ML20211H976

Forwards Util 860529 Record of Coordination Describing How Mgt Structure Under Vice President/Nuclear Functions So Undue Burden Not Placed on Individual

ML20211H976
Person / Time
Site:	Clinton
Issue date:	06/09/1986
From:	Siegel B Office of Nuclear Reactor Regulation
To:	Butler W Office of Nuclear Reactor Regulation
References
NUDOCS 8606260137
Download: ML20211H976 (7)

Text

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JUN 0 91986 DISTRIBUTION Docket File Docket No. 50-461 NRC PDR LPDR PD#4 Rdg.

BSiegel MEMORANDUM T0: Walter R. Butler, Director M0'Brien BWR Project Directorate No. 4 Division of BWR Licensing FROM: Byron L. Siegel, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing

SUBJECT:

ORGANIZATION AND STAFF - CLINTON POWER STATION .

1 As you are aware Peter McLaughlin of the NRC staff raised a concern that the number of managers reporting directly to the Vice President in charge of nuclear at Illinois Power Company (IPC) could have an adverse effect on the decision process for safety issues. Following discussions between Frank Spangenberg (IPC), Peter McLaughlin, you and I, IPC agreed to provide a Record of Coordin-ation describing how the management structure under the Vice President functions so undue burden is not placed on that individual. The enclosure contains the Record of Coordination provided by IPC to address this concern.

@ f yron L. Sie el, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing

Enclosure:

As stated cc: P. McLaughlin PD#4/PM BSiegel:lb 06/f/86 me2mu

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• ENCLOSURE Prepared by:

Y Q ff Date P. J. Telthorst, V-920 May 29, 1986 l

, Y- 37802 Copies to: D. P. Hall, V-275 File Code L30-86(os-29)-L f

J. S. Perry, V-275 Retention Code L

1. $U0h Rec cd Type 1A.165 F.A.Spangenberg,V-920h8I .

Class of Record 0 D. W. Wilson, V-920 J. L. Peterson, V-920 T. L. Riley, V-920 Quality of Record NS

.J. D. Weaver, V-920

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RECORD OF COORDINATION X Meeting Telecon Other:

Type:

May 14, 15, 1986 Time:

Date:

Participants:

P. McLaughlin (NRC/MTB), F. A. Spangenberg, P. J. Telthorst

Subject:

Organization and Staffing - FSAR Ch 13 Amend 37 Summary ISSUE P. M'cLaughlin raised a concern that the number of managers reporting directly to the Vice President (VP) could have an adverse af f ect on the decision making process for safety issues. Mr. McLaughlin referenced the following section of the Standard Review Plan on page 13.1.1-6.

" Variations in staffing may also be expected between applicants who lack prior experience with nuclear plant operation and those who have such experience. It is important that the reviewer assure himself that  ;

applicants in the former category do not underestimate the magnitude of the

. task. The reviewer should be alert to the possibility that excessive workloads may be placed upon too small a number of individuals."

SU.W.ARY In addition to the Manager Nuclear Program Coordination who acts for the VP in the following managers and his capacity as deputy to the Vice President, directors report to the Vice President:

a. Manager - Scheduling and Outage Management

b. Manager - Clinton Power Station ' '

c. Director - Nuclear Training Manager - Quality Assurance d.

e. Manager - Licensing & Safety '

f. Manager - Nuclear Station Engineering

h. Manager - Startup

i. Director - Nuclear Program Assessment Group ,

All Managers are located at the plant site with the V.P. ,

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4 The Plant Manager, Manager - Nuclear Station Engineering and Manager - Startup work closely with the Manager - Nuclear Program Coordination in coordinating plant startup activities. The Manager - Quality Assurance and Manager -

Licensing & Safety provide an independent perspective on issues affecting safety.

The~present organization as described in the FSAR and as discussed in this meno can be managed effectively by the Vice President.

Note: The Startup department will be disestablished on or about the date of fuel load. ,

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' DISCUSSION

1. NRC Coc=ent. The IP. corporate : structure to provide technical support to the i Clinton Power Station, as described in Amendment 37, had the following departments and groups reporting to the Vice President position.

a) Director - Nuclear Program Assessment Group

. b) [ Deleted. See note below]

c) Manager - Scheduling and Outage Management d) Manager - Clinton Power Station e) Director - Nuclear Training f) Manager - Quality Assurance i g) Manager - Licensing and Safety

' .h) Manager - Nuclear Station Engineering

1) Manager - Nuclear Planning and Support '

j) Manager - Startup

[ Note: NRC com=ent indicated that the Director of Nuclear Review and Audit Group (NRAG) reports to the Vice President. Further discussion of NRAG is in the response below.]

This appears to be an inordinate number of managers under the control of one individual. A typical span of control is four or five major departments. Please provide an explanation how this organization will effectively provide adequate technical support to CPS without risk to public safety. Of particular concern is the process to be employed to manage decision making during full power operation, and to coordinate and prioritize contending department safety, issue priorities.

CPS Response. The Manager Nuclear Program Coordination assists the Vice President and has the authority of the Vice President in carrying out those responsibilities that have been specifically delegated to him. The Manager Nuclear Program Coordination (NPC) works closely with the Vice . President and

confers with him on a daily basis. For example, the Manager Nuclear Program

) Coordination was initially responsible for organizing the Project Control Center i

(PCC) to coordinate daily planning of startup testing, system turnover and j construction (i.e., commodities such as hangers and conduit installation). The Manager - Nuclear Program Coordination held daily meetings with key managers,

! i.e., Plant Manager, Startup, Quality Assurance, Licensing & Safety, Nuclear Stations Engineering and Construction Project Manager to expedite solving problems holding up plant testing and system schedules. The Manager - Scheduling l and Outage Management is now responsible for managing the PCC allowing the Manager - Nuclear Program Coordination to work on other issues while maintaining an overview role of the PCC and startup activities. This organization provides

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high level management attention and detailed planning to resolve conflicts before they have a significant impact on system testing. The Vice President is free to  !

concentrate on the major issues, while having a direct representative in plant startup activities. While all managers and directors in figure 13.1-1A report directly to the Vice President, they may report to the Manager - Nuclear Program Coordination for activities delegated to the Manager - NPC by the Vice President.

The involvement of each department in the decision making process on issues affecting the safe operation of Clinton varies with each department. The key managers involved in solving the day to day problems during the startup phase of Clinton are the Plant Manager, Manager - Nuclear Station Engineering, Manager -

Startup, Manager - Quality Assurance, and the Manager - Licensing & Safety.

After Illinois Power has completed the startup phase testing, the Startup

_ Department will be disestablished leaving four key managers during plant ,

operation. During outages, the Manager - Scheduling and Outage Management will be a key manager involved in the day to day decisions of plant activities.

a a. Director - Nuclear Program Assessment Group is responsible for coordinating the Institute of Nuclear Power Operations (INPO) programs and assessing Clinton programs. Issues raised from review of these programs are typically progra==atic and not of a time sensitive nature requiring an immediate resolution.

b. . Director - Nuclear Review and Audit Group. The Nuclear Review and Audit j, Group (NRAG) is an advisory committee that provides independent review and

. audit of designated activities specified.in the technical specifications.

NRAG is not shown on the CPS erganization chart, and is not involved in the *

' day to day operation of the plant.

It is required to meet quarterly during the first year of operation and semiannually thereafter. NRAG is not expected to compete for the Vice President's attention or distract him from the daily issues'that arise during plant operations,

c. Manager - Scheduling and Outage Management is responsible for the following activities:

i Coordinate and prepare schedules for all nuclear departments in support of the Integrated Milestone Plan.

Manage and direct the actions of the maintenance. support contractor in support of.the Plant Manager.  :

Coordinate outage planning and preparation.

Support the Plant Manager during scheduled and forced outages to ensure early and efficient completion of all work.

The Manager - Scheduling and Outage Management (SOM) is responsible for the Project Control Center and has established a special task force to perform the detailed scheduling of Startup Phase Testing, surveillances, deferred maintenance activities, and deferred Checkout & Initial Operation (C&IO), Preoperational Testing, and Acceptance Testing.

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_4-During the trans'ition from construction to operation the Manager-Scheduling and Outage Management is responsible ^ for the PCC. During plant operation this department will be involved primarily in planning and preparing for outages and supporting the plant maintenance staff. The Manager- SOM will play a major role in the day to day activities during an outage.

The f ormation of this department reflects IP's strong emphasis on plant maircenance and efficient outage planning and performance. The major activities of ;his department occur when the plant is shutdown.

d. Manager - Clinton Power Station is responsible for overall facility operation including safety, the direction of the operations, maintenance, refueling, chemistry, radiation protection, radwaste and technical se rvices. The delegation of training and outage management to other independent departments allows the Plant Manager to concentrate his efforts on the day to day operation of the plant.

e. Director - Nuclear Training position was established as a separate depart-ment head to place greater emphasis on training. The activities of the training department incorporate feedback from plant operating experience such as lessons learned into the requalification program, buttis independent of the day to day activities of plant operation.

.f. Manager - Quality Assurance is responsible for the IP quality assurance 1 ' program and is responsible for conducting audits of vendors and contractors.

The size of the department and level of activity will decrease as the plant fundergoes the transition from construction to operation. This is a key

- department in monitoring plant activities for issues affecting safety,

g. Manager - Licensing and Safety is responsible for providing representation and interface with regulatory agencies. This department was originally in the Nuclear Station Engineering Department. As a separate department,

! Licensing & Safety is able to' raise safety issues independent of the engineering or the operations departments which may be responsible for the

. corrective action. This is exemplified by the Independent Safety Engineering Group (ISEG) in licensing whose sole purpose is to inspect the

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plant and nuclear staff programs for safety concerns. These concerns are better represented by a Manager who is independent of the departments under review. Although Licensing & Safety (L&S) is not involved in the day to day op'eration of the plant, a separate L&S department enhances safety and facilities communication with the NRC. This is a key management position that adds another perspective to address safety issues. A separate licensing department is an improvement over the past organization when licensing was in Nuclear Station Engineering Department,

h. Manager - Nuclear Station Engineering is a key manager who is involved in resolving problems that arise in the operations of CPS.

i. Manager - Nuclear Planning and Support is responsible for human resources, support services, material management, maintenance services, budgeting, site accounting and program planning. He would not be directly involved in resolving problems that affect the safe operation of the plant.

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J. Manager - Startup directs the day to day startup testing activities. The startup activities are coordinated and closely monitored by the Project Control Center under the supervision of the Manager - Scheduling and Outage

! Management. The Startup department will be eliminated after the plant is operational. ,

2. NRC Comments. No information was provided to describe the duties and functions of the Scheduling and Outage Management department. Please provide this information with an explanation of how the plant level maintenance planning office wil1~ interface with this organization. Are employees How of the Scheduling is IP controlling and Outage Management department IP or contract employees?

qualifications of these employees?

CPS Response. A descr*iption of the Scheduling and Outage Management department is in item 1.c. This department will be supported by Stone and Webster Engineering Company (SWEC) technical and craft personnel as the maintenance contractor. All plant maintenance work will be controlled by the Plant Manager who must approve all schedules involving the plant. The maintenance contractor will complete maintenance that is beyond the scope or resources of the plant maintenance staff. This will allow p1' ant, staff to concentrate on the routine The day to day maintenance activities and problems that occur during operation.

upper management position of this department, i.e. managers, and directors are IP employees. The maintenance service contractor (MSC) technical support secff and craf t personnel will be SWEC employees. Training of the MSC will be performed by 4

SWEC to Illinois Power training program requirements. Training records will be '

maintained by the IP Nuclear Training Department.

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