ML20213F818
| ML20213F818 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/12/1986 |
| From: | Roisman A TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C. |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1518 OL, NUDOCS 8611170196 | |
| Download: ML20213F818 (45) | |
Text
4 N TRIAL l.AWYERS FOR.Pusuc JUSTICE, P.C.
" "N COUNse.10R5 AT law ,
SulTE 611 l;NP 2000 P STREET. NORTHWYST ANTHONY Z. ROISMAN WASHINGTON DC.l20036 EXECUTM DIRECTOR 86 NOV 18*O# @ M 6 ARTHUR BRYANT STAFF ATTORNEY CLucCARDt Of f!! E /-- - '"
DiPICTOR. tNVIRONMENTAL 00CKEil% 4 : a wr:F WHISTLISLOMR PROIECT Sk'AhL" BARBARA PRATT OFTICE MANAGER .
x4THtun cuMacRaATCH November 12, 1986 SECRETARY Peter B. Bloch, Chairman Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission 4350 East-West Highway, 4th floor
'Bethesda, MD 20814 Dr. Walter H. Jordan Administrative Judge 881 West Outer Drive Oak Ridge, TN 37830 Dr. Kenneth A. McCollom
~)___
~ ~
_Administ_ra_t_ive Judge 1107~~ West Knapp_
Stillwater, OK 74075 RE:; Texas Utilities Electric Co.' (Comanche Peak)
Dkt. Nos. 50-445, 446-OL Gentlemen:
i In keeping with our obligation to provide the Board with information obtained in discovery or otherwise which bears on pending issues, we are enclosing copies of two reports (da ted September 20, 1984, and November 1984) describing the nature and scope of the Southern Engineering Company monitoring program at Comanche Peak prepared on behalf of Tex-La. We received these documents, among many others, in discovery from Tex-La, and they bear directly on Tex-La's claims regarding the relevance of the monitoring reports and papers prepared as part of those reports advanced in their opposition to our motion to compel.
Sincerely, sS*
i ecr-Anthony Z. isman enclosures .
cc: Service List (w/ enc.)
8611170196 861112 5 PDR ADOCK 0500 Dw3
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 cj b cIV1 On Behalf of TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC.
y t
by SOUTHERN ENGINEERING COMPANY SEPTEMBER 20, 1984 I
l l
f-TABLE OF CONTENTS PAGE
- 1. COMANCHE PEAK STEAM ELECTRIC STATION - UNITS 1 AND 2 1 CONSTRUCTION AND OPERATION MONITORING PROGRAM G0ALS AND OBJECTIVES
- 2. COMANCHE PEAK UNIT 1 - OPERATIONS MONITORING PROGRAM 3
- 3. COMANCHE PEAK UNIT 2 - CONSTRUCTION MONITORING PROGRAM 7
- 4. EXPECTED SOUTHERN ENGINEERING MANPOWER REQUIREMENTS 10
, . . = - = = - - - .- . - - - - - . . -- - . - = = =.- - - - -
4
COMANCHE PEAK STEAM ELECTRIC STATION - UNITS 1 AND 2 CONSTRUCTION AND OPERATION MONITORING PROGRAM GOALS AND OBJECTIVES The overall requirements of Tex-La as a cooperative participating in the construction of a nuclear power plant should include an effec-tive construction and operations monitoring program that is useful in leading to decisions and action. This requires a construction and operations monitoring program designed to provide active participation in the project. It leads to:
Broad understanding of complex construction and operational p robl ems.
Innovative and practical business strategies.
Commitment to and support of the project.
Mea s u rement.. o f_ per fo rmance = to - provid e-repo rt s-for= REA; -
=="-- '
Reduction in the number and severity of surprises.
Timely problem identification and problem solving.
Better knowledge of funding requirements and expenditure fo recasts.
The goals of the project monitoring program include:
j 1. Active review and participation - not just approvals.
I 2. Measuring and analyzing performance.
- 3. Forecasting performance independent of the Project Manager.
1
A regular evaluation cycle must be established to develop an ongoing knowledge base from which to tackle unanticipated problems and to promote consistency in performance measurement. Active routine monitoring enhances the understanding of external events and con-sequences. This results in increased confidence and promotes realism in predicting cost and schedule. Project monitoring gives management a timely preview of foreseeable problems, the means to evaluate options and the capability to assess risks and take action.
Specific benefits of first-hand knowledge and confidence will be realized in the following areas:
- 1. Plant schedule and probability of meeting it.
- 2. Cost of project and confidence in estimate.
- 3. Utility's management capabilities to complete construction on
--- - - - - ~- - ~~
schedule end-~ ope ~ rate in mostTo5t-effective manner Tp~eis~oiinel~
and qualifications).
4 Utility's cost control of the project.
- 5. Utility's prudence in fuel management, fuel inventory, contracts.
- 6. Utility's contingency plans (technical, construction and financial) to handle major problems.
- 7. Regulatory and environmental appraisal of the project.
- 8. A comparison of the CPSES schedule and costs to similar plants in the same time frame.
2
COMANCHE PEAK UNIT 1 - OPERATIONS MONITORING PROGRAM As construction and pre-operational testing are essentially complete on Unit 1 and the unit goes into fuel load, power ascension testing and commercial operation, we are outlining a program to meet your needs as a joint owner of an operating nuclear power plant. The important features of this program are:
Periodic on-site observation and review of plant operations; Review of Utility, NRC and INP0 correspondence and reports to detect problem areas; Use of nuclear utility experienced management and operations personnel ;
Detailed review of operating and capital budgets and budget
.m_._____. . . _ _- comgaf[ sons _._ _, ___ _ _ _, _
_ ._ _ _ _ . _ = _ _ _ _ _. __ . _ . _
Audits and interviews should be conducted for the most part at the plant. Occasional visits with Texas Utilities in Dallas may be required for matters related to fuel contracts, licensing or issues raised at the plant which require higher level resolution.
I. Plant Operating Performance By review of Texas Utilities internal reports and memoranda, industry data and by plant visits we will obtain and analyze data concerning unit availability, capacity factors and heat rates. We will review unit reactor trips and other forced outages to determine if root causes are being addressed and if appropriate management attention is being directed to 3
correcting such problems. Fuel utilization and burn-up data will be reviewed to see that proper operation is achieving predicted energy output from each batch of nuclear fuel.
Nuclear waste generation and shipping practices will be reviewed.
II. Outage Performance Outage management systems will be reviewed to assure that efficient techniques are being utilized to keep outage time to a minimum and to control contractor's costs. Of par-ticular interest is to review the advanced planning and outage work lists.
III. Operating Budget Performance
- We-will- review =the--control = systems-to enable you to" -" -
understand data received, to assure adequate budgetary controls exist and that adequate audit trails exist. Budgets will be compared to industry norms and against plant specific requirements to determine if fat exists and if adequate resources are being applied to problem areas. Monthly budget comparisons will be reviewed. Future trends, both plant specific and industry-wide, will be brought to your attention for your knowledge and use in your budget planning.
4
IV. Capital Budgets Of particular interest will be a review of the Unit I capital budget. Operating nuclear plants have continuously sustained high levels of additional capital investment for NRC mandated changes; changes necessary to make the plant perform as designed and plant improvements. Capital budgets will be reviewed to determine that regulatory alternatives have been adequately explored, that necessary changes are being ade-quately implemented and that improvements are indeed cost beneficial . If additional REA financing is necessary, we expect the REA staff to be most interested in these reviews.
V. Regulatory Performance By review of NRC regional ad headquarters correspondence,. . - - .
inspection reports, violations and responses, Licensee Event Reports, Systematic Appraisal of Licensee Performance Reports, Texas Utilities internal non-conformance reporting documents and other pertinent material and by interviews with plant personnel, we will assess Texas Utilities' performance in the highly important area of regulatory compliance. Good regulatory relations and license compliance will minimize exposure to fine, bad public relations and general inter-ference into plant operations.
5
4 VI. Personnel and Training We will evaluate the corporate and plant management by review of qualifications and by observation of achieved results.
Training programs and pass / fail records of license candidates will be compared to industry averages. Personnel retention and turnover will be analyzed.
VII. INP0 Evaluation INP0 evaluation will be reviewed to help determine weak points in plant operations. Proposed corrective actions will be reviewed for adequacy as well as timely implementation.
VIII. Quality Assurance Program The Quality Assurance Program will be periodically evaluated to measure program effectiveness and' management commitment-to--- -- ~--^
performing work according to their committed written program.
~
I J
6 l
l
I COMANCHE PEAK UNIT 2 - CONSTRUCTION MONITORING PROGRAM
.As Unit 1 is completed, full attention will be turned to Unit 2 for completion and testing. An opportunity exists for very productive work utilizing the benefits of complete engineering, lessons learned from Unit 1, an experienced construction and start-up organization and a well-trained and experienced plant staff. We must all work together to see this happen. We are outlining a program to monitor the construction of Unit 2 and meet your needs as a joint owner.
I. In reviewing engineering, we will monitor and evaluate the progress in system design activities, electrical and mechan-ical design work (such as hangers and instrument loops) and the in-service inspection and pump and valve programs. The rate of progress during design has a direct effect on the rate of procurement and installation during constructio'n.
II. We will monitor and evaluate the bulk connodity installation rates and to-go quantities of the large and small piping, the tray and conduit, the wire and cable and the terminations and connections. During the construction phase, the installation and acceptance of these commodities have the largest poten-tial to impact the Pre-operational and Start-up programs.
i 7
1
- . - . .. _ . - . - . , . - _ , , , _ y . ._ ,, _ - , . . . _ _ . . _
r - _ _ _ _ , , _
III. As systems and areas are transferred to start-up, we will review and evaluate the management systems which control this phase, and we will track and evaluate the rate of turnover very closely. The identification and closure rates of criti-cal punchlist items will be reviewed and evaluated as this can severely impact this critical phase of the project.
IV. During system testing and turnovers we would inspect and evaluate the program management and control procedures to assure that the Construction Testing and the Pre-operational and Acceptance Testing programs are workable and that they support the Integrated Operational Test program. System test and turnover rates would be monitored and evaluated against the target Fuel Load date.
V. Throughout the project, we would inspect and evaluate the schedule and the associated costs. The engineering schedule would be evaluated with regard to logic and the support of construction. Construction would be evaluated with respect to activity sequencing, completions and the support of Start-up. The Start-up schedule would be analyzed to assure support of Fuel Load and Commercial Operation. Critical
! Paths would be closely monitored in terms of recovery efforts and impacts on project milestones. We would review and ana-lyze cost expenditures and budgets to assure the completeness and reasonableness of each category of major significance.
8 l
i
-, .- - . _ . - - ---__.,--, - .. - - - . . , - . _ - . . - - = . _ . _ _ - _ -
1 VI. In monitoring the Regulatory process, we would review the NRR Open Issue Resolution Process. Safety Evaluation Reports, ASLB hearings and technical specificatirn development to determine progress and problem areas. Based on our knowledge of the project and on the industry, we would offer our opi-nions on Regulatory impacts (positive or negative) with respect to Fuel Load and Commercial Operations dates, as well as associated cost trends.
VII. We will review the staffing and training programs to deter-mine if adequate personnel are available to perform scheduled activities during the construction phase. We will determine
, if corporate as well as plant management personnel are addressing such matters as prior experience, qualification and testing schedules and the quality of the training programs to support turn-overs, Fuel Load and Commercial Operation.
VIII. We will monitor and evaluate fuel procurement activities, I
fuel contracts and the status of manufacturing to be sure that TV is taking advantage of the best available options and that Tex-La is receiving the most for its money in this area.
9
c EXPECTED SOUTHERN ENGINEERING MANPOWER REQUIREMENTS To do the thorough job, we expect to apply only experienced personnel to this effort. We feel that approximately 100 engineering manhours per month for Unit 1 and Unit 2 should provide adequate coverage of both efforts. This time will be expended at Comanche Peak, Dallas and in Atlanta in the following general areas:
Review of Texas Utility, NRC and INP0 reports and correspondence; On-site inspection, document review and audits, and interviews; Attending Texas Utility management meetings, NRC meetings and INP0 meetings; Preparation of reports and correspondence to Tex-La; Responding to special requests and problems.
10
.s i
i l
l A CONSTRUCTION MONITORING PROGRAM FOR COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 ANO UNIT 2 IN BEHALF 0F l
l BRAZOS ELECTRIC POWER COOPERATIVE, INC.
[ __ ,_ . - . -
._. Waco , _Texa s --
, _ _..e_-
AND j TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC.
l Nacogdoches, Texas
! NOVEMBER 1984 i
i l
by l SOUTHERN ENGINEERING COMPANY l 1800 Peachtree Street, N.W.
Atlanta, Georgia 30367-8301 (404) 352-9200 l
l
o CONSTRUCTION AND OPERATIONAL
, MONITORING PROGRAM TABLE OF CONTENTS PAGE
1.0 INTRODUCTION
1 2.0 COMANCHE PEAK UNIT 1 -
OPERATIONAL MONITORING PROGRAM 4 2.1 PLANT OPERATING PERFORMANCE 5 2.2 OPERATING BUDGET PERFORMANCE 6 2.3 OUTAGE PERFORMANCE AND CAPITAL BUDGETS 7 2.4 REGULATORY PERFORMANCE 8 2.5 PERSONNEL AND TRAINING 9 2.6 INP0 EVALUATION 10 2.7 OVALITY ASSURANCE PROGRAM 11 2.8 NUCLEAR FUEL 12 3'. 0 COMANCHE PEAK UNIT 2 - 13 CONSTRUCTION MONITORING PROGRAM 3.1 ENGINEERING 13 3.2 CONSTRUCTION 14 3.3 SYSTEM COMPLETION 15 3.4 PRE-0PERATIONAL TESTING 16 3.5 COST AND SCHEDULE 17 3.6 REGULATORY , 18 3.7 STAFFING 19 4.0 SCOPE OF SERVICES 20 5.0 RESUMES 23
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM
1.0 INTRODUCTION
- G0ALS AND OBJECTIVES The overall requirements of Brazos and Tex-La as cooperatives participating in the construction of a nuclear power plant should include an effective construction and operations monitoring program that is useful in leading to decisions and action.
Unit 1 is essentially complete as a construction project. The approximately
$200 million (excluding I.D.C.) remaining to be spent on Unit 1 will be used in the completion of licensing, fuel load, low power testing and the power ascension program. These completion efforts are accomplished using the same administrative controls as in an operating plant:
Station administrative procedures, the operating license and the plant technical specifications. Unit 2 is in a construc-tion mode, much different than Unit 1. As a result, the approaches to each unit will be dif ferent. These are outlined in separate sections of this program. The
- -actual-hours-spent-wiH-be-accomplished 7n-the same plant visits within the hours outlined in Section 4.
This document presents a construction and operations monitoring program designed to provide active participation in the pro-ject. It leads to:
Broad understanding of complex construction and operational problems; Innovative and practical business strategies; Commitment to and support of pro-ject; Measurement of performance to pro-vide reports for REA; Page 1 i
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM Reduction in the number and severity of surprises; Timely problem identification and problem solving; Better knowledge of funding require-ments and expenditure forecasts.
The goals of the project monitoring program include:
- 1. Active review and participation - not just approvals.
- 2. Measuring and analyzing performance.
- 3. Forecasting performance independent of the Project Manager.
e A regular evaluation cycle must be established to develop an ongoing knowledge base from which to tackle unan-
.____r.. -.. __ _._ticipated-problems and--to promote-con - - - - -
sistency in performance measurement.
Active routine monitoring enhances the understanding of external events and con-sequences. This results in increased con-fidence and promotes realism in predicting cost and schedule. Project monitoring gives management a timely preview of fore-seeable problems, the means to evaluate options and the capability to assess risks and take action.
Specific benefits of first-hand knowledge and confidence will be realized in the following areas:
- 1. Plant schedule and probability of meeting it.
- 2. Cost of project and confidence in esti-mate.
Page 2
- - _ - - - , . . - ~ - , ,
, . - . . . . - _ _ _ _ _ . , ._.--____,___-__,,_,,__m _ _ . _ _ . . . _ _ , - - -
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM
- 3. Utility's management capabilities to complete construction on schedule and operate in the most cost-effective manner (personnel and qualifications).
- 4. Utility's cost control of the project.
- 5. Utility's prudence in fuel management, fuel inventory, contracts.
- 6. Utility's contingency plans (technical, construction and financial) to handle major problems.
- 7. Regulatory and environmental appraisal of the project.
- 8. A comparison of the CPSES schedule and costs to similar plants in the same time frame.
, , . .o. +
_ ,.* '4 + "' ** * * " ' ' **
i h
(
i i
Page 3 l
t
i I
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 2.0 COMANCHE PEAK UNIT 1 - OPERATIONAL MONITORING PROGRAM As construction and pre-operational testing are essentially canplete on Unit 1 and the unit goes into fuel load, power ascension testing and commercial opera-tion, we are outlining a program to meet your needs as a joint owner of an operating nuclear power plant up until com-mercial operations. The important features of this program are:
Periodic on-site observation and review of plant operations; Review of Utility, NRC and INP0 correspondence and reports to detect problem areas; Use of nuclear utility experienced managenent and operations personnel; Detailed review of operating and
_ m - z =. , = _ - . . _ _ Capi tal-budgetsmandebudget-cc::;
. : = --- =
parisons.
Audits and interviews should be conducted for the most part at the plant.
Occasional visits with Texas Utilities in Dallas may be required for matters related to fuel contracts, licensing or issues raised at the plant which require higher level resolution.
i Page 4
B CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 2.1 PLANT OPERATING PERFORMANCE By review of Texas Utilities internal reports and memoranda, industry data and by plant visits we will obtain and analyze data concerning unit availability, capa-city factors and heat rates. We will review unit reactor trips and other forced outages to determine if root causes are being addressed and if appropriate manage-ment attention is being directed to correcting such problems. Fuel utiliza-tion and burn-up data will be reviewed to see that proper operation is achieving predicted energy output from each batch of nuclear fuel. Nuclear waste generation and shipping practices will be reviewed.
We expect to do the following:
2.1.1 Review, Analyze and Evaluate a) Visit plant, interview management;
" . ~ _ _
' .~.--. . -
. . - - - - - = - . - - = =----- - - ---
b) Weekly and monthly management reports; c) Scram reports.
2.1.2 Attend Meetings as Cooperatives' Representatives a) Weekly management meetings (attend once per month);
b) Other meetings (attend as can be scheduled with other visits).
2.1.3 Prepare Reports a) Bi-monthly Report to Cooperatives; b) Special reports.
l l
1 Page 5 l
l L
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 2.2 OPERATING BUDGET PERFORMANCE We will review the control systems to enable you to understand data received, to assure adequate budgetary controls exist and that adequate audit trails exist.
Budgets will be compared to industry norms and against plant specific requirements to determine if expenses are inflated and if adequate resources are being applied to problem areas. Monthly budget comparisons will be reviewed. Future trends, both plant specific and industry-wide, will be brought to your attention for your knowledge and use in your budget planning.
Specific tasks are:
2.2.1 Review, Analyze and Evaluate a) Monthly budget comparisons; b) Annual operating budget;
~
c) Annual btJget work sheets.
2.2.2 Attend Meetings as Cooperatives' Representative a) Annual budget review.
2.2.3 Prepare Reports a) Budget report in bi-monthly report; b) Report on annual budget review.
f i
Page 6
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 2.3 OUTAGE PERFORMANCE AND CAPITAL BUDGETS Outage management systems will be reviewed to assure that efficient techniques are being utilized to keep outage time-to a minimum and to control contractor's costs.
Of particular interest is the review of advanced planning and outage work lists.
A Review of the Unit 2 capital budget is very important. Operating nuclear plants have continuously sustained high levels of additional capital investment for NRC man-dated changes -- changes necessary to make the plant perform as designed and pignt improvements. Capital budgets will'be reviewed to determine that regulatory alternatives have been adequately explored, that necessary changes are being adequately implenented and that improve-ments are indeed cost beneficial. If additional REA financing is necessary, we expect the REA staff to be most interested in these reviews.
2.3.1 Review,InakyzeandEvaluate a) Outage work plans; b) Capital budget work sheets; c) NRC license commitments; d) Annual construction forecast.
2.3.2 Attend Meetings as Cooperatives' Representative a) Texas Utilities capital budget review; b) Outage planning review meetings.
2.3.3 Prepare Reports a) Budget report in bi-monthly report; b) Report on annual capital budget items.
1 Page 7 i
I
---.,r, --
-""r^* w'*---=- W**'"-- '*-"--m'~~=~ **'m--'-**--**-ee- - - - - - *- -
- CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM
$ 2.4 REGULATORY PERFORMANCE By review of NRC regional and headquarters 1 correspondence, inspection reports, viola-tions and responses, Licensee Event Reports, Systematic Appraisal of Licensee Performance (SALP) Reports, Texas Utilities internal non-conformance reporting documents and other pertinent material and by interviews with plant per-sonnel, we will assess Texas Utilities' performance in the highly important area of regulatory compliance. Good regulatory relations and license compliance will minimize exposure to fines, bad public relations and general interference into plant operations.
2.4.1 Review, Analyze and Evaluate a) NRC I&E and NRR correspondence; b). . Violations and TUEC-response; ---
-- =
c) SALP reports; d) Licensee event reports. ~
2.4.2 Attend Meetings as Cooperatives' Representative a a) SALP report briefings;
< b) Major enforcement conferences and exit meetings.
2.4.3 Prepare Reports i
a) Licensing and regulatory compliance sections in bi-monthly report.
i l
Page 8
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 2.5 PERSONNEL AND TRAINING We will evaluate the corporate and plant management by review of qualifications and by observation of achieved results.
Training programs and pass / fail records of license candidates will be compared to industry averages. Personnel retention and turnover will be analyzed. Status of INP0 accreditation and simulator con-figuration control will be reviewed.
2.5.1 Review, Analyze and Evaluate a) Meet with training and personnel departments; b) TUEC internal program documents and reports; 2.5.2 Attend Meetings as Cooperatives' Representative a) Probably none.
2.5.3 Prepare Reports a) Include a section annually in bi-monthly report.
Page 9
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 2.6 INP0 EVALUATION INP0 evaluation will be reviewed to help determine weak points in plant operations.
Proposed corrective actions will be reviewed for adequacy as well as timely i
impl ementation.
2.6.1 Review, Analyze and Evaluate a) INP0 evaluation reports; b) TUEC corrective actions.
2.6.2 Attend Meetings as Cooperatives' Representative a) INP0 evaluation exit meetings.
2.6.3 Prepare Reports a) Include section in bi-monthly reports; b) Special reports.
_. -. -. .- - .- . .. -. - - . = - - - - - - --
1 i
i i
Page 10
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 2.7 OVALITY ASSURANCE PROGRAM The Quality Assurance Program,will be annually evaluated to measure program effectiveness and management commitment to performing work according to TUEC's com-mitted written program. This review could be accomplished in cor. junction with SALP review and other work.
2.7.1. Review, Analyze and Evaluate a) TUEC QA management reports; b) SALP reports.
2.7.2 Attend Meetings as Cooperatives' Representative a) None.
2.7.3 Prepare Reports a) Include annually in bi-monthly report h
1 Page 11 i
y .
1
-y - -
CONSTRUCT!0N AND OPERATIONAL -
s MONITORING FROGRAM ,
2.8 NUCLEAR FUEL
Southern will review TUEC's nuclear fuel perforfinance. In-core fuel utilization and burn-up data will'5e analyzed. Lif fuel ;
mechanical integrity or reactivity anoma- '
lies occur, Southern kill eeview the l .
problems and proposed solutions for tech-nical adequacy and to determine if the Cocperatives' interests are being con- '
sidered in burn-up strategy changes; Southern'will review TUEC Nucl.nr Fuels "
Department reports to keep watch on TUEC's '
prucency in fuel procurement and . inventory strategy and in major procurement actions.
2.8.1 Review, Analyze and Evaluate
.) -
a) Fuel Department reports; b) Annual fuel cost report; c) Procurement recommendations. '
- _ . . . -- L m - . -- - = m == ~
2.8.2 Prepara Reports a) Semi-annual sssessment of fuel perior- -
mance and pro:urement.
t r
o d I f.
h g g h
T 4
Page.12'
~ ,
. _ - . - - . . . , . _ . . _ . . - . . , . - , _ - , , . . _ . _ _ . _ _ , _ . - - . . . . - . . . - , _ _ _ , .__, - - . . . - -. _ ~ _ _ . , _,
e CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 3.0 COMANCHE PEAK UNIT 2 - CONSTRUCTION MONITORING PROGRAM t
As Unit 1 is completed, full attention will be turned to Unit 2 for completion and testing. An opportunity exists for very productive work utilizing the bene-fits of complete engineering, lessons learned from Unit 1, an experienced construction and start-up organization and a well-trained and experienced plant staff. We are outlining a program to monitor the construction of Unit 2 and meet your needs as a joint owner. ,
3.1 ENGINEERING In reviewing engineering, we will monitor and evaluate the progress in system design activities, electrical and mechanical design work (such as hangers and instru-l ment loops) and the in-service inspection and pump and valve programs. The rate of
._ __ =.-.s_ -
.. =^7rogress--during1esign~has74trect ce fect == ~"
on the rate of procurenent and installa-tion during construction.
3.1.1 Review, Analyze and Evaluate a) Visit site and interview engineering managers; ,
b) Review engineering progress reports.
3.1.2 Attend Meetings as Cooperatives' Representative a) Attend weekly management meeting (once ,
per month);
b) Attend other important engineering meetings.
3.1.3 Prepare Reports a) Section in bi-monthly report.
Page 13 I
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 3.2 CONSTRUCTION We will monitor and evaluate the bulk com-modity installation rates and to-go quan-tities of the large and small piping, the tray and conduit, the wire and cable and the terminations and connections. During the construction phase, the installation and acceptance of these commodities have the largest potential to impact the Pre-operational and Start-up programs.
3.2.1 Review, Analyze and Evaluate a) Visit site and interview construction manager; b) Review weekly progress reports.
3.2.2 Attend Meetings as Cooperatives' Representative a) Attend weekly management meetings (once per month) .
3.2.3 Prepare Reports a) Section in bi-monthly report.
l l
l .
4 Page 14
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 3.3 SYSTEM COMPLETION As systems and areas are transferred to start-up, we will review and evaluate the management systems which control this phase, and we will track and evaluate the rate of turnover very closely. The iden-tification and closure rates of critical punchlist items will be reviewed and eva-luated as this can severely impact this critical phase of the project.
3.3.1 Review, Analyze and Evaluate a) Visit site and interview construction manager; b) Review weekly progress reports.
3.3.2 Attend Meetings as Cooperatives' Representative a) Attend weekly management meeting (once per month).
_. .. _ ._ - - - - = . - -
3.3.3 Prepare Reports a) Section in bi-monthly report.
Page 15
e CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 3.4 PRE-0PERATIONAL TESTING During system testing and turnovers we
- would inspect and evaluate the program management and control procedures to assure that the construction testing and the pre-operational and acceptance testing programs are workable and that they sup-port the integrated operational test program. System test and turnover rates would be monitored and evaluated against the target fuel load date.
3.4.1 Review, Analyze and Evaluate a) Visit site and interview construction manager; b) Review weekly progress reports.
3.4.2 Attend Meetings as Cooperatives' Representative a) Attend weekly management meetings
_ . -(once per month) .
3.4.3 Prepare Reports a) Section in bi-monthly report.
t Page 16
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 3.5 COST AND SCHEDULE Throughout the project, we would inspect and evaluate the schedule and the asso-ciated costs. The engineering schedule would be evaluated with regard to logic and the support of construction.
Construction would be evaluated with respect to activity sequencing, comple-tions and the support of start-up. The start-up schedule would be analyzed to assure support of fuel load and commercial operation. Critical paths would be clo-sely monitored in terms of recovery efforts and impacts on project milestones.
We would review and analyze cost expen-ditures and budgets to assure the comple-teness and reasonableness of each category of major significance.
3.5.1 Review, Analyze and Evaluate a) Visit site and interview project mana-
__ - - - . - - - - - - = _ . - =- -- gers; "
b) Review schedule logic and logic changes; c) Review TUEC cost estimates and revi-sions; d) Compare with other plants.
3.5.2 Attend Meetings as Cooperatives' Representative a) Attend schedule meetings.
3.5.3 Prepare Reports a) Schedule section in bi-monthly report.
Page 17
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 3.6 REGULATORY In monitoring the Regulatory process, we would review the NRR Open Issue Resolution Process, Safety Evaluation Reports, ASLB hearings and technical specification devel-opment to determine progress and problem areas. Based on our knowledge of the pro-ject and of the industry, we would offer our opinions on Regulatory impacts (positive or negative) with respect to Fuel Load and Commercial Operations dates, as well as associated cost trends.
Specific work would be accomplished along with that included in Section 2.4, Regulatory Performance.
O Page 18
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 3.7 STAFFING We will review the staffing and training programs to determine if adequate person-nel are available to perform scheduled activities during the construction phase.
We will determine if corporate as well as plant management personnel are addressing such matters as prior experience, qualifi-cation and testing schedules and the quality of the training programs to sup-port turn-overs, Fuel Load and Commercial Operation. Specific work would be accomplished along with that in Section 2.5, Personnel and Training.
l Page 19
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 4.0 SCOPE OF SERVICES The following table lists the tasks Southern will perform and the associated man-hours estimate.
...= . -. . - _ . - - . . . . ..
- a. .. .. _ -_== -
Page 20
- - _ - _ _ _ - _ _ _ _ _ _ . 1
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM Monthly Annual Annual Basis Basis Total 2.1 PLANT OPERATING PERFORMANCE 2.1.1 Review, Analyze, Evaluate 16 192 2.1.2 Attend Meetings 2.2.3 Prepare Reports 10 120 2.2 OPERATING BUDGET PERFORMANCE 2.1.1 Review, Analyze, Evaluate 2 16 40 2.1.2 Attend Meetings 8 8 2.2.3 Prepare Reports 2 8 32 2.3 OUTAGE PERF'RMANCE O &
CAPITAL BUDGETS 2.3.1 Review, Analyze, Evaluate 16 16 2.3.2 Attend Meetings 8 8 2.3.3 Prepare Reports 16 16 2.4 REGULATORY PERFORMANCE 2.4.1 Review, Analyze, Evaluate 4
__48 _
==a=_;=_.--- ~~
==2.4!2 = Attend ~Me~etings- -- - - - - -
16 16 2.4.3 Prepare Reports 2 8 32 2.5 PERSONNEL & TRAINING 2.5.1 Review, Analyze, Evaluate 8 8 2.5.2 Attend Meetings 2.5.3 Prepare Reports 8 8 2.6 INP0 EVALUATION 2.6.1 Review, Analyze, Evaluate 8 8 2.6.2 Attend Meetings 8 8 2.6.3 Prepare Reports 8 8 2.7 OUALITY ASSURANCE PROGRAM 2.7.1 Review, Analyze, Evaluate 8 8 l 2.7.2 Attend Meetings 2.7.3 Prepare Reports 4 4 6
2.8 NUCLEAR FUEL l
2.8.1 Review, Analyze, Evaluate 16 16 2.8.2 Attend Meetings 8 8 2.8.3 Prepare Reports 8 8 l
Page 21
{
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM Monthly Annual Annual Basis Basis Total 3.1 ENGINEERING 3.1.1 Review, Analyze, Evaluate 2 24 3.1.2 Attend Meetings 3.1.3 Prepare Reports 1 12 3.2 CONSTRUCTION 3.2.1 Review, Analyze, Evaluate 4 48 3.2.2 Attend Meetings 2 24 3.2.3 Prepare Reports 2- _
e<3CT9._ . _ .
3.3 SYSTEM COMPLETION D'
3.3.1 Review, Analyze, Evaluate 2 24 3.3.2 Attend Meetings 3.3.3 Prepare Reports 1 12 3.4 PRE-OPERATIONAL TESTING 3.4.1 Review, Analyze, Evaluate 4 48
' ' ' ~ ~ ~ - - ~
3.4.2 Attend Meetings
~~~3 4.3 Prepare Reports
~
1 12 4
3.5 COST AND SCHEDULE 3.5.1 Review, Analyze, Evaluate 4 32 80 3.5.2 Attend Meetings 1 8 8 40 3.5.3 Prepare Reports 1 8 8 f;-
3.6 REGULATORY 3.6.1 Review, Analyze, Evaluate 3.6.2 Attend Meetings
- 3.6.3 Prepare Reports 3.7 STAFFING 3.7.1 Review, Analyze, Evaluate 3.7.2 Attend Meetings
- 3.7.3 Prepare Reports j/
p TOTAL 912
(
- Included in 2.4 and(2.8) total [r d
- , - ;?
s: )
i l
Page 22 l
. . - . - a
G l
CONSTRUCTION AND OPERATIONAL MONITORING PROGRAM 5.0 Resumes Page 23
NAME: James P. McGaughy, Jr.
POSITION: Director of Generation Services EDUCATION: B.S. , Electrical Engineering, MIT,1964 U.S. Navy Nuclear Power Training Program, 1964-65 M.S., Mechanical Engineering, Stanford University,1969 ENGINEERING REGISTRATION: Registered Professional Engineer PROFESSIONAL MEMBERSHIP: American Nuclear Society Institute of Electrical and Electronic Engineers EXPERIENCE:
Mr. McGaughy directs the power generation services function at Southern Engineering. He has 19 years experience in the nuclear generation field in the areas of licensing, design, construction, start-up, operation, and maintenance of nuclear power plants.
Mr. McGaughy has worked with top utility management to solve problems ,
on a wide range of power generation issues. He has successfully managed extremely large and complex generation projects which required 1 the rigorous maintenance of project schedules and quality.
Specific Experience Includes:
~~~~~~~~" Mississippi Power and Light Company - Mr.. McGaughy served .as. .V1.ce_.
- ~ .
__ _ _ _y President, Nuclear'(1983-84) and Assistant Vice President, Nuclear
- ~ ~ ~
l Production (1980-82). He was responsible for all aspects of construc- l tion and operation of a multi-billion dollar power generation facility.
In this capacity he hired and trained the nuclear power plant staff of over 500 people, including 29 licensed operators and numerous experienced utility managers. Mr. McGaughy also established a unique design engineering group which grew to over 125 people. During this tenure, cost and schedule performance was better than at any other similar plant (G.E. Boiling Water Reactor, BWR-6 design).
Mississippi Power and Light Company - Mr. McGaughy served as Director l of Power Production (1978-80). In this capacity he was responsible for all power production related activities including construction, operation, engineering, maintenance, licensing, staffing, and training. He prepared and administered annual personnel and operating budgets for 600 people and more than $50 million, and an annual capi-tal budget of $280 million. He also established a formal screening program for hiring craft personnel, established a formal preventive maintenance program, and reorganized his department based on job per-formance rather than time in grade.
Page 24
NAME: James P. McGaughy, Jr. (Continued)
Mississippi Power and Light Company - He served as Nuclear Project Manager (1976-78) and Assistant Project Manager (1973-75). He was responsible for forming and managing an organization to control the prime contractor on a $4 billion construction project. He began the formation of plant staff organization. He was also responsible for relations with the Nuclear Regulatory Commission and the prime contractor (Bechtel). The construction permit was awarded in record time.
Middle South Services, Inc. - Mr. McGaughy served as a nuclear engineer on the holding company staff responsible for economic and engineering studies including the feasibility evaluation for Grand Gulf Nuclear Station. He also perfonned nuclear fuel and uranium buying functions.
Arkansas Power and Light Company - Mr. McGaughy was responsible for nuclear fuel procurement and performed the licensing work including the preparation of the Safety Analysis Report for Arkansas Nuclear One, Unit 2.
l l
l.
l Page 25
1
. 1 l
l l
NAME: Harry James Green POSITION: Senior Consultant - Power Generation Services )
EDUCATION: U. S. Naval Advanced Nuclear Power School,1958 U. S. Naval Academy, B.S./ Engineering,1953 West Virginia University, Two Semesters / Mechanical Engineering, 1948-1949 Davis and Elkins College, Four Semesters / Engineering, 1946-1948 PROFESSIONAL MEMBERSHIPS: American Nuclear Society - ANS-3; Reactor Operations and Support Systems Management Committee Detroit Edison, FERMI-2 Nuclear Safety- Review Group EXPERIENCE:
As a Senior Power Generation Consultant for Southern Engineering, Mr. Green has 24 years of project experience in the field of utility management. His expertise is based on various assignments with Mississippi Power and Light Company, Tennessee Valley Authority, and the U. S. Navy. In these assignments, Mr. Green was responsible for numerous managerial and engineering projects, some of which are abstracted below.
Mr. Green was a full-time consultant to Mississippi Power and Light
~ Company during7he7erMd7f Tive pWcent o~pe~ ration, TUT 1 power licensing, and power ascension of Grand Gulf Nuclear Station.
As Director of Nuclear Power for the Tennessee Valley Authority, Mr. Green was responsible for those activities necessary to ensure the safe, efficient, and environmentally sound operation and maintenance of all the TVA nuclear generating plants and appurtenant facilities.
Mr. Green was the Assistant Manager, Power Operations for the Tennessee Valley Authority. In this capacity he assisted the Manager of Power Operations, whose responsibility included coordinating the operation and maintenance of a 31,000-MW electric generation and distribution system.
Also, while at Tennessee Valley Authority, Mr. Green was Power Plant Superintendent, Browns Ferry Nuclear Plant. In this position, Mr. Green was responsible for staffing, training, plant startup, and the operation and maintenance of the Browns Ferry Nuclear Plant--a 3-unit, 3,294-MW generating plant equipped with General Electric boiling water reactors and turbogenerators.
Page 26
NAME: Harry James Green (Continued)
As Assistant Power Plant Superintendent, Gallatin Steam Plant (also at TVA), Mr. Green was responsible for the operation and maintenance of the Gallatin Steam Plant. This was a 4-unit, 945-MW coal-fired generating plant located at Gallatin, Tennessee.
While in the U. S. Navy, Mr. Green attended the U. S. Naval Advanced Nuclear Power School and served in the Navy Nuclear Submarine Program.
4 1
i i
Page 27
O NAME: William A. Ruhlman POSITION: Senior Consultant - Power Generation Services EDUCATION: USNRC Basic, Advanced and Refresher Schools on PWR and BWR Systems, 1973-1979 Associate of Arts (Business Administration), Miami-Dade Junior College, 1973 PROFESSIONAL REGISTRATIONS: Registered Professional Nuclear Engineer PROFESSIONAL MEMBERSHIPS: American Society for Quality Control, Energy / Nuclear Division Korea Nuclear Society Nuclear Records Management Association EXPERIENCE:
As a Senior Power Generation Consultant for Southern Engineering, Mr. Ruhlman has 21 years of experience in utility management. His expertise is based on various assignments with Theophilus, Inc.,
USNRC, International Atomic Energy Agency, and several large southern utilities. In these assignments, Mr. Ruhlman was responsible for numerous managerial and engineering projects, some of which are
_ _ ab_strac.ted bel _ow. _. __. . _ . _ _ _ _ _ _ . . _.
At Theophilus, Inc., Mr. Ruhlman developed and documented an Operational Quality Assurance Program, including implementing proce-dure, for a large Southern utility. He also reviewed their activities for regulatory compliance and assisted in training their QA inspectors in techniques and requirements for inspection of areas of operations, preoperations, startup testing, quality control, and training.
Reviewed 0A programs for four (4) other utilities and provided com-ments, suggestions, and alternatives. Participated in internal nuclear utility audits and external audits and surveys of suppliers.
Conducted training programs for 0A and operations personnel .
As Assistant to the Director, USNRC, Region II, Mr. Ruhlman acted as Enforcement Coordinator and performed other functions for the Director of the Region. He also worked on the TMI task force in NRC headquar-ters for a three-month period.
Mr. Ruhlman was Acting Section Chief, USNRC, Region II for over one year. In this capacity, Mr. Ruhlman directed 'the Nuclear Support Section #2 (OA, procedures, training, maintenance) in carrying out all regul atory operations.
Page 28
NAME: William A. Ruhlman (Continued)
Prior to this, Mr. Ruhlman was Lead QA Inspector with USNRC, Region II. His responsibilities included training initial team of four inspectors and directing inspections of all companies / corporations licensed to operate nuclear power plants in the Region.
While at USNRC, Region I, Mr. Ruhlman was Reactor Inspector assigned to Nuclear Support Section #2. In this capacity, he performed inspec-tions of all operating plants and plants in the pre-operational phase in this Region. Inspection areas were primarily in Quality Assurance and training.
Mr. Ruhlman was 0A Expert with the International Atomic Energy Agency assigned to the Republic of Korea for three and one-half months. His responsibilities included inspecting PWR and PHWR operational and construction sites and making recommendations for QA programs to both the licensee and the regulator.
Page 29
NAME: Gregory M. Nickerson POSITION: Director, Project Development EDUCATION: MBA, Finance /0rganizational Management University of Hartford, West Hartford, Connecticut MS, Nuclear Engineering UCLA, Los Angeles, California BS, Engineering Analysis UCLA, Los Angeles, California PUBLICATIONS: Four on the subject of nuclear fuel properties and behavior.
EXPERIENCE:
As director of Project Development, Mr. Nickerson has dual respon-sibilities within Southern Engineering: providing project support and technical assistance to the Generation Services Departnent, and pro-viding direction to development of new projects for Southern's clients. Mr. Nickerson has over ten years of electric power industry experience in nuclear engineering design and analysis, and project management . He is familiar with the various NSSS plants systems, and the processes of NRC licensing commitment tracking and resolution of generic safety issues. He is also knowledgeable of LWR fuel systems design.
~~ '
Prior to joining Southern Engineeriog, Mr. Nickerson's professional
~
affiliations included a nuclear engineering consulting firm where his duties included project management for several tasks associated with the final design of V. C. Summer Plant. He also was affiliated with a major NSSS equipment supplier where his duties included transient safety analysis, nuclear fuel system performance engineering, project management, and resolution of nuclear licensing issues related to secondary side plant design.
Florida Power and Light /Ebasco Services / Combustion Engineering; St. Lucie Unit 2 Design Engineering Analysis - Responsibilities included overall coordination for drafting Chapter 15 to FSAR, main-taining PERT scheduling network for project, and tracking 50,000 manhour project budget. Specific tasks performed included: resolving technical design problems among AE and client organizations, design transient safety analysis for plant licensing, and quality assurance records preparation.
Electric Power Research Institute; Various Research Projects - Responsibilities included project develop-ment, execution and reporting. Specific tasks performed included the evaluation of nuclear fuel behavior models used by all LWR vendors, literature reviews, and progress reporting.
Page 30 l ;
6 NAME: Gregory M. Nickerson (Continued)
US00E Hanford Engineering & Development Laboratory; Fast Test Reactor - Responsibilities included evaluation of design and safety criteria for the purpose of establishing a carbide fuel test position in the FTR. Specific tasks included the review and evaluation of existing reactor design and safety documentation to determine the adequacy of the proposed test. Progress reporting included recommen-dations for needed procedural changes.
Southern California Edison; Mandalay Generating Station - Responsibilities included plant main-tenance and performance testing. Specific tasks included establishing procedures for oil storage and shipment to sister station at Ormond Beach, maintenance scheduling and heat rate optimization.
Page 31 l
l
.