ML20004F768
| ML20004F768 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/15/1981 |
| From: | Frazar R, Goldberg J, Moles R, Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20004F767 | List: |
| References | |
| RTR-NUREG-0780, RTR-NUREG-780 ISSUANCES-OL, NUDOCS 8106220302 | |
| Download: ML20004F768 (49) | |
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9 UNITED STATES OF AMERICA 0, NUCLEAR REGULATORY COMMISSION 1
2
.3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.4 In the Matter of: 5 7 5 14 HOUSTON LIGHTING & POWER 5 Docket Nos. 50-4980L
'$ COMPANY, ET AL. 5 50-4990L 5
9, (South Texas Project, 5 j,
Units 1 & 2) 5 5
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.4
.5 TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL. --
.5 7, OF
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- 9 MR. GEORGE W. OPREA, JR.
- 0 MR. JEROME H. GOLDBERG
- L MR. ROBERT I. MOLES .
- 2 MR. RICHARD A. FRAZ33.
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- 4 REGARDING
- THE OPERATION OF THE SOUTH TEXAS PROJECT 17 ,
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17 cfJM1 Office of the W fg
- g px,heting & Service 19 t Branch
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$1 t 4 8106220301
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) UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION L
1 3 BEFORE THE ATCMIC SAFETY AND LICENSING BOARD 4
l- In the Matter of: $
7, $
g, HOUSTON LIGHTING & POWER $ Docket Nos. 50-4980L 3
J 4
5 Testimony of George W. Oprea, Jr. , Jerome E. Goldberg, 6! Robert I. Moles and Richard A. Frazar Regarding 7 the Oceration of the South Texas Project S
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1 Ql. State your names and current employment.
2 3 A1. George W. Oprea, Jr., Executive Vice President for
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Houston Lighting & Power Company (HL&P).
) Jerome-H. Goldberg, Vice President, Nucle,ar Engineering 8 and Construction, for EL&P.
O Robert I. Moles, Plant Superintendent at the South 1 Texas Project (STP), for EL&P.
3:
4! Richard A. Fra:ar, STP Project Quality Assurance 5}
6 (QA) Manager for EL&P.
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3, 4, Mr. Oprea, describe your professional experience Q2.
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6 and educational background.
7 8 A2. (GWO): That information is presented in my test.imony 9,
0: regarding HL&P's experience in the construction of STP. .
1 2 -Q 3 . Mr. Goldberg, describe your professional experience 3 and educationT1 background.
5, 6 A3. (JHG): That information is presented in my testi-7 g '. mony regarding HL&P's management of design and construction o!
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of the STP.
Q4. Mr. Moles, describe your professional experience
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3 and educational background.
4 3 A4. (RIM): I received the degree of bachelor of 6
7' se d .ence in Electrical Engineering from the University of
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- 9' Texas in 1965.
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.1 I joined HL&P*in 1965 as a Junior Engineer in the
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3; Energy Production Department. As a Junior Engineer, I
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- g , performed testing on the 481 MWe P. H. Robinson Unit 1, and
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- 7l participated in the installation and startup of 12 gas IS - turbine generating units. In 1968 I was promoted to Assistant
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il Electrical Engineer in the Electrical Maintenance section,
- "-:! which is responsible for maintenance of various electrical 13 I4 : and electronic equipment in ten generating plants. In 1971 15 !
16 ', -I became Assistant Superintendent at the H. O. Clarke Generating 17 '
LS j' Station and in 1972 I was transferred to a similar position j 19 i 50 :
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'[ii at the Cedar Bayou Generating Station, where I supervised i
the operation and maintenance of three 750 MWe gas-fired I units. I was appointed to my present position in 1977. I ma a Registered Professional Engineer in the State of Texas.
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[, Since becoming Plant Superintendent at STP I have I
g attended the Westinghouse 30 week Reactor Operator Training i I' Course, certifying at the Senior Reacter Operator (SRO)
r' level. I have also attended requalification training on the 7
Zion simulator in 1979 and 1981.
QS. Mr. Frazar, describe your . professional experience h.
and educational background.
i AS. (RAF): That information is presented in my testi-i T: many on HL&P's current QA program for the design and construc-3'
) tion of STP.
3 L Q6. Panel, describe the purpose of your testimony.
j A6. (Pan.cl) : The purpose of our testimony is to
} describe the HL&P management organization and plans for the ii operation of STP; to show that HL&P will have the necessary 3
technical competence to operate STP safely and has.already 3 taken important steps in that direction; that HL&P's planned Li 1I staffing and organization meets applicable Nhc requirements; 3!
4l 51 and to demonstrate that HL&P's QA program for Plant operations 5' will meet applicable NRC requirements.
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Q7. Mr. Oprea, describe HL&P's management organization 5t 6: for the operation of STP.
7 3 A7. (GWO): As Executive Vice President I have ultimate 9'
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responsibility for nuclear operations, including STP. The .
1 2 nuclear operations staff will report to me thrcugh a senior 3'
4 management position at the Vice President level. That Vice 6 President will be responsible for operation of both tne 7
g Allens Creek and STP plants. The organization for management a
of STP is shown on the attached chart (figure 1). We have f'
been recruiting for a Vice President of Nuclear Operations 3 and expect to fill that position in the near future with a 4
person who has extensive nuclear operations experience. .
b 7 Also reporting directly to me will be the Manager S
9 of the QA Department. Our QA Manager will have under him 0 .
1 separate staffs for nuclear operations, nuclear and fossil 2
3 design and construction, and supporting services. Our QA 4
jl Manager, Mr. Frazar is currently serving as the STP QA i
Manager, and his office is at the Plant site. However, we 8
expect to bring Mr. Frazar back to Houston once his replacement 9
0 as STP QA Manager has taken over at STP. Mr. James Geiger, 2' the new STP QA Manager is scheduled to report to work on 3-4l June 22, 1981.
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6 In addition to the nuclear operations and QA
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,8 ! pe rsonnel there will be a technical support group. This e9 , ,
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3 4 group is a part of the Nuclear Engineering and Construction 5
6' organization that reports to Mr. Goldberg.
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3 EL&P has a Nuclear Fuel group that is responsible 9
0 for nuclear fuel support activities. The Director, Nucle.r .
1 2 Fuel. reports to me.
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]: In addition to the staff working full time in the
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nuclear area, there are other EL&P staffs that will be fl a
providing suppcrt services for STP. Our Fossil Plant Engineering and Construction organiration represents a f
1 resource of engineering expertise that will be utilized as 3 needed. Although assistance from other EL&P groups and from 5 outside consultants will be available to supplement our full 6
7' time staff on the STP, we plan to make BL&P essentially self 3
9 sufficient in regard to the conduct of our nuclear operations.
0 1 There are also two committees of executives and 3 managers that will be reviewing the performance of Plant
'l operations and QA. These are the Nuclear Safety Review
-0 Board (NSRB) and the QA Program Evaluation Committee. These 8 two committees are described in FSAR Section 13.4 and 17.2, 0l
.j respectively, and are discussed below.
2 Q.8 Mr. Moles, describe the organiration of the Plant I
4 Operations staff, s!
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a A.8 (RIM): Figura 13.1-2 of Section 13.1 of the Final i Safety Analysis Report (FSAR) shows the organization for the 1
3 operation of the two STP units, including the number of 9
3 personnel per our current plans. While the details may vary 1
2, as our planning progresses, I do not expect any major chaages.
3 4 As shown in figure 13.1-2 and described in Section 6 13.1 of the FSAR, the organization includes four major 7
g, Sections: Operating; Technical; Maintenance; and Training, e'
f each headed by a General Supervisor. The two other groups j shown, the Radiation Protection Group and the Administrative 3 Group, will also have senior level Supervisors. Section 4
5 13.1 of the FSAR summarizes the responsibilities of each 6
7 group as well as the qualifications of key personnel. In my 8
9, answers to the next few questions I describe the functions 0 .
1 of eacn of these organizations, their ultimate staffing 9
3, levels, and their staffing levels as of May 27, 1981.
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5l Q.9 Describe the Operating Sec~, ion.
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A.9 (RIM): The Operating Section includes personnel 8' licensed to operate the reactor and Auxiliary Operators.
g 0' The Operating General Supervisor is in overall charge of 1, reactor ocera.tions. and will hold. a Senior Reactor Ocerator
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4 (SRO) license on each unit.
6 The organiza .on chart shows six Operating Supervisor 7
8 i positiens in the op,erating Section, our equivalent of the 9 >
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I! Shift Supervisor required by the NRC. Operating Supervisors I will hold an SRO license on each nnit. A corporate managem'ent i
i directive will be issued prior to fuel load, i learly establishing
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)l the command duties of the operating Supervisor and emphasizing f
[ his primary responsibility for safe operation of the Plant.
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- Plant procedures will clearly define the duties, responsibilities 3
5 and authority of the operating Supervisor and other licensed
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The Watch Supervisors, reporting to Operating l Supervisors, will be licensed SRO's.and will be responsible 2,
3 for reactor operations command in the control roca. Each 4
5 one will receive supervisory training designed to optimize a
7 his performance as a Watch Supervisor.
3 9 We currently have one operating Supervisor, two 0
1 Watch Supervisors and 23 other personnel in the Operating 2 i 3 Section. The three Supervisors were previously licensed
! SRO's on operating commercial nuclear power plants. We are fi preparing all 26 personnel to be eligible for cold . licensing f!
0 on Unit 1. At present 24 of them either have the required nuclear experience or have been certified in the Westinghouse
_ .l 2i Reacter Operator Training Program, and training for the 3!
4i other two is in progress.
5l 6' We will have 22 Reactor Operators and approximately 7
8, 30 Auxiliary Operators for two unit operation. ;
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3 4 The Reactor Operations personnel are currently 5l 5i involved in writing' system descriptions and/or operating 7>
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procedures. As systems are turned over to EL&P these people-3 will be participating in preoperational testing. .
1 2, Q.10 Describe the Technical section.
2 4 A.10 (RIM): The Technical Section is made up of four 6 groups: Reactor Engineering, Chemical Analysis, Chemical Operations, and Results Engineering.
4 The Reactor Engineering Group will consist of a f
h Lead Reactor Engineer and two Reactor Engineers, one for a
3' each unit. The two Reactor Engineer positions are filled.
5 One of the Engineers has had extensive nuclear experience, 6,
7 including several years as a Navy Reactor Operator and 31 9 Reactor Technician and 12 years working on the Research 04 .
1' Reactor at the Texas A&M Nuclear Science Center. The other 2
3, joined HL&P upon receipt of a Bachelor of Science. degree in Nuclear Engineering from Texas A&M in 1977 and has since f attended the 30 week Westinghouse Reactor Operator Training 0
Program, certifying at the SRC level. Both Reactor Engineers 9,
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have attended the Westinghouse Nuclear Engineers Course, 1 The Reactor Engineers are currently developing the.
3 4i core physics and thermal hydraulic testing programs to 3l 6 monitor core performance. They are developing the Initial 7:
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Startup Test Progrmn, the onsite Special Nuclear Materials
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Accountability Program, and tne New Fuel Receipt, Inspection 6i and Storage Procedures. Their responsibilities during Plant 7
8: operation will include operational planning to determine 9
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plant loading and stretchout or coastdown capability to 2 ensure that refueling periods correspond to the proper core 3
4 burnup and system load demand. The Reactor Engineers will l also implement the Special Nuclear Materials Accountability Program for control and accountability of all special nuclear o
material at the Plant site. They ensure that the receipt, l inspection, and storage of fuel is conducted in accordance with applicable criteria.
3l 5 The Chemical Operations Group will consist of 42 6;
7 personnel, inciuding a Supervisor, 6 Foremen, 15 Chemical 3
9 Operators and 20 Trainees and Auxiliary Operators. The 0
,1 number of Chemical Operations Foremen has been increased to
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,3 , provide supervision on each shift. We have one Chemical j ..
Operations Foreman, three Chemical Operators, and four
. ?. Chemical Operator Trainees on board at this time. These le ,
l8 Chemical Operators and Operator Trainees have nuclear navy 19 1 10! backgrounds.
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II The: Chemical Operations Group is responsible for 63 L-% I the operation of Chemical Process Systems, Demineralizer 15 !
16 Systems, Radioactive Waste Processing Systems, and Non-17
- ' Radioactive Waste Processing Systems. They are currently IS 1 19 I 30 writing procedures and developing training materials.
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l The Chemical Analysis Group will consist of 23 personnel, including a Supervisor, 2 Foremen, a Nuclear Plant Chemist, and 19 Chemical Technicians, Monitors, Junior Monitors and Trainees. The Chemical Analysis Group presently.
consists of a Supervisor, Foreman, and seven chemical technicians.
i At the time we reviewed our organisation after TMI, we had i!
- one Supervisor over both Chemical Analysis and Chemical Operations, our review concluded that this job was more
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than one man could properly handle, so it was split into 3
two. A Nuclear Chemist also has been added on the current I chart.
i i, The Chemical Analysis Group is responsible for s' '
T plant chemistry and radioch.imistry. Chemical Analysis 3
) personnel perform laboratory analyses on samples as contrasted
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t, , with Chemical Operations personnel who operate systems
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3 supporting reactor operation. Currently Chemical Analysis 4l 5
personnel are writing procedures, developing training materia'Is,
) }- conducting uhe preoperational environmental sampling program, 3 and providing chemical analysis support for hydrostatic 9
0 ! tests.
5I The- Results Engineering Group will consist of a 3 i 4 Lead Results Engineer and approximately eleven Results 5 !
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. Engineers. We have the Lead Results Engineer and five Plant 7 !
8 i Results Engineers at this time, all of whom have engineering o !
O degrees. Three of them have completed the 30-week Westinghou"e i 1
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Reactor Operator Training Course. l l
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The Plant Results Engineers prepare test procedures,
- - perform tests, and prepare test reports for initial startup',
post-maintenance, and performance testing of Plant ip systems. They implement programs for In-service Testing of I
[ Pumps and Valves, EEPA Filter Testing, Containment Integrated I
g Leak Rate Testing, and Technical Specification Surveillance j; Testing. One of these Engineers will have lead responsibility for implementation of the Plant Fire Protection Program.
3 Results Engineers develop solutions to problems and equipment 4
malfunctions in various Plant systems. The Results Engineers 5 are currently developing the programs discussed above, i writing procedures, and coordinating the Plant staff review 6'
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of documents. 'The two Engineers developing the Fire Protection 3
9 Program have each attended several schools and seminars on 0
fire protection. In addition, we expect to utilire the i
2 3 services of a consultant to review our Fire Protection 4
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! Progren.
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Q.11 Describe the Maintenance Section. '
i A.11 (RIM): The Maintenance Section is divided into O four Groups; Electrical, Mechanical, Instruments & Controls r
- and Support, each headed by a Supervisor. Electrical and 3
4 l Mechanical Maintenan 2 were originally headed by a single
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.6 . Supervisor, but this position was split so that each Group 3 !
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will have its own Supervisor. This was done because of the
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magnitude of the workload. With the exception of the Electrical I
Maintenance Group, the Supervisor positions have been filled.
Two of the Supervisors whose experience was in fossil plants have been assigned to operating nuclear plants to gain experience by participating in eling outages.
The Maintenance Engineering Group will consist of 11 personnel, including a Supervisor, a Planning Scheduler, 7 Specialists and 2 Clerk-Typists. The Supervisor and one of the Specialist positions are now filled.
The Electrical Maintenance Group will consist of 21 personnel, including a Supervisor, 2 Foremen and 18 Electricians, Apprentices and Helpers. One Foreman, 5 Electricians and 3 Apprentice positions are now filled.
The Mechanical Maintenance Group will consist of 44 personnel, including a Supervisor, a Welding Specialist, 5 Foremen and 37 Mechanics, Apprentices and Helpers. The t
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Supervisor, a Foreman, 13 Mechanics and one of the Apprentice'
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positions are now filled. .
3 The Instrumentation & Control (I&C) Group.will y ;
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consist of 51 personnel, including a Supervisor,1 Engineers, T ;
' 4 Foremen and 44 I&C Technicians and Apprentices. The
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Supervisor, an Engineer, a Foreman and 12 Technician positions 6 are now filled.
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L I 1 2 i Maintenance personnel are currently performing I. preventative and corrective maintenance on the Reservoir Ii
! Makeup Pumping Facility and Meteorological Tower equipment.
7 3 They will assume maintenance responsibility for Plant equipment Li I> as it is released for Preoperational Testing. Maintenance 3
- , personnel will provide support, both manpower and procedural,
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j, for initial wire checks and functional checks, instrument 7
g and relay calibration, initial motor checks, initial pump 3
g checks, checkout of valves, electrical continuity, meggar l and hi-potential tests, and final coupling alignment. The 3 Maintenance Section will also provide support for test 4
5 calibration and assistance in leak testing, flushing of 6'
7 piping systems, and the preoperational testing. All Maintenance S'
9 Groups are currently writing procedures and developing spare O
L parts requirements. .
2 3
Q.12 Describe the Training Gection.
l A.12 (RIM): The' Training Section is responsible for bi Plant staff training activities. Since ene of the recommenda-
't tions resulting from a recent organizational review was an 0 expanded training organization, we plan a large Training it Section. We have three Groups in. our Training Section:
a i 4i Operator Training, Simulator Training and General Training.
5l 6 The Simulator Training Group will utilize a plant specific 7
a simulator which is now on order cnd is scheduled to be o
6, installed on the site by mid-1983. A I
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I The Trainirg General Supervisor has 20 years Navy
! experience, 15 in the nuclear area. He has attended an 8-week training course at the training center in Zion and is
- participating in the INPO Instructor Qualification and .
Certification Workshops.
The Operator Training Group will consist of the Operator Training Supervisor and 3 Training Instructors, all of whom will be licensed SRO's. This group will be respon-sible for all operator license training, except that utiliring j the simulator. .
The Simulator Training Group will consist of a Supervisor, 3 Instructors, 2 Programmer Technicians, a Draftsman and a Clerk. This Group will utilire the plant i specific simulator to train Reactor Operators and a number of other personnel, including members of the Technical l' Support Staff.
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The General Training Group will consist of a Supervisor and 7 Instructors. Thi.m Group will provide l
technical and general employee training.
l 3 ! The three Instructor positions in the Operator L !
1 Training Group have: been filled. The Instructors each havs 3 ;
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about 7 years of nuclear Navy experience. All three have i
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attended the 30-week Westinghouse Reactor Operator Training 7 !
S > Program, and each i,s certified at the SRO level.
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4 Q.13 Describe the Radiation Protection Group.
5 6 A.13 (RIM): The Radiation Protection Supervisor is 7
3 assigned to the Plant staff from the corporate Health Physics 9
0, organization. The Supervisor receives technical direction .
1 2, from.the corporate Health Physics organization but receives 3
4 dir2ction on scheduling from me. The Group is responsible 6 for a radiation exposure control program to assure that f'
9 exposure to the Plant staff and the public are kept as low as reasonably achievable.
! The Radiation Protection Group will consist of 33 3 personnel, including a Supervisor, two Health Physicists and 5 30 Radiation Protection Technicians, Monitors, Junicr Monitors 6'
7 and Trainees. 'We currently have a Supervisor and one Health 3
9 Physicist. The Supervisor has 30 years experience in applied 0
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radiation protection including both Navy and commercial nuclear power plant experience.
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6 Q.14 Describe the Administrative Group.
A.14 (RIM): The Administrative Group will consist of d:
9i 15-20 personnel, including a Supervisor. Its function will 0i be to provide clerical and administrative-support to the 1! Plant organization.
3 4! Q.15 Mr. Fra ar, describe the QA program for operations.
5i 6 A.15 (RAF): As described in Section 17.2 of the FSAR, 7:
8I HL&P has a QA Manual that estr_blishes the corporate QA 9
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- 1) policy and commitments. The QA Manual will be implemented ae a
3 for STP operations by an Operations QA Plan (OQAP), which 7
3 contains general criteria and requiremencs for STP operati.ons.
3' 3, The OQAP is in turn implemented in accordance with procedures-1' 2' that provide detailed instructions to employees performing-3 4 quality related work. The EL&P QA Manual has been in use i
6, for a number of years. The OQAP is currently under development, 7
g; with a significant amount of the work already accomplished.
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our plan shows a tentative completion of the OQAP by the middle of 1982, with further refinements occurring as we 3
3 move toward the fuel load date. This will allow more than 5 adequate time to continue development of the detailed procedures 6,
7 and training program;.
3 9 Q.16 Describe the QA organization for operation of STP.
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, A.16 (RAF): Our organization structure for operationa 2,
3! QA will parallel the QA organization for design and construction 4, .
5 described in my previous testimony. The QA organization for 6'
7i operations will report to executive level managemen.t not 81 i directly responsible for power production. The operations 9
f! QA~ organization consists of a Quality Engineering Group, an I! Auditing Group, a Surveillance Group, snd a Quality Control
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d (QC) Group. 'See figure 2) The functions of these Groups
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6 are set forth in Section 17.2 of the FSAR and are summarized ,
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Il I Q.17 What are the functions of the Quality Engineering i
i Group?
i I A.17 (RAF): Quality Engineering performs inspection
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); planning; investigates nonconformance reports and corrective .
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[ action requests; performs trending; reviews procedures,
- procurement documents, quality records, audit responses, i'
- specifications and receiving documents; evaluates test data; I
g writes procedures and revisions to the OQAP; maintains the r
3 working QA files; prepares various QA reports; and provides 3-L, QA training. .
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3 Q.18 What are the functions of the QA Auditing Group?
i 5 A.18 (RAF): The QA Auditing Group schedules audits; 5, ~
7 prepares audit plans; recommends auditor certification; _
3 3 provides input to the training program; and reviews and 3
L, approves responses to the audit deficiency reports.
j; Re,sults of auditing activities are reported to executive-4'
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management as well as management responsible f?r the activiti.es
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which have been audited. This audit group does not, by
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j itself, perform all of the audits necessary to satisfy 3! criterion. XVIII of Appendix 3. EL&P has an additional 1,
1 auditing group which is off-site and which provides broader-3!
4I scoped program audits to ensure that all 18 criteria of 5!
6' Appendix B are audited. Although there will be some overlap 7i 8!
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- between these auditing functions, the purpose of the on-site i
- i group is to provide frequent smaller-scope audits to inform 7;
3 Plant and QA management regarding the current status of the l program. The off-site audit group provides a macroscopic f, view of the QA program implementation by the whole STP 3 organization.
1; 5 Q.19 Will the QA functions in Houston that you described 3!
7i in your earlier testimony continue during Plant operation?
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3: A.19 (RAF): Yes. The QA Department in Houston will-3 L, continue to provide services to the Plant, including document 3' review, vendor surveillance and auditing.
j Q.20 What are the functions of the QA Surveillance 3 Group? -
e1 ll A.20 (RAF): The QA Surveillance Group performs sur-f veillance on th2 document control center, the record manage-IL ~
ment systela, general plant housekeeping, and activities 3!
4! centrolled by the- technical specifications. Results of 5i 6 surveillances are reported to Plant and QA management.
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3{ Q.21 What are the functionL of tha QC Group?
9 q A.21.(RAF): The QC Group performs inspections to t
{ verify that acceptance criteriathave been met for work dona-2i,i- by Operations and Maintenance personnel.
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The Group recommends approval o'f procedures and 7 checklists; develops QC procedures; inspects activities i 8 '
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- i during maintenance, repair, and modification; and initiates 5
5i nonconformance reports (NCR's).
Q.22 What is the current staffing level for the operations 3
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QA staff?
1 A.22 (RAF): We currently have six professional personnel 2
3 assigned to the Plant QA organization. Personnel will be 4
5; added to support the operations QA program according to a 6-7' , staffing schedule based on Project schedule information.
SI g! Q.23 What qualifications will be required for QA personnel?
Ol 1 ! A.23 (RAF): Quality Engineering personnel should n
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preferably have a degree in a specific technical discipline (such as mechanical, electrical, or nuclear engineering) and
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experience in QA. Our intent is to employ a mixture of 3' seasoned personnel with 5 to 10 years experience in nuclear 9,
Oi QA, coupled with junior personnel to 'ork alongside the 1!
2i senior people in a career development role.
3 4i Quality Surveillance personnel should hay 4 licensed 5I 6l operations experience in the commercial nuclear power industry 7
8l or have had experience in one of the military programs as a o 1 b!
3I nuclear reactor operator or a senior person in charge of an sl ,
operating reactor, 'such as. an Engineering- Officer of the 3:
,I Watch in the Navy nuclear program.
i Diditing personnel should have previous experience Q
7 and certification as auditor or lead auditor and be certified 8 ,
9 in.c cordance with' ANSI N45.'2.23 requirements. i 0 i
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Our QC personnel will be certified in accordance
! with ANSI N45.2.6 requireaents as Level II in the discipline
! to which they are assigned. Level III support to the QC l!
organization will be provided from the QA Department.
Management level personnel directly responsible
!, for the operations QA functions must have QA experience and t
i preferably a degree in engineering or science, and must be t-j knowledgable in nuclear power operations and maintenance.
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! Q.24 Mr. Oprea, does EL&P have an Operations QA Manager?
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, A.24 (GWO): No, we have been actively recruiting to
. fill that position, and expect to have a qualified individual i
,, on board by the fall of 1981.
o Q.25 Mr. Goldberg, is EL&P planning how to provide i
3! technical support for Plant operation. e Studying and planning for technical fl A.25 (JHG): Yes.
2 support of operations started in 1976 when EL&? defined the 3
4! role of EL&P Engineering in pre-operational testing and 5l 5j start-up. In 1978 and early 1979, the scope of activities 7i 3; and responsibilities of the Site Engineering group during 9I Oi the design and construction stage was defined. Also, in
{j 1979, a. study was completed recommending'that EL&2 develop 3i its own capability to perform non-LOCA transient analysis.
4 3 l We are now developing that capability. In the last two o ;
I i years, EL&P personnel have visited nuclear facilities of 8 i 9 !
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- Public Services of Colorado, Sacramento Municipal Utilities 3! District, Southern California Edison, Virginia Electric and 3i
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Power Company, Arizona Public Services, and Florida Power &
3 I Light to review various organizational ctructures used for 3;!
technical support of Plant operations. Findings from these 1
3' , trips have been factored into our plans.
1 5> One of our most signif; cant recent efforts was a i
7l study performed by Nuclear Services Corporation (NSC),
i
- 3 completed in January 1980. A principal purpose of the NSC 3
(l study was to evaluate, in light of TMI, the EL&P staff
{'
expertise needed to provide technical support during Plant operation. Numbers, skill type and skill levels of personnel a
3 as well as technical review areas were identified.
3L Q.26 What are EL&P's current plans for providing technical
?
3 support for Plant operations.
L.
2 A.26-(JEG): Most likely the present Site Engineering 3
4i Group will form the nucleus for the technical group supporting 5i 5' Plant operation. We plan to have a technical group on-site, 7>
3; close to the activities it will support, to aid in developing 3 i 3; a clcse relationship with the operating staff. Although t :
s!
formal procedures will govern such matters as requested 3lI design changes, a close relationship will be an aid to
, 1 3l communications and. mutual understanding. Some support will j e i ,
?! also be available from the headquarters office.
6!
9i 0l 1'
1 l
1
1 L
L l
- , Our goal is to have an on-site staff technically i
- ' capable of performi
- . g design verification for all technical Ti 3
areas, especially those that are uniquely nuclear. For very
)
, specialized and complex areas, such as seismic analysis, we r .
will most likely continue to employ outside consulting
{
{* assistance. We believe that a utility must have in-depth I knowledge and involvement in technical matters affecting 3
7' Plant operation and we will direct our recruiting and training 3l
} efforts to that end.
3 i As we move into the operations phase, our technical j activities will shift from the headquarters to the site to
}, perform, in support of the Plant Operations staff, such
!o >
functions as:
l
- 1) Provide a program and procedures for control 7 of Plant design.
2' 2) Review proposed changes to operating ~ procedures.
3i 4 3) Review and evaluate operating. experience and 5!
6j ,
performance of selected systems and components.
7!
gl 4) Review activities such as maintenance,. outages, 9,
aj r .
anr surveillance testing and the associated
~! procedures.
- i. 5) Provide engineering design for Plant modifications l
+ !
C i l
- e! (in-house and/or through contractors).
i I!
Ei 9i Gl L! ,
I i '.1 1
L 2,
3' 4 6) Participate in the resolution of nonconformances.
3 ; 7) ?articipate in procurement of engineered 7
equipment, including spare parts.
9l 0'
- 8) Interface with the Plant technical staff.
1! Q.27 Mr. Moles, please summarize the current staffing 2
3l level of the STP Operations Division.
4 5' A.27 (RIM): Although Plant operation is still a few 5
7i years away, EL&P has a significant part of the Plant operations 3i staff on the job at STP.
9l O;
- Staffing the Plant c'
- ganization began when the Assistant Plant Superintendent and I were named to our respective positions in February of 1977. Since that time 6
we have grown to a staff of about 112 persons. We expect to _
3 build up to a staff of approximately 360 for two unit operation.
9 0 To plan an orderly development of the operations staff we 1 ;.
2' have identified the tasks which must be-accomplished by the 3i 4I Plant staff up through commercial operation of Unit No. 2.
5i 6: We have been hiring personnel with nuclear experience 7'
8; in the military services. We plan to continue to do this, 9l 0j realizing, however, that the demand for chese personnel has ii VI greatly increased since TMI'. We also plan to fill some-key
,i
- ! positions with personne-1 'iith commercial nuclear power plant 3
i operating experience.
6l; 7!
8! l 9! l 0 i l L!
6
.m l
.l
I!
6 Q.28 What are Plant Operations personnel doing during I
- the construction phase?
7!
g) A.28 (RIM): One of the major pre-operational activities
)
); we have identified is procedure development. We have made
- , significant progress in preparing our Plant Procedures I Manual. As of March 3, 1381, 137 procedures had been approved 1
3 '.
and another 149 were in some stage of development. The a!
7! procedure index identifies over 1600 procedures which we 3}
}l plan to have in our Manual.
- 3. .
Li The Plant Operations Review Committee (PORC),
7 3f which is described below, has been meeting monthly since j July 1978. The Committee's primary activity to date has j been the review of safety-related procedures. Other major
~-
activities of Plant personnel to date have included spare
) ,
f-t parts evaluations and development of training materials.
{! t Another major activity which Plant personnel will
?. be' involved in is pre-operational testing. Operators, Elec -
5i 5l tricians, Mechanics, and I&C Technicians will be assigned to 7i sl the Test Engineers as needed. Very valuable experience will 9l g! be gained by our personnel in this way. Present personnel
{i 1
are giving emphasis in procedure- development to procedures 3!
4, that will be: utilired for pre-operational testing.
, In additi'an to working on plans for Plant operation, j my staff. is undergoing training and is reviewing and commenting I
9 O ;
L !
2 3
- , on the Plant design. The experience of our operations staff
-i ll '
in operating similar systems at other plants has been reflected in suggested changes to the design to improve system operability 3I and maintenance.
3 1' Q.29 Mr. Moles and Mr. Frazar, describe the transition 2
3 from construction to Plant operation.
4 5' A.29 (RIM, RAF): Before fuel is loaded in the Plant, 6
7 EL&P will conduct tests of the' Plant equipment and systems.
3l!
3l A separate EL&P organization, called the Startup Group, has 0
1+' been established.to conduct these tests. The Startup Manager, 3
Barry Duncan, is also Assistant Plant Superintendent and his
$ qualifications are described in Section 13.1 of the FSAR.
s b.< !
The Startup Organization is described in Section 14.2 of the ,
l FSAR. It includes a number of experienced engineers working 0 on STP under a contract with Westinghouse. Plant operations 1l 2! personnel, including Electricians, Mechanics, Chemical 3'
4l Operators, Chemical Technicians, I&C Technicians and Re-actor 5!
6! ,
Operators will be assigned to the Startup Group to assist in 7!
g, the performance of testing. The Startup Group is now writing 9
0, the Startup test procedures utilizing, where practical, i
T l; Plant procedures.
1 As each Plant system nears completion the EL&P 3!
c i Startup Group, EL&P Plant QA, Brown & Root (B&R) QA and B&R
=
'! Construction Engineering will jointly review the status of 8 .
9 !
0 ,
L !
l L i
- 3
!i ll l the system to determine what must be done for the system to i be ready for testing. This activiuy includes " walk-downs" I of the system to identify hardware exceptions or deficiencies.
i j , When nonconforming conditions are identified by
[l HL&P Plant QA or Startup an NCR will be generated. The NCR
- will be dispositioned by the construction NCR system.
! Depending on the scope of work necessary to disposition the t
NCR, EL&P maintenance or B&R construction will implement the I! disposition of the NCR.
1'
.! Once a system is tested and the test results approved,
!i i it will be turned over to Operations.
I i Q.30 Mr. Goldberg, has EL&P hired the personnel who i
7 will provide technical support for Plant operations?
I'
- A.30 (JHG)
- As I mentioned before, the current design 1
,, and construction technical staff will form the nucleus for 7
the technical staff during operations. Technical activities
!j on the Project are under the direction of the Project Engineering 2 i
. i 2! .
Manager. The experience and qualifications of that staff Ii i! were described in my previous testimony in this proceeding.
?I
)l NUREG-0731 identifies technical support skills L t
- 1; required. for both normal and emergency operations. We 3i
&l already have on staff individuals that meet or will meet 5'
5 most of the qualifications outlined in that document. We 7
3I plan to acquire or train additional individuals so that all
?!
- ;
t i
L 2
3l 8 the requirements are satisfied. For instance, this year we 5
5 are actively recruiting specialized skills in the areas of 7
3 welding engineering, metallurgy, ASME Division III pipe 3-
), stress analysis, and transient analysis.
i t
- , Q.31 Mr. Moles, describe the program for training STP 3
Plant operations staff.
4
!l 3
A.31 (RIM): An important element of our training 7l program will be the use of a plant specific simulator.
3!
3l Early this year we placed an order for a simulator J
L for STP. The purchase of a simulato,r was one of the recom-2 3 mendations made after review of the lessons learned from 4
3; TMI.
We have formed a project organization to follow y the design, manuf.cture, installation, and testing of our 3
j simulator. It is expected that the nucleus of our Simulator 2' Training Group will come from this-Project organization.
3 4l The Operator Training Gro"p will be responsible a\
5( for all operator license training except tha utilizing the 71 3i simulator. The objective of HL&"'s operator training .is to af bl
, i equip the operator to assess any given situation and to use i: the available information to evaluate the Plant parame.ters 3l displayed in the control room. The key to the operator's 4j e i jl ability to do this is understanding such factors as the
' l physical laws that govern the operation of Plant systems and
9i 0i L!
l l
- l ,
i I
- how those systems function. We expect to have a staff of l trained personnel who will be able to handle any situation i
they may be confronted with in the control room.
i our on-site operator license training program t
consists of three parts: the Nuclear Steam Supply System (NSSS) Training Package developed by Westinghouse, a Balance of Plant Package, and a Procedures Package. The NSSS Training
- Package consists of 43 lessons including health physics, chemistry, reactor theory, systems, accidents, transient and
- i instrument failure analysis. It includes system descriptions, j lesson plans, and training aids. The Balance of Plant
[ Package is being developed by our Operator Training Group.
e
- It will consist of 62 lessons on Plant systems. Each lesson _
i will include system descriptions, lesson plans, and training
)
, aids. The current status is:
I System Descriptions: _ 32 completed, 15 in draft 3
! Lesson Plans: 20 completed al i! Training Aids: 20 in development I) 3! The Procedures Package has not yet been developed. It will 3i
) ; consist of 12 lessons covering op2 rating procedures, including 1i normal, abnormal, emergency, and annunciator response.
3! The General Training Group will provide the other 4j j I' training for the Plant staff including General Employee 7
g Training (Security, QA, health physics, etc.). Technical 9 !
0 l L i i
1
f !
~.
I' .
3; il Training will also be provided for six of the Plant groups:
ai 5 Chemical Analysis, Chemical Operations, Radiation Protection, 7!
3' Mechanical Maintenance, Electrical Maintenance, and Instrumentation 9'
3i and Controls. .
1 ii .Q.32 Describe the training completed to date.
~
~
4 A.32 (RIM): Since.1977, we have sent three groups of
-; trainees through the Westinghouse Phase I, Phase II, and Phase III programs at Zion.
9 These groups consisted of Reactor Operators, 0
1! Supervisors, Plant management personnel and Engineers.
2' 3i Through this program we have certified 17 individuals at the 4
5; SRO level and 8 individuals at the RO level. In addition to 6,
7< that program, we have taken 8 individuals who were already _
8 9; cold licensable and put them through a Westinghouse 8-week 0i t: intensive course to familiarize them with Westinghouse 2'
3 commercial PWR's. Six additional co-licensable individuals began the Westinghouse 8-wee. course on June 8, 1981.
2l 2
3l i
We think it is important to periodically provide 8 l- refresher training to those individuals who have been through 9
0 the Westinghouse programs. Accordingly, we have-contracted L!
I with. Westinghouse for 4-day Requalification programs on the 3
4 Zion aimulator. To meet current retraining requirements we 5
6, . intend to send our licensed operators to Zion on an annual t
a basis for the 4-day Requalification progrma.
9 0
L ;
I
l I l l.
l In September, October, and November of 1979, we i
! sent 24 personnel to the Westinghouse 4-day Requalification' program at Zion. In January, February, and March of this i
l year we returned 33 personnel to Zion for that program. .
l
.Q.33 How 'till the training program be utilized to i
prepare for initial Plant operation?
! A.33 (RIM): This spring we are conducting an abbreviated on-site lecture series. In early 1982 we intend to send our
! people back to Zion for the 4-day Requalification program j and in the spring begin a 15 week on-site lecture series.
In early 1983, we plan two weeks of Simulator training.
When that is completed we will have the Westinghouse Pre-License
Review Series and Audit and then personnel will be taking the license examination. Our plan is to put enough people 1
l into the start of this program to man both Units 1 and 2.i
, i j ! Although we do not expect a 100% pass rate, we are confident
! that this approach will ensure that we have enough licensed s ,
personnel for Unit 1. We expect 40-50 people to be taking 3
1 3I the license examination.
)I '
) q.34 How will the training progrma be utilized once the-L 1! Plant begins operation?
3 4 A.34 (RIM): After Unit 1 fuel load, our program will be 5
. structured to bring peopl in at the eatry level and train 6;
7 them to qualify for the SRO license by means of three programs.
g 9!
0i L!
-3 0 -
S 1,
21 3l 4I The first is the Auxiliary Operator Training Program.
5l 6i Annually, we intend'to have one class which will include the 7+
8 following: 2 weeks indoctrination, 7 weeks Nuclear Power 9i
,0 -
Plant fundamentals, 8 weeks of systems, 8 months of on-the-job
.1
,2 ; training, and 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of simulator training.
'3
,4 ' After an Auxiliary Operator has been with us for 18
- 5 i '
,6 months, he is eligible to go into hot license training at g the RO. level. That is the second of the three programs. We 9! intend annually to have one class which will include: 10
!O I
!1! week lecture series, 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of simulator training, and 13
!2 :
L3 weeks of standing watch in the control room under the direction
!4 i
!S : of a licensed Reactor Operator. Finally, candidates for RO
!6 ! .
t'7 l and SRO certificates will take the Westinghouse Pre-License
!8 !
ggl Review Series and Audit, followed by the license examination.
10 :
it i
The third program is the RO to SRO upgrade. Annually,
- 12. '
13l we will conduct one class which will include: 13 weeks of
- standing watch at the SRO level under the direction of a l6 licensed SRO, 40 class room hours of supervisory leadership 18 training, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of simulator training at the SRO level, 19 10 and 4-weeks of advanced. theory.
11 I2. l All Auxiliary Operators, Reactor Operators, and 13 i l
14 Senior Reactor Operators will undergo retraining on a con-15 16 , .tinuous basis. We plan.to utilize a six shift rotation 17 !
18 '
19 30 il
L, 3:
1l which provides that five days in each 42 are used exclusively 2
i! for retraining. Another four days in 42 are available for T.
3' relief duty. When relief operators are not standing relief *
)
); watches in the plant, they will be involved in additional .
L!
- , retraining activities on an as-needed basis.
3'
- The retraining program will include lectures,
. ! simulator exercises, examinations, general employee training, 7l 7
Licensee Event Report (LER) review, respiratory training, 3! fire brigade training, procedures review, and supervisory 3
1, training. .
2 3, Our plant specific simulator for STP will be 41 5 located at the site. We hope to have the simulator operational 5,
7! in time to utiiize it during the cold license training of a' .
9; our first group of operators. Of the simulator training 0'
t; that I mentioned previously, that which is done before we 2!
3 l have our simulator operational will be conducted at Zion.
}l Q.35 Mr. Erazar, please. describe how the training kli\
program of the QA Department will be conducted during Plant 8l 9i operations.
0l A.35 (RAF): The- QA Department will perform indoctrination 1i and training for QA personne1 as well as: other EL&2 employees.
v 2i 31 I
4 whose- duties and responsibilities will be governed by the QA 5
6 . program.
7 g Indoctrination and. training of QA and non-QA EL&P 9
0 employees will be: conducted to familiarize new or transferred LI l _
-3 2 -
1 1
Il ij employees with the Nuclear QA Program. The program will 8
i stress the importance and meaning of QA as it applies to th'e f!
!; employee's new position. It will include a discussion of Il 1 the philosophy and objectives of the QA Prcgram; an explanation
[l 1'
of the QA Program and how it affects the duties and respon-
- sibilities of the employee; and the purpose, scope and i
- i implementation of quality-related manuals, instructions, i procedures, Regulatory Guides, standards and codes, with g
I specific emphasis on the sections which most directly affect
)
L the employee's new position. Emphasis will be placed on the 2
3i fact that the QA Program has been endorsed by the President 4
5 of EL&P and that quality policies and the various plans and 5' .
7i procedures that make up the QA Program are mandatcry require- .
3 3 ! ments which must be implemented and enforced.
3
[i2i? In addition to the QA Department training and'indoctrina-tion described above, each set of departmental procedures 3l io and the-Plant procedures will provide for training and
$ certification, if required, of personnel who perform quality-i 3 related work.
9 0 Q.36 Mr. Goldberg, will there also be training programs 1!
1I for technical support personnel?
3 4 A.36 (JEG): Yes. T aining of the technical support 5
6 . groups involves a number of considerations. First, a general 7!
8 training program is planned for each technical discipline.
9 0
1i l
n _
-3 3 -
Il
'i Included in this planned training will be the use of the STP et ir ! simulator. We beli~ eve it is important that the technical Ii support staff understand plant operations from the reactor p'
I operator's viewpoint. .
[ Another important part of the technical support I '
- staff training is health physics training. We plan to i1
- ! perform this function totally in-house and to have on board 7i che instructors and the appropriate multimedia equipment to y;
accomplish this task.
Q.37 Mr. Moles, describe the organization for each l shift during reactor operation.
5 A.37 (RIM): The shift organization is shown in Figure 3.
5, 7 An Operating Supervisor with an SRO license will be on site 31 3 anytime a unit is loaded with fuel. All personnel on shift 3i L
i are responsible to him.
Z
- 3! Reporting directly to him is an organization for 4 ! .
5 i each reactor unit headed by a hatch Superviser with an SRO
$s license and a Chemical Operations Foreman with asso,ciated 3
staff. Each unit will also have two operators with RO k licenses, a. Radiation Protection Technician / Monitor and.a f_
1 Chemical Technician / Monitor.
3i Chemical Operations personnel working on a unit 4l "l
6; .will keep the Watch Supervisor informed of their activities, 7
8 but will receive di,rection on priorities for scheduling work 9,
Ol activities from the Operating Supervisor.
1I i, -
.i
!l I I' We have added administrative aides on shift as a il i- result of TMI lessons learned. Administrative functions T!
1- that detract from or are subordinate to the Operating Super-
)!
}[ visor's management responsibility for the safe operations of .
the plant will be delegated to these personnel. Even before 1'
- TMI we had anticipated a PBX operator on shift to relieve
!i 2
the control room of telephone answering responsibilities.
Il ii Our current plans call for the fire brigade to be
} headed up by the Chemical Operations Foreman. The other 3
L four members will be made up of Chemical Technicians and 2
3 Chemical Operators from the Chemical Analysis Group.
Oi 5 Q.38 Does EL&P plan to include a Shift Technical Advisor 5
7 (STA) in its shift organiration?
3> .
g A.38 (RIM): Our present plan is to provide the expertise 3'
tl of the STA through increased training of our Operating 2i Supervisors. The STA position was recommended aa a lesson 3
b a,
learned from TMI in NUREG 0578. The purpose was to provide 6li an individual on-shift, with training in nuclear en,gineering 8! or a related science and' training in plant desijn and transient 9I Gl response, to complement the functions of other shift operations L
I! personnel. The- STA would be. available in the control room 3
4 within 10 minutes of being summoned to diagnose off-normal 5 -
6 . events and advise the shift supervisor. I understand that 7 i
- g. l STA's are serving now at currently operating'ccamercial
~
9 !
g L nuclear power plants.
L i
i._
- l
- 1 g.. _ _ _ . . . . _ . . _ _ _ _ . . ,
La 2
3l 4l In NUREG 0731, " Guidelines for Utility Management S'
6, Structure and Technical Resources", the NRC staff took the 7,i 8, position that "the lorg-tern need for a shift technical 9l 0; advisor to provide advice to the control room supervisor may .
1 i 2' be eliminated when upgraded qualifications for the control
] room supervisor ... and improved coitrol rooms ... have been attained." We believe that the long term approach discussed f6 in NUREG 0731 is preferable. The person making the decisions
.09fi about reactor operation should have the necessary experience ill and education to perfcrm properly. .
l2 '
'3 i
. However, if the NRC continues to require STA's as 14 l5 ; separate advisors, EL&P will add qualified STA's in accordance
!6 l
!7 , with the NRC require ent. -
!8 i tg Q.38 What will be the procedures for controlling access 10 '
gt j to the control room?
12 -
g3 ', A.38 (RIM): Plant procedures will limit normal access I ~
- to the Control Room to those individuals responsible for 16 ! -
direct operation of the Plant, technical advisors, and 17l 38 specified NRC perscnnel, and will establish a clear.line of 19 10l authority, responsibility, and. succession in the control 11 i i 62 room. Limited special access to the control room may be- l 13 14 approved by the Watch Supervisor for specified purposes.
45 46 , Q.39 Will there be shift turnover procedures?
$7 i 48 I ,
49 50 5L ,
l A.35 (RIM): Yes. Plant procedures for shift relief and i
I turnover will require signed check-licts and logs to. assure
's
- ! that the operating staff (including Auxiliary operators and i
? -
maintenance personnel) possess adequate knowledge of critical.
.?
- plant parameter status, system status, availability and i'
- alignment.
f! Q.40 Mr. Goldberg, how does EL&P plan to control design ri i changes during plant operation?
7 I
1 A.40 (JHG): All changes affecting basic engineerinej
-! design (equipment,' structu.ec, sizing and arrangement) or I Plant operability will be reviewed and approved by the i
i, technical staff. Procedures will also require the approval i
7' of QA, the PORC and the NSRB. In addition to the~ normal i'
); review for technical adequacy or desirabilit'1, these requests
) ~
r i for design changes will be reviewed with close attention to 7 1
~
! the impact on FSAR commitments, any affected analyses and
&! whether or not an unreviewed safety question is involved.
- ' l Once the request is approved, implementation of the. design 3' change will be directed by the site technical group. through 7
3l L
the normal engineering process-.
1! Q.M Does. EL&P' nave; a Fysten for learning from the l 3!
! 4 operating experience of other utilities?
5 i A.41 (JHG): Yes, that type of information is available T .
l 3 in documents such as NRC I&E Bulletins'and LER's.
At present,
! 9 0l L
-3 7 -
1 i
l l
L' l L . l 1l Ii NRC generated input, including I&E Bulletins, Notices, new 2
I regulations, and Regulatory Guides are screened by our Ii 3 Nuclear Licensing Department for applicability and importance I!
); -
and then sent for action to the appropriate management and .
Li The 2; technical personnel, including those in Operations.
3!
< publication, Nuclear Power Experience Reports, is used as 5l 5
another source of input to the technical support and Operations g staffs. The reports are reviewed by the cognizant discipline
! and factored into the Plant design, construction and/or 1i olanned operation as appropriate along with other inputs.
2, 3' In addition, both Mr. Moles, STP Plant Superin-4 5 tendent and Dr. James Sumpter, of my staff, are members of 6;
7! the EEI Nuclear Operations Subcommittee. This group, is 8.
9i composed of the chief technical support and operations 0'
1l i personnel from many utilities in the U.S. They meet tri-
- 3. annually and exchange information concerning operational 4I .
3l experiences.
6 Through the efforts of Nuclear Safety Analysis 7l 8 center and the Institute of Nuclear Power Operations, the 9
0 many hundreds of LER's are now being screened and distri-1 1 buted to interested parties, through a service known as t 3 4 NOTEPAD. We are a user of that service.
5 6 i Q.42 Mr. Moles, how will Plant operating procedures be 7 '
8 I controlled? .
- 0 l
, it l
l ~
l i
i I
O
- .
i
, l A.42 (RIM): Responsibility for preparation of each ii procedure is assigned to a supervisor in the Plant organization.
r i ii After appropriate reviews, the procedure is submitted for I(
); approval to the Plant Superintendent. For safety-related t
[j procedures, the cycle includes review by the PORC, a group i'
- required by the Technical Specifications to perform such 3
reviews as well as other functions. Procedures governing I!
Ii the activities of the PCRC are included in the Plant Adminis-
}!
3' trative Procedures.
L! Q.43 Describe the PORC. .
2' 3l A.43 (RIM): The PORC is a committee established by the 4I Plant Administrative Procedure Manual and required by the 5;
5 7' Technical Specifications. Its meabers inclade the Plant 3i 9' Superinte:'. dent, the Assistant Plant Superintendent, the 0*l
- i operating General Supervisor, the Technical General Supervisor, 2 the Maintenance General Supervisor, a Reactor Engineer, the -
3li 2!
at Radiation Protection Supervisor, the Plant QA Supervisor and
$ a. Site Engineering Representative.
t 8! The PORC reviews procedures, tests, changes to 9
0 Technical Spec 1fications and safety-related systems, Technical 1
- 2i specification violations, 24-hour notificauion items, Plant
! 3 l
4l operations, and the Security and Emergency plans.
5 6 The PORC advises the Plant Superintendent regarding l 7 g these matters, and he- makes his decisions after considering 9
l 0 l 'l !
l i ..
! -3 9 -
i
i i
i j their advice. We have built safscuards into this mechanism
, !, to minimize the possibility of suppression of dissenting
. opinions regarding safety matters. In the event of a disagree-
> ment between a PORC member and the Plant Superintendent, the .
member may request that the disagreement be documented in i
the meeting minutes. PORC meeting minutes go to the Chairman
- f lI of the NSRB, which is discussed below. If a majority of 7
i PORC members disagree with the Plant Superintendent, the I
NCRB Chairman and the Executive Vice President must be I1
- ! notified in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
I The PORC has been meeting monthly since July 1978.
i!
i The Committee's primary function to date has been the review i! '
T- of safety-related procedures.
3li 3
Q.44 Mr. Goldberg, describe the NSRB.
1.
i, ' -
A.44 (JUG): The NSRB iJ a corporate headquarters 7
committee that is chaired by me as Vice President, Nuclear
{
!l Engineering and Construction. Its members include the Vice 3
+ .
3 I
Prasident, Nuclear Operations; the Manager, QA; the, Manager, ,
3 Nuclear Services; the Director, Nuclear Fuel; the General I'
) l 3 Manager, Fossil Power Plant Engineering'; the nuclear plant i L l: :
1! Superintendents, and the Manager, Nuclear Licensing.
3 4 The NRSB reviews such matters as proposed changes 5
5 .to procedures, equipment, systems, Technical Specifications 7'I 3 and the operating licenses. It reviews reports and meeting 3
0l l Lj i i.
-4 0 -- .
?
n I!
I' minutes of the PORC and significant operating abnormalities, il ij including violations of license requirements or internal Ii it procedures having nuclear safety significance.
It jl In addition, it conducts periodic audits of the ,
t !
{ following areas:
!. 1. The conformance of facility operation to provisions 2
contained within the Technical Specifications and a:
7!
I, applicable license conditions.
?! 2. The performance, training, and qualf.fications of 3*
Ll the entire facility staff.,
I' 3 3. The results of actions taken to correct deficien-i.
3l cies occurring in facility equipment, structures, 5 ', syst ms or method of operation that affect nuclear 7
31 3; safety.
fl
- 4. The performance of activities required by the OQAP 2l 3
to meet the criteria of Appendix B to 10CFR50.
4 5. The facility Emergency Plan and implementing '
s 1 6: procedures.
I S
j 6. The facility Security Plan and implementing pro-9 !
Oj t ,
cedures.
5l 3
Q.45 Will there-also be a dedicated engineering staff 4 at the site, without operational responsibilities, which 5
6 .w ill perforn independent safety reviews?
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A.45 (JHG): Yes, as a result of our review of the NRC i! proposed post-TMI requirements, ELCP is commioted to having 7I 3! an effective Independent Salety Engineering Group (ISEG) and i ;
3l -
we have under study the details of its operation. Our .
L g current plan is that the ISEG will report to ma and will be 3
4 composed of a small staff of on-site, full-time engineering
=,
!! personnel. Its responsibilities will include those specified 3 1 7!
a in NUREG 0737, " Clarification of TMI Action Plan Requirements."
- ' Q.46 Mr. Oprea, during Plant operation will EL&P continue Ot 1! to utilize the QA Program Evaluation Committee described in 2:
3! your previous testimony?
4
- 5) A.46 (GWO): Yes. The QA Program Evaluation Committee 6' .
7 is a corporate level group that evaluates the performance of -
81 9l QA activities on all EL&P projects. Review of the performance 0'
1 of the STP Operations QA program will be an important function
-t 3
f this Committee.
I '
i! Q.47 What is the composition of that Committee?
3 6
A.47 (GWO): I will continue to chair the-Committee.
7, 8' The other members include the Group Vice President,. Fossil 9
0 Plant Engineering and. Construction; the Vice President, 1i l
2i Nuclear Engineering and. Construction; the Vice. President, l 3 4 Nuclear Operations; the-Vice President, Purchasing and
=
6 . Services; the Vice President, Fossil Power Plant Crnstruction; 7
g the Manager, STP; the Ilanager, QA; and the Director, Nuclear Q
0 Fuel.
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il3 t Q.48 What will be the functions of the QA Program
'I ! Evaluation Committee during plant operation?
T' 1 A.48 (GWO): The QA Program Evaluation Committee will
)
)i continue to assess the effectiveness of the EL&P nuclear QA ,
r'
[ program from the management viewpoint. It will review NRC 3;
- reports, trend analysis data, selected audit reports, and f!
management QA audits. It will also review major substantive changes to methods and systems being implemented as part of h
3i 3i the Nuclear QA program.
l! Q.49 Mr. Goldberg and Mr. Moleg, does the FSAR describe 2'
3! how HL&P will conduct the operation of STP?
4l A.49 (JHG, RIM): Yes, Chapter 13 of the FSAR is entitled 5;
6:
It describes the HL&P organization 7l Conduct of Operations.
Si g{ for Plant operations, the personnel training program, certain 0!
3j Plant operating procedures and the review and audit program.
2' Section 12.3 references the separate volume containing the 3
ia Emergency Plan which is now being revised to meet POST-TMI 6 requirements, and Section 13.6 references the Security Plan. -
1 8 Q.50 How were Sections 13.0, 13.1, 13.2, 13 . 4 and 13 . 5 9
0 of the FSAR prepared?
L, 2l A.50 (JEG, RIM): The Plant operations staff was responsible-3 4 for drafting major portions of those sections. The Nuclear 5'
6 ; . Licensing Section then coordinated an internal review of the T i 8 drafts. These sections were reviewed and updated earlier 9 l iO i ,)
1 it .
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this year and we both personally reviewed and approved these i FSAR sections as revised.
l Q.51 Are the contents of FSAR Section 13.0, 13.1, 13.2, l
13.4 and 13.5 true and correct to the best of your knowledge
and belief?
A.51 (JHG, RIM): Yes.
! Q.52 Mr. Frazar, is the Operations QA program described i
in the.FSAR?
i A.52 (RAF): Yes, there is a description of the Operations 1
! QA program in Section 17.2 of the FEAR.
'i
! Q.53 How was Section 17.2 prepared?
! A.53 (RAF): Section 17.2 was originally submitted in
\
! 1978. In 1981'HL&P submitted a substantial revision. I reviewed section 17.2 and its revisions in draft, as did i
I various other staffs of HL&P and their comments were considered I
! in the preparation of the final drafts that were then provided i
to EL&P Licensing for final editing, printing and submittal
, {
f to NRC.
I Q.54 Are the contents of FSAR Section 17.2 true and
)
I correct to the best of your knowledge and belief?
! { A.54-(RAF): Yes.
I i
& Q.55 What guidelines were used in the preparation of 5
g ,
.Section 17.2?
7 3
9 0
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i l A.55 (RAF): We used the NRC's standard format Reg.
i l Guide 1.70, Revision 1 and the Standard Review Plan, Nureg 75/087.
In addition we considered the applicable industry Standards and Regulatory Guides, including Reg. Guide 1.33, " Quality .
t Assurance-Program Raquirements (Operation), Reg. Guide 1.58,
\
" Qualification of Nuclear Plant Inspection, Examination, and
! Testing Personnel", and the applicable ANSI N45 daughter documents.
t
! Q.56 Mr. Frazar, in your opinion does HL&P's Operations QA program comply with Appendix 3 to 10 CFR Part 50, and l applicable Regulatory Guides and industry standards?
I' A.56 (RAF): Yes. In my opinion the Operations QA program complies with Appendix B and the with relevant NRC
- guidance mentioned in Answer 55 above.
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PRESIDENT D.D. JORDAN EXECUTIVE VICE PRESIDENT G.W. OPREA .
VICE PRESIDENT NUCLEAR OPERATIONS SOUTH TEXAS PROJECT ALLENS CREEK PLANT SUPERINTENDENT PLANT SUPERINTENDENT R. I. MOLES i
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