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Ferry Nuclear Power Plant"

Docket IIos. 50-440; 50-441Eesponse to Action Items - |*

ISC "anagement Audit at i

PliPP, 1/25 - 1/29 :r

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Dear "r. Schwencer:

1his letter transmits our responses to action items identifed

isy the lac t'ar:25c ~nt Awilt Team during a site tisit at PHPPr

corrlueled from 1/29/02-1/29/02. ,

it .is our intention to revice Chapter 13 of the FSAR to in-'

e, ri orate any co::xi.tr ;nts I:ade in the attached recponses.

Very Truly Yours,t,

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Lalwyn R. EavidronVice FresidentEystem Engineering and Construction L

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cc: Jay GilbergJohn Stefano*%x GildnerEric redersen P

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Action Item 1:

Training Coordination at PNPP

Response

la). Training Section Description

On February 15, 1982, the Nuclear Project Training Section was formed asa new Section in the Perry Project Services Department in response to theNRC Team's concerns about training,. Mr. Cyril M. Shuster, General Super-vising Engineer, was transferred from System Planning Engineering to headthe new Training Section. Eight persons (6 professional, 2 clerical) areassigned to the Training Unit in Perry Plant Department with responsi-bility for Operations and Maintenance Training. Ongoing trainingactivities include the following: CEI has entered into a lease / purchaseagreement with GE for the Perry Simulator now located in Tulsa, Oklahoma;General Electric is being used to provide instructors for OperatorTraining on the Simulator; Ohio State University is under contract todevelop a General Employee Training Program; and an arrangement is ineffect with Ohio State University and Lakeland Community College whereininstructors from these institutions present college level courses in mathand science on-site. The objective of the newly established Section isto provide total site training coordination, so as to insure the Projectis staf fed with trained, qualified individuals capable of supporting,maintaining, and operating the Perry Plant.

The Section organization chart has been established, as shown on attachedFigure 1, with staf f size shown as of March 8, 1982. As of March 8,Section manning was at five persons, with plans to enlarge to sevenpersons by the end of March.

The initial Nuclear Project Training Section organization design consistsof a Program Developmental Activity, a General Nuclear Training Activity,and a Training Services and Support Activity. Initially, this Section isresponsible for consolidating all on going training in the Construction /Support Departments and maintaining close coordination with the PerryPlant Department Training Unit in the communications of information,development of programs, development of procedures, and recordkeepingactivities.

The ultimate assimilation of the Perry Plant Training Unit into theNuclear Project Training Section is as shown on Figure 2. The time framefor bringing the two elements together is currently projected as being

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Action Item l_i(Page 2)

at fuel load, so as not to cause any disturbances for the currentoperator training efforts. The estimated manning of the overall trainingorganization will be approximately 20-22 persons plus consultants asneeded. Approximately 75% of the staf f will be professional persons,

th). HWR training for PPD staff

Observation training will be scheduled for IIcalth Physics personnel. Thellealth Physicist, whose prior experience has been chiefly in PWR plants,will spend at least four weeks at an operating BWR. This will beaccomplished prior to scheduled fuel load at the Perry Plant.

Selected health physics technicians, at least five, will participate inradiation protection activities at commercial BWR plants for at leastfour weeks each.

Observation training for the Operations and Maintenance Section GeneralSupervisors will be supplemented with at least four weeks at an operatingBWR plant prior to the scheduled fuel load at the Perry Plant.

Ic). Operator Qualifications Pipeline

The operator qualification pipeline currently includes 35 persons withten additional nuclear power plant experienced people to be hired duringthe first half of 1982 for training prior to fuel load. This number doesnot include upper management, training and technical staff engineers who

also completing licensed operator training (12 of 17 to be trainedare

presently certified at the SRO level).

Expectations are that there will be 40 operator 11censeo candidatestrained prior to fuel load to ultimately fill 12 SRO positions (six ShiftSupervisors and six Unit Supervisors), and 12 RO positions (SupervisingOperators). This allows for 16 additional license candidates to providefor last-minute attrition and examination failures. While the goal is tostaff for six shift rotation, fewer licenses could suffice for a limitedperiod of time to allow re-examination in case of unexpected failures.

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Action Item 2:

Availability of Operating Nuclear Power PlantExperience in Plant Management in Operations Areas

1 Resoonse

! A person with operating nuclear power plant experience will be obtained ineither an advisory capacity or integrated into the plant organization as

| Superintendent, Plant Operations for at least one year in advance of fuel; load. This person will serve as a member of the Plant Operation Review'

Committee, and if not a permanent member of the Plant Staff, will remain inplace at least for 12 me..ths following fuel load.

In addition, each operating shift will have assigned to it a person withcommercial BWR start-up experience during the period from fuel load until 100%power is attained or for one year, whichever comes first.

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Action Item 3:

Letter of Commitment on the ReorganizationPlan for PNPP

Response

During a January 25, 1982, oral presentation to the NRC Management Audit Team,Managers of the PNPP Site Organization described current and future plans for-

the Site Organization. Described below are steps taken since the Januaryi audit as well as future plans to complete a full site reorganization to

separate functions related to start-up and operation of Perry 1 from functionsrelated to construction of Unit 2 six months prior to fuel load.

Two major changes have already occurred which respond to NRC and CEI concerns:

1. On February 15, 1932, the Nuclear Project Training Section was formed asa new section within the Perry Project Services Department. The objec-tive of the newly established Section is to provide total site trainingcoordination to insure that the PNPP Project is staffed with trained,qualified individuals capable of supporting, maintaining and operatingthe Perry Plant.

2. As of March 12, 1982, the Nuclear Engineering Department's position ofGeneral Supervising Engineer (GSE), Nuclear Design and Analysis has beensplit to form two GSE positions: GSE, Nuclear Construction Engineeringsection; and GSE, Nuclear Design and Analysis section. The attachedorganization chart shows the changes which have occurred.

The organizational changes described above are the first of several majorchanges which will occur between now and a date six months prior to fuel load.The numerous organizational charts attached show the current site organizationcompared to the site organization expected to be in place six months prior tofuel load of Perry 1. When these changes are initiated, an amended FSARChapter 13 will be transmitted to the NRC.

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CHANGES TO THE NUCLEAR ENGINEERING DEPARTMENT SINCE THE JANUARY REVIEW:DEPARTMENT ORGANIZATION AS OF MARCH 22, 1982

Nuclea r EngineerDepa rtment Manager

M. R. EdelmanI

i 6 iNuclea r Test Section Nuclear Construction Nuclea r Licensing and

GSE Engineering Section fuels Management SectionB. L. Barkley GSE CSE

J. M. La s tov ka L. O. Beck

Nuclear Construction Nuclea r Design and Administ rativn andSection CSE Analysis Section Special ProjectsJ. A. Kline GSE Section GSL

J. H. Bellack L. E. Hartline

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PNPP SITE ORGANIZATION: SIX MONTHS PRIOR TO FUEL LOAD OF PERRY 1

Nuclea r Group VP

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Nuclea r Engineering Nuclea r Construct ion Nucleah Quality Pe r ry P l a'n t Dept. Pe rryDept. Manager Dept. Manager Assurance Dept. Manager P roj ec t

Manager j Se rv i ce sManager

Nuclea r Ana lysis and Records and Adh.in- Cdnstruction ! Ope ra t i'ona l AuditDesign GSE i st ra t ion GSE Quality GSE Quality GSE Element 1

Nuclear Licensing T ra ining and Admini s-and fuels Manage- t ra t ion CSE

ments GSE

SuperintendentPlant Operat ions

| Constru6 tion Ou t a'g e Nuc l ea r Co'nst ruct i on Nucle 6r Test 3 Nuclea r Services Radi'aMonEngineering Engineering GSE GSE GSE Protection

GSE GSE CSE

TechnicaI'Section OpeFation Ma i n t'o r.a nceGSE Section Section GSE

GSE

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PNPP SITE ORGANIZATION: SIX MONTHS PRIOR TO FUEL LOAD Of PERRY 1 (Cont'd)

Nuclea r Group VP Admini st ra t ive Se rvicesi Group VPs

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P rocu remerit Systems and' Procedures f ac i l i t i es' a nd T ra i di ngGSE GSE Services GSE GSE

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_A_c_ tion Item 4:!

BWR-Operating Experience on Nuclear Safety'

- Review Board

Response

The Nuclear Safety Review Board will have as members at least two seniorindividuals with commercial BWR operating and/or management experience.

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Action Item 5:

Adequancy of Plant Staffing Levels

I1

Response !

The proposed plant staffing has been reviewed as a result of additionalcommitments made to provide on shift an Instrument and Control Technician, a .

Shift Technical Advisor, a goal of six operating shifts and the consolidationof training in a separate organizational element. Thus, the total staffingexpected at fuel load for Unit 1, devoted exclusively to Unit 1 operation,is as follows:

Total Site Staffing For Unit 1 Operation

Perry Plant Department - 297Nuclear Engineering Department (on site) - 87 |Project Services Department (Training) - 20 |Operational Quality Assurance (QA/QC) - 25

iTotal Staff (Unit 1 Operation) - 429

{Dased on these changes, the following is a tabulation of proposed staffing bysection.

Perry Plant Department Units 1&2 Unit 1 '

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Management 3 3 *'

Maintenance 155 85Operations 101 63 -

Technical 82 53Radiation Protection 56 43Services 52 42Security 8 8

J Total 457 297.

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The training function, which at fuel load will report to the Manager, ProjectServices Department, will incorporate the licensed operator training as wellas all the Perry Project personnel training. This function will require about,

20-22 personnel. The Nuclear Engineering Department, including the'

Independent Safety Review Group, will be reorganized to support, on site, theI operation of Unit 1. A separate department, Nuclear Construction Department,

;will assume responsibility for completing Unit 2 including pre-operationaltesting. The Nuclear Engineering Department is proposed to be staffed with

,about 87 employees. Operational Quality Assurance is also a separate[reporting function with both QA and QC responsibility handled by a staff of 25

employees deveted exlcusively to the Unit 1 operation. ,

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Action Item 5:

](Page 2) ;

The above staffing does not include security personnel outside of the super-visory personnel.

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The staffing described here provides for meeting all commitments for on-shiftpersonnel without excessive reliance upon overtime in routino operation.Extensive provision for training time is included, and adequate numbers of

! entry-level personnel will ensure fully trained skills will be available asrequired as construction progresses and Unit 1 is completed.

In addition to Unit I staffing for operation, there is located on site addi-tional Engineering, Quality Assurance, Construction and Project Services staffinvolved with the continuing construction of Unit 2 as outlined previouslyunder Action Item 3.

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Action Item 6:

Engineering Support Staff for PSPP

Response

The Perry Nuclear Power Plant Site Organization will reorganize prior to fuelload for Perry 1 to separate the support functions for Perry 1 start-up andoperation from the support functions for construction of Perry 2. Six monthsprior to fuel load for Perry 1, the site organization will be as follows:

Nuclear Croup VP AdministrativeServices Group

| VP

l Nuclear | Quality1 I

Nuclear Engineering Perry Plant Perry ProjectDept. Manager Assurance Dept. Dept. Manager Services Dept.

Manager Manager

Nuclear ConstructionDept. Manager

The new Nuclear Engineering Department will provide engineering support toPerry I during its start-up and operation: the Department will have aninitial staffing level at Perry 1 fuel load of about 87 employees. TheNuclear Analysis and Design, Nuclear Licensing and Fuels Management, and theRecords and Administration Sections will report to the Manager of the NuclearEngineering Department. Most of these individuals will be Cleveland ElectricIlluminating Company employees. However, CEI will continue to retain GilbertCommonwealth Associates to provide additional engineering support wherenecessary. General Electric, as NSSS supplier, will also be retained on aconsu1 ting basis where required.

The new Nuclear Construction Department will provide engineering support forUnit 2 construction. The Nuclear Construction, Nuclear Test, ConstructionEngineering and Outage Engineering Sections will report to the Manager of theNuclear Construction Department. CEI will continue to retain GilbertCommonwealth Associates as the Architect / Engineer for Perry 2 construction.Staffing levels for this department have not yet been projected.

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Action Item 7:

FSAR Chapter on PNPP Compliance with NUREG 0737

Response

CEI will amend the PNPP/FSAR to include a new chapter describing the status ofPNPP compliance with NUREG 0737.

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Action Item 8:

Shift Staffing

Response

The shift staffing described in the FSAR Section 13.1.2.3 for the Perry PlantControl room, with two units operating, provides for six licensed personnelfor the two units; three SRO's and three RO's. This staffing exceeds theNUREG 0737 interim guidance staffing level for Two Units, One Control Roomconfigurat. ion by one SRO license and is less than the interim guidancestaffing level for Two Units, TWo Control Rooms by one R0 license.

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The original Perry Plant control room design was arranged for optimizing thehuman factors impact for operators moving from one unit to the other while inthe single control room. This was the basis for arranging the two controlboards side by side with identical positioning of all operating deviceslocated on each control board. As a result of fire protection considerations,a partition was installed between the two control boards with a normallyclosed door at the partition and for more effective command and control during ;emergency operation, an SRO has been added to each shift crew.

For starting up or shutting down a generating unit, two R0 licensed operatorsare normally required. With three RO's available each shift, one RO will beregularly assigned to each unit with the third RO available for assignment tothe unit which may be starting up or shutting down. It is not normallyexpected that both units would be in that mode of operation at the same time.If such would be the case, an additional RO will be provided by calling out orholding over an extra person if not available on shift. Thus, it does notrepresent the proper utilization of critically skilled manpower to require i

full time on shift the fourth R0 licensed operator for those rare instanceswhen he or she would be needed. Therefore, exception is taken to the interim

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staffing guidance for Two Units, Two Control Rooms as tabulated in NUREG 0737I.A.I.3-4.

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