedures will establish the rules and instructions pertaining to activities such as procedure preparation, plant personnel responsibilities and authorities, plant modifications, corrective and preventive maintenance, clearance orders, temporary changes to approved procedures, reviews of plant documents, surveillance testing and inservice inspection, equipment control and material control.
Shift Supervisor Responsibility The applicant has stated that the administrative duties of the Shift Manager
~ (shift supervisor) will be reviewed and inappropriate functions delegated to other personnel; and that directives and procedures will define the responsibility and authority of the Shift Manager, Control ~ Room Supervisor and operators; and to establish the Shift Manager's responsibilities for control room command.
The Shift Manager's responsibilities will be reinforced cy a management directive issued annually from the Office of the Director of Generation.
The Shift Manager's administrative duties will be reviewed annually to ensure that administrative responsibilities do not interfere with his primary responsibility.
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p Shift Relief and Turnover Procedure WNP-2 will prepare procedures and checklists for shift personnel to implement shift and relief turnover. These procedures and checklists will be designed to ensure that critical plant parameters are monitored and are within allowable i
limits, to ensure the availability and correct alignment of essential systems, and to identify all systems or components which are in a degraded mode of operation and compare each length of time in the degraded mode to techh1 cal specification requirements.
4 Checklists designed for auxil.iary operator shift turnover will identify any equipment under maintenance or test which could either:
(a) by itself degrade a system which is critical to the prevention and mitigation of operational transients and accidents; or (b) initiate an operational transient.
Control Room Access L
WNP-2 will prepare and implement a procedure to establish the Shift Manager (SRO) and, in his absence, the Control Room Supervisor (SRO) as having the authority and responsibility for limiting access to the control room. Nones-sential personnel will be excluded from the control room when their presence is hampering operations.
Additionally, procedures will establish a line of succession for control room authority and responsibility in the event of an emergency.
Limitations on Working Hours The applicant has stated that he will establish administrative procedures that will stipulate that work schedules for the Shift Manager, Control Room j
Supervisor, Shift Technical Advisor, Control Room Operators, and Equipment Operators shall be established in advance to ensure that the potential for exceeding the following guidelines is minimized when filling the minimum shift manning requirements:
i s
{
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j
[*
r%,
a.
No individual should work more than 12 consecutive hours.
This does not.
include time necessary for shift turnover.
b.
No individual should work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period.
c.
No individual should work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period.
d.
No individual should work more than 14 consecutive days without having two consecutive days off.
Those instances resulting in deviations will be documented and reviewed by the Plant Manager or his designee as soon as practicable following the occurrence.
]
In order to ensure that sufficient personnel are available to meet this policy, the applicant is staffing for six shift crew rotation, j
It is our position that the overtime limitation be expanded to include other personnel perfo'rming safety-related functions such as health physicists and key maintenance personnel, and that deviation from the above guidelines be authorized by the Plant Manager or his deputy, or higher levels of management.
Feedback of Operating Experience The information for the operating experience feedback program is obtained principally from I&E Bulletins and the INP0 Notepad program. This information j
comes in through the WNP-2 Licensing group and is disseminated to the Safety Engineering Group (SEG) for implementation of the program.
The WNP-2 SEG will initiate a review of operating experience material utilizing j
all technical expertise within WPPSS as appropriate.
Extraneous and unimportant information will be sorted out. The SEG will supply detailed information to j
the appropriate section managers for dissemination to identified recipients (supervisory personnel, STAS, operators, maintenance personnel, health physics i
technicians,etc.).
It shall be the responsibility of the appropriate section l
manager receiving the operating experience information to provide the informa-tion to the training section for inclusion in the retraining program and to 13-28
).;c n
disseminate the information directly to the identified recipients if a more rapid transmittal is appropriate.
The SEG, with assistance from the appropriate section manager, will make recommendations to the Plant Manager on the need i
for propedure changes or plant mcdific0tions identified from the operating experience review. The WNP-2 Training Section will be responsible for incor-porating into the training program, the information prosided to them from the operating experience review program.
To prevent conflicting or contradictory 4
information being conveyed to plant personnel, the Training Section will crear through the SEG any operating experience information received from other sources. The Manager of the SEG will be responsible for periodic surveillan;:e of the entire operating experienco review process.
Pat ticular attention will be paid to appropriate and timely incorporation of procedure enange and plant modification recommendations respiting from the review of operating experiences.
Operational QA will periodically audit the operating experiences review program.
Verification of Correct Performance of Operating Activities WNP-2 will prepare procedures to implement a system for the verification of operating activities important to safety. These procedures will be consistent with Section 5.2.6 of ANS 3.2 and will apply to both maintenance and surveil-lance activities, i
The Shift Manager will have the designated responsibility for implementing procedures for release of systems and equipment for maintenance or survillance l
testing and for return-to-service.
This responsibility may be delegated to any other Licensed Senior Heactor Operator (SRO) stationed within the control The Shift Manager will remain informed by reviewing and receiving room.
turnover records. Work permits involving tagging for maintenance or sur-veillance testing are verified by the Shift Manager (or his designee) for correct implementation of control measures.
Independent verification is also j
made for installation or removal of temporary modifications such as jumpers, l
lifted leads, or bypass lines.
Routine independent verification of equipment status at the location of the equipment will be performed for return-to-service activities of all important safety related equipment having no control room status indications.
This may be limited to return-to-service activities 9
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