ML20246H514
| ML20246H514 | |
| Person / Time | |
|---|---|
| Site: | 05508347 |
| Issue date: | 05/09/1989 |
| From: | Hunemuller N, Zwolinski J Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML20246H520 | List: |
| References | |
| CON-#289-8593 TAC-68699, TAC-68700, NUDOCS 8905160120 | |
| Download: ML20246H514 (40) | |
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NUCLEAR REGULATORY COMMISSION sA
-m BEFORE THE ATOMIC SAFETY AND LICENSING B0ARD f 0
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stWgc??,Ma In the Matter of
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G-MAURICE P. ACOSTA, JR.
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Docket No. 55-0834? b A
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Operator License No. 6010-2
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DIRECT TESTIMONY OF NEAL K. HUNEMULLER AND JOHN A.
ZWOLINSKI IN SUPPORT OF NRC STAFF'S ORDER OF JUNE 15, 1988 Q1.
Please state your names, position and business address.
A1.
(NKH) My name is Neal K. Hunemuller i
I am a Reactor Engineer in the Operator Licensing Branch of the Division of Licensee. Performance and Quality Evaluation in the Office of Nuclear Reactor Regulation (NRR).
My business address is U.S. Nuclear Regulatory Commission Washington, D.C.
20555 A1.
(JAZ) My name is John A. Zwolinski I am the Deputy Director of the Division of Licensee Performance and Quality Evaluation in NRR.
My business address is the same as Mr. Hunemuller's.
Q2.
Please describe your educational and professional experience.
A2.
(NKHandJAZ)Statementsofoureducationalandprofessional qualifications are attached to this testimony as Attachments 1 and 2, respectively.
Q3.
Mr. Hunemuller, please summarize your experience as a Shift Technical Advisor and Senior Reactor Operator.
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A3.
(NKH) As an employee of the Iowa Electric Light & Power Company (Iowa Electric), I served as a Shift Technical Advisor (STA) and later as an Operations Shift Supervisor (OSS) at the Duane Arnold Energy Center (DAEC) located in Palo, Iowa. The DAEC is a 1658 megawatt thermal, 560 megawatt electrical,
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nuclear power plant, utilizing a General Electric (GE) boiling water reactor (BWR), GE turbine and GE generator.
3 After completing approximately 1,000 classroom hours of training at Iowa Electric, emphasizing those subjects which an STA would require to perform his duties in_ assisting the OSS during accidents, transients, and abnormal events, I assumed the duties of the STA in accordance with the shift manning requirements in the DAEC Technical Specifications.
I spent one year on the rotating shift actively performing the duties of the I
STA as part of the control room crew. Those duties consisted largely of writing incident reports for reportable events or as requested by the OSS, reviewing completed Surveillance Test Procedures, and observing the control room operations.
After one year as an STA, I was selected for Senior Reactor l
Operator (SRO) training. This consisted of approximately 1,700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> of additional classroom training in theory, plant design, l
and procedures at Iowa Electric. Shortly after completing this training, I was assigned to assist the Detailed Control Room Design Review (DCRDR) and subsequently became the DCRDR Team Leader.
I recieved my Senior Operating License in January,1986 and became a member of the Operations Department as an OSS.
Due 1
_. l to my involvement with the DCRDR, and later with the simulator I
project, my time on shift, actively performing the duties of the OSS, was limited. From the time I received my license until the new 10 C.F.R. 5 55 rule became effective in May 1987, I spent approximately 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> actively performing the duties of the
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OSS as part of the control room crew. After the new 10 C.F.R. 6 55 rule became effective I ceased to maintain an active status regarding my license since it was no longer a regulatory requirement.
However, during the entire time I held the license' I participated in the requalification training program.
Q4.
What qualifications must an individual possess in order to be considered for a reactor operator's license and renewal?
A4.
(NKH) In accordance with 10 C.F.R. 55, an applicant for a license must, among other things, have a medical examination.
Holders of licenses must have a medical examination every two years.
These medical examinations are to determine that the applicant's or operator's medical condition and general health will not adversely affect the performance of. assigned operator job duties or cause operational errors endangering public health and safety.
Form NRC-396, " Certification of Medical Examination by Facility Licensee," must be provided for application. An applicant must successfully complete the facility licensee's requirements to be a licensed operator and the facility licensee must provide evidence of the need for the applicant to perform operator duties. The applicant, as a trainee, must have I
successfully manipulated the controls of the facility for at
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l 4 I least five significant control manipulations which affect reactivity or power level.
Holders of licenses must be participating in a requalification training program.
The specific requirements for obtaining an operator's license are set forth in Attachment 3 to this testimony.
Q5.
What training is typically required before an individual can receive a reactor operator's license and maintain it?
AS.
(NKH) In accordance with ANSI /ANS-3.1-1981 as endorsed by Regulatory Guide 1.8, training should include fundamentals, systems, operating practice, general employee training, and requalification.
A fundamentals course should cover the theory of the nuclear fission process and reactor operation. The course should contain instruction in: (1) Principles of reactor operation.
(a) Atomic structure and radioactivity.
(b) Nuclear reaction and the fission process.
(c) Neutron behavior and control of the fission process.
(d) Core'and Nuclear Steam Supply (NSS) characteristics thermal hydraulic design.
4 (2) Design features of the nuclear power plant.
(3) General operating characteristics of the nuclear power plant.
(4) Reactor instrumentation and control systems.
(5) Radiation control and safety provisions, i
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(6) Fundamentals of heat transfer, thermodynamics and fluid flow related to transient analysis.
The course should contain instruction in mathematics, electricity, mechanics and other subjects of a theoretical or engineering nature in support of the preceding listing.
Systems instruction for a licensed candidate should include both observation and classroom work. This instruction shall be plant specific.
Instruction covering nuclear power plant systems should include the following:
Plant iristrumentation and control systems Safety, fire and secondary mechanical systems Electrical systems Plant auxiliary and support systems Plant protection systems Fuel handling systems Waste processing systems Integrated plant operation, system interactions and casualty
. response.
Use of installed plant systems for the control and mitigation of.
an accident in which the core is severely damaged.
This instruction should also include system and component malfunctions.
Planned systematic observation training of license candiciates should be performed on accessible plant equipment.
Emphasis should be on understanding system operation, local plant control, system interactions and indication.
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Training in operating practices should take place both in the control room for which the candidate will undergo an examination _for a license, and at a simulator if one is available.
1 Instruction during this period should include:
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(1) Standard and emergency operating procedures.
'(2) Plant transients.
(3) Accident identification and analysis including trending.
(4) Controlling the plant from a central control room during normal, abnormal and emergency situations.
(5) -Operating philosophy, use of procedures, shift and relief turnover, and verification of system status.
Candidates should observe the operating practices and the operation of a nuclear. power plant from a central control room.
Hot license candidates shall manipulate the controls under the direct supervision of a licensed operator at the individual's duty station for a variety of plant operations.
Candidates should practice manipulating the controls of a plant as represented by an applicable simulator.
Examinations using the si.nulator should be provided, and should include an i
examination while operating at power with plant malfunctions, l
and while starting up the reactor. The certification examination should demonstrate the candidate's ability to:
(1) manipulate the controls in a safe and competent manner,
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L (2) predict instrument response and use the instrumentation available,
.(3) follow the facility procedures, and (4) understand alarms and annunciators and take proper' action, and (5) communicate promptly and effectively.
A comprehensive examination to determine the individual's ability to operate the plant in a safe and competent manner
-should be administered by the owner organization. 'This examination should be required prior to certification of competency of this individual to the NRC.
Oral and written examinations are encouraged. An intensive period of instruction prior to the NRC license examination should be provided.
Operating features of the facility. design and experience at similar plants should be included.
Regarding general employee training, all persons regularly employed in the nuclear power plant should be trained in the following areas commensurate with their job duties:
General Description of Plant and Facilities Job Related Procedures and Instructions.
Radiological Health and Safety Program Station Emergency Plans Industrial Safety Program Fire Protection Program Security Program
Quality Assurance Program.
The individual's understanding of the information provided by this program should be evaluated by. administering an examination of sufficient difficulty covering the previously listed areas to ensure the individual has sufficient knowledge to work independently at the facility.
Individuals who do not pass this examination will not be permitted inside the protected area without a full time escort.
The last phase of required training is that needed to maintain a license. This phase is called requalification and it is a continuing retraining program which covers material similar to the initial training as well as additional material.
This retraining program should be established to maintain the proficiency of the operating organization. Mechanisms should be established to ensure that individuals in the operating organization performing safety related functions remain cognizant of charaes to the facility, procedures, governmental regulations, and quality assurance requirements as j
well as industry operating experience, Licensee Event Reports 1
(LERs), and personnel errors as applicable for their area of responsibility.
Personnel temporarily removed from or prevented from performing operating activities for periods greater than six months should be requalified for their specific job duties.
Annual retraining programs should include pre-planned lectures, on-the-job training and operator evaluation on a regulator and
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continuing basis. A simulator should be used to fulfill portions of the retraining program for those evolutions where the simulator is capable of simulating continuously and in real time plant operations of the referenced facility.
The following control manipulations and plant evolutions where applicable to the plant design are acceptable for meeting the reactivity control manipulations required. The starred items should be performed annually; all other items should be performed on a two-year cycle. Multiple failure casualties should be included in the program. However, the requalification 4
programs should contain a commitment that each individual perform or participate in a combination of reactivity control manipulations which may be perforced as part of normal plant evolutions. Those control manipulations which are not performed at the plant should be performed on a simulator.
The use sf the Technical Specifications should be maximized during the simulator control manipulations.
- (1) Plant or reactor startups to include a range that reactivity feedback from nuclear heat addition is noticeable and heatup rate is established.
- (2) Plant shutdown.
- (3) Manual control of steam generators or feedwater, or both, during startup and shutdown.
(4) Boration or dilution, or both, during power operation.
- (5) Any significant (10 percent) power changes due to i
manual changes in control rod position or recirculation flow.
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- (6). Loss of coolant including:
1.
Significant steam generator tube leaks.
2.
Inside and outside primary containment.
3.
Large and small, including leakrate determination.
4.
Saturated Reactor Coolant response.
(7) Loss of instrument air (if simulated plant specific).
(8) Loss of electrical power (or degraded power sources, orboth).
- (9) Loss of core coolant flow / natural circulation.
(10) Loss of condenser vacuum.
(11) Loss of service water is required for safety.
(12)Lossofshutdowncooling.
(13) Loss of component cooling system or cooling to an individual component.
(14) Loss of normal feedwater or normal feedwater system failure.
- (15) Loss of all feedwater (normal and emergency).
(16) Loss of protective system channel.
(17) Mispositioned control rod or rods (or rod drops).
(18) Inability to drive control rods.
(19) Conditions requiring use of emergency boration or standby liquid control system.
(20) Fuel cladding failure or high activity in reactor coolant or offgas.
(21) Turbine or generator trip.-
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(22)Malfunctionofautomaticcontrolsystem(s)which affect reactivity.
.(23) Malfunction of reactor coolant pressure / volume control system.
(24)'Reactortrip.
(25) Main steam line break (inside or outside containment).
(26)'Nuclearinstrumentationfailure(s).
The requalification program should include review of system operational requirements including limitations, set points, trips, alarms and the required operator response to alarm and trip conditions.
Acceptable methods to demonstrate this training may include; but are not limited to:
(1) Manipulation of the systems and their associated equipment.
(2) A walk-through of the procedural steps required to start, stop or change conditions of the systems.
(3) An applicable simulator may be used to demonstrate knowledge of plant systems; however, walk-through is required to demonstrate knowledge of physical characteristics of plant systems.
i The program should clearly indicate the methods to be employed to assure each licensea individual is cognizant of facility design changes, procedure changes, facility license changes, and operating experience.
The program should indicate the methods to be employed to assure each licensed individual reviews the abnormal, emergency and security procedures.
The security procedures covered should include only those which plant personnel have a need to know.
Annual examinations should be given to each licensed operator and senior operator. The examination should contain categories of examination questions as follows:
a.
Theory and principles of operation, b.
General and specific plant operating characteristics.
c.
Plant instrumentation and control systems, d.
Plant protection systems.
e.
Engineered safety systems.
f.
Normal, abnormal, and emergency operating procedures.
g.
Radiation control and safety.
h.
Technical Specifications.
i.
Applicable portions of Title 10, Chapter 1, Code of Federal Regulations.
j.
Operating experience from similar plants.
k.
Operating philosophy, use of procedures, shift and relief turnover, and verification of system status.
1.
Fundamentals of heat transfer, thermodynamics, fluid flow and dynamics as related to transient analysis.
m.
Responsibilities during emergency conditions.
An annual oral requalification examination should be given.
It should be noted that the term "requalification training" does not mean only retraining on previously covered material.
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It also includes training on facility changes, procedure l
changes, facility license changes, and operating experience.
The operator is constantly required to learn new material as well as to reinforce prior training.
Q6.
At San Onofre Units 2 and 3 what is the makeup of an operating shift?
A6.
(NKH) In accordance with San Onofre-Unit 2 Technical
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Specifications, Amendment No. 16, Table 6.2-1, " Minimum Shift Crew Composition," If Unit 3 is in Cold Shutdown, Refueling or De-fueled and Unit 2 is in Power Operation, Startup, Hot Standby or Hot Shutdown then there shall be:
1 Shift Supervisor (SS) with a Senior Reactor Operators License on Units 2 and 3 who may also fill the same position on Unit 3.
1 Senior Reactor Operator (SRO) licensed on Units 2 and 3 2 Reactor Operators (RO) licensed on Units 2 and 3 2 Auxiliary Operators (A0) 1 Shift Technical Advisor (STA)
If Unit 3 is in Cold Shutdown, Refueling or Defueled and Unit 2 is in Cold Shutdown or-Refueling then there shall be:
1 SS who may also fill the same position on Unit 3 l
1 RO who may also fill the same position en Unit 3 2 A0s one of which may fill the same position on Unit 3 If both Units 2 and 3 are in Power Operation, Startup, Hot Standby or Hot Shutdown (in any combination) then there shall be:
1
1 SS who may fill the same position on Unit 3 1 SR0 who may fill the same position on Unit 3 2 R0s one of which may fill the same position on Unit 3 2 A0s one of which may fill the same position on Unit 3 1 STA who may fill the same position on Unit 3 If Unit 3 is in Power Operation, Startup, Hot Standby or Hot Shutdown and Unit 2 is in Cold Shutdown or Refueling then there shall be:
1 SS who may fill the same position on Unit 3 1 R0 1 A0 For no longer than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> the Shift Crew may lack one of the above personnel, except for the SS, in order to accommodate unexpected absences of on-duty shift crew members provided immediate action is taken to restore any missing personnel.
This does not allow a position to be unfilled upon shift change due to an oncoming person's tardiness or absence.
During any absence of the SS from the Control Room Area while Unit 2 is in Power Operations, Startup, Hot Standby or Hot l
Shutdown, an individual (other than the STA) with a valid SR0 f
l license shall assume the Control Room command function. During I
any absence of the SS from the Control Room Area while the unit j
is in Cold Shutdown or Refueling an individual with a valid SR0 or R0 license shall assume the Control Room command function.
In accordance with Operations Division Procedure S0123-0-30, Revision 0, TCN0-7, dated Sept. 29, 1988, " Shift i
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Manning", the Control Room command function carries with it the command responsibilities for operation of the specified unit including primary responsibility for directing the operators in the implementation of Emergency Operating Instructions.
Q7.
What, in general, are the reactor operator's responsibilities and duties?
A7.
(NKH). In accordance with Operations Division Procedure S0123-0-3, Revision 0, TCN-0-1, dated June 29, 1987, " Control Operator's Responsibilities and Duties", the Unit Reactor Operator (RO) is the R0 assigned to a specific unit. The Common R0 is the R0 assigned to those systems shared by Unit 2 and 3.
Responsibilities:
1.
The R0 is directly responsible to the SR0 Operations Supervisor.
2.
The R0's primary responsibility is the safe and efficient operation of his assigned equipment.
3.
The R0 is responsible for operation within the requirements of the Operating License, Technical Specifications, orders of the Nuclear Regulatory Commission, approved Station procedures and operating instructions.
4 The Unit R0 is responsible and authorized to shutdown the reactor if he determines the safety of the unit is in jeopardy, or if operating parameters exceed the reactor protection setpoints and an automatic shutdown has not occurred.
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5.
It is the responsibility of the R0 not to base operational decisions solely on a single plant indication when.more than one indication of the same parameter is available.
Readings from non-qualified instruments exposed to post-LOCA(lossofcoolantaccident)environmentsshouldbe checked against qualified instruments if possible.
6.
It is the responsibility of the R0 not to manually override any emergency safety system unless continual operation could result in unsafe plant conditions, e.g.,
overpressurization of the reactor coolant system.
7.
During emergencies, the R0 is responsible to identify himself to and assist in clearing the Control Room of unnecessary personnel.
8.
The R0 is responsible for taking timely and appropriate action in accordance with existing procedures during abnormal or emergency conditions.
9.
It is the R0's responsibility to notify the Shift Superintendent of any emergency condition as soon as possible.
10.
It is the R0's responsibility to be cognizant of the Unit's Emergency Operating Instructions, shall commit to memory the immediate actions of the Emergency Operation l
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Instructions and shall reference these Instructions after l
l' implementation.
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- 11. The R0 is responsible for reviewing routine operating data to. assure safe operation and to maintain the capability to shutdown and cooldown the unit.
12.
It is the responsibility of the R0 to be cognizant of construction, modification, maintenance or engineering activities in the station which might jeopardize the capability of reactor shutdown and cooldown.
- 13. The Unit R0 is responsible for directing the activity of licensed and nonlicensed personnel on the assigned unit under the supervision of the SR0 Operations Supervisor.
1.
For the Common R0, these activities shall only be on common systems, and shall not directly affect reactivity or power level of the reactor (s).
14.
The R0 assumes the responsibility and authority to direct the activities of other operating personnel as required during the absence of the Shift Superintendent and Control Room Supervisor from the Control Room.
1.
When in Cold Shutdown or Refueling, the Control Room Command Function may be passed to a licensed R0 during the absence of the Shift Superintendent and the Control Room Supervisor from the Control Room area.
15.
Each R0 shall have jurisdiction of his assigned equipment.
i 1.
Units 2 and 3 Unit R0's equipment responsibilities are listed on Attachment 4.
2.
Common R0's equipment responsibilities are listed on.
- 16. -The R0, or his designee, is responsible for the issuance of all Work Authorizations and shall ascertain that the workmen are aware of the hazards and safety significance of the equipment they are working on.
- 17. The Common R0 is responsible for coordination of outages on electrical distribution systems which affect the operatisa of the respective unit (s).
- 10. The R0 is responsible for the use of safe and efficient operational work practices to keep personnel radiation exposure "As Low As Reasonable Achievable" (ALARA).
Duties 1.
Prior to assuming the position of on-shift R0, the on-coming R0 shall relieve the off-going R0.
2.
The R0 shall maintain a log of shift activities.
3.
The R0 shall monitor Control Room indications, operate Control Room controls, and direct all manual adjustments and operations as needed to maintain control of the various assigned system processes.
4 The R0 shall perform the following:
1.
Ensure Control Room round sheets or shift relief status logs and surveillance are completed in the assigned time frame.
2.
Report to the SR0 Operations Supervisor any out-of-specification conditions, and keep him informed of corrective action, i
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3.
Review completed round sheets for equipment trends.
5.
The R0 shall perform routine operations under the supervision of the SR0 Operations Supervisor and direct the assistantR0andPlantEquipmentOperator(PE0)inthe performance of their duties during all phases of plant operation in accordance with applicable procedures and instructions.
6.
The R0 shall not. leave the Control Room without being properly relieved.
7.
The R0 shall make periodic inspections of the Control Room instrumentation and controls. The frequency is dependent upon plant status and the conditions that prevail on individual systems or components.
In cases where very frequent observations are necessary, delegation to an assistant R0 may be advisable.
1.
The Control Room and the relay rack area immediately behind the Control Room panel are classified as a Vital area for the purposes of the Station Security Plan.
Observance of any abnormal condition related to equipment in this area that is not readily explained should be treated as a potential act of sabotage and reported immediately to the Shift Superintendent.
8.
Inconsistent instrumentation response between radiation monitoring channels and their associated recorders shall be reported to the SR0 Operations Supervisor. The on-shift i
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-Nuclear Chemical Technician shall be notified to collect appropriate samples.
9.
Indication above expected reading on any release path radiation monitor shall be reported to the SR0 Operations Supervisor and an evaluation shall be performed to identify the source.
10.
The R0 shall notify the Nuclear Chemical Technician of any operational transients (such as changes in status of blowdown or releases, load changes, or maintenance of equipment) so that appropriate samples may be taken.
11.
The R0 shall notify the Health Physics Technician of any operational transients which might result in changes in radiation or contamination levels in the plant.
12.
The R0 should make himself aware of plant status by discussing plant conditions with shift personnel.
In turn, the R0 should keep shift personnel informed of activities occurring in their areas that they may not be aware of.
13.
The R0 shall keep the Shift Superintendent and the Control Room Supervisor aware of plant status and of any unusual or abnormal conditions.
14 The R0 shall read and understand System Operating Bulletins, Technical Specifications, Operating Instructions, Special Orders, Emergency Procedures and Abnormal Operating Instructions.
K 15.
Common R0 shall write switching orders on orders from the System Operating Supervisor, Mira Loma Switching Center operator.or the Shift Superintendent.
- 16. The Common R0 should notify the Energy Control Center of L
all developments or events which pose a threat to SONGS operating capacity and make a log entry regarding the notification.
- 17. The Unit R0 shall load the assigned unit as directed by the System Operating Supervisor or as emergency conditions may.
dictate within the guidelines of'the Technical Specifications.
- 18. The Common R0 shall log and notify the Switching Center of any unusual arcing or noise in the switchyard or towers beyond the switchyard,
- 19. The Common R0 shall normally function as the Fire Department's Technical Advisor for Units 2 and 3.
This position shall be fulfilled by a licensed individual or other operator with similar plant knowledge.
The Fire Department's Technical Advisor shall:
1 1.
Coordinate and advise or assume command authority in all matters concerning the effects of fire, smoke, heat and fire suppressants on the Plant Safe Shutdown capability.
2.
Report the plant safety and operational impact of the fire to the Shift Superintendent and assist in accident classification.
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20.
When notified by the operator of upcoming evolutions, which are known to cause plant vent stack alarms, the R0 shall inform affected Control Room personnel and Shift Supervision.
21.
The R0 shall assist assistant R0's and PE0's in preparation for advancement and assist in the development of trainees.
assigned to the station.
- 22. The R0 shall assist in the preparation of Operating Instructions, abnormal evolutions and alignments and training material under the direction of.the SR0 Operations Supervisor.
- 23. The R0 should follow a course of study and observation that will prepare him for advancement.
24.
The R0 shall attend all required training as scheduled.
25.
The R0 shall perform light housekeeping duties in the Control Room in order to maintain a clean, safe work area.
Q8.
In what ways is the reactor operator responsible for directing the actions of other plant personnel?
A8.
(NKH) The reactor operator is directly responsible for coordinating the actions of the non-licensed personnel on the shift crew and the licensed personnel that work with him. The reactor operator should ensure the plant operations performed outside the control room neither degrade, nor needlessly challenge, the safety functions of plant equipment.
He must also be aware of other activities in the plant which may impact plant operations. These activities include, w__________
for example, ongoing maintenance, surveillance tests, area radiological surveys, and construction work. The reactor operator may need to direct the actions of personnel conducting i
these activities in order to protect plant equipment, plant personnel, or the health and safety of the public.
A Senior Operator normally has-overall responsibility for directing all plant operations during a shift.
However, the reactor operator is responsible for carrying out the directions of the Senior Operator and this often means directing the detailed actions of others.
Q9.
What types of procedures is the reactor operator directly responsible for performing?
A9.
(NKH) The reactor operator is responsible for performing the operations delineated in:
- individual systems' normal operating procedures, i
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- integrated plant normal operating procedures,
- annunciator or. alarm response procedures,
- selected equipment surveillance test procedures,
- abnormal conditions operating procedures, and
- emergency operating procedures.
Furthermore, he is responsible to perform his duties in accordance with the plant's administrative procedures.
Q10.
For what types of procedures is the reactor operator indirectly responsible for performance or coordination?
l A10.
(NKH) The reactor operator is indirectly responsible for the performance of:
1
4.
- maintenance procedures,
- the remainder of the surveillance test procedures,
- health physics or radiological and chemical control procedures,
- plant modification procedures He is responsible for these procedures to the extent that he ensures that activities occuring.while he is on duty, which are governed by these procedures, neither degrade plant safety nor endanger plant equipment, personnel or the public.
Q11.
What are the immediate duties and responsibilities of each reactor operator on shift during transient or accident conditions?
All.
(NKH) The primary responsibility of the reactor operator under these or any conditions is to protect the health and safety of the public.
He is also, as always, responsible for the protection of the health and safety of plant personnel and the protection of plant equipment.
The immediate duties of the reactor operator generally are defined by procedures such as annunciator or alarm response procedures, plant trip or scram procedures, abnormal operating procedures, and emergency operating procedures.
Prerequisites to performing these duties normally include acknowledging alarms, verifying' automatic actions, assessing the plant conditions, and recognizing the entry conditions to the applicable procedures.
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The reactor operator is well-trained on the immediate actions necessary to put the plant in a safe condition.
In spite of this, as soon as time allows, he will review the appropriate procedures to verify all of the immediate actions have been completed and begin the follow-up activities.
Q12.
Are all the duties of a reactor operator the subject of detailed procedures which ca'n be learned and performed by rote?
A12.
(NKH) No, there are far too many procedures for anyone to memorize all of them. Moreover, even those procedural steps which are memorized cannot be performed without thinking.
It is the reactor' operator's duty to comply with procedures but, it is also his responsibility to understand the intent of those procedures and determine whether they are applicable to any 1
given situation. The reactor operator must constantly use his judgment based on his knowledge of plant procedures, technical specifications, equipment and his assessment of the condition of the plant.
The reactor operator relies on procedures for guidance to operate the plant safely but procedures cannot l_
encompass every situation which may arise.
For those duties l
which are the subject of detailed procedures the operator should understand the purposes and limitations of those procedures.
.Q13.
Then, what kinds of decisions is a reactor operator expected to make which are outside procedural guidelines or which require his good judgment?
A13.
(NKH) The power plant exists to generate electricity for the utility's customers. Therefore, the reactor operator should I
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. l strive to keep the plant operating and producing as nicch power for as mach time as possible.
However, the primary responsibility of the reactor operator is to protect the health and safety of the public. These objectives are certainly not mutually exclusive but do often require the reactor operator to exercise good judgment.
j For example, the reactor operator may need to judge how rapidly a transient is progressing and decide whether he should initiate an immediate reactor trip (or scram), or simply reduce power, or take some other action which would leave the plant in a safe condition yet operating at full power. Another example is the determination of whether to override plant safety systems' operations.
Procedures may allow or recommend 'that safety features be overridden in certain situations.
The reactor operator must judge both the consequences of taking, and not taking, this action. Under some conditions, to allow the safety function to occur may result in unnecessary recovery time or even further degradation of the plant's safe operation.
The decision to shutdown the plant or override a safety system function cannot be made lightly.
An unnecessary loss of electrical generation is clearly undesirable.
Yet, if a safety system is operated incorrectly it may result in undue risk to the public. The reactor operator must exercise good judgment and he and the regulators need to have confidence in his decision-making ability.
- I.. t Q14 Have you ever been present in the control room as a-Shift Technical Advisor or an Operations Shift Supervisor at the time of an abnormal occurrence? If so, please describe the actions taken by the reactor operator including the time available to take those actions.
A14.
(NKH)Ihavebeenpresentinthecontrolroombothasa Shift Technical Advisor and as an Operations Shift Supervisor at the time of several abnormal occurrences.
For clarification, none of these were of severe accident proportions which had the potential for any significant radioactive releases to the public. That is to say, most actual events to date termed.
" abnormal occurrences", while they may have seriously impacted continued power operation, rarely have had the potential to harm the health and safety of the public.
I think it is appropriate to recall the event which provides the best example of the need for the reactor operator's good judgment and ability to assess the plant situation. The cause of this particular incident was a body-to-bonnet leak from a recirculation pump discharge bypass valve.
This was a typical small leak from the primary coolant system into the primary containment.
While the systems may be considerably different between the DAEC and the San Onofre Nuclear Generating Station I
Units 2 and 3, a leak of the primary coolant into the primary containment is possible at either plant.
I was on-shift as an STA when this incident occurred.
I chose the following event because I thought it was the best example I experienced where a l
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reactor operator needed to weigh the consequences of his actions based on their_ impact on the health and safety of the public versus plant availability.
As a result of the leak, primary containment pressure and temperature were gradually increasing. The reactor operator observed this and reported it to the OSS, postulating that a small leak had developed. Both the OSS and the reactor operator were aware that if primary containment pressure continued to increase, an automatic reactor scram and many automatic Emergency Core Cooling Systems (ECCS) initiations would occur.
The OSS and reactor operator evaluated the rate of primary containment pressure increase and decided that it was slow enough to allow the OSS to contact plant management while the reactor operator attempted to locate and isolate the leak. The reactor operator determined the probable leak location and that it was unisolable.
Upon the recommendation of plant management, the OSS directed the reactor operator to equalize pressure between the drywell and suppression pool and to manually scram the reactor prior to exceeding the ECCS initiation setpoint.
Here is where the reactor operator had to use his judgment.
He had been trained that the differential pressure maintained between the drywell and suppression pool was a conservative safety feature. Therefore, he had to judge the merits of equalizing pressure to avoid unnecessary ECCS initiation versus the safety function of the differential pressure. He also had to judge the merits of taking manual action in order to prevent
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automatic actions designed to put the plant in a safe condition.
In this case, the reactor operator did not contest the given direction. The plant was put in a safe condition and the recovery time was minimized.
In this event there was sufficient time for consultation with the OSS and plant management prior to taking action.
However, time was limited if the ECCS initiations were to be avoided.
The reactor operator had to make his decisions within minutes. 'Although he had more than a few seconds, he'did not have ten minutes.
Q15.
Are there built-in checks on every duty a given reactor operator performs? If so, what are these checks?
A15.
(NKH) No, while there are many built-in checks, they do not encompass every duty a given reactor operator performs. There are annunciators which alarm the operator to equipment malfunctions or abnormal conditions.
(According to the " Control Room Design Review Report" for SONGS Units 2 & 3, SCE Document No. M37328, there are approximately 2150 alarm windows total for both units). There are system interlocks enforced by electrical logic which prevent misoperation. There are computers which can monitor the plant and provide information to the reactor operator.
There are also the many control board indications which provide information. The other personnel on the shift crew provide additional checks on the duties of any given operator.
However, in spite of the many redundant safety features of a nuclear power plant, the reactor operator is the
one who must determine the validity of alarms, decide whether to override interlocks, and interpret the feedback he receives.
The safe operation of the plant relies heavily on the knowledge and abilities of the reactor operator as well as on good plant design which incorporates built-in checks.
Q16.
State the basis for the issuance of the June 15, 1988 Order l
which the Staff issued to Mr. Maurice P. Acosta, Jr.
A16..
(JAZ) The Staff believes that one way to ensure that the public health and safety is protected is for licensees of l
nuclear power plants to develop policies and implementing procedures in those areas relevant to plant. safety.
It is critical that licensed reactor operators, who directly control the operation of nuclear power plants, adhere strictly to those policies and implementing procedures. We consider SCE's Fitness for Duty program (FFD) to be clearly relevant to safety. It is our position that Mr. Acosta violated SCE's FFD program which could impact on safety and as such he could not be trusted to exercise good judgment while at the controls of a nuclear power plant. The staff issued the Order in recognition of the fact that Mr. Acosta had tested positive for marijuana for a third time. Thus, it was the position of the Staff that he had demonstrated a lack of reliability, trustworthiness and an inability to exercise sound judgment in not adhering to this important SCE policy.
Accordingly, we chose to suspend his operator's license and to deny his pending application for renewal.
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The Staff's position with respect to power reactors and licensed reactor operators is that public health and safety must not be compromised. Thus, the Staff is very sensitive to issues which have the potential of compromising plant safety. As noted in the June 15, 1988, Order:
[Mr. Acosta's] history of positive drug tests indicates a continuing use of marijuana and violation of SCE's drug program. This suggests a pattern of behavior and lack of sound judgement that may be inimical to the public health and safety.
The failure of [Mr. Acosta] to conform to SCE's prohibition against illegal drug use, which has the purpose of protecting the public health and safety, demonstrates a disregard of the important obligations of a licensed operator and of the public's trust in him. While the tests themselves do not necessarily establish that [he]
was incapacitated at the time the samples were taken, the NRC does not have the necessary reasonable assurance that the Licensee will carry out his duties in the future with sufficient
- 53 Fed. Reg. at 24384.
alertness and ability
- Operators trust.be trustworthy and reliable in the exercise of their duties. Mr. Acosta's repeated failure to follow SCE polices regarding the Fitness for Duty program reflects seriously on his trustworthiness, reliability and ability to exercise sound judgment.
In sum, by virtue of his repeated violation of SCE policy and implementing procedures Mr. Acosta has, demonstrated a lack of trustworthiness reliability and has exercised poor judgment.
For these reasons the Staff no longer
'has reasonable assurance that Mr. Acosta can continue to carry out his duties as a licensed reactor operator, l
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ATTACHMENT 1 NEAL K. HUNEMULLER' STATEMENT OF EDUCATIONAL PROFESSIONAL EXPERIENCE EDUCATION Iowa State University, Ames, Iowa Bachelor of Science in Nuclear Engineering, 1980 LICENSES SeniorReactorOperator(SOL #30565)
Duane Arnold Energy Center (DAEC)
CERTIFICATIONS CertifiedShiftTechnicalAdvisor(STA)
Engineer-in-Training #6237, Iowa State Boar /. of Engineering Examiners EXPERIENCE BACKGROUND U.S. NUCLEAR REGULATORY COMMISSION October, 1988 OPERATOR LICENSING BRANCH to Rockville, MD Present Administers 7he simulation facility evaluation program..' Assembles and serves as team leader for review teams.
Reviews simulation facility certifications and documents results of these evaluations. Monitors plans for development of non-ANS-3.5 simulation' facilities.
IOWA ELECTRIC LIGHT & POWER COMPANY April, 1988 TRAINING DEPARTMENT tedar Ra ids, Br, Supervisor, continued technical IA Duane Arnold Energy Center to As the imu at October, 1988 support to.the simulator procurement project while also providing administration and technical direction for.the development of the permanent staff and procedures necessary to support simulator maintenance, operation and related activities.
April, 1987 OPERATIONS DEPARTMENT to Cedar Rapids, IA Duane Arnold Energy Center April, 1988 Tsrf6rmed Lead'Te,chnical Engineer's duties for the Training Department's ongoing procurement of a plant specific control room simulator.
Completed a two week course at the Gould Computer Systems Division and a three week course at Link Simulation Systems Division.
January,1986 OPERATIONS DEPARTMENT to Cedar _ Rapids, IA, Duane Arnold Energ Center April, 1987 FsrT5rmed on-sETft Operation ShTit supervisor "B" duties. Provided administrative and technical direction for the Detailed Control Room Design Review (DCRDR)astheDCRDRTeamLeader.
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Neal Hunemuller Page 2 I
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April, 1983 DESIGN ENGINEERING DEPARTMENT Cedar Ra) ids, iring to IA, Duane Arnold Energy Center January,1986 System _s Engine Completed STA training.
Performed on-shift STA duties. Performed post-SCRAM and other post-incident analyses.
Reviewed NRC letters and bulletins. Completed SRO Training. Provided technical assistance to the DCRDR.
September, 1982 DESIGN ENGINEERING DEPARTMENT to Cedar Rapids, IA, Duane Arnold Energy Center April, 1983 THe Engineeriiig Diviloped design changes, verified and closed design change packages. Coordinated STA training I
program.
GENERAL ELECTRIC COMPANY December, 1981 NUCLEAR POWER SYSTEMS ENGINEERING DEPARTMENT to San Jose 3 A-September, 1982 C5re and FITil Systems Design Pirformed analyses to determine control blade lifetimes using Monte Carlo and 3-D core simulation computer codes.
July, 1981 NUCLEAR SERVICES DEPARTMENT to San Jose, CA December, 1981 PTant Analyses Program Performed program management for work such as Load Line Limit Analyses and Analyses for Determination of Conformance to NUREG-0612 Control of Heavy Loads at Nuclear Power Plants.
December, 1980 NUCLEAR FUEL & SERVICES ENGINEERING DEPARTMENT to San Jose CA -
July, 1981 Nuclear Evaluations Performed analyses to develop and optimize core loading strategies incorporating reconstituted fuel bundles. Performed cycle simulation analyses including fuel cycle economics.
June, 1980 NUCLEAR SERVICES DEPARTMENT
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to San Jose, CA December, 1980 Eiijineer_ing Training Providi3 training to utility trainees in basic Nuclear Engineering and Engineering Fundamentals.
PUBLICATIONS Coauthor, as the Team Lead, of the " Detailed Control Room Design Review Summary Report" for the DAEC submitted to the NRC in Dece;nber,1986.
Coauthor, as the DCRDR Team Leader, of the " Design Guide for the Human Factors Considerations of the Control Room, Duane Arnold Energy Center,"
Revision 3, November 6, 1986.
e ATTACHMENT 2 BIOGRAPHY OF JOHN A. ZWOLINSKI Mr. Zwolinski is currently the Deputy Division Director for the Division cf Licensee Performance and Quality Evaluation. He has worked in numerous progressively responsible positions since joining NRC in November 1974.
Work experiences and different positions held include activities in the auxiliary and containment systems areas to include significant involvement in several Unresolved Safety Issue matters. In the early 1980s fir. Zwolinski
. served as Technical Assistant to the Director, Division of Human Factors Safety, NRR. More recently, Mr. Zwolinski has served as Section Leader in the Operating Reactors Assessment Branch. Upon selection as the Operating Reactors Branch f5 Branch Chief, in November 1984, Mr. Zwolinski entered SES.
He continued his efforts in managing projects through the formation of the Office of Special Projects. As the Assistant Director for Projects Mr. Zwolinski played a pivotal role in developing the overall Sequoyah 2 Restart Recovery Plan. In November 1987 Mr. Zwolinski was appointed to his current position.
Mr. Zwolinski received a Bachelor of Science degree in Mechanical Engineering from Washington State University in 1968 and a Master of Science degree in Engineering from George Washington University in 1971. He has performed extensive independent study in the areas of managefrent effectiveness and technical / engineering management. Prior to his appointment with the Comission, Mr. Zwolinski served as a project engineer with the Department cf Defense at Fort Belvoir, Virginia.
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ATTACHMENT 3 REQUIREMENTS FOR OBTAINING AN OPERATOR'S LICENSE In accordance with ANSI /ANS-3.1-1981, "American National Standard for j
Selection, Qualification and Training of Personnel for Nuclear Power i
I Plants" as endorsed by Regulatory Geide 1.8, " Qualification and Training of Personnel for Nuclear Power Plants", requirements for obtaining an l
operator's license are:
l 1.
A High School Diploma.
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2.
3 years power plant experience, I of which is at the license-specific plant and 6 months of which is as a non-licensed operator.
3.
Successful completion of a written examination and operating test.
4 3 months on-the-job training.
The written examination samples the operator's knowled following areas (taken from 10 C.F.R. 55.41(b)(1) through (ge in the 14)):
(1) Fundamentals of rector theory, including fission process, neutron multiplication, scurce effects, control rod effects, criticality indications, reactivity coefficients, and poison effects.
(2) General design features of the core, including core structure, fuel elements, control rods, core instrumentation, and coolant flow.
(3) Mechanical components and design features of the reactor primary system.
(4) Secondary coolant and auxiliary systems that affect the facility.
(5) Facility operating characteristics during steady state and transient conditions, including coolant chemistry, causes and effects of temperature, pressure and reactivity changes, effects of load changes, and operating limitations and reasons for these operating characteristics.
(6) Design, components, and functions of reactivity control mechanisms and instrumentation.
(7) Design, components, and functions of controls and safety systems, including instrumentation, signals, interlocks, failure modes, and automatic and manual features.
(8) Components, capacity, and functions of emergency systems.
(9) Shielding, isolation, and containment design features, including access limitations.
(10) Administrative, normal, abnormal, and emergency operating procedures for the facility.
(11) Purpose and operation of radiation monitoring systems, including alarms and survey equipment.
(12) Radiological safety principles and procedures.
(13) Procedures and equipment available for handling and disposal of radioactive materials and effluents.
(14) Principles of heat transfer thermodynamics and fluid mechanics.
The operating test samples the operator's understanding of and ability to perform the actions necessary to accomplish the following items (takenfrom10C.F.R.55.45(a)(1)through13):
(1) Perform pre-startup procedures for the facility, including operating of those controls associated with plant equipment that could affect reactivity.
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(2) Manipulate the console controls as required to operate the facility between shutdown and designated power levels.
(3) Identify annunciators and condition-indicating signals and perform l
appropriate remedial actions where appropriate.
(4)
Identify the-instrumentation systems and the significance of facility instrument readings.
(5) Observe and safety control the operating behavior characteristics of the facility.
(6) Perform control manipulations required to obtain desired operating results during normal, abnormal, and emergency situations, (7) Safely operate the facility's heat removal systems, inc1r i g primary cociant, emergency coolant, and decay heat removal syste.x, and identify the relations of the proper operation of these systems to the operation cf the facility.
(8) Safely operate the facility's auxiliary and emergency systems, including operation of those controls associated with plant equipment that could affect reactivity or the release of radioactive materials to the environment.
(9) Demonstrate or describe the use and function of the facility's radiation monitoring systems, including fixed radiation monitors and alarms, portable survey instruments, and personnel monitoring equipment.
(10) Demonstrate knowledge of significant radiation hazards, including permf uible levels in excess of those authorized, and ability to perfum other procedures to reduce excessive levels of radiation and to guard against personnel exposure.
(11) Demonstrate knowledge of the emergency plan for the facility, including, as appropriate, the operator's or senior operator's responsibility to decide whether the plan should be executed and the duties under the plan assigned.
(12) Demonstrate the knowledge and ability as appropriate to the assigned position to assume the respNoibilities associated with the safe operation of the facility.
(13) Demonstrate the applicant's ability to function within the control room team as appropriate to the assigned position, in such a way that the facility licensee's procedures are adhered to and that the limitations in its license and amendments are not violated.
ATTACHMENT 4 I~
UNITS 2 AND 3 UNIT CONTROL OPERATOR EQUIPMENT RESPONSIBILITIES EQUIPMENT / SYSTEM 1.
Main Steam System 2.
Main Turbine 3.
Condensate and Feedwater System 4
. Full Flow Condensate Polishing Demineralized 5.
Feedwater Heater Extraction 6.
Auxiliary Feedwater System 7.
Reacter Coolant System 8.
Chemical Volume Control System 9.
CVCS Boric Acid Mix and Storage
- 10. Safety Injection System and Refueling Water Tanks
- 11. Containment Spray System -
- 12. Steam Generator Blowdown Processing System
- 13. Steam Seals 14 Main Turbine Lube Oil System
- 15. Generator Gas Control System (Hydrogen and CO,)
- 16.. Hydrogen Seal Oil System
- 17. Stator Water Cooling System
- 18. Condenser Air Removal System
- 19. Main. Turbine Controls
- 20. Circulating Water, Traveling Screens and Fish Handling
- 21. Amertap Condenser Tube Cleaning System
'22.
Turbine Plant Cooling Water System
- 23. Fuel Pool Cooling and Cleanup System 24 Component Cooling System
- 25. Saltwater Cooling System
- 26. Auxiliary Turbines and Lube Oil 27.
Intake Structure Ventilation
- 28. Turbine Building HVAC
- 29. Fuel Handling Building HVAC
- 30. Charging Pump and Boric Acid Makeup Pump Room HVAC
- 31. Containment Building HVAC
- 33. Penetration Building HVAC 34 Containment Hydrogen Recombiner and Hydrogen Purge
- 35. Safety Equipment BM 1 ding HVAC
- 36. Storage Tank Area, Safety Equipment Bldg., Fuel Handling Bldg.,
Penetration Bldg., Sumps and Drains, Containment Sump
- 37. Fuel Handling and Reactor Servicing 38.
Isophase Bus and Main Generator
- 39. Boron and Containment Heat Tracing
- 40. Turbine Plant Sampling System
- 41. Plant Computer
- 42. Plant Annunciators
- 43. Flooding-Sensors and Alarms
- 44. Engineered Safety Features Actuation Systen
- 45. Reactor Protection System 46.
In-Core Reactor Instrumentation
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UNITS 2'AND3UNITCONTROLOPERATOREQUIPMENTRESPONSIBILITIES(Continued)
EQUIPMENT / SYSTEM
- 47. Ex-Core Nuclear Instrumentation
- 49. Reactor Regulation
- 50. Nuclear Sampling System
- 51. Loose Part Monitoring / Internal Vibrations
ATTACHMENT 5 k
COMMON CONTROL OPERATOR EQUIPMENT RESPONSIBILITIES EQUIPMENT / SYSTEM 1.
Demineralized Water Makeup and Transfer 2.
Condensate Transfer and Storage 3.
Condensate and Feedwater Chemical Control 4.
Lube Oil-Storage, Transfer and Purification 5.
Chlorine Injection 6.
Nuclear Service Water 8.
Auxiliary Boiler and Auxiliary Steam 9.
Normal Chilled Water.
- 10. Auxiliary Building /Radwaste HVAC
- 11. Emergency Chilled Water
- 12. Control Room HVAC (Emergency and Normal)
-13.
Control Building HVAC
- 14. Diesel Building HVAC (Normal and Emergency)
- 15. Continuous Exhaust
- 16. Cable Tunnel and Misc. HVAC
- 17. Gaseous Radwaste
- 18. Liquid Radwaste
-- 19. New and Spent Resin Handling
- 20. Filter Precoat and Crud Tank
- 21. Solid Radwaste
- 22. Primary Plant Makeup
- 23. Boric Acid Recycle
- 24. RadioactiveDraias(CCWandRadwaste)
- 25. Coolant Radwaste
- 26. Auxiliary Boiler Fuel Oil
- 27. Diesel Fuel Oil 28.
Instrument and Service Air
- 29. Fire Protection
- 30. Domestic Water
- 32. Standby Diesel Engines
- 33. Gravity Collection - Diesel Building 34 Oily Waste and Gravity Collection
- 35. Sewage Treatment
- 36. Main and Unit Auxiliary Transformers 37, 220KV Switchyard
- 38. Reserve Aux. Transformer XR3 and 6.9 KV Buses
- 39. Reserve Aux. Transformers XR1 and XR2
- 40. Non-1E 4KV Buses
- 41. Non-1E 480V Load Centers
- 42. Switchyard Relay House Load Center
- 43. Non-1E 40V MCC's D
- 44. Non-1E 250V DC System
- 45. Non-1E 125V DC System
- 46. Non-1E 124 VAC Instrument Power 47.
- 2'-
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COMMONCONTROLOPERATOREQUIPMENTRESPONSIBILITIES(Continued)
EQUIPMENT /SYSTE
- 49. IE 480V Load' Centers
- 50. 1E 480V MCC's 51.
1E:125V DC System 52.
1E.125VAC' Instrument Power.
- 53. Lighting Systems. (Includes DC Lighting)'
- 54. Station Grounding System
- 56. Fire Detection and Alarm System
. 57. Caustic Heat Tracing
- 58. Miscellaneous Waste System Heat Tracing
- 59. Evacuation Warning System.
- 60. Meteorological Instrumentation
- 61. Personnel Monitoring
- 62. Fire Monitoring
- 63. All Bulk Lt.emical Storage - Acid, Caustic, Ammonia, Sodium Hypochlorite
- 64. Area Radiation Monitors
- 65. ~ Seismic Monitoring-
- 66. Process and Airborne Radiation Monitoring m___ _ _. _ _ _ _. _ - _ - _ _ _._ _ _. _. _ _ _. _ _ _