ML20246H122
| ML20246H122 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-0800, NUREG-0800-13.1.2-R3, NUREG-800, NUREG-800-13.1.2-R3, SRP-13.01.02, NUDOCS 8909010111 | |
| Download: ML20246H122 (11) | |
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- NUREG-0800 (Formtrly NUREG 75/087)
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U.S. NUCLEAR REGULATORY COMMISSION 5'
STANDARD REVIEW PLAN OFFICE OF NUCLEAR REACTOR REGULATION
' % ; .' . . . . f Standard Review Plan for the
- Review of Safety Analysis Reports for Nuclear Power Plants Section No. 13.1.2-13.1.3 j Revision No. 3 Appendix No. NA i Revision No. NA E;anch Tech. Position NA Revision No. NA 1
Date issued July 1989 .
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( FILING INSTRUCTIONS PAGES TO BE REMOVED NEW PAGES TO BE INSERTED PAGE NUMBER DATE PAGE NUM BER DATE 13.1.2-13.1.3 Rev. 2 July 1981 13.1.2-13.1.3 Rev. 3 July 1989 page 1 page 1 thru thru 13.1.2-13.1.3 13.1.2-13.1.3 i page 9 page 9 q l
3 8909010111 890831 PDR NURE(;
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The U.S. Nuclear Regulatory Commission's l '*\-- Standard Review Plan NUREG-0800, prepared by the
! Office of Nuclear Reactor Regulation, is available for sale by the National Technical Ir: formation l Service, Springfield, VA 22161.
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% 4 NUREG-0800 (Formerly NU,';EG-75/067) i p p nacug f "i
/ If US NUCLEAR REGULATORY COMMISSION 4@/1 STANDARD REVIEW PLAN
\f esee e o# OFFICE OF NUCLEAR REACTOR REGULATION u
13.1.2-13.1.3 OPERATING ORGANIZATION.
REVIEW RESPONSIBILITIES Primary - Performance and Quality Evaluation Branch (PQEB)
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 (PSAR and FSAR) should l describe the structure, functions, and responsibilities of the onsite organ-ization established to operate and maintain the plant. Specific information to be reviewed is as follows:
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) 'A. 'An organization chart showing the title of each position, the minimum number of persons to be assigned to common or duplicated positions, the number of operating shift crews, and 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.
B. The schedule, relative to fuel loading for each unit, for filling all positions should be presented.
C. The functions, responsibilities, and authorities of plant positions co: responding to the following should be described:
l l: 1. Overall plant management
{ 2. Operations supervision l Rev. 3 - July 1989 USNRC STANDARD FIEVIEW PLAN
- Standard review plans are prepared for the gt4 dance of *?e Office of Nuclear Reactor Rerulation staff responsible for the review of applications to construct anik operate nuclear power plants. These docun.tnts are msde available to the public as part cf the Commission's policy to inform the nuclear industry and the general public of regulatory procedures and policies. Standard review plans are not substitutes for regulatory guides or the Commission's mgulations and compliance witn them is not required. The i
[_\ standard rmview plan sections are keyed to the Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants.
Not all sections of the Standard Format have a corrasprmding review plan.
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\d Published standard review plans will be revised periodical */, as appropriate, to ar.commodate comments and to reflect new informa-tion and experience.
Comments and suggestions for improvement wil! he contidered and should be sent to the U.S. Nuclear Regulalory Commission.
Ofsico of Nuclear Reactor Ragulation, Washington, o.C. 20555.
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- 3. Operating shift crew supervision
- 4. Shift technical advisors
- 5. Licensed operators L 6. Non-licensed operators
- 7. Technical supervision
- 8. Radiation protection supervision
- 9. Instrumentation and controls maintenance supervision
- 10. Equipment maintenance supervision
- 11. Fire protection supervision
- 12. Quality assurance supervisor (when part of the plant staff) l For each position, where applicable, required interfaces with offsite personnel or positions identified in SAR Section 13.1.1 should be cascribed. Such interfaces include defined lines of reporting respon-sibilities, e.g., from the plant manager to his immediate superior, as well as functional or communication channels. In the Final Safety Analysis Report (FSAR), the foilowing should also be described: (1) the line of succession of authority and responsibility for overall station operation in the event of unexpected contingencies of a temporary nature, and (2) the delegation of authority that may be granted to operating supervisors and to shift supervisors, including the authority to issue standing or special orders.
I The FSAR should describe the extent and nature of the participation of the plant operating and technical staff in the initial test program.
If the station contains or is planned to contain power generating facili-ties other than those relating to the application in question arid 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 ua.its, a description {
of their duties, and the proportion of their time they will routinely be assigned to the other unit.
D. 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 l; 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.
E. The education, training, end 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. At the PSAR stage, it is 1 recognized that many details of the plant organization (see A, above) and i staffing have not been finalized. Consequently, the information to be !
reviewed should demonstrate an understanding of and committment to the acceptance criteria below. At the FSAR stage, this section should in addition provide evidence, in the form of personnel resumes, that the initial selections made for mansgement and principal supervisory positions down through the shift supervisory level conform to those requirements. 1 i
13.1.2-2 Rev. 3 - July 1989 l
In addition'to examining.the above areas of review, PQEB will coordinate
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other branch evaluations that interface with the overall review of the applicants operating organization as follows:
The Radiation Protection Branch (PRPB) reviews the detailed radiological protection organization as part of its primary review responsibility for SRP Section 12.5. The Emergency Preparedness Branch (PEPB) reviews.the emergency organization as part of its primary review responsibility for SRP Section 13.3. The PQEB also reviews the detailed quality assurance organization as part of its primary review responsibility for SRP Section 17.0.
For those areas of review identified above as being reviewed as part of
' 4 the primary review responsibility of other branches, the acceptance cri -
teria necessary for the review and their methods of application are con-tained in the referenced SRP section of the corresponding primary branch.
II. ACCEPTANCE CRITERIA 4
This section of the SAR should demonstrate the applicant's commitment to. (PSAR) and implementation of (FSAR) plans to staff the onsite operating organization
, and to define'and delegate responsibilities to provide. assurance that the plant can be operated safely.
The staff acceptance criteria are designed to produce reasonable assurance of applicant compliance with the relevant requirements of the following regulations:
1 -. O d -1. 10 CFR Part 50, S50.40b 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 Part 50, S50.54j, k, 1, and m as it relates to operator requirements during the operation of the facility, the responsibility for directing activities of licensed operators, and the senior operator availability L during reactor operations and other specific reactor conditions or mode of I
operation.
Specific criteria necessary to meet the relevant requirements of the regulations are as follows:
A. The requirements of ANSI N18.7, Section 3.4, " Operating Organization," as endorsed by Regulatory Guide 1.33, should be met. Additionally, the following characteristics should be satisfied:
- 1. The reporting responsibility and authority of the functional areas of radiation protection, quality assurance,-and training should assure 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.
- 2. There are clear lines of authority to the Plant Manager.
- 3. Responsibility for all activities important to the safe operation of V the facililty are clearly defined. l 13.1.2-3 Rev. 3 - July 1989 W_ - _ - - - __
- 4. Distinct functional areas are separately supervised and/or nanaged.
- 5. Sufficient manag rial depth is available to provide qualified backup in the event of the absence of the incumbent. j B. Responsibilities and authorities of operating organization personnel should conform to the requirements of ANSI N18.7, Sect. ion 5.2, " Rules of Practice"; i Section 4.4, "0nsite Review," as endorsed by Regulatcry Guide 1.33; Cranch I Technical Position CMEB 9.5-1; ANSI N18.1; Section 3.2, " Operating Organ- I ization," as endorsed by Regulatory Guide 1.8. In addition, to meet TMI j Action Plan item I.C.3 of NUREG-0694, the responsibilities of the shift i
supervisor shall clearly establish the command duties of the shift super- )
visor and emphasize the primary management responsibility for the safe l operation of the plant.
C. Assignments of onsite shift operating crews should be made in accordance with 10 CFR 50.54(m) and the staff positions of TMI Action Plan item I.A.1.3 of NUREG-0737. l Adjunct requirements to these shift staffing criteria are as follows:
- 1. 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.
- 2. In addition to the licensed personnel specified in 10 CFR 50.54(m),
an auxiliary operator (non-licensed) shall be assigned 20 each reactor and an additional auxiliary operator shall be assigned for each con-l trol room from which a reactor is operating. These operators shall be properly qualified to support the unit to which assigned. Note:
The above requirements are shown in tabular form in Table 1.
- 3. To meet TMI Action Plan item I.A.1.1 of NUREG-0737, engineering exper-l tise 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 shall meet the Commission Policy Statement on Engineering Expertise on Shift.
- 4. A health physics technician shall be onsite at all times when there is fuel in a reactor.
- 5. 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 l for a BWR.
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- 6. Assignment of operators and senior operators within the control room j l shall be described in Regulatory Guide 1.114.
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D. Total complements of licensed personnel and unlicensed personnel, C. above, i
should be provided such that the use of overtime is avoided (note Section
! 13.5.1 on work hour limitations). To meet this policy, staffing plans i should provide for no less than the number required for five shift rotations.
Gi E. The plant. operating and technical staff should be used to the maximum extent possible in the facility initial test program. '
13.1.2-4 Rev. 3 - July 1989
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->~j- TABLE 1 SHIFT STAFFING ** 1
, :One. Unit Two Units Two Units One Control One Control Two Control-Room Room Rooms 1 One: Unit Operating
'2 R0 3 R0 -3 R0 1 2 A0 3 A0 3 A0 l Two Units Operating
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All Units Shutdown 1 SS (SRO) 1 SS (SRO) l'SS (SRO) 1 R0 2 R0 2 R0 4 1 A0' 3 A0 3 A0
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SS - Shift Supervisor R0 - Licensed Reactor Operator l SR0 - Licensed Senior Reactor Operator- AO - Auxiliary Operator
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' NOTE: 1. In order to operate or supervise the operation of more than one unit, an operator (SR0 or RO) must hold an appropriate, current license for each sech 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. 1
- Modes 1 through 4 for PWRs.
Modes 1 through 3 vor BWRs.
- Shift staffing of unlicensed personnel for special cases such as 3 units operating from 1 or 2 control rooms will be determined on a case-by-case i basis, based on the principles defined in item II C. of this SRP section.
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F. Assignments of persons to implement the fire birgade requirements of the fire protection program should meet the guideline of SRP Section 9.5.1 including the following:
- 1. The responsibilities of the fire t,rigade members under normal conditions should not conflict with their responsibilities during a fire emergency.
- 2. 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.
G. Regulatory Guide 1.0, " Personnel Selection and Training," sets forth the staff position on plant personnel qualifications and indicates that the criteria for selection (qualifications) contained in ANSI N18.1 are generally acceptable, except as noted in the regulatory position section of Regulatory Guide 1.8. Plant staff personnel listed in items A. through D. above should meet this staff position.
I In addition, although the qualification levels of the standard 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 mini-mum 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.
Ill. REVIEW PROCEDURES Each element of the SAR 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 assure 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 tae applic-able version of references, Regulatory Guides, and Codes and Standards used in the review.
In the review and evaluation of the subject matter of this section of the SAR, the following points should be taken into consideration.
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. For multi-unit sites, consideration must be given to the possibility that off-shift supervision may be stretched too thin to provide effective supervision. For example, a single 13.1.2-6 Rev. 3 - July 1989
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d operations manager may have difficulty covering more than two units. For on-v}
shift persons, the total manpower available should be reviewed to assure that in excess of five full operating shift crews are planned so that excessive over-time is not routinely scheduled for these crews. 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 operating organization, as demonstrated oy organization charts and descriptions of functions and responsibilities, 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. 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 who lack prior experience with nuclear plant operatica and those who have such experience. It is impor-tant that the reviewer assure himself that applicants in the former category do not underestimate the magnitude of the task. The reviewer should be alert to the possibility that excessive workloads may be placed upon too small a number of individuals.
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.
At the construction permit (CP) stage, the applicant will generally not have A 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 appli-(U) cant to conform to the stated acceptance criteria.
Where a clear comparison cannot be made between the proposed plant staff positions and those defined in Section 4 of ANSI N18.1, the applicant should list each position on its plant staff and designate the corresponding position of Section 4 of ANSI N18.1, or describe in detail the proposed qualification requirements for each position en its plant staff. !
The review of the FSAR, at the operating license (OL) stage, consists first of the same examination as made at the CP stage, and secondly, of ar, analysis of each resume. The reviewer should make an explicit comparison of the educa-tional and experience records obtained from each resume with the corresponding requirements set forth for the applicable position in Section 4 of ANSI N18.1 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.
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 quali-fications through the appropriate Regional Office, e.g., by discussion with inspection personnel or review of inspection reports. l (m) The reviewer then determines, based upon the foregoing, the overall acceptability (f of the applicant's operating organizations and plant staffing plans.
13.1.2-7 Rev. 3 - July 1989 L__ ___
IV. EVALUATION FINDINGS The reviewer verifies that the information presented and its review support conclusions of the follcwing type to be used in the staff's Safety Evaluation Report:
The staff concludes that the applicants operating organization is acceptable and meets the relevant requirements of 10 CFR Part 50, 650.40b and 650.54j through m. This conclusion is based on the foisowing:
The applicant has described the assignment of plant operating responsi-bilities; the reporting chain up through the chief executive office of the company (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 (FSAR-submitted personnel resumes for management and principal supervisory and technical positions). This information has been reviewed, and it is the conclusion of the staff that the proposed organization is acceptcble.
Acceptability of the applicants operating organization is a significant input to the requirement that the applicant is technically qualified as required by 10 CFR Part 50, 650.40(b); that adequate licensed operators are available to meet the requirements of Section 50.54(j) through (m); the adequacy of the on-shift personnel to provide initial facility response in the event of an emergency; organizational requirements for the plant manager and radiation protection man-ager; qualification requirements and qualifications (FSAR) of plant personnel as stated in Regulatory Guide 1.8, and organizational requirements as stated in Regulatory Guide 1.33.
In addition, the applicant has complied with the requirements of TMI Action Plan items 1.A.1.1 and I.A.1.3.
V. IMPLEMENTATION The following is intended to provide guidance to applicants and licensees regarding the NRC staff's plans for using this SRP section.
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 con-formance with Commission regulations.
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, S50.40, " Common Standards."
L 2. 10 CFR Part 50, S50.54, " Conditions of Licenses."
- 3. Regulatory Guide 1.8, "Personncl Selection and Training."
l 13.1.2-8 Rev. 3 - July 1989 i
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-fN E4. . Regulatory Guide 1.33, " Quality Assurance' Program Requirements (Operation)."'
- 5. . Regulatory Guide 1.114, " Guidance to Operators at the Controls' and to '-
Senior Operators in the Control Room of a Nuclear Power Unit."
- 6. Branch Technical Position' CMEB 9.5-1, " Fire Protection Program, attached to Standard Review Plan Section 9.5.1.
'7. NUREG-0694, "TMI-Related Requirehients for Operating Licenses."
- 8. NUREG-0737, " Clarification of TMI Action Plan Requirements."
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