Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-1 CHARLES W. ADEY Mr. Adey, staff consultant, has more than 40 years of experience in nuclear and fossil fueled power plant engineering, construction, start-up, operations & maintenance and the decommissioning of nuclear power and research facilities. He has a strong background in plant performance evaluation and consulting for domestic and international clients. Prior to D. L. English Consulting, Inc., Mr. Adey was a principal for TTX Associates, Inc. and held a variety of engineering, consultant and management positions at Stone & Webster Engineering Corporation. Early in his career, he participated in the construction, startup, and refueling of five nuclear power plants. He was a licensed SRO shift supervisor during the start-up of Millstone Unit 1 and Pilgrim. PROFESSIONAL EXPERIENCE 2008 – Present D. L. English Consulting, Inc., Staff Consultant 1994 - 2008 TTX Associates, Inc, Principal 1976 - 1994: Stone & Webster Engineering Corporation, Vice President and Manager 1965 - 1976 General Electric Company, Manager of Nuclear Services – New England CONSULTING EXPERIENCE Decommissioning of Nuclear Research Facilities Recently completed an assignment as the Reactor Projects Group Manager at the US DOE Brookhaven National Laboratory, responsible for the overall planning and execution of the decommissioning of the Brookhaven Graphite Research (BGRR), High Flux Beam Reactor (HFBR) and the Brookhaven Medical Research Reactor (BMRR). Also served as Project Manager for the ongoing Brookhaven Graphite Research Reactor decommissioning. For the BGRR, HFBR, BMRR assignments he: Achieved a performance turnaround CPI from 0.69 to 1.02, EAC from $59M to $53M Developed and presented monthly programmatic and technical assessments and cost & schedule variance analyses. Developed and negotiated contract modifications (Baseline Change Proposals) Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-1 Re-baseline BGRR and HFBR projects Provided technical support to the DOE/EPA/NYS DEC Core Team for BGRR endstate decision Made presentation to various stakeholders including the Brookhaven Executive Roundtable, Community Advisory Council, and the BGRR Working Group Prepared for conduct of and reconciliation of findings from multiple internal and external audits and assessment including DOE EM-1, DOE EM-6, OSHA, NRC, and BSA entities Performed complete stabilization and implement cost effective surveillance and maintenance programs Developed cost estimates and schedules for decommissioning alternatives ranging from risk based end states through Greenfield Developed mission needs statement, project definition, project maturity self assessment and CD/0 through project approval in accordance with DOE Project Acquisition Guidelines Monitored de-fueling and stabilization activities in anticipation of project transfer from DOE Office of Science to Environmental Management Brookhaven National Laboratory High Flux Beam Reactor, U.S. DOE: As Blue Ribbon Panel Member, assisted in the evaluation of reactor vessel removal and disposal options with an emphasis on engineering. Plum Brook Reactor Facility, NASA: As a team member, participated in a Non Advocate Review of planning efforts for the decommissioning of the facility with a focus on project management. Developed findings and recommended closure criteria. Prepared an independent cost estimate and schedule for benchmarking project team efforts. Operating Plant Services Surry Power Station - Units 1 and 2, Virginia Power: As Engineer, prepared EWR for design and installation for a temporary containment spray pump dewatering system. Fort Calhoun Nuclear Power Plant, Omaha Public Power District: As Engineer, prepared detailed mechanical system planning documents for engineering of modifications to instrument air system, service air instrument air cross tie, and post accident containment sampling systems. North Anna Nuclear Power Station - Unit 1, Virginia Power: As Engineer, conducted study to compare the cost, man rem exposure, scope of work, and scheduled duration for the two selected steam generator replacement methods, i.e., pipe cut and channel head cut, and recommended the preferred approach. Sultan Ismail Combined Cycle Power Plant, NEB Malaysia: As Consultant, conducted technical design audit at the 900 MW Combined Cycle Paka Power Station which included review of contract documents, records and station reports, interviews with station personnel, and system walkdowns. Determined system equipment condition; identified critical components, capacity limiting equipment Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-1 and factors, and developed modernization task recommendation to improve reliability/availability for circulation water, hypochlorination, service water, and fire protection systems. Deerpath Group: As Consultant, conducted review of contractor compliance and adequacy of programs provided for startup testing, training, operations, and maintenance support of the Midland Cogeneration Venture 1340 MW world's largest combined cycle cogeneration plant. Performed detailed reviews of demineralized water supply and backup fuel gas supply systems, evaluated material condition of facility, and conducted an in-depth assessment of the owners readiness to assume responsibility for operations, maintenance, and engineering support for the plant. United Nations' Department of Technical Co-Operation for Development: As Consultant, undertook mission to assess the scope of fossil fuel power plant upgrading and modernization at the Egyptian Electricity Authority (EEA) in Egypt. The mission included evaluating EEA rehabilitation accomplishments, modernization efforts underway and planned, and current power plant performance; identifying opportunities for improvements; and making recommendations for EEA implementation and UNDTCD funding. Pilgrim, Millstone 1 and Vermont Yankee: As General Electric Manager, Nuclear Services, responsible for development of nuclear contract maintenance business in the New England region. Assignment included development and implementation of an organization consisting of a peak of more than 50 professional personnel. Project responsibilities included marketing, proposal preparation, contract and subcontract negotiations, and maintaining customer relations. Other responsibilities included administering product department's Service Engineering Program with customers, personnel salary reviews, performance appraisals, and maintaining interfaces with other General Electric components. Decommissioning of Nuclear Power Generating Facilities Nuclear Barge Sturgis, U.S. Department of the Army: Developed decommissioning plans, cost estimates and schedules for the decommissioning of a barge mounted nuclear power plant. San Onofre Unit One, Southern California Edison: Developed and presented management seminar and project team workshop on nuclear plant decommissioning. Provided consultation on development of project controls system for decommissioning. Was Team Leader for the Large Components Disposition Options Analysis study. Confidential Architect Engineer firms, Japan and Korea: Developed report on recent US Decommissioning experience including decontamination and dismantlement technologies and costs. Developed cost estimates for Independent Spent Fuel Storage Installations. Contributed to report entitled, “Estimated Cost of Removal of Large Components from BWR and PWR Nuclear Power Plants.” Greifswald Nuclear Power Plant, Treuhandanstalt, Germany and Confidential Client: Performed evaluations and made recommendations in the areas of technical Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-1 feasibility, regulatory compliance, costs and scheduling. Task included the evaluation of decommissioning activity scope changes and the identification and performance of additional technical studies. Trojan Nuclear Plant, Portland General Electric Company, as consultant reviewed and provided comment in development of the Trojan Nuclear Plant Decommissioning Plan. Developed preliminary material flow pathways, locations for decontamination stations and staging areas for further segmentation and packaging of radwaste for the decommissioning of plant structures, systems and components. Kozloduy Nuclear Power Plant, National Electricity Company (NEK), as consultant participated in the detailed technical, economic, and financial feasibility study for the development of decommissioning and radioactive waste disposition plans to assist the Government of Bulgaria’s to develop a viable national strategy for reactor decommissioning and the disposition of reactor-generated radioactive wastes. Shoreham Nuclear Power Station, New York Power Authority, as Project Engineer, responsible was responsible for staffing, budget and schedule adherence, program management and coordination of all offsite engineering support for Stone & Webster scope of work. Developed new LIPA Nuclear Organization Corporate Policies, Department Charters, Position Descriptions, Program Descriptions, and detailed Implementing Procedures. Participated in developing the Decommissioning Plan and preparing responses to NRC interrogatories. As Reactor Pressure Vessel Engineering Section Head, supervised the engineering group responsible for the development of all Engineering Change Requests, Station Modification Packages, and 10CFR50.59 Safety Evaluations for the decommissioning of an 849 MWe boiling water reactor in accordance with the NRC approved Decommissioning Plan. As Nuclear Analysis Section Head, supervised an engineering group responsible for providing offsite monitoring, radiological analysis, radiation protection, radiological environmental monitoring, ALARA and chemical and low level radioactive waste process and control expertise in support of the decontamination and dismantlement and fuel disposition activities associated with the plant decommissioning. Field Service Engineering Pilgrim Nuclear Power Station, Boston Edison Company: As Operations Shift Supervisor, responsible for writing and conducting pre-operational tests on control rod drive hydraulic, reactor manual control, and steam turbine drive reactor core isolation cooling systems. Reviewed clients' operating procedures. Obtained NRC Senior Reactor Operator License (cold). Supervised plant operations and conduct of tests. Millstone Nuclear Power Station, Unit 1, Northeast Utilities: As Operations Shift Supervisor, responsible for writing procedures and direction of plant preoperational testing for reactor feedwater, full flow condensate demineralizer and makeup water systems; supervising overall plant conditions and the conducting of Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-1 tests during the startup test program. Obtained NRC Senior Reactor Operator License. Oyster Creek Nuclear Power Station, General Public Utilities: As Shift Engineer, supervised refueling floor activities during initial fuel loading; also assisted shift supervisor in the operation and troubleshooting of plant systems. Qualified for NRC Reactor Operator Certification. As Construction Field Engineer, supervised installation of reactor internals, and provided technical direction and supervision in the construction of various nuclear steam supply and balance of plant systems. Nine Mile Point Nuclear Station, Niagara Mohawk Power Corp: As Construction Field Engineer, provided technical direction and supervision on the installation of the control rod drive hydraulic system, reactor recirculation system, and reactor internals. EDUCATION Northeastern University - B.S. in Mechanical Engineering Graduate Courses at Syracuse University in Business Administration General Electric and Stone & Webster Engineering and Management Courses LICENSES AND REGISTRATIONS NRC Reactor Operator Certification Oyster Creek NRC Senior Reactor Operator Pilgrim NRC Senior Reactor Operator Millstone Unit 1 CERTIFICATIONS/ PROFESSIONAL AFFILIATIONS American Society of Mechanical Engineers - Member American Nuclear Society – Member American Nuclear Society Northeastern Section – Chair 98-99, Vice Chair 97-98, Exec. Committee 95-97, 99-00, Secretary 00-01 PUBLICATIONS "Shoreham Decommissioning: A Case Study", ANS Topical Meeting: The Best of D&D, April 1996 "Engineering Requirements for the Planning and Execution of Contaminated Systems Removal In Decommissioning the Shoreham Nuclear Power Station", The Fourth International Topical Meeting on Nuclear Thermal Hydraulics, Operations and Safety, Taipei, Taiwan, April 1994. "Refuel Floor Reconfiguration for Plant Decommissioning" presented at the American Nuclear Society Winter Meeting, November 1993. “Valve Stem Packing Improvement Study, EPRI 2560,” Electric Power Research Institute, August 1982. Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-1 “Operations and Maintenance Cost Analysis for Nuclear Power Plants”, presented at the American Power conference, April 1978. Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-2 Home > Electronic Reading Room > Document Collections > Generic Communications > Regulatory Issue Summaries > 2001 > 01006 - Criteria for Triggering a Review under 10 CFR 50.80 for Non-owner Operator Service Companies Criteria for Triggering a Review under 10 CFR 50.80 for Non-owner Operator Service Companies February 15, 2001 Addresses Intent Background Information Summary of Issue Backfit Discussion Federal Register Notification Paperwork Reduction Act Statement Addresses All holders of operating licenses for nuclear power reactors. Intent The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS) to inform licensees of the criteria for determining when the use of contract service operating companies in connection with the operation or maintenance of nuclear power reactors requires approval by the NRC under the regulations governing transfers of licenses in 10 CFR 50.80. This RIS requires no action or written response on the part of an addressee. Background Information According to 10 CFR 50.80, "Transfer of Licenses," the Commission must give its consent in writing before a license for a production or utilization facility may be transferred, assigned, or in any manner disposed of. As nuclear utilities evolve, the NRC recognizes that licensees may pursue various alternative and potentially complex arrangements with non-owner operators. Whether a licensee must submit an application to the NRC for approval under 10 CFR 50.80 depends on the extent to which operating control is being transferred and the degree of autonomy being granted to the operating company. The NRC recognizes that more detailed guidance on when to obtain the agency's approval of new arrangements would be helpful. This RIS provides information so that the nuclear industry and NRC staff may have a common understanding of the criteria for deciding when the use of a non-owner operating service company requires NRC review and approval under the requirements of 10 CFR 50.80. To date, most cases of non-owner operating companies have involved an existing operations organization that split Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-2 off from the owner and transferred to a newly formed operating company in connection with a reorganization or merger agreement. One example involved the transfer approval and license amendments for Farley Units 1 and 2, Hatch Units 1 and 2, and Vogtle Units 1 and 2 when Southern Nuclear Operating Company became the licensed operator of the facilities replacing Alabama Power Company and Georgia Power Company. All three companies are subsidiaries of the Southern Company. Another example was the transfer approval and license amendment for River Bend Unit 1 when Entergy Operations, Inc., a subsidiary of Entergy Corporation, became the licensed operator at the same time that Entergy Corporation acquired Gulf States Utilities, the former owner. In each case, there was no wholesale change of operations personnel; the existing operations organization was merely transferred to a new operating company. In each case, the licensees recognized that a 10 CFR 50.80 license transfer review and approval was necessary. In a further example, in early 1997, Maine Yankee Atomic Power Company (Maine Yankee) signed a management services agreement with Entergy Nuclear, Inc. (ENI), under which ENI would provide operations management personnel, including the Maine Yankee President and the Vice President, Licensing. The ENI personnel provided would become employees of Maine Yankee while remaining employees of ENI and would serve at the pleasure of and take direction from the Maine Yankee Board of Directors. Maine Yankee stated in a letter to the NRC that it had concluded that neither the management services agreement with ENI nor the specific management changes would require prior NRC approval or a change to the Technical Specifications. The NRC staff concurred with this assessment since Maine Yankee retained ultimate safety-related decisionmaking authority and ENI personnel would become employees of Maine Yankee as well as of ENI. In January 1998, Illinois Power Company (IP) entered into a management services agreement with PECO Energy for nuclear operational support at Clinton Power Station. The service agreement between IP and PECO was similar in certain aspects to the Maine Yankee management services agreement with ENI. The service agreement stated that PECO management personnel serving at Clinton would be treated as employees of IP for operational and functional purposes and would exercise their authority in the IP organization on behalf of, and subject to the direction of, IP senior management. One PECO manager was appointed by the IP Board of Directors as Chief Nuclear Officer, serving as the senior nuclear manager at Clinton and reporting directly to the Chief Executive Officer and President of IP. PECO also provided additional experienced nuclear managers to assist IP in the operation of the station. All licensed operators at Clinton remained employees of IP alone. The staff agreed with IP's conclusion that, notwithstanding the management services agreement between IP and PECO, IP retained the authority and responsibility for the safe operation of the plant and for regulatory compliance. In addition, PECO would not be performing activities that would require a license. Approval under 10 CFR 50.80 was, therefore, not required. In late 1999, several midwestern utilities agreed to combine their operating staffs to form the Nuclear Management Company (NMC). NMC's corporate purpose was to provide services in connection with the operation and eventual decommissioning of licensed nuclear facilities on behalf of and for the benefit of the owner utilities. NMC was established as a Wisconsin limited liability corporation owned equally by Alliant Energy Nuclear, LLC, NSP Nuclear Corporation, WEC Nuclear Corporation, and WPS Nuclear Corporation. Alliant Energy Nuclear, LLC, is a wholly owned subsidiary of Alliant Energy Corporation, the parent holding company of IES Utilities Inc., owner and operator of the Duane Arnold Energy Center. NSP Nuclear Corporation is a wholly owned subsidiary of Northern States Power Company, owner and operator of the Prairie Island and Monticello Nuclear Plants. WEC Nuclear Corporation is a wholly owned subsidiary of Wisconsin Energy Corporation, the parent holding company of Wisconsin Electric Power Company, which owns and operates the Point Beach Nuclear Plant. WPS Nuclear Corporation is a wholly owned subsidiary of WPS Resources, Inc., the parent holding company of Wisconsin Public Service Corporation, majority owner and operator of Kewaunee Nuclear Plant. In November 2000, Consumers Energy Company, owner and operator of the Palisades Plant, joined the other owners mentioned above in requesting a transfer of operating authority under each respective license to NMC. In each case the owners of the NMC member plants retained ownership of their respective facilities and retained the necessary authority under the licenses to possess the plants. Pursuant to 10 CFR 50.80, the NRC reviewed the transfers and issued conforming license amendments to include NMC as a licensee and to designate NMC as the licensee authorized to use and operate each of the facilities in accordance with the terms and conditions of the licenses. Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-2 Summary of Issue NRC review and consent are necessary when a license for a nuclear power plant or any right thereunder is to be transferred or assigned. The NRC staff has developed criteria for judging whether the use of a different or new nuclear power plant operating entity involves a transfer and requires NRC review and consent under 10 CFR 50.80. The criteria are to be used in conjunction with the concept of final decisionmaking authority: if an entity, for example, a service company, provides advice but does not have the authority to make a final decision (i.e., a decision that cannot be modified, overruled, or is not subject to reversal by the current licensee), (1) there has been no transfer of authority. A senior manager reviewing contractor decisions after the fact would not be considered to have final decisionmaking authority, unless the senior manager could reverse or overrule the contractor decisions. The following are a list of areas the staff considers in determining whether the transfer of final decisionmaking authority makes 10 CFR 50.80 review necessary: Decision to continue operation or shut down for repairs Decision to start up the plant Authority to make operability determinations for safety-related equipment Authority to change staffing levels for licensed personnel Authority to make organizational changes for TS required positions Decision to defer repairs on safety-related equipment Authority for quality assurance responsibilities (selecting audits, approving audit reports, accepting audit responses) Budget-setting and spending authority Authority to control the terms of employment for licensed staff Authority over the design control of the facility Decision to continue operations or permanently cease operation Authority to determine whether NRC approval is needed under 10 CFR 50.59 Authority to perform maintenance on safety-related equipment Authority for the emergency preparedness program Authority to approve licensee event reports Authority to decide whether to make a 10 CFR 50.72 report Authority to provide health physics program services Authority to provide chemistry program services Authority to provide fire protection program services Authority for engineering work on safety-related systems Authority for maintaining design basis documentation Authority for compliance engineering or licensing engineering services This list may not be complete. The staff has attempted to identify representative examples of activities that may require a 10 CFR 50.80 review. Authority for site security program services was not included in the list because service companies handling site security typically do not provide services in other areas. If a service company currently providing security program services were being considered for a contract to provide services in some of the above-listed areas, a 10 CFR 50.80 review may be required.(2) It is difficult to identify precisely the point at which an operating service entity must be added to the operating license and thus when a license transfer application must be filed. Clearly, some areas are more important than others, and each operating agreement the NRC reviews is likely to be unique. The more operational areas in which an operating entity has final decisionmaking authority, the more likely it is that NRC must review and approve an application for a license transfer and an amendment to add the operating entity to the license. Backfit Discussion Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-2 This regulatory issue summary requires no action or written response. Consequently, the staff did not perform a backfit analysis. Federal Register Notification A notice of opportunity for public comment was not published in the Federal Register because the information contained in this RIS was previously published as Draft Regulatory Guide DG-1086 in December 1999. The preliminary criteria were previously published in the Federal Register on October 9, 1998 (Vol. 63, No. 196, 54389 54391). Public comments on DG-1086 have been incorporated in this RIS. Paperwork Reduction Act Statement This RIS does not request any information collection. Please contact the lead project manager listed below if there are any questions about this matter. /RA/ David B. Matthews, Director Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Lead Project Manager: Attachment: M. Davis, NRR 301-415-1016 E-mail: mjd1@nrc.gov List of Recently Issued NRC Regulatory Issue Summaries (ADAMS Accession Number ML010390294) 1. That is, final decisionmaking authority is defined as authority to make a decision that cannot be modified, overruled, or is not subject to reversal except by the decisionmaker. 2. The NRC notes that lines of authority and responsibility in the organizational chain of command are specified in the Administrative Controls section of the plant's Technical Specifications (Section 5.0 of the Standard Technical Specifications). The NRC staff expects licensees considering the use of service company management to examine their licensing basis to see what management structure, authorities, and responsibilities have been approved. If the lines of authority or responsibilities specified in the Technical Specifications are being changed, the changes must be reviewed and approved by the NRC as a license amendment under 10 CFR 50.90. The NRC expects that licensees will ensure that service company personnel meet educational and experience requirements specified in the Technical Specifications for the positions they will be taking and will seek approval for any license changes that may be necessary, above and beyond any transfer approval and conforming amendment approval. Privacy Policy | Site Disclaimer Monday, February 19, 2007 Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-2 Charles W. Adey Docket No. 7404 May 20, 2008 Exhibit DPS-CWA-3 Charles W. 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