[Federal Register Volume 64, Number 106 (Thursday, June 3, 1999)]
[Notices]
[Pages 29922-29931]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 99-14050]
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
Proposed Revision to Standard Review Plan (NUREG-0800), Chapter
13, ``Conduct of Operations, Sections 13.1.1, ``Management and
Technical Support Organization,'' and 13.1.2-1.3, ``Operating
Organization''
AGENCY: Nuclear Regulatory Commission.
ACTION: Notice of opportunity for public comment.
-----------------------------------------------------------------------
SUMMARY: The Nuclear Regulatory Commission (NRC) has prepared a
revision to NUREG-0800, ``Standard Review Plan for the Review of Safety
Analysis Reports for Nuclear Power Plants--LWR Edition,'' Chapter 13,
``Conduct of Operations,'' sections 13.1.1, ``Management and Technical
Support Organization,'' and 13.1.2-1.3, ``Operating Organization.'' The
Standard Review Plan (SRP) contains guidance used by the staff to
review safety analysis reports for light water reactor commercial
nuclear power plants. The proposed revision incorporates changes that
have been made since the sections were last revised in April, 1996, and
publically noticed in the Federal Register, Vol. 61, No. 162, Tuesday,
August 20, 1996. There were no public comments received to these
sections. The proposed revision addresses 10 CFR 50.80 requirements for
``Transfer of Licenses.'' Specifically, the staff has revised Chapter
13, ``Conduct of Operations,'' sections 13.1.1, ``Management and
Technical Support Organization,'' and 13.1.2-1.3, ``Operating
Organization'' of the SRP as they relate to 10 CFR 50.80 requirements
for the applicant's technical qualifications. The April, 1996 revision
of these SRP sections did not include guidance for the staff to review
the technical qualifications of applicants for license transfer.
The purpose of this notice is to solicit specific public comment on
whether the revised text accurately and fully reflects the established
NRC staff positions and existing regulations. The SRP is made available
to the public as part of the NRC's policy to inform the nuclear
industry and the general public of regulatory procedures and policies.
The SRP is not a substitute for regulatory guides or NRC regulations.
Compliance with the SRP is not required. The published SRP will be
revised periodically, as appropriate, to accommodate comments and
reflect new information and experience. The NRC encourages comment from
all interested parties; however, public
[[Page 29923]]
review is not intended to reopen a dialogue on the merits of the
requirements themselves but, rather, should be focused on the
previously stated purpose.
DATES: The comment period expires July 6, 1999. Comments received after
this date will be considered if it is practical to do so, but the
Commission is able to assure consideration only for comments received
on or before this date.
ADDRESSES: Mail comments to: Chief, Rules Review and Directives Branch,
Division of Freedom of Information and Publications Services, Mail Stop
T-6D59, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
Comments may be hand delivered to 11545 Rockville Pike, Maryland,
between 7:45 a.m. and 4:15 p.m., on Federal workdays.
FOR FURTHER INFORMATION CONTACT: James P. Bongarra, Jr., U.S. NRC,
Office of Nuclear Reactor Regulation, Mail Stop O9D24, Washington, DC,
20555; telephone (301) 415-1046; e-mail:jxb@nrc.gov.
SUPPLEMENTARY INFORMATION: The proposed revised text to NUREG-0800,
``Standard Review Plan for the Review of Safety Analysis Reports for
Nuclear Power Plants--LWR Edition,'' is the work of the NRC staff. It
has received review by the Director, Division of Inspection Program
Management, Office of Nuclear Reactor Regulation, and the NRC's Office
of General Counsel. A final revision will be published upon resolution
of public comments and review by the Director, Office of Nuclear
Reactor Regulation, the NRC's Committee to Review Generic Requirements
(CRGR), and the Advisory Committee on Reactor Safeguards (ACRS).
The proposed revision to NUREG-0800, ``Standard Review Plan for the
Review of Safety Analysis Reports for Nuclear Power Plants--LWR
Edition,'' Chapter 13, ``Conduct of Operations,'' sections 13.1.1,
``Management and Technical Support Organization,'' and 13.1.2-1.3,
``Operating Organization,'' follows:
NUREG-0800--Standard Review Plan, Chapter 13, Conduct of Operations
13.1.1 Management and Technical Support Organization
Review Responsibilities
Primary--Human Performance Branch
Secondary--None
I. Areas of Review
The branch with primary responsibility for reviewing human
performance will review the corporate level management and technical
organization of the applicant for a construction permit (CP), operating
license (OL), combined license (COL), or license transfer. The review
will also include the applicant's major contractors including the
nuclear steam supply system (NSSS) vendor, and architect/engineer (A/E)
for the project. The technical resources to support the nuclear power
plant design, construction, testing, and operation are reviewed. The
review for a CP or COL will include an examination of the
responsibilities, technical staff, interface arrangements, and
management controls used to ensure that the design and construction of
the facility will be performed in an acceptable manner. The review for
an OL or COL will examine the applicant's corporate organization and
technical staff that will provide support for safe plant operation. The
review for license transfer will examine the acceptability of any
changes to the technical organization or personnel qualifications
proposed as a result of a license transfer under 10 CFR 50.80.
The objective of this review is to ensure that the corporate
management is involved with, informed of, and dedicated to the safe
design, construction, test and operation of the nuclear plant. In
addition, the review is to ensure that sufficient technical resources
have been, are being and will continue to be provided to adequately
accomplish these objectives.
A. Reviews of Initial Construction Permit (CP) and Early Stage Combined
License (COL) or Reviews of Transfer of Construction Permits (CP) and
Early Stage Combined License (COL)
The applicant's past experience in the design and construction of
nuclear power plants, and past experience in activities of similar
scope and complexity should be described. The applicant's management,
engineering, and technical support organization should also be
described. The description should include organizational charts for the
current headquarters and engineering structure, as well as planned
modifications and additions to those organizations to reflect the added
functional responsibilities associated with the nuclear plant.
1. Design and Construction Responsibilities
A description of the implementation or delegation of design and
construction responsibilities should be included for the following:
a. Principal site-related engineering work such as meteorology,
geology, seismology, hydrology, demography, and environmental effects.
b. Design of plant and ancillary systems, including fire protection
systems.
c. Review and approval of plant design features, including human
factors engineering (HFE) considerations.
d. Site layout with respect to environmental effects and security
provisions.
e. Development of safety analysis reports (SARs).
f. Material and components specification review and approval.
g. Procurement of materials and equipment.
h. Management of construction activities.
2. Preoperational Responsibilities
A description of the proposed plans for the management organization
related to the initial test program should include the following:
a. Development of plans for the preoperational and startup testing
of the facility.
b. Development and implementation of staff recruiting and training
programs.
c. Development of plant maintenance programs.
The descriptions of the design and construction and preoperational
responsibilities should include the following:
a. How these responsibilities are assigned by the headquarters
staff and implemented within the organizational units;
b. Identification of the responsible working or performance level
organizational unit;
c. An estimate of the number of persons expected to be assigned to
each of the various units with responsibility for the project;
d. The general educational backgrounds and experience requirements
for qualification in identified positions or classes of positions;
e. The role of the applicant's management in interfacing with the
NSSS and A/E organizations;
f. Specific educational and experience background for assigned
management and supervisory positions; and
g. The required review of contractor work by the applicant's staff.
h. For identified positions or classes of positions that have
functional responsibilities other than the CP or COL application, the
expected proportion of time assigned to the other activities should be
described.
i. The early plans for providing technical support for the
operation of the facility should be described.
[[Page 29924]]
The CP- or COL-stage review of the NSSS and A/E organizations
includes an evaluation of the ability of the technical staff of each
organization to support or perform the activities specified in the
application, as applicable. The information submitted should include a
description of the specific activity (including scope) to be engaged
in, organizational description and charts reflecting organizational
lines of authority and responsibility for the project, the number of
persons assigned to the project, and qualification requirements for
principal management positions related to the project. For those NSSS
and A/E organizations with extensive experience, a detailed description
of this experience may be provided in lieu of the details of their
organization as evidence of technical capability. However, a specific
description should be provided of how this experience will be applied
to the particular project.
B. Operating License (OL and COL) Reviews
The SAR should provide the following information:
1. Organizational charts of the applicant showing the corporate
level management and technical support;
2. The relationship of the nuclear oriented portions of the
structure to the rest of the corporate organization;
3. A description of the specific provisions which have been made
for technical support for operations; and
4. The organizational unit and any augmenting organizations, or
other personnel who will manage or execute any phase of the test
program, including the responsibilities and authorities of principal
participants.
Technical services and backup support for the operating
organization should become available in advance of the conduct of the
preoperational and startup testing program and continue throughout the
life of the plant.
The SAR should (1) Describe approximate numbers, educational
background, and experience requirements for each identified position or
class of positions providing technical support for plant operations,
and (2) include specific educational and experience background for
individuals holding the management and supervisory positions providing
support in the areas identified below.
The special capabilities that should be included in the support for
the operation of the plant are:
1. Nuclear, mechanical, structural, electrical, thermal-hydraulic,
metallurgical and materials, and instrumentation and controls
engineering.
2. Plant chemistry.
3. Health physics.
4. Fueling and refueling operations support.
5. Maintenance support.
6. Operations support.
7. Quality assurance.
8. Training.
9. Safety review.
10. Fire protection.
11. Emergency organization.
12. Outside contractual assistance.
C. Reviews of Transfer of Operating License (OL) and Late Stage
Combined License (COL)
An applicant for transfer of an operating license should provide a
description of the organization to support plant operations. The
description should include:
1. Organizational charts showing the corporate level management and
technical support organization and emphasizing the changes to be made
as a result of the transfer;
2. The relationship of the nuclear oriented portions of the
organization to the rest of the corporate organization; and
3. A description of the specific provisions which have been made
for technical support for operations.
D. Review Interfaces
The branch with primary responsibility for human performance
reviews performs the following reviews under the SRP sections
indicated:
SRP Sections 13.1.1 through 13.1.3--for organizational structure,
personnel qualifications and experience
SRP Section 13.2.1--for training for licensed operators
SRP Section 13.4--for organizational provisions for independent reviews
and verifications
SRP Section 13.5.2--for procedure adequacy
SRP Section 18.0--for use of human factors engineering principles
The branch with primary responsibility for human performance will
coordinate evaluations and reviews by other branches that interface
with the overall review of the management and technical support
organization as follows:
1. With the branch responsible for Emergency Preparedness and
Radiation Protection, as part of its primary review responsibility for
SRP section 13.3, for the acceptability of the emergency organization
and as part of its primary review responsibilities for SRP section
12.5, for the acceptability of the radiation protection organization.
2. With the branch responsible for Safeguards as part of its
primary review responsibility for SRP section 13.6 for the
acceptability of the applicant's plans and provisions for security,
including the security organization.
3. With the branch responsible for Quality Assurance, as part of
its primary review responsibility for SRP chapter 17, for the
acceptability of the quality assurance organization and, as part of its
primary review responsibilities for SRP section 13.4, for the
acceptability of the organization of the independent safety engineering
group (ISEG).
4. With the branch responsible for Plant Systems, as part of its
primary review responsibility for SRP section 9.5.1, for the
acceptability of the organization responsible for fire protection.
For those areas of review identified above as being part of the
review under other SRP sections, the acceptance criteria necessary for
the review and their methods of application are contained in the
referenced SRP sections.
II. Acceptance Criteria
A. General Guidance
The applicant's description of its resources to deal with safety-
related problems connected with the proposed addition of nuclear
generating capacity should provide contributory evidence as to the
technical qualifications of the applicant, as required by 10 CFR
50.40(b) and 10 CFR 50.80, as applicable.
In the review and evaluation of the subject matter of this section
of the SAR, the following points should be taken into consideration.
1. The corporate level management and technical support structure,
as demonstrated by organizational charts and descriptions of functions
and responsibilities, should be free of ambiguous assignments of
primary responsibility.
2. A corporate officer should be clearly responsible for nuclear
activities, without having ancillary responsibilities that might
detract attention to nuclear safety matters.
3. Design and construction responsibilities should be reasonably
well defined in both numbers and experience of persons required to
implement their responsibilities.
4. Similarly, management and organizational responsibilities should
be clearly defined with regard to human factors engineering (HFE)
considerations in the management of human-system interface issues. This
subject is addressed in more detail in NUREG-
[[Page 29925]]
0711 and in SRP Chapter 18 (DRAFT, April 1996).
B. Specific Criteria
Specific criteria which contribute to meeting 10 CFR 50.40(b) with
respect to the CP, OL, or COL reviews and 10 CFR 50.80 with respect to
license transfer reviews are described below.
For Review of Initial Construction Permit (CP) and Early Stage Combined
License (COL) or for Review of Transfer of Construction Permit (CP) and
early Stage Combined License (COL)
1. The applicant has identified and functionally described the
specific organizational groups responsible for implementing
responsibilities for the project.
2. The applicant has described the method of implementing its
responsibilities for dealing with the safety-related aspects of the
design and construction of the project and the transition to operation
of the facility, including control of major contractors.
3. Clear, unambiguous management control and communications exist
between the organizational units involved in the design and
construction of the project.
4. Substantive breadth and level of experience and availability of
manpower exist to implement the responsibility for the project.
5. The applicant has clearly described the role and function of the
A/E and NSSS vendor during both design and construction and has
demonstrated appropriate control over the project-related activities of
the A/E and NSSS vendor.
6. The applicant has designated the responsible organizations that
will participate in the test program and early plans indicate
reasonable assurance that such designated organizations can
collectively provide the necessary level of staffing with suitable
skills and experience to develop and conduct the test program.
7. The applicant plans to utilize the plant operating and technical
staff in the development and conduct of the test program and in the
review of test results.
8. For COL applicants subject to 10 CFR 50.34(f), the applicant has
identified plans for the organization and staffing to oversee design
and construction of the nuclear facility in accordance with the
guidelines of Item II.J.3.1 of NUREG-0718 as related to the
requirements of 10 CFR 50.34(f)(3)(vii). As reflected in SRP Section
18.0, (DRAFT, April 1996) the review criteria for the human factors
engineering (HFE) design team is provided in NUREG-0711, Chapter 2,
``Element 1--HFE Program Management.''
Although the requirements of 10 CFR 50.34(f) apply only to the
specific applicants listed in that section, OL applicants should
include information related to the organizational and management
structure responsible for the design and construction of the proposed
plant to ensure that the staff has complete and accurate information
for its review.
For Review of Operating License (OL) and Later Stage Combined License
(COL)
The review and evaluation of management and technical
organizational structure for OL and COL applicants is based on the
guidelines of TMI Action Plan Item I.B.1.2 originally described in
NUREG-0694. Specific criteria are as follows:
1. The applicant has identified and described the organizational
groups responsible for implementing the initial test program, and
technical support for the operation of the facility.
2. The applicant has described the method of implementing its
responsibilities for dealing with the initial test program, technical
support, and operation of the facility.
3. The organizational structure provides for the integrated
management of activities that support the operation and maintenance of
the facility.
4. Clear management control and effective lines of authority and
communications exist between the organizational units involved in the
management, operation, and technical support for the operation of the
facility.
5. Substantive breadth and level of experience and availability of
manpower exist to implement the initial test program and technical
support for the operation of the facility. The need to supplement the
corporate structure with additional experienced personnel for the
initial years of operation will be determined on case-by-case basis.
6. Qualifications of members of the technical support organization
should meet or exceed those endorsed by Regulatory Guide 1.8.
7. The technical staff will be utilized in the initial test program
to the maximum extent practicable. Participants in the test program
should receive plant-specific training/indoctrination in the
administrative controls for the test program prior to the start of
testing. The level of staffing should be adequate based on the
reviewer's judgment.
For Review of Transfer of Operating License (OL) and Later Stage
Combined License (COL)
The criteria for the review and evaluation of management and
technical organizational structure for license transfer applicants are
as follows:
1. The applicant has identified and described the organizational
groups responsible for the technical support for the operation of the
facility.
2. The applicant has described the method for implementing the
technical support and operation of the facility.
3. The organizational structure provides for the integrated
management of activities that support the operation and maintenance of
the facility.
4. Clear management control and effective lines of authority and
communications exist between the organizational units involved in the
management, operation, and technical support for the operation of the
facility.
5. Substantive breadth and level of experience and availability of
manpower exist to implement the technical support for the operation of
the facility.
6. Qualifications of members of the technical support organization
should meet or exceed those endorsed by Regulatory Guide 1.8.
C. Technical Rationale
The technical rationale for application of the above acceptance
criteria to the review of the management and technical support
organization is discussed in the following paragraphs.
1. Compliance with the relevant requirements of 10 CFR 50.40(b)
requires that the applicant be technically qualified to engage in
activities associated with the design, construction, and operation of a
nuclear power plant in accordance with the regulations in 10 CFR 50.
Similarly, 10 CFR 80 requires that the applicant for the transfer of a
license be technically qualified to be the holder of the license.
The management and technical support organization established by
the applicant to oversee the design and construction of a nuclear power
plant provides valuable insight into the corporate management's
understanding of its safety role in the design, construction,
operation, and maintenance of the facility. This information
contributes to the determination that an applicant is technically
qualified by ensuring that appropriate considerations were used in the
establishment of general qualification requirements and staffing levels
for all key positions on which the safety of the facility will depend.
[[Page 29926]]
Meeting the requirements of 10 CFR 50.40(b) and 10 CFR 80, as
applicable, provides assurance that the applicant is technically
qualified to engage in the proposed activities and has established the
necessary management and technical support organization to safely
operate the proposed facility.
III. Review Procedures
Preparation for reviewing the application should include
familiarization with the documents listed as references in this SRP
section.
Each element of the application information is to be reviewed
against this SRP section. The reviewer's judgment during the review is
to be based on an inspection of the material presented, whether items
of special safety significance are involved, and the magnitude and
uniqueness of the project. Any exceptions or alternatives are to be
carefully reviewed to ensure that they are clearly defined and that an
adequate basis exists for acceptance.
The applicant should identify the applicable version of references,
Regulatory Guides, and Codes and Standards used. The reviewer should
identify the applicable version of references, Regulatory Guides, and
Codes and Standards used in the review.
In the review and evaluation of the information related to this
section of the management and technical support organization, the
following points should be taken into consideration:
A. In the early construction stage, the applicant's plans for
headquarters staffing to provide technical support when operating may
not yet be firm. It is acceptable, therefore, if these plans are not
fully specific in terms of numbers of people, provided the commitment
made is sufficiently firm to ensure the responsibility can be met.
B. The reviewer must recognize that there are many acceptable ways
to define and delegate job responsibilities. Variations in staffing may
also be expected between applicants with and without prior experience
in nuclear plant design, construction, or operation. The reviewer must
be convinced that an applicant has not underestimated 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. Interface arrangements and controls between the applicant
and major contractors (NSSS vendors, architect/engineers, constructors)
should be examined to ensure that the applicant will be in charge of
and responsible for design and construction activities.
If the application involves the addition of more than one unit, the
reviewer should ensure that headquarters staffing plans take this fact
into account. This is particularly important if additional units are
scheduled to come on line at intervals of about one year or less, since
the shakedown period for the operation of a new plant can be expected
to produce quite heavy workloads. In some of these cases the applicant
may plan to bolster the plant staff organization during such periods so
that it is necessary to evaluate headquarters staffing plans in
conjunction with those for the plant staff organization.
C. The reviewer should assess the degree of participation during
the design and construction phases by the headquarters group that
typically has plant operating (generating) responsibility. Interfaces
between such a group and those with project engineering
responsibilities should be examined.
D. At the time of this review, if the applicant has had experience
in the operation of a previously licensed nuclear power plant, the
reviewer may seek independent information about headquarters staffing
and qualifications through the appropriate NRC Regional Office.
The review procedure for this section consists, therefore, of the
following:
1. An examination of the information submitted to determine that
all areas identified in subsection I, ``Areas of Review,'' above have
been addressed.
2. A comparison of the information with the acceptance criteria of
subsection II, Review Criteria,'' above.
3. Review of information provided by the NRC Regional Office
position statement on the applicant's organizational and administrative
commitments made in the SAR, if applicable.
4. Verification of the implementation of the management structure
and technical resources based on visits to corporate headquarters and
the site, if applicable.
The reviewer then determines, based on the foregoing, the overall
acceptability of the applicant's management and technical support
organization and staffing plans.
For OL and late stage COL license transfer under 10 CFR Part 50,
the existing organization was found acceptable for operations as part
of the initial licensing review. Therefore, the review in support of a
license transfer should be focused on the organizational changes
proposed as a result of that transfer. The reviewer should ensure that
the proposed changes will result in an organization that will continue
to meet the relevant review criteria.
For Standard Design Certification under 10 CFR Part 52, the
procedures above should be followed, as modified by the procedures in
SRP Section 14.3, (DRAFT, April 1996) to verify that the design set
forth in the standard safety analysis report, including inspections,
tests, analysis, and acceptance criteria (ITAAC), site interface
requirements and combined license action items, meet the acceptance
criteria given in subsection II. SRP Section 14.3 (DRAFT, April 1996)
contains procedures for the review of certified design material (CDM)
for the standard design, including the site parameters, interface
criteria, and ITAAC.
IV. Evaluation Findings
The reviewer verifies that the information presented supports
conclusions of the following type to be used in the staff's safety
evaluation report:
The staff concludes that the management and technical support
organization is acceptable and meets the requirements of 10 CFR 50.40.
This conclusion is based on the following:
A. For a Safety Evaluation Report of an Initial CP or COL or for a
Transfer of CP or COL
The applicant has described clear responsibilities and associated
resources for the design and construction of the facility and has
described its plans for management of the project and for utilization
of the NSSS vendor and A/E. These plans have been reviewed and give
adequate assurance that an acceptable organization has been established
and that sufficient resources are available to satisfy the applicant's
commitments for the design and construction of the facility. These
findings contribute to the judgment that the applicant complies with
the requirements of 10 CFR 50.40(b) and 10 CFR 50.80, as applicable;
i.e., that the applicant is technically qualified to engage in design
and construction activities.
B. For a Safety Evaluation Report of an Initial OL or Late Stage COL
The applicant has described its organization for the management of,
and its means for providing technical support for the plant staff
during operation of the facility. These measures have been reviewed and
it is concluded that the applicant has an acceptable organization and
adequate resources to provide offsite technical support for the
operation of the facility under both normal and off-normal conditions.
[[Page 29927]]
C. For a Safety Evaluation Report of a Transfer of an OL or Late Stage
COL License
The applicant has described its organization for the management of,
and its means for providing technical support to the plant staff for
operation of the facility after the license transfer. These measures
have been reviewed and it is concluded that the applicant has an
acceptable organization and adequate resources to provide offsite
technical support for the operation of the facility under both normal
and off-normal conditions.
D. For Design Certification
For design certification reviews, the findings will also summarize,
to the extent that the review is not discussed in other safety
evaluation report sections, the staff's evaluation of inspections,
tests, analyses, and acceptance criteria (ITAAC), including design
acceptance criteria (DAC), site interface requirements, and combined
license action items that are relevant to this SRP section.
In addition to the finding based on the type of application, the
safety evaluation report should also address the following:
These findings contribute to the judgment that the applicant
complies with the requirements of 10 CFR 50.40(b) and 10 CFR 50.80, as
applicable (that the applicant is technically qualified to operate a
nuclear power plant); that the applicant will have the necessary
managerial and technical resources to provide assistance to the plant
staff in the event of an emergency; and that the applicant has
identified the organizational positions responsible for fire protection
matters and the authorities that have been delegated to these positions
to implement fire protection requirements.
V. Implementation
The following is intended to provide guidance to applicants and
licensees regarding the NRC staff's plans for using this SRP section.
This SRP section will be used by the staff when performing safety
evaluations of license applications submitted by applicants pursuant to
10 CFR 50 or 10 CFR 52 and for transfer of a license pursuant to 10 CFR
50.80. Except in those cases in which the applicant proposes an
acceptable alternative method for complying with specified portions of
the Commission's regulations, the method described herein will be used
by the staff in its evaluation of conformance with Commission
regulations.
The provisions of this SRP section apply to reviews of applications
docketed six months or more after the date of issuance of this SRP
section.
Implementation schedules for conformance to parts of the method
discussed herein are contained in the referenced regulatory guides and
NUREGs.
VI. References
1. 10 CFR Part 50, ``Domestic Licensing of Production and
Utilization Facilities.''
2. Regulatory Guide 1.8, ``Qualification and Training of Personnel
for Nuclear Power Plants.''
3. Regulatory Guide 1.68, ``Initial Test Programs for Water-Cooled
Nuclear Power Plants.''
4. NUREG-0694, ``TMI-Related Requirements for New Operating
Licenses.''
5. NUREG-0711, Human Factors Engineering Program Review Model.
6. NUREG-0718, ``Licensing Requirements for Pending Applications for
Construction Permits and Manufacturing License.''
7. NUREG-0737, ``Clarification of TMI Action Plan Requirements.
NUREG-0800--Standard Review Plan, Chapter 13, Conduct of Operations
13.1.2-13.1.3 Operating Organization
Review Responsibilities
Primary--Human Performance Branch
Secondary--None
I. Areas of Review
The applicant's operating organization, as described in its safety
analysis report (SAR), is reviewed. This section of the SAR should
describe the structure, functions, and responsibilities of the onsite
organization established to operate and maintain the plant.
A. Reviews of Initial Construction Permit (CP) and Early Stage Combined
License (COL) or Reviews or Transfer of CP and Early Stage COL
During the early stages of construction or plant design it is
recognized that many details of the plant organization and staffing
have not been finalized. The organizational information provided at
this time should include the following elements:
1. The applicant's commitment to meet the guidelines of Regulatory
Guide 1.33 for the Operating Organization.
2. The applicant's commitment to meet the guidelines of Regulatory
Guide 1.33 for Onsite Review and Rules of Practice.
3. The applicant's commitment to meet Branch Technical Position
SPLB 9.5-1.
4. The applicant's commitment to meet the guidelines of Regulatory
Guide 1.8 for the Operating Organization.
5. The applicant's commitment to be consistent with the options in
the Commission Policy Statement on Engineering Expertise on Shift.
6. The applicant's commitment to meet TMI Action Plan items I.A.1.1
and I.A.1.3 of NUREG-0737 for Shift Technical Advisor and Shift
Manning.
7. A schedule, relative to fuel loading for each unit, for filling
all positions.
B. Review of Operating License (OL) and Later Stage Combined License
(COL)
During the later stages of construction, plant design, and
licensing, the applicant should provide evidence that the initial
personnel selections conform to the commitments made in the early
stages of licensing.
The organizational information provided by the applicant should
include the following elements:
1. An organization chart should have the following elements:
a. The title of each position,
b. The minimum number of persons to be assigned to common or
duplicated positions,
c. The number of operating shift crews, and
d. The positions for which reactor operator and senior reactor
operator licenses are required.
For multi-unit stations, the organization chart (or additional
charts) should clearly reflect changes and additions as new units are
added to the station.
2. The personnel resumes for those selected for management and
supervisory positions down through the shift supervisor.
3. The functions, responsibilities, and authorities of plant
positions corresponding to the following should be described:
a. Overall plant management.
b. Operations supervision.
c. Operating shift crew supervision.
d. Shift technical advisors.
e. Licensed operators.
f. Non-licensed operators.
g. Technical supervision.
h. Radiation protection supervision.
i. Instrumentation and controls maintenance supervision.
j. Equipment maintenance supervision k. Fire protection
supervision.
l. Quality assurance supervisor (when part of the plant staff).
For each position, where applicable, required interfaces with
offsite personnel or positions identified in SAR Section 13.1.1 should
be described. Such interfaces include defined lines of reporting
responsibilities, e.g., from the plant manager to the immediate
[[Page 29928]]
superior, as well as functional or communication channels.
4. The line of succession of authority and responsibility for
overall station operation in the event of unexpected contingencies of a
temporary nature, and the delegation of authority that may be granted
to operating supervisors and to shift supervisors, including the
authority to issue standing or special orders.
5. The extent and nature of the participation of the plant
operating and technical staff in the initial test program.
6. If the station contains or is planned to contain power
generating facilities other than those relating to the application in
question and including fossil-fueled units, this section should also
describe interfaces with the organizations operating such other
facilities. The description should include any proposed sharing of
persons between the units, a description of their duties, and the
proportion of their time they will routinely be assigned to non-nuclear
units
7. The position titles, applicable operator licensing requirements
for each, and the total number of people planned to man each shift
should be described for all combinations of units proposed to be at the
station in either operating or cold shutdown modes. Shift crew staffing
plans unique to refueling operations should be described. The proposed
means of assigning shift responsibility for implementing the radiation
protection and fire protection programs on a round-the-clock basis
should also be described.
8. The education, training, and experience requirements
(qualification requirements) established by the applicant for filling
each management, operating, technical, and maintenance position
category in the operating organization above should be described. This
includes those persons who will conduct preoperational and startup
tests. Consequently, the information to be reviewed should demonstrate
an understanding of and commitment to the acceptance criteria below.
C. Review of a Transfer of Operating License (OL) or Late Stage
Combined Operating License (COL)
The initial operating organization was found acceptable as part of
the initial licensing review. Subsequent safety-related changes to the
operating organization should have been evaluated with an appropriate
methodology and, therefore, the existing organization remains
acceptable. The review to support a license transfer should focus on
evaluating any changes to the operating organization that are being
proposed as a result of the transfer.
D. Review Interfaces
The primary Human Performance review branch performs the following
reviews under the SRP sections indicated:
SRP Sections 13.1.1 through 13.1.3,--for organizational structure,
personnel qualifications and experience
SRP Section 13.2.1--for training for licensed operators
SRP Section 13.4--for organizational provisions for independent reviews
and verifications
SRP Section 13.5.2--for procedure adequacy
SRP Section 18.0--for use of human factors engineering principles
The primary Human Performance review branch will coordinate
evaluations and reviews by other branches that interface with the
overall review of the operating organization as follows:
1. With the branch responsible for Emergency Preparedness and
Radiation Protection, as part of its primary review responsibility for
SRP Section 13.3, for the acceptability of the emergency organization
and as part of its primary review responsibilities for SRP Section
12.5, for the acceptability of the radiation protection organization.
2. With the branch responsible for Safeguards as part of its
primary review responsibility for SRP Section 13.6 for the
acceptability of the applicant's plans and provisions for security,
including the security organization.
3. With the branch responsible for Quality Assurance, as part of
its primary review responsibility for SRP Chapter 17, for the
acceptability of the quality assurance organization.
For those areas of review identified above as being part of the
review under other SRP sections, the acceptance criteria necessary for
the review and their methods of application are contained in the
referenced SRP sections.
II. Acceptance Criteria
A. General Criteria
This section of the SAR should demonstrate the applicant's
commitment to and implementation of plans to staff the onsite operating
organization and to define and delegate responsibilities to provide
assurance that the plant can be operated safely.
In the review and evaluation of the subject matter in this section
of the SAR, the following points should be taken into consideration:
1. Plant staff organizational structures are not rigidly fixed.
However, experience has shown that certain components are common to and
necessary for all plants. Among these are operational, onsite technical
support, and maintenance groups, under the direction and supervision of
a plant manager.
2. The operating organization should be free of ambiguous
assignments of primary responsibility. Operating responsibilities
should be reasonably well defined in both numbers and experience of
persons required to implement their responsibilities.
3. The total on-shift manpower available should include a
sufficient number of full operating shift crews so that excessive
overtime is not routinely scheduled.
The staff acceptance criteria are designed to produce reasonable
assurance of applicant compliance with the relevant requirements of the
following regulations:
1. 10 CFR 50.40(b) as it relates to demonstrating in conjunction
with other reviews that the applicant is technically qualified to
engage in nuclear activities licensed under these regulations.
2. 10 CFR 50.54(j), (k), (l), and (m) as they relate to operator
requirements during the operation of the facility, the responsibility
for directing activities of licensed operators, and the senior operator
availability during reactor operations and other specific reactor
conditions or modes of operation.
3. 10 CFR 50.80 as it relates to demonstrating in conjunction with
other reviews that the applicant for the transfer of a license is
technically qualified to be the holder of a license.
B. Specific Criteria
Specific criteria necessary to meet the relevant requirements of 10
CFR 50.40(b), 10 CFR 50.80, and 10 CFR 50.54(j), (k), (l), and (m) as
follows:
1. The requirements of ANSI N18.7/ANS-3.2, Section 3.4, ``Operating
Organization,'' as endorsed by Regulatory Guide 1.33, should be met. In
addition, the following characteristics should be satisfied:
a. The reporting responsibility and authority of the functional
areas of radiation protection, quality assurance, and training should
ensure independence from operating pressures. In utilities with large
commitments to nuclear power plants, overall management and technical
direction in these areas may be concentrated at the home office.
b. There should be clear lines of authority to the Plant Manager.
[[Page 29929]]
c. Responsibility for all activities important to the safe
operation of the facility should be clearly defined.
d. Distinct functional areas should be separately supervised and/or
managed.
e. Sufficient managerial depth should be available to provide
qualified backup in the event of the absence of the incumbent.
2. Responsibilities and authorities of operating organization
personnel should conform to the requirements of ANSI N18.7/ANS-3.2,
Section 5.2, ``Rules of Practice''; Section 4.4, ``Onsite Review,'' as
endorsed by Regulatory Guide 1.33; Branch Technical Position SPLB 9.5-
1; and Regulatory Guide 1.8 for the ``Operating Organization.'' In
addition, the organization should reflect the staff position in TMI
Action Plan Item I.C.3 of NUREG-0694, by having the responsibilities of
the shift supervisor clearly establish the command duties of that
position and emphasize the primary management responsibility for the
safe operation of the plant.
3. Assignments of onsite shift operating crews shall be made in
accordance with 10 CFR 50.54(j), (k), (l), and (m). In addition, the
staffing should reflect the staff positions of TMI Action Plan items
I.A.1.1 and I.A.1.3 of NUREG-0737 as follows:
a. A shift supervisor with a senior reactor operator's license, who
is also a member of the station supervisory staff, shall be onsite at
all times when at least one unit is loaded with fuel.
b. In addition to the licensed personnel specified in 10 CFR
50.54(m), as a minimum, an auxiliary operator (non-licensed) shall be
assigned to each reactor and an additional auxiliary operator shall be
assigned for each control room from which a reactor is operating. These
operators shall be properly qualified to support the unit to which
assigned.
Note: The shift composition described above is shown in tabular
form in Table 1.
c. To meet TMI Action Plan item I.A.1.1 of NUREG-0737, engineering
expertise shall be onsite at all times a licensed nuclear unit is being
operated in Modes 1-4 for a PWR or in Modes 1-3 for a BWR. This
engineering expertise should be consistent with the options presented
in the Commission Policy Statement on Engineering Expertise on Shift.
d. A health physics technician shall be onsite at all times when
there is fuel in a reactor.
e. A rad/chem technician shall be onsite at all times when a
licensed nuclear unit is being operated in Modes 1-4 for a PWR or in
Modes 1-3 for a BWR.
f. Assignment, stationing, and relief of operators and senior
operators within the control room shall be as described in Regulatory
Guide 1.114.
4. Total complement of licensed personnel and unlicensed personnel
for on-site shift operating crews should be sufficient to avoid the
routine heavy use of overtime.
Note: SRP Section 13.5.1 contains guidance on work hour
limitations.
To meet this policy, staffing plans should provide for no less than the
number required for five shift rotations.
5. The plant operating and technical staff should be used to the
maximum extent possible in the facility initial test program.
6. Assignments of persons to implement the fire brigade
requirements of the fire protection program should meet the guideline
of SRP Section 9.5.1, including the following:
a. The responsibilities of the fire brigade members under normal
conditions should not conflict with their responsibilities during a
fire emergency.
b. The minimum number of fire brigade members available onsite for
each shift operation crew should be consistent with the activities
required to combat the most significant fire. The minimum size of the
fire brigade shift should be five persons unless a specific site
evaluation has been completed and some other number justified.
7. Regulatory Guide 1.8, ``Qualification and Training of Personnel
for Nuclear Power Plants,'' sets forth the staff position on plant
personnel qualifications and training.
In addition, although the qualification levels of the standards are
endorsed as acceptable minimums for each position, it is expected that
the collective qualifications of the plant staff will be greater than
the sum of the minimum individual requirements described in the
standard, particularly in the area of nuclear power plant experience
and in supervisory and management positions involved in the operational
aspects of the facility. In those cases where the collective
qualifications do not exceed the sum of the minimums for individual
positions, additional technical support for the plant staff may be
required. These will be determined on a case-by-case basis.
Table 1
----------------------------------------------------------------------------------------------------------------
Shift Staffing **
------------------------------------------------------------------------------
One unit, one control Two units, one control Two units, two control
room room rooms
----------------------------------------------------------------------------------------------------------------
One Unit Operating *............. 1 SS (SRO) 1 SS (SRO) 1 SS (SRO)
1 SRO 1 SRO 1 SRO
2 RO 3 RO 3 RO
2 AO 3 AO 3 AO
Two Units Operating *............ NA 1 SS (SRO) 1SS (SRO)
1 SRO 2 SRO
3 RO 4 RO
3 AO 4 AO
All Units Shutdown............... 1 SS (SRO) 1 SS (SRO) 1 SS (SRO)
1 RO 2 RO 2 RO
1 AO 3 AO 3 AO
SS (SRO).........................
2 RO.............................
3 AO.............................
----------------------------------------------------------------------------------------------------------------
SS--Shift Supervisor.
SRO--Licensed Senior Reactor Operator.
RO--Licensed Reactor Operator.
AO--Auxiliary Operator.
[[Page 29930]]
Notes:
1. In order to operate or supervise the operation of more than one unit, an operator (SRO or RO) must hold an
appropriate, current license for each such unit.
2. In addition to the staffing requirements indicated in the table, a licensed senior operator will be required
to directly supervise any core alteration activity.
* Modes 1 through 4 for PWRs. Modes 1 through 3 for BWRs.
** Shift staffing of unlicensed personnel for special cases such as 3 units, operating from 1 or 2 control
rooms, etc. will be determined on a case-by-case basis, based on the principles defined in item II.B.3. of
this SRP section. Shift staffing of licensed personnel for special cases including temporary deviations and
staffing for 3 units must meet the requirements of 10 CFR 50.54(m), however.
C. Technical Rationale
The technical rationale for application of these acceptance
criteria to reviewing the operating organization is discussed in the
following paragraphs:
1. Compliance with the relevant requirements of 10 CFR 50.40(b)
requires that the applicant be technically qualified to engage in the
proposed activities in accordance with the regulations in Chapter 50.
Similarly, 10 CFR 50.80 requires that an applicant for the transfer of
a license be technically qualified to be the holder of a license.
A review of the operating organization established by the applicant
to oversee operation of a nuclear power plant provides valuable insight
into corporate management's understanding of its safety role in the
operation and maintenance of the facility. This information contributes
to the determination that an applicant is technically qualified to
engage in the proposed nuclear activities by ensuring that appropriate
considerations were used in the establishment of general qualification
requirements and staffing levels for all key positions on which the
safety of the facility will depend.
Meeting the requirements of 10 CFR 50.40(b) and 10 CFR 50.80, as
applicable, provides assurance that the applicant is technically
qualified to engage in the proposed activities and has established the
necessary management and technical support organization to safely
operate the proposed facility.
2. Compliance with 10 CFR 50.54(j), (k), (l), and (m) requires the
applicant to demonstrate that its operating organization satisfies
minimum requirements for operator supervision and the availability of
licensed senior operators and licensed operators during reactor
operations and other specific reactor conditions or mode of operation.
These are key positions for ensuring the safe operation of the
plant. A staffing review of the operating organization provides
valuable insight regarding the determination that an applicant is
technically qualified to operate the facility.
III. Review Procedures
Preparation for reviewing the SAR or license transfer applilcation
should include familiarization with the documents listed as references
to this SRP section.
Each element of the SAR or transfer application information is to
be reviewed against this SRP section. The reviewer's judgement during
the review is to be based on an inspection of the material presented,
whether items of special safety significance are involved, and the
uniqueness of the facility. Any exceptions or alternatives are to be
carefully reviewed to ensure that they are clearly defined and that
adequate basis exists for acceptance.
The applicant should identify the applicable version of references,
Regulatory Guides, and Codes and standards used. The reviewer should
identify the applicable version of references, regulatory guides, and
Codes and standards used in the review.
In the review and evaluation of the information related to the
operating organization, the following points should be taken into
consideration:
A. During the early stages of construction or plant design, the
applicant will generally not have made selections for plant staff
positions. The review procedure, therefore, is to examine this section
of the SAR for a commitment on the part of the applicant to conform to
the stated acceptance criteria.
B. The reviewer must recognize that there are many acceptable ways
to define and delegate job responsibilities. Variations in staffing may
also be expected between applicants with and without prior experience
in nuclear plant operation. It is important that the reviewer verify
that applicants lacking in experience do not underestimate the
magnitude of the task and that all applicants adequately consider the
potential effects of human error. Guidance on human error
considerations may be found in NUREG-0711, Chapter 7, ``Element 6--
Human Reliability Analysis.'' The reviewer should be alert to the
possibility that excessive workloads may be placed upon too small a
number of individuals.
The reviewer should also consider that the structure of onsite
technical support and maintenance groups may depend somewhat on
headquarters staffing and the division of effort between onsite and
offsite personnel.
C. During the later stages of construction, plant design, and
licensing, the review consists first of the same examination as made
for the early stages of construction or plant design, and secondly, of
an analysis of each resume. The reviewer should make an explicit
comparison of the educational and experience records obtained from each
resume with the corresponding endorsed consensus standards requirements
and regulatory positions set forth for the applicable position in
Regulatory Guide 1.8 or other approved qualifications. ``Applicable
experience'' should be judged in the light of the position
responsibility. Credit for experience, which may not be entirely
applicable, should be weighed to a degree commensurate with its
applicability.
Where a clear comparison cannot be made between the proposed plant
staff positions and those defined in the standards endorsed in
Regulatory Guide 1.8, the applicant should list each position on its
plant staff and designate the corresponding position of these
standards, or describe in detail the proposed qualification
requirements for each position on its plant staff.
In addition, if the applicant, as of the time the review takes
place, has had experience in the operation of previously licensed
nuclear power plants, the reviewer may seek independent information
relative to plant staffing and qualifications through the appropriate
Regional Office, e.g., by discussion with inspection personnel or
review of inspection reports.
D. For onshift persons, the total manpower available should be
reviewed to ensure that a sufficient number of full operating shift
crews are planned so that excessive overtime is not routinely scheduled
for these crews. Additional staffing guidance may be found in NUREG-
0711, Chapter 6, ``Element 5--Staffing.'' For multi-unit sites, overall
site responsibilities should be checked for clarity during those
periods of time when senior level supervision is not onsite.
The review procedure for this SRP section consists, therefore, of
the following:
1. An examination of the information submitted to determine that
all subject
[[Page 29931]]
matter identified in subsection I, ``Areas of Review,'' above has been
addressed.
2. A comparison of the information with the acceptance criteria of
subsection II, ``Acceptance Criteria,'' above.
3. Review of information provided by the NRC Regional Office
position statement on the applicant's organizational and administrative
commitments made in the SAR, as appropriate.
4. Verification of the implementation of the management structure
and technical resources based on visits to corporate headquarters and
the site, as appropriate.
The reviewer then determines, based upon the foregoing, the overall
acceptability of the applicant's operating organizations and plant
staffing plans.
For transfer of an operating license or late stage COL under 10 CFR
Part 50.80, the operating organization was found acceptable as part of
the initial licensing of the plant. Subsequent changes to the operating
organization should have been made in accordance with an appropriate
evaluation methodology. Therefore, the existing organization should
still be acceptable. The review for license transfer should be focused
on the changes that are proposed to the operating organization as a
result of the transfer.
For standard design certification reviews under 10 CFR Part 52, the
procedures above should be followed, as modified by the procedures in
SRP Section 14.3, to verify that the design set forth in the standard
safety analysis report, including inspections, tests, analysis, and
acceptance criteria (ITAAC), site interface requirements and combined
license action items, meet the acceptance criteria given in subsection
II, ``Acceptance Criteria.'' SRP Section 14.3 contains procedures for
the review of certified design material (CDM) for the standard design,
including the site parameters, interface criteria, and ITAAC.
IV. Evaluation Findings
The reviewer verifies that the information presented and its review
support conclusions of the following type to be used in the staff's
safety evaluation report:
For a Safety Evaluation Report on an Initial CP or early stage COL or
for Transfer of a CP or early stage COL
The staff concludes that the applicant's operating organization is
acceptable and meets the relevant requirements of 10 CFR 50.40(b), 10
CFR 50.80, as applicable, and 10 CFR 50.54(j) through (m). This
conclusion is based on the following:
The applicant has described the assignment of plant operating
responsibilities; the reporting chain up through the chief executive
office of the applicant; the proposed size of the regular plant staff;
the functions and responsibilities of each major plant staff group; and
the proposed shift crew complement for single unit or multiple unit
operation; the qualification requirements for members of its plant
staff; and (personnel resumes for management and principal supervisory
and technical positions as submitted during the later stages of
construction, plant design, and licensing). This information has been
reviewed, and it is the conclusion of the staff that the proposed
operating organization is acceptable.
The applicant's operating organization is characterized as follows:
1. The applicant is technically qualified as specified in 10 CFR
50.40(b) and 10 CFR 50.80, as applicable;
2. An adequate number of licensed operators will be available at
all required times to satisfy the minimum staffing requirements of 10
CFR 50.54(j) through (m);
3. Onshift personnel are able to provide initial facility response
in the event of an emergency;
4. Organizational requirements for the plant manager and radiation
protection manager have been satisfied;
5. Qualification requirements and qualifications of plant personnel
conform with the guidance of Regulatory Guide 1.8; and
6. Organizational requirements conform with the guidance of
Regulatory Guide 1.33.
In addition, the applicant has complied with TMI Action Plan items
I.A.1.1 and I.A.1.3.
For a Safety Evaluation Report on a transfer of an OL or Late Stage
COL, the findings will summarize the staff's evaluation of the
applicant's proposed changes to the operating organization.
For design certification reviews, the findings will also summarize,
to the extent that the review is not discussed in other safety
evaluation report sections, the staff's evaluation of inspections,
tests, analyses, and acceptance criteria (ITAAC), including design
acceptance criteria (DAC), site interface requirements, and combined
license action items that are relevant to this SRP section.
V. Implementation
The following is intended to provide guidance to applicants and
licensees regarding the NRC staff's plans for using this SRP section.
This SRP section will be used by the staff when performing safety
evaluations of license applications or license transfer applications
submitted by applicants pursuant to 10 CFR parts 50 or 52. Except in
those cases in which the applicant proposes an acceptable alternative
method for complying with specified portions of the Commission's
regulations, the method described herein will be used by the staff in
its evaluation of conformance with Commission regulations.
The provisions of this SRP section apply to reviews of applications
docketed six months or more after the date of issuance of this SRP
section.
Implementation schedules for conformance to parts of the method
discussed herein are contained in the referenced guides and NUREGs.
VI. References
1. 10 CFR Part 50, ``Domestic Licensing of Production and
Utilization Facilities.''
2. Regulatory Guide 1.8, ``Qualification and Training of Personnel
for Nuclear Power Plants.''
3. Regulatory Guide 1.33, ``Quality Assurance Program Requirements
(Operation).'' (endorses ANSI N18.7-1976/ANS-3.2, ``Administrative
Controls and Quality Assurance for the Operational Phase of Nuclear
Power Plants,'' as supplemented by its regulatory positions)
4. Regulatory Guide 1.114, ``Guidance to Operators at the Controls
and to Senior Operators in the Control Room of a Nuclear Power
Unit.''
5. NUREG-0694, ``TMI-Related Requirements for Operating Licenses.''
6. NUREG-0711, ``Human Factors. Engineering Program Review Mode.
7. NUREG-0737, ``Clarification of TMI Action Plan Requirements.''
8. The Commission Policy Statement on Engineering Expertise on Shift
(50 FR 43621).
Dated Rockville, Maryland, this 27th day of May, 1999.
For the Nuclear Regulatory Commission.
Robert M. Gallo,
Chief, Operator Licensing, Human Performance and Plant Support Branch,
Division of Inspection Program Management.
[FR Doc. 99-14050 Filed 6-2-99; 8:45 am]
BILLING CODE 7590-01-P
