NUREG-0634, Forwards Region 3 Input to Ser.Applicants Organizational Structure & Conduct of Operations Acceptable.Resolution of Open Items Will Be Addressed in Suppl SER
| ML20040A095 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 01/13/1982 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0634, RTR-NUREG-0660, RTR-NUREG-0737, RTR-NUREG-634, RTR-NUREG-660, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.A.1.2, TASK-1.A.1.3, TASK-1.A.2.2, TASK-1.B.1.2, TASK-1.C.2, TASK-1.C.3, TASK-1.C.4, TASK-1.C.5, TASK-1.C.6, TASK-TM NUDOCS 8201200339 | |
| Download: ML20040A095 (36) | |
Text
JAN 1 3 :992 1
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Docket Numbers: 50-454, 50-455 d
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l MEMORANDUM FOR:
R. L. Tedesco, Assistant Director fo %,icensing,' Division
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of Licensing, NRR l
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I FROM:
C. E. Norelius, Director, Division of En ineering and,'
l Technical Inspection, Region III k.-
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SUP. JECT:
REGION III INPUT FOR BYRON UNITS 1 AND 2 SER l
1 P1 ANT NAME:
Byron Station, Units 1 and 2 1
j LICENSING STAGE: OL DOCKET NUMBERS: 50-454, 50-455 t
i RESPONSIBLE BRANCH AND PROJECT MANAGER:
LB1, S. Chestnut REVIEW STATUS: Completed, except as noted in report Region III has reviewed Sections 13.1.1, 13.1.2, 13.2.2, 13.4, and 13.5.1 4
of the Standard Review Plan, Action Plan Items I.A.1.1, I.A.1.2, I.A.1.3, I.A.2.2, I.B.I.2, I.C.2, I.C.3, I.C.4, I.C.5, I.C.6, NUREG-0654 Emergency Planning (Organizational Aspects), and 10 CFR 50.48 Fire Protection (Training Aspects). Attached, for the areas mentioned above, is the Region III input for the Byron, Units 1 and 2 SER. An information gathering (Region III/NRR) site visit was made during September 8-11, 1981, which consisted of meetings and interviews with both plant and selected corporate personnel.
Our evaluation of the organization and management structure is based on information received during the site visit, the review of the FSAR for Byron Station, the applicant's response to the NRC Action Plan NUREG-0660, i
and the applicant's letters of August 28, October 5, December 24, and December 29, 1981.
We have concluded that the applicant's organizational structure and conduct 1
of operations is acceptable with the following exceptions:
1.
The applicant has not provided a commitment or proposal to meet our position that epmmercial PWR operating and/or startup experience be s
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8201200339 820113 PDR ADOCK 05000454 I
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provided on each shift, at least up to attainment of 100% power (Section 13.1.2).
i 2.
The applicant has not committed to establishing the administrative I
controls discussed in our evaluation of the applicant's position on j
Item I.A.1.1 of NUREG-0737.
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3.
The applicant's Fire Brigade training program does not satisfy the requirements of 10 CFR 50, Appendix R, with respect to minimum I
frequencies of drills and individual members' drill participation.
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4.
The applicant's response to Item I.C.4 does not contain sufficient l
information for us to determine acceptability.
5.
The applicant's response to Item I.C.6 does not contain sufficient i
information for us to determine acceptability.
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We will continue to seek resolution of these open items and address each j
one in the Supplementary Safety Evaluation Report (SSER).
i This review was conducted by K. A. Connaughton, Inspector, Management Pro-j grams, K. R. Baker, Section Chief, Management Programs, and J. M. Peschel, Inspector, Management Programs.
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'T. :;*n;I CI:nzd by C.E. Norclius" C. E. Norelius, Director Division of Engineering and Technical Inspection l
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Enclosure:
Region III Input for Byron, Units 1 and 2 SER I
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1 13.
Conduct of Operations f
13.1.1 Organizational Structure of Applicant l
A.
General During the period September 8-11, 1981, members of a joint NRR/RIII l
revieu team visited Byron Station Units 1 and 2 near Byron, Illinois.
The purpose of the visit was to review the proposed organization for 1
operation of Byron 1 and 2 from the level of senior corporate officer, who will be in overall charge of nuclear operations for the Commonwealth Edison Company (CECO), down to and including the proposed operating staff at the plant. The team visit consisted of reviewing the organi-i zational structure for operation and for support of the plant staff, the levels or staffing, the experience level of principal individuals of both corporate and plant staffs and the interfaces between the plant j
staf f and its corporate support structure. The review team consisted of two individuals from NRR and three from Region III.
Beginning with a meeting at the Byron Plant, the applicant provided the review team with a briefing on its organization for the operation of Byron 1 and 2.
This briefing was followed by discussions with several plant personnel so that the review team could gain a feeling for the responsibilities and attitudes of the individuals, an understanding of how they fit into the organization, and how they interface with other onsite and offsite organizational units. Dis-cussions with corporate personnel were also held to obtain the same type of information. At the conclusion of the meeting, the NRR/RIII team presented the results of the visit to the CECO management.
The following description and evaluation are based on information contained in the FSAR, the applicant's response to the NRC Action Plan Items (NUREG-0660) and supplemental information obtained during the visit.
In our evaluation, we used the guidelines of NUREG-0731,
" Guidelines for Utility Management Structure and Technical Resources,"
draf t report dated September 1980, ard the requirements outlined in NUREG-0737, " Clarification of TMI Action Plan Requirements."
B.
Corporate Organization The corporate organization and lines of responsibility for operation of Byron 1 and 2 are shown in Figure 1.
The senior corporate official responsible for engineering, construction and operation of the company's generating stations, including fossil units, is the Executive Vice-President (Construction, Production and Engineering). Reporting to him is the Vice-President (Nuclear Operations) who is responsible for the management of the Station Nuclear Engineering Department, the Nuclear Licensing Department, the Nuclear Fuel Services Department, all headed by the Assistant Vice-President (Operations), and the company's Nuclear Station's Division headed by the Division Vice-President (Nuclear Stations).
Prior to the issuance of an operating license, engineering, construction and testing of nuclear stations is the responsibility of the Manager of Projects, The Manager of Projects l
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organization is shown in Figure 2.
The Byron /Braidwood project is j
the responsibility of the Project Manager who reports to the Manager i
of Projects, and coordinates the activities of the Project Engineerint,,
Project Construction, Project Operations, and Project Operational I
Analysis groups. These groups are formulated from the Station Nuclear Engineering Department, Station Construction Department, the Nuclear Station's Division and the Operational Analysis Department (OAD),
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respectively. Following the issuance of an operating license, these j
Project Groups revert back to the organizations from which they were j
formed and the Vice-President (Nuclear Operations) assumes responsi-i bility for all aspects of Byron 1 and 2 operation. Organizational units under the Vice-President (Nuclear Operations) providing technical j
support for operation are discussed below in items 1 through 7.
j 1.
The Station Nuclear Engineering Department is organized as shown j
in Figure 3.
The Station Nuclear Engineering Manager reports j
directly to the Assistant Vice-President (Nuclear Operations).
j Reporting to the Station Nuclear Engineering Manager are the Station Nuclear Design Engineers and a group of reliability and i
j design specialists.
Project Engineers for operating nuclear j
stations report to a Station Nuclear Design Engineer while Project 3
Engineers for stations under construction report to their respective i
Project Engineering Managers. Electrical, mechanical, civil, and i
nuclear engineers are assigned to each Project Engineer on an as-j needed basis. The Station Nuclear Engineering Department consists 1
of approximately 100 individuals, and has the following respons-ibilities:
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a.
Review and control the scope of work involving the elec-j trical, mechanical, structural, and instrumentation and j
control designs of the NSSS vendor and Architect Engineer j
to verify that applicable Safety Analysis Report (SAR),
j regulatory requirements, ASME Code requirements, and design bases are properly translated into specifications, drawings, procedures and instructions.
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i b.
Review and accept the specifications for electrical, l
mechanical and structural material, equipment and erection work, prepared by the Architect Engineer and NSSS vendor, to verify inclusion of inspection, testing and acceptance criteria.
c.
Analyze bids, make purchase recommendations, control expend-itures, and assure that necessary quality requirements are included in purchase orders and contracts.
d.
Disposition of electrical, mechanical and structural design changes.
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Review the Architect Engineer's evaluation of fabricator's e.
j and erector's detailed designs, drawings and work instruc-tions for reasonableness and completeness.
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f.
Review and approve resolution of nonconformances relating 3
to electrical, mechanical and structural portionn of the generating station.
g.
Establish the plans for the preoperational and startup test j
p rograms.
h.
Coordinate the preparation and review of preoperational and startup test programs.
i.
Coordinate the evaluation of the adequacy of the results of the preoperational testing. Make recommendation for accept-
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ance of test results when results are judged satisfactory.
j.
Develop overall schedules for construction and modification activities.
2.
The Nuclear Fuel Services Department _provides technical support for fueling and refueling activities including development of fuel loading patterns, refueling schedules and new fuel require-l ments. This department also monitors fuel performance trends and assists the NSSS vendor and fuel supplier in the development l
of reactor operating guides and procedures.
The Director of the Nuclear Fuel Services Department reports directly to the Assistant Vice-President (Nuclear Operations) who in turn reports to the Vice-President (Nuclear Operations). The staff consists of approximately 20 individuals includir.g the Staff Engineer and two Supervising Engineers who direct the technical support work.
I 3.
The Director of Nuclear Licensing reports directly to the Assistant Vice President (Nuclear Operations) and manages the Nuclear Licensing Department. The Nuclear Licensing Department coordinates the applicant's efforts to support requests for NRC licensing action and provides a focal point for the exchange of information between the applicant and the NRC.
4.
The Operations Manager reports to the Division Vice President -
Nuclear Stations and has functional responsibility for operations of nuclear stations ia a safe and efficient manner and in accord-ance with Company procedures, NRC Technical Specifications and governmental regulations. His responsibilities include:
Providing direction to the Operating Assistant Superintendent
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a.
regarding day-to-day operation of station units.
b.
Coordinating unit outages with Power Supply.
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c.
Reviewing station operating performance for adherence to j
procedures, technical specifications and other governmental regulations.
d.
Reviewing the results of personnel performance investigations and follow-up on corrective actions. _
Participating in personnel performance investigations as e.
assigned.
f.
Participating in station Action Item Record (AIR) meetings, the CECO tracking system for items requiring action within a given time period, and followup as appropriate on corrective actions.
g.
Reviewing licensee event reports and deviation reports for trends, effects on other units and corrective action.
h.
Communicating common equipment and system problems among stations in a timely manner.
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Reviewing station response to NRC inspections and Quality Assurance audits for trends, corrective action, and followup on completion of commitments.
j.
Initiating and coordinating General Station Emergency Plan drills.
k.
Coordinating the implementation of nuclear security regulations.
The Operations Manager and his staff of approximately six individuals are shown in Figure 4.
5.
The Maintenance Manager - Nuclear Stations and his staff are shown in Figure 5.
The Maintenance Manager reports to the Division Vice-President - Nuclear Stations and is responsible for functional direction of maintenance activities at nuclear stations including In-Service Inspection activities, special tool and equipment development, equipment and refueling outage schedules and con-tractor and vendor activities. He is responsible for providing direction to the Maintenance Assistant Superintendent regarding day-to-day maintenance operations, forced outages, scheduled outages and refueling operations plus an effective maintenance program for ALARA radiation exposures.
6.
The Technical Services Manager - Nuclear Stations and his staff are shown in Figure 6.
The Technical Services Manager reports directly to the Division Vice President - Nuclear Stations and has the following responsibilities:
i a.
Providing technical support to the stations to augment the i
station technical staff as needed.
b.
Career planning for station technical personnel.
c.
Development of operating strategies to improve system avail-ability and thermal performance.
Technical Services personnel are supervised by group leaders who in turn report to one of three Supervisors. The Supervisor of Health Physics and Emergency Planning has a staff of approximately ten individuals providing expertise in health physics, radiobiology and emergency planning. The Supervisor of Chemistry and Radwaste Services oversees a staff of approximately 26 individuals who cre grouped by the following functional areas; radwaste management, career development, operational chemistry, analytical services, administrative services, and special projects. The Supervisor of Station Support Services has a staff of approximately six indi-viduals. Support is provided for staff studies, fire protection, and computer services.
7.
Each nuclear generating station is managed by a Station Super-intendent who is responsible for direct management of the station including industrial relations, planning, coordination, and direction of the operation, maintenance, refueling and technical activities. The Station Superintendent is responsible for compliance with the Station's NRC Operating License, government regulations, ASME Code Requirements and the Company Quality Assurance Program. He also authorizes the use of procedures I
i contained in the Station Procedure Manual, and is responsible for final approval and distribution of station reports. The Station Superintendent authorizes all modifications to the Station after the issuance of an Operating License and completion of preopera-tional testing. He forwards requests for modifications to the Station Nuclear Engineering Department. Repair and equipment maintenance needing technical review for substitution of equipment are reviewed by the Station Technical Staff and completed as maintenance activities under station management. He supervises the Station's on-site review function as provided in the Adminis-trative Section of the Technical Specifications.
Technical Support for plant operations is also provided by several organizational units reporting to senior corporate officers other than the Vice-President (Nuclear Operations). These organizations are listed in items 8 through 11 below.
8.
The System Operational Analysis Department is shown in Figure 7.
The Operational Analysis Manager reports to the Vice-President (Engineering) through the Assistant Vice-President (Engineering).
The Operational Analysis Department provides technical support for operations in the following areas:
a.
Specialized field testing.
b.
Standardizing and calibration of instrumentation.
c.
Materials science.
d.
Inspection and proof testing of electrical generation transmission, and distribution equipment.
Personnel and procedure development and qualification to e.
Code requirements for NDE and NDT activities.M l l
As shown in Figure 7, the System Operational Analysis Department is comprised of seven specialist groups who report through two Supervising Staff Engineers to the Operational Analysis Manager.
An eighth group, not shown in Figure 7, the Division Operational Analysis Department, reports functionally to the Operational Analysis Manager.
After issuance of the operating license, all electrical troubleshooting, testing, and network interfacing (routine) tests are performed by Division of Operational Analysis Engineers as requested by the station.
9.
The Quality Assurance Department is shown in Figure 8.
The Manager of Quality Assurance reports directly to the Vice Chair-man of Commonwealth Edison. The Quality Assurance Organization is divided into essentially three functional a,eas; Engineering and Construction, Operations, and Maintenance. The Director of Quality Assurance (Engineering and Construction) oversees the activities of the Site Quality Assurance Organization and the Quality Assurance Coordinators assigned to the Station Nuclear Engineering Department and the System Operational Analysis Department.
The Director of Quality Assurance (Operations) oversees activ-ities of the Nuclear Fuel Inspector as well as Quality Assurance Inspectors or Engineers assigned to each operating station. The Supervisor of Quality Assurance (Maintenance) supervises Quality Assurance Inspectors or Engineers assigned to each operating station.
10.
The Production Training Department under the direction of the Production Training Manager coordinates training activities for l
the applicant's nuclear generating stations. They oversee the preparation of training materials, monitor on-the-job instruction activities and schedule simulator training and other off-site training.
11.
The Department of Nuclear Safety is discussed in Section 13.4 as part of our evaluation of the applicant's response to TMI Action Plan Items I.B.I.2 and I.C.5.
l C.
Conclusion The applicant has described its organization for the management of, and its means for providing technical support for the plant staff during operation of the facility. These measures have been reviewed and we conclude that the applicant has an acceptable organization and adequate resources to provide offsite technical support for the operations of the facility under both normal and off-normal conditions.
13.1.2 Operating Organization A.
Organization In FSAR Section 13.1.2, the applicant has described the organization of the Byron 1 and 2 plant staff as shown in Figures 9A and 9B. l l
Reporting directly to the Station Superintendent are; the Maintenance Assistant Superintendent, the Operating Assistant Superintendent, the Administrative and Support Services Assistant Superintendent, and the Personnel Administrator. The Site Quality Assurance Group is independent of the operating organization and reports directly to the Director of Quality Assurance (Operations) offsite as described in Section 13.1.1.
The plant staff presently consists of about 339 individuals with a pro-jected number of 360 individuals by Unit 1 fuel load and a projected number of 410 individuals by Unit 2 fuel load.
The Station Superintendent has been assigned responsibilities for the maintenance of occupational radiation exposure ALARA as outlined in Regulatory Guide 8.8, Revision 3.
Plant activities are further divided into functional areas under the Assistant Superintendent and the Personnel Administrator. The lines of authority and responsibility for these functional areas are described below.
1.
Personnel Development The Personnel Administrator is responsible for station manpower planning, labor relations, employee career path planning, training, safety and "PR0" programs. The Petaonnel Administrator reports directly to the Station Superintendent and is assisted in carrying out his duties by the Training Supervisor.
2.
Training The Nuclear Station Training Department under the direction of the Nuclear Station Training Supervisor is responsible for the development and administration of training programs consistent with Production Training Department Training Standards, Company and Station policies and procedures, and with external require-ments. The training staff currently consists of approximately 10 individuals. The Training Supervisor or an instructor reporting to him will be SRO qualified.
Commonwealth Edison has contracted with Westinghouse to have a plant specific simulator constructed at Braidwood, Illinois. Completion of this simulator is projected for mid-1983.
3.
Administration The Administrative Clerical Department under the direction of the Office Supervisor is responsible for providing clerical support for all station departments, coordinating activities of the station's clerical staff, and maintaining files of quality assurance docu-ments as assigned. The Office Supervisor reports directly to the Assistant Superintendent, Administrative and Support Services, and supervises the Central File Supervisor and the Word Processing Supe rvisor.
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4.
Radiation - Chemistry NOTE:
Insert the discussion on Rad-Chem submitted by the j
j Radiological Assessment Branch here.
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Quality Control 1
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The Station Quality Control Department under the direction of the Quality Control Supervisor is responsible for the quality control i
activities at the Station such as:
reviewing drawings; specifi-cations; maintenance / modification procedures; requests for purchase for inclusion of applicable quality requirements; performing re-ceiving inspection for ASME and safety-related incoming materials and items; inspection of fabrication and installation activities; i
and having nondestructive examination and other testing performed i
as required.
1 6.
Technical Staff j
j The Station Technical Staff under the directon of the Technical Staff Supervisor, provides technical support for plant operations, refueling, maintenance, modifications, inservice inspection, evaluation of process data and equipment performance, and j
evaluation of the adequacy of station procedures.
In accordance i
with Technical Specifications, the Technical Staff Supervisor is responsible for implementation of the onsite review functions. The Technical Staff is organized as shown in Figure 10.
The Technical Staff Supervisor reports directly to the Assistant Superintendent, i
Administrative and Support Services. Reporting to the Technical Staff Supervisor, are eight technical groups; the Computer Group, q
the Fuel Group, the Primary Group, the Environs Group, the Venti-i lation Group, the Thermal Group, the Electrical Group, and the j
Inservice Inspection Group. Each group consists of approximately 5 individuals and is supervised by a designated Group Leader.
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Each Group has the following responsibilities:
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Provide expertise in assigned systems and componeats.
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b.
Provide day-to-day engineering support to Operations and i
Maintenance on problems related to his assigned systems.
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c.
Perform long-term studies, evaluations, and trend analysis
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on assigned equipment and systems.
d.
Investigate causes of deviations and reportable occurrences j
and propose corrective actions and actions to prevent i
recurrences.
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e.
Prepare deviation reports and licensee event reports.
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Perform and/or evaluate Technical Specification Surveillances i
on assigned systems.
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Provide responses and technical reports to regulatory agencies.
h.
For modifications as follows:
Initiate the modification package; prepare supporting documentation, including work requests, drawing changes, 10 CFR 50.59 safety evaluations, economic justification, materials list and test procedures; participate in design meetings and discussions with SNED, the Architect Engineer and the Vendors; prepare SPR's, single source letters, etc., as appropriate; perform evaluations of bids for equipment, materials and services; coordinate the installation and testing of the modification.
i.
Evaluate equipment and system performance and submit results and recommendations to the Technical Staff Supervisor.
Also reporting to the Technical Staff Supervisor, through Assistant Technical Staf f Supervisors, are a Licensing Staff and a Start-up Staff. The Assistant Technical Staff Supervisors, in addition to supervising their respective staffs, are respon-sible for station related licensing issues, review and approval of procedures, procedure changes, and reports, coordinating technical groups and assuming the Technical Staff Supervisor's responsibilities in his absence.
The Technical Staff currently consists of approximately 43 indi-viduals with a projected number of 54 individuals by Unit 1 fuel load and 57 individuals by Unit 2 fuel load.
7.
Maintenance The Maintenance Department under the direction of the Maintenance Assistant Superintendent is responsible for the mechanical, elec-trical, and instrument and control maintenance in the plant and for the control of spare parts in the stores. The maintenance department section currently consists of 100 individuals with a projected number of 120 Ly the fuel load date for Unit I and a projected number of 142 by the fuel load date for Unit 2.
Person-nel are being added as maintenance work becomes available with training scheduled to accommodate additions to the maintenance work force occurring prior to achieving commercial operation. Training milestones for Unit 2 lag those for Unit 1 by approximately one year.
8.
Operations The Operating Department, under the direction of the Operating Assistant Superintendent, is responsible for:
the operation of mechanical and electrical equipment and certain common plant systems such as fuel handling and radioactive waste processing; recommending maintenance for such equipment; authorizing functional acceptance tests to be conducted by Operating and Technical Staff -
personnel and; operating the plant in compliance with the Station Operating License and the Station Operating Procedures. The plant operating organization currently consist of 103 individuals with a projection of 103 individuals by fuel load of Unit 1 and 115 individuals by fuel load of Unit 2.
The Operating Assistant Superintendent will be SRO licensed.
Byron, Units 1 and 2, will operate with a six shift rotation, to allow one shift to be training at all times. Each operating shift will consist of three SRO's, two R0's and two nonlicensed auxiliary operators (A0's) for single unit operation. For 2 unit operation, each operating shift will consist of three SRO's, three R0's and three A0's.
At least one Rad Chem Technician will be provided on each operating shif t for single or dual unit operation.
The applicant's fire brigade is composed of five individuals from the operating crew which meets the 10 CFR Appendix R requirement.
The 10 man shift will allow adequate manning for safe shutdown of the plant.
At present, Commonwealth Edison has 27 positions identified for SR0 licensed individuals and 24 R0 licensed individuals. The numbers of positions designated for SRO and R0 licensed indi-viduals are based on shift manning requirements, a six shift rotation, and on assumption of some losses due to attrition and failure to license.
We believe this is an acceptable number due to information pro-vided during our October, 1981 site visit, which describes the
" pipeline" of additional candidates. All Equipment Attendants (EA), Equipment Operators (EO) and Nuclear Station Operators (NS0) undergo the same selection program as an SR0 candidate with a line of promotion existing to the SRO position.
Shift manning is further discussed in our evaluation of the applicant's response to TMI Action Plan Item I.A.l.3 at the end of this section.
The Training program for " cold" license candidates consists of a seven week course, " Reactor Theory and Reactor 0 eration," a 1
four week " Nuclear Reactor Training" program conducted at the Westinghouse training reactor located in Zion, Illinois, a ten week course " Plant Systems and Observations," nine weeks of simulator training, a ten week course " Byron /Braidwood Slant Systems," and a four week course " Technical Training Resiew." A one week course, " Simulator Refresher" will be scheduled if the time period between simulator training and NRC cold licensing examination is greater than six months. The training program for
" hot" license R0 candidates consists of five phases; nuclear power plant fundamentals, Byron systems, on-the-job training, simulator training and review.
SRO candidates receive, in addition, ten weeks of reactor theory, a seven week pre-simulator course, ten weeks of simulator training, three months of on-the-job training, and approximately two months of pre-license exam preparations.
The applicant has proposed to have the Shift Technical Advisor (STA) function performed by a Shift Control Room Engineer who will be a licensed SRO. We find this proposal acceptable on an interim basis as discussed in our evaluation of the applicant's response i
to TMI Action Plan Item 1.A.1.1 at the end of this section.
We have reviewed the qualifications of the supervisors in the Operating Department and have concluded that inadequate PWR operating experience exists. The Assistant Superintendent, Operations has previous commercial PWR operating experience (SRO-Zion I and 2).
Of the six shift engineers, only one has previous commercial PWR operating experience. Of the eight shift foremen already hired, only two have previous commercial PWR operating experience. None of the five Shift Control Room Engineers already hired have previous commercial PWR operating experience.
We do not require that all key personnel have extensive commer-cial PWR operating experience. However, we believe that such experience, especially during the first six months to a year of Byron, Units 1 and 2 operation should be available to the operating group. We informed the applicant that at least one person should be provided on each operating shift, at least up to attainment of 100% power, who has commercial PWR operating experience, or has experience in startup of a similar Westinghouse plant, or has otherwise acquired familiarity with the types of l
problems frequently encountered during the initial startup of similar Westinghouse plants. We also informed the applicant that the acceptability of his proposal to meet this position would be determined on a case by case basis.
In a letter dated December 29, 1981, Commonwealth Edison stated that a requirement to have previously licensed commercial PWR operating personnel on each shift would be burdensome and unnecessary, based on the experience levels of individuals on the plant staff and technical support organizations. The letter i
L did not contain any commitment or proposal to provide experienced individuals on each operating shift. We therefore find the appli-cant's position on this issue to be unacceptable.
The Operating Department will be responsible for the operation of all equipment and systems released by Station Construction and will assign personnel to the maximum extent consistent with completion of necessary training to assist the Technical Staff during the pre-operational testing and major system integrated tests, in particular, the hot functional tests.
l The Station Nuclear Engineering, Operational Analysis, and Station Construction Departments will provide technical support or participate in the test program as required. The Station
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Nuclear Engineering Department has overall responsibility for the successful review and completion of the initial test program.
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1 9.
TMI Action Plan Items 1
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I.A.1.1 Operating Personnel and Staffing - Shift Technical Advisor (organizationtl aspects) t
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l In a letter dated August 28, 1981, the applicant described its l
plans to provide a technical graduate, licensed at the senior l
reactor operator (SRO) level on each shift while a unit is in power operation, startup, hot shutdown or cold shutdown (Modes 1-4).
This individual will normally function as the control room SRO and will also be qualified as a Shift Technical Advisor. The title a
Commonwealth Edison has given this individual is " Station Control i
Room Engineer" (SCRE).
j In addition to the SCRE, there will also be two other SRO's on
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each shift crew who will be part of the minimum shift crew required by the Technical Specifications. One of these SR0's is
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the Shift Engineer (Shift Supervisor) and the other is the Shift
.i Foreman (Plant SRO). The SCRE will report to the shift supervisor j
and will directly supervise the plant SRO and the activities in j
the control room during normal plant operations; thus, he will j
exercise a command and supervisory function in the control room during normal plant operations.
j In the event of an accident, both the shift supervisor and the I
plant SRO will be required to report to the control room within i
ten minutes. The shift supervisor will assume the control room command function and the SCRE will assume the advisory role of l
the STA. As directed by the shift supervisor, the plant SR0 i
will be available to perform any function, including the control room SR0 role that was previously assigned to the SCRE.
The combination of the STA and control room SRO function had not l
been evaluated as a means of satisfying the staff positions on the STA and maintaining an SRO in the control room at all times when these positions were established. The CECO proposal has since been evaluated as part of the LaSalle County Station SER.
The CECO proposal will provide a control room SRO with the addi-l tional technical qualifications of the STA. This should greatly enhance the control room SRO's understanding of the technical i
basis for limits and the design and operation of plant systems.
The proposal also provides an STA whose performance should be l
enhanced by the operational training and experience required of f
an SRO, an immediate knowledge of plant status and sequence of events preceding an emergency, and always being available in the control room.
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Potential shortcomings of the CECO proposal concern the orderly i
transition from normal shift crew functions to those following l
an accident. The plant SR0 may be unfamiliar with the detailed plant operating status and events preceding an emergency when assuming the role of control room SRO. The SCRE may be so involved in directing plant evolutions that quick, orderly turn-over of authorities and functions to the Shift Engineer and Shift Foreman may be hindered.
We believe that with the following administrative controls, the impact of the shortcomings discussed above will be minimized to the extent that the advantages of the proposal far outweigh the disadvantages and that the proposal to use STA's, licensed at the SRO level, as control room SRO is acceptable on a trial basis until the staff determines the long-term STA requirements.
a.
The oncoming plant SR0 comes to the control room and parti-cipates with the control room SRO (the SCRE) in the shift turnover that occurs at the beginning of the shift.
I b.
The plant SR0 returns to the control room two or three times l
per shift to assure that he is aware of the overall plant I
status and any evolutions that are being carried out or are expected to be carried out by the control room SRO.
i c.
In the event of an accident, the plant SR0 assumes the i
position of control room SR0 that was previously held by l
the STA/SCRE.
d.
The administrative procedures include guidelines to assure an orderly transfer of control room command functions between the SCRE/STA, plant foreman (SRO) and shift supervisor in the event of an abnormal or accident situation when the SCRE must assume the STA function.
We will require, in writing, a commitment by the applicant to modify, as necessary, Byron Administrative Procedures to assure they include these requirements prior to fuel load.
I.A.1.3 Shift Manning In a letter dated August 28, 1981, the applicant provided a copy of its position on T.A.P. I.A.1.3 which will be incorporated into Appendix E of the Byron /Braidwood FSAR. The applicant's position includes a commitment which meets or exceeds the minimum staffing and overtime limitations provided as guidance in NUREG-0737.
FSAR Section 13.1.2 and the applicant's position state that the minimum shift crew for one unit operation will include three SRO licensed individuals (Shift Engineer, Shift Foreman and SCRE),
two R0 licensed individuals, two non-licensed auxiliary operators and one Rad / Chem Technician. For two unit operation, the minimum shift crew will consist.of three SRO licensed individuals (Shift Engineer, Shift Foreman, and SCRE), three R0 licensed individuals, three non-licensed auxiliary operators, and one Rad / Chem Techni-cian. During core alterations, an additional licensed SR0 or SROL, an SRO licensed to supervise fuel handling, may have fuel handling 1
\\
t l
duties but will not have other concurrent duties. This meets the guidance given in NUREG-0737.
By letter dated December 29, 1981, the applicant informed us that procedures required by NUREG 0737 will be available and implemented prior to fuel load.
10.
NUREG-0654 Emergency Planning (organizational aspects)
The response to NUREG-0654 was reviewed with regard to organiza-tional aspects and all of our concerns are being addressed by the Region III Division of Emergency Preparedness and Operational Support in its input to the SER.
B.
Summary and Conclusion Based upon our review of information provided in the FSAR, in our information gathering meeting with applicant in October,1981, and in letters from the applicant dated June 3, August 28, Octobe; 5 and December 29, 1981, we are able to conclude that the plant staff organization is acceptable for the operation of Byron 1 and 2 with tro exceptions. The applicant has not made an acceptable commitment to meet our postion concerning the presence of individuals with comaercial PWR experience on each shift at least until attainment of 100% power. The applicant has not committed to establishing the administrative controls discussed in our evaluation of the applicant's position on Item I.A.l.1 of NUREG-0737.
13.2.2 A.
Discussion In the Byron /Braidwood FSAR, the applicant has provided a description of its training programs for non-licensed personnel.
The Station Superintendent has overall responsibility for the training of personnel within the plant organization. The Training Supervisor who reports administrative 1y through the personnel administrator, has ready access to the Station Superintendent to discuss problems within the training department, training needs of station personnel, and any other matters related to training.
The Training Supervisor also reports functionally to the Production Training Manager. The Production Training organization supports Station Training by coordinating the preparation of training materials, surveillance of on-the-job instruction and the scheduling of simulator training and other off-site training.
The Station Training Department is fully manned with 11 personnel. The Training Supervisor and/or at least one training instructor reporting to the Training Supervisor will hold an SRO license on Byron, Units 1 and 2.,
The applicant has contracted with Westinghouse to have a plant specific simulator constructed at Braidwood, Illinois. With the completion of this simulator, which is scheduled for mid-1983, simulator training for Byron and Braidwood personnel will be greatly enhanced.
In the meantime, simulator training will be conducted primarily at the Zion
~,
Westinghouse facility.
The training for non-licensed individuals includes training for opera-tions personnel, radiation chemistry personnel, instrument maintenance personnel, maintenance mechanics and electricians, and technical staff personnel.
General Employee Orientation Training is administered to all personnel j
regularly employed at the Byron Station. The two-day course includes a basic description of a nuclear power plant, training in:
radiclogical health and safety; emergency plans and procedures; industrial safety and firc~protedtion; access control; use of protective clothing, and equip-ment; plant security and the quality assurance program.
1
- Training for mitigating core damage is described in the staff's evalu-ation of the applicant's response to TMI Action Plan, Item II.B.4.
B.
MPActionPlanItems I.A.3.1 Operating Personnel and Staffing - Shift Technical Advisor (training aspects)
N In a letter dated August 28, 1981, the applicant has described the j
selection criteria ad guidelines as well as the training program for individuals who will qualify as Shift Technical Advisors (Station Control Room Engineers (SCRE)).
The seiection guidelines used to assess an individual's eligibility as a SCRE candidate require that the individual possess a technical degree in an engineering or science field. For those individuals possessing a degree in an area other than Mechanical or Nuclear Engi-neering, a careful study of courses taken will be made to identify demonstrated competence in college level mathematics, physics, and chemistry. Consideration is given to the grade received and reputation of the college or university for strength in the scientific or engi-neering field. For individuals with considerable company experience, work performed and training completed will also be utilized to identify demonstrated competence in college level mathematics, physics, or chemistry.
The training program for SCREs described in the applicant's letter dated August 28, 1981, is designed to complete the training of an individual who has a technical degree and has completed Senior Reactor Operator training.
According to the applicant, "The first training modules developed for SCRE training will enable the trainees to satisfy the NRC STA training requirements." Further modules to augment this training will be,
^
i developed and administered to on-shift SCREs through the requalifi-cation training program.
When all modules are developed, long-term scheduling arrangements can be secured with the universities involved, j
whereby the SCRE post-SRO training will be incorporated into the SR0 training program. Accreditation will be sought for parts of the SCRE training program such that individuals working on a technical degree l
can complete their degree requirements while in the training program.
SCRE selection guidelines will then be modified to allow for individuals in this category.
We have reviewed the education and experience of five of the SCRE candidates and find that all have attained Bachelor of Science degrees I
in Nuclear, Mechanical, or Electrical Engineering and that they meet the experience recommendations of the INPO document entitled, " Nuclear Power Plant Shift Technical Advisor - Recommendations for Position Description, Qualifications, Education and Training."
In a letter dated December 29, 1981, the applicant provided us with an advance copy of FSAR Section 13.2.1 which has been revised to include a description of the SCRE (STA) training program. The training program was developed to incorporate the outline of NUREG-0737, Item 1.A.I.1, Appendix C, Section 6, " Education and Training Requirements."
The training is conducted under the direction of the applicant's Production Training Department.
I.A.2.2 Training and Qualifications of Operating Personnel -
Training and Qualifications of Operations Personnel The applicant's position on T.A.P. I.A.2.2 described its progress in conducting a position task analysis for station operating positions, Radiation-Chemistry, Nuclear Engineer, Station Control Room Engineer (SCRE) and some maintenance positions.
)
Currently, generic task analyses have been completed for all of the operating positions, and an effort is being made to complete the cor-responding site-specific task analyses fer each nuclear power plant position. Surveys, checklists, and interviews between task analyst and station personnel (subject matter experts) are being used by the Production Training Department to acquire the data needed for the site-specific analyser. Each task is evaluated in terms of physical difficulty, mental difficulty, safety-related importance, operatioral importance, environmental conditions, and frequency at which the task is performed. The task is then given a priority in relationship with other tasks within that position. A similar approach is being taken with non-operator positions.
The results of these analyses will be used eventually to establish training objectives for each of the positions. These plans may be altered depending on progress by INPO in the task analysis area.
C.
50.48 Fire Protection (Training Aspects)
By a letter dated August 31, 1981 the applicant submitted a point by point comparison of its fire protection program against 10 CFR 50, 1 :
i l
Appendix R.
The comparison revealed that the applicant's fire pro-tection program does not conform to the requirements of 10 CFR 50, Appendix R, paragraph I.3.b which states, " drills shall be performed j
at regular ir.tervals not to exceed 3 months for each shift fire brigade.
Each fire brigade member should participate in each drill, but must participate in at least two drills per year."
j The applicant claimed that the planned six shift rotation precluded meeting the requirements of 10 CFR 50, Appendix R, paragraph 1.3.b.
We i
expressed our position that drills be performed at whatever frequency is necessary to assure conformance with 10 CFR 50, Appendix R.
D.
Conclusion We have reviewed the applicants overall training program and conclude that the training program meets the requirements of ANSI N 18.1 - 1971 as endorsed by Regulatory Guide 1.8, Revision 1, and is acceptable with one exception. The applicant's training program for Fire Brigade personnel does not conform to 10 CFR 50, Appendix R, paragraph I.3.b.
13.4 operational Review I
A.
General i
The applicant has established a review and audit program to assure that the operation of the plant is in conformance with established j
operating procedures and license provisions and to review and approve j
design changes, changes in operating procedures, or changes in the j
Technical Specifications that may constitute an unreviewed safety i
question, as defined in 10 CFR 50.59.
I i
Four organizations have been established to accomplish the review and audit program:
1.
On-site Review
]
l 2.
Off-site Review j
3.
Quality Assurance l
j 4.
Independent Safety Engineering Group The On-site Review, Off-site Review and Quality Assurance Audit programs have been established and are functioning. The Independent Safety Engineering Group has had a charter written and will be functioning prior to fuel load. A written charter has been prepared for each group covering such areas as group responsibility, subjects requiring review, reporting requirements, organization, and membership.
4 l
B.
On-site Review Section 13.4 of the FSAR and the applicant's response to question 422.2 incorporate by reference, Commonwealth Edison Topical Report CE-1-A
, 4 w
and Section 16.6 of the FSAR which describe the administration of the On-site Review Committee, including membership, responsibility for selecting alternates, designation of the senior participant, provisions for interdisciplinary review, qualifications of those apppointed to the committee; responsibilities and authority of the committee; records and procedures.
The membership of the On-site Review cominittee consisis of; the Station Superintendent (Chairman), the Technical Staff Supervisor or alternate (Senior Participant), and members with expertise in one or more of the j
following disciplines, as appropriate:
i l
1.
nuclear power plant technology l
2.
reactor operations
-l
^
3.
utility operations 4.
power plant design 1
5.
reactor engineering 4
2 6.
radiological safety 7.
reactor safety analysis 1
8.
instrumentation and control
)
9.
metallurgy 10.
other, as required i
Reviews and recommendations of the On-site Review Committee are docu-1 mented with copies to the Division Manager - Nuclear Stations, the Supervisor of Off-site Review, the Station Superintendent, and the Manager of Quality Assurance. Copies are also maintained in station files.
i C.
Off-site Review During our September, 1981 site visit, the applicant provided a copy of the organization and administration manual for the Office of L
Nuclear Safety. The Office of Nuclear Safety, headed by the Director of Nuclear Safety, contains the Off-site Review Organization as well l
as the Independent Safety Engineering Groups for each station.
a The Off-site Review Group will operate in accordance with Sections 6.1.C.I. a-f of the Technical Specifications which describe the administration, scope of items reviewed, authority, records, proce-dures, and personnel qualifications.
i i
j i 4
i The Off-site Review Committee and Investigative Function is performed by designated personnel under the Director of Nuclear Safety supple-mented by others as may be appropriate to the subject matter being reviewed. These personnel who together perform the Off-site Review i
and Investigative Function are called the "Off-site Review." The Supervisor of the Off-site Review selects his alternate, the Senior Participants, their alternates and personnel qualified in specific areas of expertise according to the Technical Specification require-ments.
Individual reviews are directed by the Senior Participant.
The Supervisor of Off-site Review has the authority to order unit shutdown or request any other action which he deems necessary to avoid unsafe plant conditions.
i The Off-site Review will normally meet on a weekly basis tc discuss issues and problems which have come to the attention of staff members since the last staff meeting. A brief summary will be prepared to document issues and problems discussed at each meeting. A file of these summaries will be maintained.
D.
Quality Assurance (Audit Function)
The Audit Function will be the responsibility of the Manager of Quality Assurance independent of the Production Department and thereby removed from operating pressures. Responsibility for the audit of operating activities will rest with the Director of Quality Assurance (Operating) and responsibility for the audit of maintenance activities will be deleFated to the Staff Assistant to the Manager of Quality Assurance.
Audits will be conducted in accordance with Commonwealth Edison's approved quality assurance program and procedures as necessary to assure that safety related areas specified in Technical Specification Section 6.1.6.1.b at the required intervals which in no case exceed two years.
The Manager of Quality Assurance reports directly to the President of Commonwealth Edison and has the authority to order unit shutdown or request any other action which he deems necessary to avoid unsafe plant conditions.
Records of audits and recommendations will be distributed to the Station Superintendent, the Division Manager - Nuclear Stations, Manager of Quality Assurance, the General Superintendent of Production Systems Analysis, and to the Vice President of Construction, Production, Licensing and Environmental Affairs. Records of audits and correspond-ence will also be kept on file at the station.
E.
Independent Safety Engineering Group i
The Independent Safety Engineering Group is discussed below in our evaluation of the applicant's position on TMI Action Plan Item I.B.1.2 of NUREG-0737.
2 _
l F.
TMI Action Plan Items 1.B.1.2 Management of Operations - Evaluation of Organization and Management Improvements of NT0L Applicants (ISEG)
In a letter dated October 5, 1981, the applicant committed to providing, as required by Item I.B.1.2 of NUREG-0737, an Independent Safety Engi-neering Group consisting of four dedicated full-time engineers located on-site, reporting to the Supervisor, Safety Engineering Groups, Office of Nuclear Safety.
The functions of the onsite Safety Engineering Group - Byron /Braidwood Stations will include the following:
1.
Evaluation of all procedures important to the safe operation of the station for technical adequacy and clarity.
2.
Evaluation of plant operations from a safety perspective.
3.
Evaluation of the effectiveness of the quality assurance program.
4.
Evaluation of the operating experience of the station to provide recommendations on safety-related concerns.
In this regard operating experience of other plants of similar design are assessed for applicability to the station.
5.
Overall assessment of Byron /Braidwood staff performance regarding their conformance to requirements relating to safety.
6.
Other matters relating to safe operation of Byron /Braidwood that independent review deems appropriate for consideration.
7.
Assessment of plant safety programs.
Personnel assigned to the Safety Engineering Group - Byron /Braidwood Stations, shall meet the qualification requirements described in Section 4.7 of Draft ANSI /ANS 3.1-1979.
Qualified experts in disciplines, which would not be fully utilized at one site, will be made available to the safety engineering groups of all CECO sites on an as-needed basis.
G.
Conclusion Based upon our r'eview of the FSAR, Sections 13.4 and 16.6, information received during our September, 1981 site visit, and the applicant's letter dated October 5,1981, we conclude that the applicant's program for the review of plant operations is in conformance with Section 4 of ANSI N18.7-1971, " Administrative Control and Quality Assurance for the Operational Phase of Nuclear Power Plants" as endorsed by Regulatory Guide 1.33, " Quality Assurance Program Requirements," and Item I.B. I.2 of NUREG-0737.
i.
a 1
i i
i 13.5.1.
Administrative Procedures i
A.
General j
For Byron, Units 1 and 2, employee actions and standards for plant operation will be governed by detailed written procedures in conform-
]
ance with ANSI N18.7-1972. The applicant has stated in FSAR Section 4
13.5.1 that plant procedures will be in place before fuel loading of f
Unit 1.
i i
j Responsibility for preparing plant procedures is assigned to the appro-priate department heads of the station organization. These procedures l
are prepared by members of the station staff or by persons under their 4
direction. Byron Administrative Procedures identify station organiza-
]
tion and responsibilities, control room procedures, operating criteria, j
requirements for records, a summary of required tests, analysis, and calibrations to be performed, ar.d the group responsible for this work.
Byron Administrative Procedures also identify the authorities and responsibilities for procedure review and approval. All administrative i
procedures must be authorized by the station superintendent before j
being implemented.
]
]
The applicant has provided, by letter dated December 24, 1981, a i
description of procedures to be employed to cover crane operations, I
as an interim measure, in response to NUREG-0612.
In a letter dated j
December 29, 1981, the applicant stated that this description will be j
included in FSAR Section 13.5.1.
1
{
B.
TMI Action Plan Items l
)i I.A.I.2 Operating Personnel and Staffing - Shift Supervisor Administrative Duties 4
1 i
Commonwealth Edison uses the title " Shift Engineer" for the position i
the NRC refers to as " Shift Supervisor." The Byron Shift Supervisor j
reports to the Senior Operating Engineer who, in tura, reports to the j
Operating Assistant Superintendent.
1 1
During our September, 1981 site visit, the applicant provided us with j
a copy of Byron Administrative Procedure BAP 200-1, which contains a i
position description for the Shift Engineer and other licensed operators, their responsibilities, authorities and functional relationships. This procedure delineates the command decision authority of the shift supervisor in the control room.
It states that the shift supervisor 4
i is in charge of the entire plant operation during his shift. This i
procedure also establishes the line of command and command authority of the Shift Engineer relative to other members of plant management, j
the delegation of the command function to the Control Room SR0 during j
absences of the Shift Engineer from the control room during normal operations, and the responsibilities and authorities of the Shift Engineer during site emergencies and incidents in accordance with the Generating Station Emergency Procedures (GSEP).
~
i i
, 1
We were informed by CECO during our September, 1981 visit to the Byron Station that the training program for Shif t Engineers includes indoc-trination in 6he plant administrative procedures and directives including those concerning the shift supervisor's responsibility for safe operation of the plant and the management function that the shift supervisor is to provide.
By letter dated October 5, 1981, the applicant has submitted its position on Item I.A.I.2.
The submittal states that studies were performed in September, 1977 and December, 1979 to ascertain whether or not administrative duties assigned to the Shift Engineer (Shift Supervisor) detracted from his primary responsibility of assuring safe plant operation. Both studies concluded that currently assigned administrative duties do not interfere with this responsibility. The applicant's submittal also included a commitment to delegate any administrative functions that detract from, or are subordinate to, the responsibility for assuring the safe operation of the plant to other operating personnel not on duty in the control room.
CECO has agreed to provide an appropriate management directive, prior to fuel load, that emphasizes this primary management responsibility and clearly establishes the shift supervisor's command duties. CECO has also agreed to reissue this directive annually.
I.C.2 Operations Procedures - Shift and Relief Turnover Procedures In a letter dated October 5,1981, the applicant has committed to develop administrative procedures which will govern shift and relief turnover to the extent required by the NRC requirements of NUREG-0578, Section 2.2.2.b.
Procedures will be written and implemented prior to fuel load.
I.C.3 Shift Supervisor Responsibilities This item is included with our evaluation of the applicant's position on Item I. A.1.2, Shif t Supervisor Administrative Duties.
I.C.4 Control Room Access In a letter dated October 5, 1981, the applicant has submitted, as part of Appendix E to the FSAR, a commitment to write and implement, prior to fuel load, procedures which establish the authorities and responsibilities of the person in charge of control room access during normal and emergency situations. Though we believe it is implicit in the applicant's position that these procedures will conform to the NRC position statement of NUREG-0578, we will require that the applicant I
supplement its position by providing, in writing, a commitment which states explicitly that conformance with the NRC position statement of NUREG-0578 will be achieved; or describes the implementing procedures in sufficient detail to allow us to conclude that the applicant meets the requirements of Action Plan Item I.C.4 of NUREG-0660.
i i
4 4
J 1
j I.C.5 Procedures for Feedback of Operating Experience to Plant Staff j
We have reviewed the applicant's responses contained in a letter i
dated August 28, 1981 and Amendment 34 to the FSAR, as well as the l
Organization and Administration Manual for the Department of Nuclear Safety and Byron Administrative Procedure BAP 300-8, " Operating i
Experience Feedback." Based upon our review of these documents, we find the applicant meets the requirements of Action Plan Item I.C.5 of NUREG-0737.
)
t l
1.C.6 Verify Correct Performance of Operating Activities In a letter dated October 5, 1981, the applicant submitted its posi-l tion on Item I.C.6 as part of Appendix E to the FSAR which states that i
procedures will be reviewed and revised os necessary to assure that i
an effective system of verifying the correct performance of operating i
activities is provided. Such verification may include use of automatic status monitoring systems, independent personnel verification, or functional tests. Procedures will be reviewed, revised, as necessary, and implemented prior to fuel load. The commitment to this imple-mentation schedule was not part of the applicant's original position i
statement in the October 5 letter but was subsequently committed to, I
upon our request, in a letter dated December 29, 1981. We do not have sufficient information to conclude that the applicant meets the I
requirements of Action Plan Item I.C.6 of NUREG-0737. We will require j
that the applicant augment its position to include sufficient detail to make our determination or; provide us with a copy of the procedures 1
to be implemented to satisfy the requirements of Action Plan Item I.C.6.
l C.
Conclusion
)
l Based on our review of information submitted by the applicant, we
]
conclude that the applicant's commitments to write and implement l
administrative procedures are acceptable with two exceptions. The applicant's responses to Items I.C.4 and I.C.6'do not contain suffi-cient detail to allow us to determine acceptability.
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