ML21179A111
| ML21179A111 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/15/2021 |
| From: | Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21179A130 | List:
|
| References | |
| ND-21-0486 | |
| Download: ML21179A111 (73) | |
Text
Chapter 13 UFSAR Table of Contents Chapter 1 Introduction and General Description of the Plant Chapter 2 Site Characteristics Chapter 3 Design of Structures, Components, Equipment and Systems Chapter 4 Reactor Chapter 5 Reactor Coolant System and Connected Systems Chapter 6 Engineered Safety Features Chapter 7 Instrumentation and Controls Chapter 8 Electric Power Chapter 9 Auxiliary Systems Chapter 10 Steam and Power Conversion Chapter 11 Radioactive Waste Management Chapter 12 Radiation Protection Chapter 13 Conduct of Operation Chapter 14 Initial Test Program Chapter 15 Accident Analyses Chapter 16 Technical Specifications Chapter 17 Quality Assurance Chapter 18 Human Factors Engineering Chapter 19 Probabilistic Risk Assessment UFSAR Formatting Legend Color Description Original Westinghouse AP1000 DCD Revision 19 content (part of plant-specific DCD)
Departures from AP1000 DCD Revision 19 content (part of plant-specific DCD)
Standard FSAR content Site-specific FSAR content Linked cross-references (chapters, appendices, sections, subsections, tables, figures, and references)
VEGP 3&4 - UFSAR TABLE OF CONTENTS Section Title Page CHAPTER 13 CONDUCT OF OPERATION ....................................................................... 13.1-1 13.1 Organizational Structure .............................................................................. 13.1-1 13.1.1 Management and Technical Support Organization ..................... 13.1-1 13.1.1.1 Design, Construction, and Operating Responsibilities......................................................... 13.1-1 13.1.1.2 Provisions for Technical Support Functions ............. 13.1-2 13.1.1.3 Organizational Arrangement..................................... 13.1-7 13.1.1.4 Qualifications of Technical Support Personnel ......... 13.1-7 13.1.2 Operating Organization ............................................................... 13.1-8 13.1.2.1 Plant Organization .................................................... 13.1-8 13.1.3 Qualifications of Nuclear Plant Personnel ................................. 13.1-10 13.1.3.1 Qualification Requirements..................................... 13.1-10 13.1.3.2 Qualifications of Plant Personnel............................ 13.1-10 13.1.4 Combined License Information Item .......................................... 13.1-10 13.1.5 References ................................................................................ 13.1-11 13.2 Training ........................................................................................................ 13.2-1 13.2.1 Licensed Operator Training ......................................................... 13.2-2 13.2.1.1 Licensed Operator Initial Training Program .............. 13.2-2 13.2.1.2 Continuing Training for Licensed Personnel............. 13.2-2 13.2.2 Training for Positions Listed in 10 CFR 50.120 ........................... 13.2-3 13.2.2.1 Non-Licensed Operator (NLO) Initial Training .......... 13.2-3 13.2.2.2 Shift Manager Initial Training .................................... 13.2-3 13.2.2.3 Shift Technical Advisor Initial Training Program ....... 13.2-3 13.2.2.4 Instrumentation and Control (I&C) Technician Initial Training..................................................................... 13.2-4 13.2.2.5 Electrical Maintenance Initial Training Program ....... 13.2-4 13.2.2.6 Mechanical Maintenance Initial Training Program.... 13.2-4 13.2.2.7 Radiological Protection Technician Initial Training ... 13.2-5 13.2.2.8 Chemistry Technician Initial Training........................ 13.2-5 13.2.2.9 Engineering Personnel Initial Training ...................... 13.2-5 13.2.2.10 Continuing Training for Personnel Listed in 10 CFR 50.120 .............................................................. 13.2-6 13.2.3 General Employee Training (GET) Program ............................... 13.2-6 13.2.3.1 Plant Access Training ............................................... 13.2-6 13.2.3.2 Radiation Worker Training Program ......................... 13.2-6 13.2.3.3 General Employee Requalification Training ............. 13.2-7 13.2.4 Selected Other Training Programs .............................................. 13.2-7 13.2.4.1 Fire Protection Training ............................................ 13.2-7 13.2.4.2 Emergency Plan Training Program........................... 13.2-7 13.2.4.3 Physical Security Training Program.......................... 13.2-7 13.2.4.4 Station Management Training Program.................... 13.2-7 13.2.5 Training Effectiveness Evaluation Program................................. 13.2-8 13.2.5.1 Supervisory Review for Training Effectiveness ........ 13.2-8 13.2.5.2 Trainee Review of Training Effectiveness ................ 13.2-8 13.2.5.3 Review for Effectiveness of Instructional Techniques and Materials ............................................................ 13.2-8 13.2.6 Combined License Information Item ............................................ 13.2-8 13.2.7 References .................................................................................. 13.2-8 13-i Revision 10
VEGP 3&4 - UFSAR TABLE OF CONTENTS (CONTINUED)
Section Title Page 13.2A Cold License Training Plan ...................................................................13.2A-1 13.2A.1 Licensed Operator Experience Requirements Prior To Commercial Operation...............................................................13.2A-1 13.2A.2 Crew Experience Requirements during First Year of Operation ...................................................................................13.2A-2 13.2A.3 Conduct of On-the-Job Training (OJT) .....................................13.2A-3 13.2A.4 Use of Part-Task/Limited Scope Simulators .............................13.2A-3 13.2A.5 Licensed Operator Continuing Training ....................................13.2A-3 13.2A.6 Cold Licensing Process Applicability and Termination .............13.2A-3 13.2A.7 Initial Licensed Operator Examination Schedule ......................13.2A-4 13.2A.8 References ...............................................................................13.2A-4 13.3 Emergency Planning .................................................................................... 13.3-1 13.3.1 Combined License Information Item ............................................ 13.3-1 13.4 Operational Programs .................................................................................. 13.4-1 13.4.1 Combined License Information Item ............................................ 13.4-1 13.4.2 References .................................................................................. 13.4-1 13.5 Plant Procedures.......................................................................................... 13.5-1 13.5.1 Administrative Procedures........................................................... 13.5-2 13.5.2 Operating and Maintenance Procedures ..................................... 13.5-3 13.5.2.1 Operating and Emergency Operating Procedures.... 13.5-3 13.5.2.2 Maintenance and Other Operating Procedures ........ 13.5-4 13.5.3 Combined License Information Item ............................................ 13.5-6 13.5.4 References .................................................................................. 13.5-6 13.6 Security ........................................................................................................ 13.6-1 13.6.1 Combined License Information Item ............................................ 13.6-2 13.6.2 ESP COL Action Items ................................................................ 13.6-2 13.6.3 References .................................................................................. 13.6-2 13.7 Fitness for Duty ............................................................................................ 13.7-1 13.7.1 References .................................................................................. 13.7-2 APPENDIX 13AA CONSTRUCTION-RELATED ORGANIZATION ................................... 13AA-1 13-ii Revision 10
VEGP 3&4 - UFSAR LIST OF TABLES Table Number Title Page 13.1-201 Not Used .................................................................................................... 13.1-12 13.1-202 Minimum On-Duty Operations Shift Organization for Two-Unit Plan .......... 13.1-13 13.2A-201 Comparison of Hot and Cold License Guidance .........................................13.2A-5 13.2A-202 Illustration of Cold Licensing Plan by Candidate Type ................................13.2A-9 13.2A-203 Cumulative Nuclear Power Plant Operating Crew Experience Equivalencies ............................................................................................13.2A-10 13.4-201 Operational Programs Required by NRC Regulations .................................. 13.4-2 13.5-201 Pre-COL Phase Administrative Programs and Procedures .......................... 13.5-8 13-iii Revision 10
VEGP 3&4 - UFSAR LIST OF FIGURES Figure Number Title Page 13.1-201 Not Used ..................................................................................................... 13.1-14 13.1-202 Not Used ..................................................................................................... 13.1-15 13.1-203 Not Used ..................................................................................................... 13.1-16 13AA-201 Deleted ........................................................................................................ 13AA-6 13AA-202 Hiring Schedule for Plant Staff .................................................................... 13AA-7 13-iv Revision 10
VEGP 3&4 - UFSAR Chapter 13 Conduct of Operation This chapter provides information relating to the preparations and plans for operation of the AP1000 units at Vogtle 3 and 4 after construction. Its purpose is to provide reasonable assurance that the plant will establish and maintain a staff of sufficient size and technical competence and that operating plans provide reasonable assurance of adequate protection of the public health and safety. The requirements for Initial Test Program personnel and activities are covered under Chapter 14, Initial Test Program.
13.1 Organizational Structure The organizational structure must be consistent with the human system interface design assumptions. See Section 1.8 and Chapter 18 for interface requirements pertaining to organizational structure.
This section describes organizational positions of a nuclear power station and owner/applicant corporations and associated functions and responsibilities. The position titles used in the text are generic and describe the function of the position.
13.1.1 Management and Technical Support Organization Southern Nuclear Operating Company, Inc. (SNC) has over 30 years of experience in the design, construction, and operation of nuclear generating plants. SNC, with its architectural engineering predecessor Southern Company Services, Inc., has designed, constructed, and currently operates six nuclear units at three sites: Edwin I. Hatch Nuclear Plant Units 1 and 2, Joseph M. Farley Nuclear Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 1 and 2.
Vogtle 3 and 4 will be owned by Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia1, and the City of Dalton, and operated by SNC.
13.1.1.1 Design, Construction, and Operating Responsibilities The Chairman, President & Chief Executive Officer (CEO) Southern Nuclear has overall responsibility for functions involving design, construction, and operation. Line responsibilities for those functions are assigned to the Executive Vice President of Vogtle 3&4 for the design, construction, and initial operation of Vogtle 3&4 and to the Chief Nuclear Officer (CNO) for long term operation of Vogtle 3&4. At the appropriate time designated by the President and CEO Southern Nuclear, the CNO accepts responsibility for the additional unit/units at the VEGP site and then maintains direct control of nuclear plant operation through the Site Vice President, operations support, engineering, and other direct reports.
The first priority and responsibility of each member of the nuclear staff throughout the life of the plant is nuclear safety. Decision-making for plant activities is performed in a conservative manner with expectations of this core value regularly communicated to appropriate personnel by management interface, training, and plant directives. Lines of authority, decision making, and communication are clearly and unambiguously established to enable the understanding of the various project members, including contractors, that utility management is in charge of and directs on the project. Key executive and corporate management positions, functions, and responsibilities are discussed in Subsection 13.1.1.3.1, the Nuclear Development Quality Assurance Manual (NDQAM), or the Quality Assurance Topical Report (QATR). The corporate organization is described in the NDQAM or the
- 1. On June 24, 2015, Municipal Electric Authority of George (MEAG) transferred its ownership interest to its wholly owned subsidiaries: MEAG Power SPVM, LLC; MEAG Power SPVJ, LLC; and MEAG Power SPVP, LLC.
13.1-1 Revision 10
VEGP 3&4 - UFSAR QATR. The management and technical support organization for design, construction, and preoperational activities is addressed in Appendix 13AA.
13.1.1.2 Provisions for Technical Support Functions Before beginning preoperational testing, the Executive Vice President of Vogtle 3&4 establishes the organization of managers, functional managers, supervisors, and staff sufficient to perform required functions for support of safe and efficient preoperational and startup testing. Sufficient numbers of personnel are assigned to perform preoperational and startup testing to facilitate safe and efficient implementation of the testing program. To improve operational experience, operations and technical staff are used as support in conducting the test program and in reviewing test results. Prior to fuel load, the organization of managers, functional managers, supervisors, and staff sufficient to perform the required functions for support of safe plant operation shall be present. These functions include the following:
Nuclear, mechanical, civil, structural, electrical, thermal-hydraulic, metallurgical and material, and instrumentation and controls engineering Safety review Quality assurance, audit and surveillance Plant chemistry and environmental support Radiation protection Fueling and refueling operations support Training Maintenance support Operations support Fire protection Emergency planning Outside contractual assistance In the event that plant personnel are not qualified to deal with a specific problem, the services of qualified individuals from other functions within the company or an outside consultant are engaged.
For example, major contractors, such as the reactor technology vendor or turbine generator manufacturer, provide technical support when equipment modifications or special maintenance problems are considered. Special studies, such as environmental monitoring, may be contracted to qualified consultants. See the NDQAM or QATR for description of responsibilities and authorities of management positions for organizations providing technical support.
Multiple layers of protection are provided to preserve unit integrity including organization.
Organizationally, operators and other shift members are assigned to a specific unit, with the exception of some shared shift support supervisor and system operator positions. Physical separation of units helps to minimize wrong-unit activities. In addition, plant procedures and programs provide operating staff with methods to minimize human error including tagging programs, procedure adherence requirements, and training.
13.1-2 Revision 10
VEGP 3&4 - UFSAR 13.1.1.2.1 Engineering The engineering department consists of system engineering, engineering plant support, and design engineering. These groups are responsible for performing the site engineering activities as well as providing engineering expertise in other areas. Each of the engineering groups has a functional manager who reports to the engineering director.
The engineering department is responsible for:
Support of plant operations in the engineering areas of mechanical, structural, electrical, thermal-hydraulic, metallurgy and materials, electronic, instrument and control, and fire protection. Priorities for support activities are established based on input from the plant manager with emphasis on issues affecting safe operation of the plant.
Engineering plant support.
Support of procurement, chemical, and environmental analysis and maintenance activities in the plant as requested by the plant manager.
Performance of design engineering of plant modifications.
Human factors engineering design process Quality control (QC) inspection/testing activities to support plant operation, maintenance, and outages.
Reactor engineering provides technical assistance in the areas of core design, core operations, core thermal limits, and core thermal hydraulics.
Engineering work may be contracted to and performed by outside companies in accordance with the quality assurance (QA) program.
Engineering resources are shared between units. A single management organization oversees the engineering work associated with the plant units.
13.1.1.2.2 Safety Review Review and audit activities are addressed in Chapter 17. Safety review oversight of plant programs, procedures, and activities is performed by a plant review board and a corporate safety review board.
Personnel who perform safety review are shared between units.
13.1.1.2.3 Quality Assurance Safety-related activities associated with the operation of the plant are governed by QA direction established in Chapter 17 and the QA Program Description (QAPD). The requirements and commitments contained in the QAPD apply to activities associated with structures, systems, and components that are safety-related and are mandatory and must be implemented, enforced, and adhered to by individuals and organizations. QA requirements are implemented through the use of approved procedures, policies, directives, instructions, or other documents that provide written guidance for the control of quality-related activities and provide for the development of documentation to provide objective evidence of compliance. The QA function includes:
Maintaining the QAPD.
13.1-3 Revision 10
VEGP 3&4 - UFSAR Coordinating the development of audit schedules.
Auditing, performing surveillance, and evaluating nuclear division suppliers.
Supporting general QA indoctrination and training for the nuclear station personnel.
The QA organization is independent of the plant management line organization.
Personnel resources of the QA organization are shared between units. A single management organization oversees the QA group for the plant units.
13.1.1.2.4 Chemistry A chemistry program is established to monitor and control the chemistry of various plant systems such that corrosion of components and piping is minimized to maintain reliable equipment performance and radiation from corrosion byproducts is kept to levels that allow operations and maintenance with radiation doses as low as reasonably achievable. Department responsibilities include:
Primary and secondary water chemistry Process and effluent monitoring and sampling Closed cooling water chemistry Demineralized water treatment chemistry Diesel fuel oil testing, analysis, and controls Plant chemical control The Chemistry Manager reports to the Plant Manager. The staff of the chemistry department consists of laboratory technicians, support personnel, and supervisors who report to the Chemistry Manager.
Personnel resources of the chemistry organization are shared between units. A single management organization oversees the chemistry group for the plant units.
13.1.1.2.5 Radiation Protection A radiation protection (RP) program is established to protect the health and safety of the public and the personnel working at the plant by establishing means to maintain radiation exposure as low as reasonably achievable (ALARA) and to prevent the spread of contamination. The RP program is described in Appendix 12AA. The program includes:
Respiratory protection Personnel dosimetry Bioassay Survey instrument calibration and maintenance Radioactive source control 13.1-4 Revision 10
VEGP 3&4 - UFSAR Effluents and environmental monitoring and assessment Radioactive waste shipping Radiation work permits Job coverage Radiation monitoring and surveys The RP department is staffed by RP technicians, support personnel, and supervisors who report to the Radiation Protection Manager. To provide sufficient organizational freedom from operating pressures, the Radiation Protection Manager reports directly to the Plant Manager.
Personnel resources of the RP organization are shared between units. A single management organization oversees the RP group for both units.
The terms radiation protection and health physics are used interchangeably in function descriptions.
13.1.1.2.6 Fueling and Refueling Support The function of fueling and refueling is performed by a combination of personnel from various departments including, but not limited to, work management, operations, maintenance, radiation protection, engineering, and reactor technology vendor or other contractor staff. Personnel resources used to support fueling and refueling are shared between units.
13.1.1.2.7 Training and Development The training department is responsible for analysis, design, development, implementation and evaluation of plant training programs in accordance with regulatory requirements, accreditation standards, and company policies. The objective of the training programs is to qualify operations, maintenance, RP, chemistry, and engineering personnel to operate and maintain the plant in a safe and efficient manner and in compliance with the license, technical specifications, and applicable regulations. In addition, the training department administers plant access (general employee) training, radworker training, security training, and emergency response training. The senior manager responsible for training reports independently of the line organization to provide for independence from operating pressures. Plant training programs are described in Section 13.2.
Personnel resources of the training department are shared between units. A single management organization provides oversight of plant training activities.
13.1.1.2.8 Maintenance Support In support of maintenance activities, planners, schedulers, and parts specialists prepare work packages, acquire proper parts, and develop procedures that provide for the successful completion of maintenance tasks. Maintenance tasks are integrated into the plant schedule for evaluation of operating or safe shutdown risk elements and to provide for efficient and safe performance. The Maintenance Director reports to the Plant Manager.
Personnel of the maintenance support organization are shared between units. A single management organization oversees the function of maintenance support for the plant units.
13.1-5 Revision 10
VEGP 3&4 - UFSAR 13.1.1.2.9 Operations Support The operations support function is provided under the direction of the Operations Director.
Operations support includes the following programs:
Operations procedures Operations surveillances Equipment tagging 13.1.1.2.10 Fire Protection The plant is committed to maintaining a fire protection program as described in Section 9.5. Once the nuclear plant is operational, the Site Vice President, through the engineer in charge of fire protection, is responsible for the fire protection program. Assigning the responsibilities at that level provides the authority to obtain the resources and assistance necessary to meet fire protection program objectives, resolve conflicts, and delegate appropriate responsibility to fire protection staff. Fire protection for the facility is organized and administered by the engineer in charge of fire protection.
The engineer in charge of fire protection is trained and experienced in fire protection and nuclear plant safety or has available personnel who are trained and experienced in fire protection and nuclear plant safety.
The Site Vice President, through the engineer in charge of fire protection, is responsible for developing and implementing the fire protection program including developing fire protection procedures, site personnel and fire brigade training, and inspections of fire protection systems and functions. The engineer in charge of fire protection coordinates operations-related fire protection program activities with the Operations Director or designee. Functional descriptions of position responsibilities are included in appropriate procedures. Plant personnel are responsible for adhering to the fire protection/prevention requirements detailed in Section 9.5. The Executive Vice President of Vogtle 3&4 has the lead responsibility for the overall site fire protection during construction of the new units.
Personnel resources of the fire protection organization are shared between units. A single management organization oversees the fire protection group for the plant units.
13.1.1.2.11 Emergency Organization The emergency organization is a matrixed organization composed of personnel who have the experience, training, knowledge, and ability necessary to implement actions to protect the public in the case of emergencies. Managers and plant personnel assigned positions in the emergency organization are responsible for supporting the emergency preparedness organization and emergency plan as required. The staff members of the emergency planning organization administrate and orchestrate drills and training to maintain qualification of plant staff members and develop procedures to guide and direct the emergency organization during an emergency. The staff is also responsible for maintaining emergency facilities and equipment. The functional manager in charge of emergency preparedness reports to the senior manager responsible for Regulatory Affairs.
Once the protected area is combined with Units 1 and 2, emergency response is combined with Units 1 and 2.
The site emergency plan organization is described in the Emergency Plan. Resources of the emergency planning group are shared between units. A single management organization oversees the emergency planning group for the plant units.
13.1-6 Revision 10
VEGP 3&4 - UFSAR 13.1.1.2.12 Outside Contractual Assistance Contract assistance with vendors and suppliers of services not available from organizations established as part of utility staff is provided by the materials, purchasing, and contracts organization.
Personnel in the materials, purchasing, and contracts organization perform the necessary functions to contract vendors of special services to perform tasks for which utility staff does not have the experience or equipment required. The functional manager in charge of materials, purchasing, and contracts reports to the department manager in charge of materials, purchasing, and contracts.
Resources of the materials, purchasing, and contracts organization are shared between units. A single management organization oversees the materials, purchasing, and contracts group for the plant units.
13.1.1.3 Organizational Arrangement 13.1.1.3.1 Executive Management Organization The nuclear operations organization, under the supervision of the Chairman, President & CEO Southern Nuclear, has direct responsibility for the operation and maintenance of Southern Company's nuclear plants. Executive management establishes expectations such that a high level of quality, safety, and efficiency is achieved in aspects of plant operations and support activities through an effective management control system and an organization selected and trained to meet the above objectives. Site executives and management with direct line of authority for activities associated with operation of the plant are described in the NDQAM or SNC QATR. The structure of the nuclear operations organization is described in the NDQAM or SNC QATR. Portions of the SNC Fleet Operations Support, Engineering, and General Counsel and External Affairs are also described in the following paragraphs, in the NDQAM or SNC QATR.
13.1.1.3.1.1 Associate General Counsel The Associate General Counsel is a matrixed report to the Chairman, President & CEO. This individual is responsible for the legal, compliance, and external affairs associated with the SNC plants. This individual is also responsible for external affairs activities which include governmental affairs and corporate communications. The corporate concerns and compliance manager also reports to this position.
13.1.1.3.1.2 Vice President Treasurer and Secretary The Vice President Treasurer and Secretary reports directly to the Chairman, President & CEO and is responsible for the development, coordination, management, and communication of all financial matters, including budgeting and analysis, accounting and billing, and the maintenance of an effective system of internal controls.
13.1.1.4 Qualifications of Technical Support Personnel The qualifications of managers and supervisors of the technical support organization meet the qualification requirements in education and experience for those described in ANSI/ANS-3.1-1993 (Reference 201) as endorsed and amended by Regulatory Guide 1.8. The qualification and experience requirements of headquarters staff is established in corporate policy and procedure manuals.
13.1-7 Revision 10
VEGP 3&4 - UFSAR 13.1.2 Operating Organization 13.1.2.1 Plant Organization Plant personnel responsibilities, authorities, and organizational relationships are described in the NDQAM or the QATR except for those positions described below.
13.1.2.1.1 Operations Managers The Operations Services Manager, Shift Operations Manager, and Operations Support Manager report to the Operations Director and share the responsibility to ensure plant operations are conducted per Technical Specifications, standing orders, the Offsite Dose Calculation Manual (ODCM) and approved procedures and may function as the Operations Director when designated.
13.1.2.1.2 Shift Manager (SM)
The Shift Manager (SM) reports to the Shift Operations Manager. The SM is the senior management representative on each shift and is responsible for the safe and efficient operation of the plant. The SM ensures plant operations are conducted in accordance with appropriate standing orders, the ODCM, unit operating procedures, and Technical Specifications. The SM has responsibility for the entire plant in the absence of the Site VP, Plant Manager, and Operations Director. The SM has their authority, including issuing standing orders and other special orders, in their absence. The Shift Manager shall possess an SRO License.
13.1.2.1.2.1 Shift Supervisor (SS)
One Shift Supervisor (SS) is assigned to each operating unit on each shift. The SS is responsible for the safe and efficient operation of the assigned unit. Each SS shall possess an SRO License. The SS(s) report to the Shift Manager (SM) and supervise the Reactor Operators, Non-Licensed Operators, and Shift Support Supervisors. The SS is responsible for ensuring that plant operations are conducted per the Technical Specifications, ODCM, and approved procedures and standing orders.
13.1.2.1.2.1.1 Reactor Operator (RO)
The Reactor Operators report to the SS and are responsible to operate the reactor and power plant per approved procedures, standing orders, and Technical Specifications. The Reactor Operator shall possess a reactor operators license.
13.1.2.1.2.1.2 System Operator (SO)
System Operators report to the respective unit's Shift Supervisor (SS) or Support Shift Supervisor (SSS) and are responsible for operating and monitoring plant auxiliary equipment and/or systems outside the main control room. System Operators are non-licensed operators.
13.1.2.1.2.2 Shift Support Supervisor (SSS)
The SSS reports to the Shift Manager (SM) and is responsible for ensuring shift operations are conducted per Technical Specifications, ODCM, and approved procedures and are responsible for monitoring performance of operator rounds, system and equipment lineups, and surveillances.
13.1-8 Revision 10
VEGP 3&4 - UFSAR 13.1.2.1.3 Shift Technical Advisor (STA)
One Shift Technical Advisor (STA) is assigned per shift during plant operation. A shift manager or another SRO on shift, who meets the qualifications for the combined Senior Reactor Operator/Shift Technical Advisor position, as specified for option 1 of Generic Letter 86-04, NRCs "Policy Statement on Engineering Expertise On Shift", may also serve as the STA. If this option is used for a shift, then the separate STA position may be eliminated for that shift. Section 13.2 describes STA training, and Subsection 13.1.3 describes STA qualifications.
13.1.2.1.4 Conduct of Operations Plant operations are controlled and/or coordinated through the control room. Maintenance activities, surveillances, and removal from/return to service of structures, systems, and components affecting the operation of the plant may not commence without the approval of senior control room personnel.
The rules of practice for control room activities, as described by administrative procedures, which are based on Regulatory Guide 1.114, address the following:
Position/placement of operator at the controls workstation and the expected area of the control room where the majority of the time of the supervisor/manager in charge on shift should be spent.
Definition and outline of "surveillance area" and requirement for continuous surveillance by the operator at the controls.
Relief requirements for operator at the controls and the supervisor/manager in charge on shift.
In accordance with 10 CFR 50.54:
Reactivity controls may be manipulated only by licensed ROs and SROs except as allowed for training under 10 CFR 55.
Apparatus and mechanisms other than controls that may affect reactivity or power level of the reactor shall be operated only with the consent of the operator at the controls or the manager/supervisor in charge on-shift.
During operation of the facility in modes other than cold shutdown or refueling, an SRO shall be in the control room and a licensed RO or SRO shall be present at the controls.
Line of Succession:
The line of succession of authority and responsibility for overall operations in the event of unexpected events of a temporary nature is:
- a. Plant Manager
- b. Operations Director
- c. Shift Manager
- d. Shift Supervisor 13.1-9 Revision 10
VEGP 3&4 - UFSAR 13.1.2.1.5 Operating Shift Crews Plant administrative procedures implement the required shift staffing. These procedures establish crews with sufficient qualified plant personnel to staff the operational shifts and be readily available in the event of an abnormal or emergency situation. The objective is to operate the plant with the required staff and to develop work schedules that minimize overtime for plant staff members who perform safety-related functions. Work hour limitations and shift staffing requirements defined by TMI Action Plan I.A.1.3 are retained in plant procedures. When overtime is necessary, the provisions in the Technical Specifications, 10 CFR 26, and the plant administrative procedures apply. Shift crew staffing plans may be modified during refueling outages to accommodate safe and efficient completion of outage work in accordance with the proceduralized work hour limitations.
The minimum composition of the operating shift crew is contingent on the unit operating status.
Position titles, license requirements, and minimum shift staffing for various modes of operation are contained in Technical Specifications, administrative procedures, and Table 13.1-202.
13.1.2.1.6 Fire Brigade The station is designed and the fire brigade organized to be self-sufficient with respect to firefighting activities. The fire brigade is organized to deal with fires and related emergencies that could occur. It consists of a fire brigade leader and a sufficient number of team members to be consistent with the equipment that must be put in service during a fire emergency. A sufficient number of trained and physically qualified fire brigade members are available on site during each shift. The fire brigade consists of at least five members on each shift. The fire brigade leader and at least two members will be knowledgeable of the building layout and system design sufficient to understand the effects of fire fighting on safety-related equipment. The assigned fire brigade members for any shift does not include the shift manager nor any other members of the minimum shift operating crew necessary for safe shutdown of the unit. It does not include any other personnel required for other essential functions during a fire emergency. Fire brigade members for a shift are designated in accordance with established procedures at the beginning of the shift. Fire brigade personnel may include personnel from Units 1 and 2 once the protected area is combined.
13.1.3 Qualifications of Nuclear Plant Personnel 13.1.3.1 Qualification Requirements Qualifications of managers, supervisors, operators, and technicians of the operating organization meet the qualification requirements in education and experience for those described in ANSI/ANS-3.1-1993 (Reference 201), as endorsed and amended by Regulatory Guide 1.8 and clarified in Appendix 1A.
13.1.3.2 Qualifications of Plant Personnel Résumés and/or other documentation of qualification and experience of initial appointees to appropriate management and supervisory positions are available for review by regulators upon request after position vacancies are filled.
13.1.4 Combined License Information Item The organizational structure is addressed in Subsections 13.1.1 through 13.1.3.
13.1-10 Revision 10
VEGP 3&4 - UFSAR 13.1.5 References 201. American Nuclear Society, American National Standard for Selection, Qualification, and Training of Personnel for Nuclear Power Plants, ANSI/ANS-3.1-1993.
202. U.S. Nuclear Regulatory Commission, Generic Letter 86-04, Policy Statement on Engineering Expertise on Shift.
203. American Nuclear Society, American National Standard for Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, N18.7-1976/ANS-3.2.
204. American Nuclear Society, American National Standard for Selection, Qualification, and Training of Personnel for Nuclear Power Plants, ANSI/ANS-3.1-2014.
13.1-11 Revision 10
VEGP 3&4 - UFSAR Table 13.1-201 Not Used 13.1-12 Revision 10
VEGP 3&4 - UFSAR Table 13.1-202 Minimum On-Duty Operations Shift Organization for Two-Unit Plan Units Operating Two Units Two Control Rooms All Units Shutdown 1 SM (SRO) 2 RO 3 NLO One Unit Operating(a) 1 SM (SRO) 1 SRO 3 RO 3 NLO Two Units Operating(a) 1 SM (SRO) 2 SRO 4 RO 4 NLO SM - shift manager RO - Licensed Reactor Operator SRO - Licensed Senior Reactor Operator NLO - non-licensed operator a) Operating modes other than cold shutdown or refueling.
Notes:
- 1. In addition, one Shift Technical Advisor (STA) is assigned per shift during plant operation. A shift manager or another SRO on shift, who meets the qualifications for the combined Senior Reactor Operator/Shift Technical Advisor position, as specified for option 1 of Generic Letter 86-04, (Reference 202) the commissions policy statement on engineering expertise on shift, may also serve as the STA. If this option is used for a shift, then the separate STA position may be eliminated for that shift.
- 2. In addition to the minimum shift organization above, during refueling a licensed senior reactor operator or senior reactor operator limited (fuel handling only) is required to directly supervise any core alteration activity.
- 3. A shift manager/supervisor (SRO licensed for each unit that is fueled), shall be on site at all times when at least one unit is loaded with fuel.
- 4. A radiation protection technician shall be on site at all times when there is fuel in a reactor.
- 5. A chemistry technician shall be on site during plant operation in modes other than cold shutdown or refueling.
- 6. To operate, or supervise the operation of more than one unit, an operator (SRO or RO) must hold an appropriate, current license for each unit.
13.1-13 Revision 10
VEGP 3&4 - UFSAR Figure 13.1-201 Not Used 13.1-14 Revision 10
VEGP 3&4 - UFSAR Figure 13.1-202 Not Used 13.1-15 Revision 10
VEGP 3&4 - UFSAR Figure 13.1-203 Not Used 13.1-16 Revision 10
VEGP 3&4 - UFSAR 13.2 Training This section incorporates NEI 06-13A, Template for an Industry Training Program Description with the following VEGP 3&4 exceptions:
The annual General Employee Requalification training frequency defined in Subsection 1.3.3. The General Employee Requalification training frequency is defined in Subsection 13.2.3.3.
The Engineering Personnel Initial Training defined in Subsection 1.2.9, Fundamentals, which is satisfied by prerequisite entry level education and experience.
Training programs incorporate instructional requirements to qualify personnel to operate and maintain the facility in a safe manner in all modes of operation (Reference 202). The programs are developed and maintained in compliance with the facility license and applicable regulations. The training programs are periodically evaluated and revised to reflect industry experience and to incorporate changes to the facility, procedures, regulations, and quality assurance requirements, and are periodically reviewed by management for effectiveness. These training programs are described in site and/or corporate procedures, as appropriate. Sufficient records are maintained and kept available for NRC inspection to verify adequacy of the programs.
The Training Department provides the required training based on individual employee experience, the intended position, and previous training and education. Training Department personnel may be supplemented by other personnel such as subject matter experts, contract staff, and vendor representatives. Formal instruction may be presented through a combination of classroom lectures, e-learning, assigned reading, simulator training and evaluations, and other delivery techniques.
For reactor operators, senior reactor operators, fuel handlers, fire protection personnel, and positions specified in 10 CFR 50.120 (Reference 13.2-4), programs are developed, established, implemented and maintained using a systems (or systematic) approach to training (SAT) as defined by 10 CFR 55.4 (Reference 13.2-8) and ANSI/ANS-3.1-1993 (Reference 13.2-14), as endorsed by Regulatory Guide 1.8 (Reference 13.2-16) and clarified in Appendix 1A.
Initial and continuing training programs accredited by the National Academy for Nuclear Training (NANT) provide personnel with the skills and knowledge to perform assigned tasks. Accredited training programs include the following:
Non-licensed operator Reactor operator Senior reactor operator Shift manager Shift technical advisor Continuing training for licensed personnel Instrument and control technician Electrical maintenance personnel Mechanical maintenance personnel Chemistry technician Radiological protection technician Engineering personnel The results of reviews of operating experience are incorporated into training and retraining programs in accordance with the provisions of TMI Action Item I.C.5, Appendix 1A. Training programs encompass all phases of plant operation including preoperational testing and low-power operation in accordance with the provisions of TMI Action Item I.G.1 (Reference 13.2-19). Supplemental operator 13.2-1 Revision 6
VEGP 3&4 - UFSAR training requirements during startup testing are described in Subsection 14.2.6.1. Before initial fuel loading, sufficient plant staff will be trained to provide for safe plant operations. Table 13.4-201 provides milestones for training implementation.
Operators involved in the Human Factors Engineering Verification and Validation (V&V) Program receive additional training specific to the task of performing V&V. A systematic approach to training is incorporated in developing this training program along with input from WCAP-14655, Designers Input to the Training of the Human Factors Engineering Verification and Validation Personnel (Reference 201).
Chapter 18, Section 18.10 references WCAP 14655. This document describes input from the designer on the training of the operations personnel who participate as subjects in the human factors engineering (HFE) verification and validation. The WCAP also describes how training insights are passed from the designer.
13.2.1 Licensed Operator Training The Reactor Operator (RO) and Senior Reactor Operator (SRO) training programs, including initial and requalification training, provide the means to train individuals in the knowledge, skills, and abilities needed to perform licensed operator duties. The licensed operator training program includes the requalification program as required by 10 CFR 55.59 (Reference 13.2-13). Collectively, ROs and SROs are referred to as Licensed Operators. Before initial fuel loading, the number of persons trained in preparation for RO and SRO licensing examinations will be sufficient to meet regulatory requirements, with allowances for examination contingencies and without the need for planned overtime.
The site employs a simulator in accordance with 10 CFR 55.46 (Reference 13.2-12) and guidance of Regulatory Guide 1.149 (Reference 13.2-17). This simulator is used for training licensed personnel, and for the administration of the operating test.
13.2.1.1 Licensed Operator Initial Training Program The Licensed Operator Initial Training Program prepares RO and SRO candidates for the NRC license exam. This program is implemented in accordance with administrative procedures.
13.2.1.1.1 Reactor Operator Reactor Operator candidates receive training in the topics listed in 10 CFR 55.41 (Reference 13.2-9).
RO candidates receive plant simulator training to demonstrate understanding and the ability to perform the actions listed in 10 CFR 55.45 (Reference 13.2-11).
13.2.1.1.2 Senior Reactor Operator In addition to the Reactor Operator topics listed in 10 CFR 55.41 (Reference 13.2-9), candidates for the Senior Reactor Operator license receive training in the topics listed in 10 CFR 55.43 (Reference 13.2-10). SRO candidates receive plant simulator training to demonstrate understanding and the ability to perform the actions listed in 10 CFR 55.45 (Reference 13.2-11).
13.2.1.2 Continuing Training for Licensed Personnel Continuing training for licensed personnel consists of regularly scheduled formal instruction, evaluation, and on-the-job training. Training material is developed using the SAT process, and includes Operational Experience (OE). Licensed operators participate in continuing training.
13.2-2 Revision 6
VEGP 3&4 - UFSAR Program content, course schedules and examination schedules comply with 10 CFR 55.59 (Reference 13.2-13). Continuing training for licensed personnel is conducted in accordance with administrative procedures.
13.2.2 Training for Positions Listed in 10 CFR 50.1201 This section addresses training programs for the positions listed in 10 CFR 50.120 (Reference 13.2-4). The systematic approach to training (SAT) process is used to establish and maintain training programs. Course duration and content are determined by the SAT process and by administrative procedure. This program will commence no later than eighteen months prior to initial fuel loading.
13.2.2.1 Non-Licensed Operator (NLO) Initial Training Personnel employed as NLOs receive instruction on operation of plant equipment and components under normal and emergency conditions. This program is a combination of formal instruction and on-the-job training. Training is given in:
Fundamentals of mechanical and electrical components Operation of equipment and systems Operating procedures Surveillance requirements Operation of systems important to plant safety In-plant training includes system walk downs, which emphasize the use of procedures, the proper operation of equipment, and safe operating practices.
13.2.2.2 Shift Manager Initial Training Shift managers have been trained as Senior Reactor Operators and receive additional training that addresses higher-level management skills and behaviors, and provides a broader perspective of plant operations. Initial training includes such topics as:
Application of Operating Experience Problem-solving skills Planning and managing evolutions Maintaining a broad view of plant operations Application of observation skills Operating philosophy Shift team management Application of design bases to plant operations Emergency Plan Transient and Accident Analysis Systematic Approach to Training Work controls 13.2.2.3 Shift Technical Advisor Initial Training Program Shift technical advisors provide engineering expertise on-shift. Training provides them with the skill and knowledge to monitor equipment and system operation, and assess plant conditions during abnormal and emergency events. Initial training for individuals who fill the position of shift technical advisor includes instruction in the following areas:
- 1. 10 CFR 52.78 (Reference 13.2-6) requires that Combined License applicants demonstrate compliance with 10 CFR 50.120.
13.2-3 Revision 6
VEGP 3&4 - UFSAR Responses to accidents and analyses of plant transients Application of engineering principles to protection of the core Mitigation of plant accidents Basis of plant and systems design Reactor theory, thermodynamics, heat transfer, and fluid flow General Operating Procedures, Technical Specifications, and Administrative Controls Operational transient and accident analysis Simulator training, including exercises in the following situations:
Plant or reactor startups to include a range such that reactivity feedback from nuclear heat addition is noticeable and heatup rate is established Plant shutdown Manual control of feedwater during startup or shutdown.
Significant (10 percent) power changes due to manual changes in control rod position.
Accident response training 13.2.2.4 Instrumentation and Control (I&C) Technician Initial Training Initial training for I&C technicians includes instruction in the following areas:
Fundamentals of instrumentation and control Pneumatic systems and equipment Electronics Fundamental systems training I&C and other job related procedures Surveillance requirements Mitigating core damage training commensurate with their responsibilities during accidents that involve severe core damage On-the-job training On-the-job training allows I&C technicians to practice the skills learned in the classroom under the guidance of experienced and qualified I&C personnel.
13.2.2.5 Electrical Maintenance Initial Training Program Initial training for electrical maintenance technicians includes instruction in the following areas:
Print reading Use of electrical tools and test equipment Fundamental systems training Electrical components and equipment Electrical maintenance practices Maintenance procedures On-the-job training On-the-job training allows Electricians to practice the skills learned in the classroom under the guidance of experienced and qualified electrical maintenance personnel.
13.2.2.6 Mechanical Maintenance Initial Training Program Initial training for mechanical maintenance technicians includes instruction in the following areas:
Print reading Use of hand tools, power tools, and measurement devices Fundamental systems training 13.2-4 Revision 6
VEGP 3&4 - UFSAR Mechanical components and equipment Mechanical maintenance practices Maintenance procedures On-the-job training On-the-job training allows Mechanics to practice the skills learned in the classroom under the guidance of experienced and qualified mechanical maintenance personnel.
13.2.2.7 Radiological Protection Technician Initial Training Initial training for radiological protection technicians includes instruction in the following areas:
Principles of radiation Radiation protection and safety Use of survey instruments Use of analytical equipment Radiation Protection procedures Emergency Plan procedures ALARA practices and procedures Fundamental systems training Mitigating core damage training commensurate with their responsibilities during accidents that involve severe core damage On-the-job training provides the trainee opportunities to practice actual operation of radiation protection equipment and use of procedures under the guidance of experienced technicians. Further information on training for radiological protection technicians can be found in Section 12.5.
13.2.2.8 Chemistry Technician Initial Training Initial training for chemistry technicians includes instruction in the following areas:
Chemistry procedures Laboratory practices Conduct of analytical tests Operation of laboratory equipment Fundamental systems training On-the-job training to include actual operation of analytical equipment and the use of procedures Mitigating core damage training commensurate with their responsibilities during accidents that involve severe core damage Power plant chemistry On-the-job training provides the trainee opportunities to practice actual operation of analytical equipment and use of procedures under the guidance of experienced technicians.
13.2.2.9 Engineering Personnel Initial Training Engineering personnel complete orientation training on topics such as those listed below. The topics are chosen to familiarize engineering support personnel with various aspects of nuclear technology in an operating plant environment. Training topics include:
Records management and document control Applicable industrial and nuclear regulations, codes, and standards Procedures and drawings 13.2-5 Revision 6
VEGP 3&4 - UFSAR Applicable programs such as corrective action, configuration management, work control, and the QA program Technical Specifications Plant systems, instrumentation, and components Plant operations Introductory review of accidents Design processes 13.2.2.10 Continuing Training for Personnel Listed in 10 CFR 50.120 Non-licensed plant personnel specified in Subsection 13.2.2 [i.e., personnel listed in 10 CFR 50.120 (Reference 13.2-4)] receive continuing training to maintain qualifications and enhance proficiency.
Continuing training reinforces initial training by reiterating selected portions of the material.
Continuing training also addresses new and modified procedures and plant design changes.
Operating Experience (OE) is included in continuing training, providing personnel with actual examples of good practices and lessons learned. OE topics are selected from Licensee Event Reports, corrective action databases, industry groups, and other sources.
Continuing training material is developed in accordance with the systematic approach to training and is conducted in accordance with administrative procedures.
STA qualifications are maintained by participation in continuing training for licensed personnel.
13.2.3 General Employee Training (GET) Program 13.2.3.1 Plant Access Training As part of the GET program, members of the station staff, contractor workers, and unescorted visitors participate in Plant Access Training, which consists of the following topics, prior to being granted unescorted access to the plant:
Station organization Station facilities and layout Station administration Nuclear plant overview Industrial safety Fire protection Quality assurance and quality control Plant security Emergency planning Radiological orientation Appropriate portions of 10 CFR 26 (Reference 13.2-2)
Appropriate portions of 10 CFR 19 (Reference 13.2-1) 13.2.3.2 Radiation Worker Training Program Personnel whose job duties require them to have unescorted access to radiologically controlled areas of the plant receive instruction in the applicable aspects of radiation protection. Topics include the following:
Sources of radiation Types and measurement of radiation Biological effects 13.2-6 Revision 6
VEGP 3&4 - UFSAR Limits and guidelines, including Reg. Guide 8.13 (Reference 13.2-18)
Concept of As Low As Reasonably Achievable (ALARA)
Radiation dosimetry Contamination Internal exposure Radiation work permits Radiological postings Radiological alarms Radioactive waste Rights and responsibilities Protective clothing 13.2.3.3 General Employee Requalification Training Personnel with unescorted access to the plant participate in requalification training at a frequency of every 48 months nominal, not to exceed 51 months. Requalification training includes those topics in 13.2.3.1 and 13.2.3.2, as applicable to access requirements. Emphasis is placed on significant changes to the plant, plant procedures, government regulations regarding the operation of the plant, and quality assurance requirements. As applicable, training is conducted on industry operating experiences, Licensee Event Reports, and personnel errors.
13.2.4 Selected Other Training Programs This subsection addresses training for positions not specified by 10 CFR 55 (Reference 13.2-7) or 10 CFR 50.120 (Reference 13.2-4).
13.2.4.1 Fire Protection Training Initial fire protection training is completed prior to receipt of fuel at the site. Personnel assigned as fire brigade members receive formal training prior to assuming brigade duties, and regularly scheduled retraining. Fire brigade training complies with NFPA Standard 600 (Reference 13.2-15).
Training appropriate to the assigned work is also provided for the fire protection staff, fire watch personnel, and the general employee. Subsection 9.5.1 includes additional information regarding fire protection training.
13.2.4.2 Emergency Plan Training Program Emergency Plan training meets the requirements of 10 CFR 50 Appendix E Section IV.F (Reference 13.2-5) and the standards of 10 CFR 50.47(b)(15) (Reference 13.2-3). Further details of the Emergency Plan training program can be found in the Emergency Plan, which is a separate document.
13.2.4.3 Physical Security Training Program Training of security personnel is discussed in Section 13.6 and in the Physical Security Plan, which is a separate document.
13.2.4.4 Station Management Training Program Station supervisors receive Fitness for Duty (FFD) supervisory training in accordance with 10 CFR 26.29. The remaining definitions and recommendations in this subsection are taken from ANSI/ANS-3.1-1993 (Reference 13.2-14) as endorsed by Regulatory Guide 1.8 (Reference 13.2-16).
13.2-7 Revision 6
VEGP 3&4 - UFSAR The qualification requirements for managers and middle managers include training or experience in supervision or management. Training for supervisors develops their skills in the following areas:
Leadership Interpersonal communications Management responsibilities and limits Motivation of personnel Problem analysis and decision making Administrative policies and procedures Observation skills Coaching 13.2.5 Training Effectiveness Evaluation Program The program to evaluate the effectiveness of training programs is based on three independent inputs or perspectives: the supervisor of the trainee, the trainee, and an educational content evaluation.
Each of these reviews is discussed below.
13.2.5.1 Supervisory Review for Training Effectiveness The purpose of this review is to monitor the content and effectiveness of training programs as related to the duties and job responsibilities of the trainees. Reviews may be performed by supervisors of employees meeting with appropriate Training personnel, by designated oversight personnel, or by observing subsequent job performance. Observations are discussed to determine topics that may require additional training or subjects that may be removed from the training program.
13.2.5.2 Trainee Review of Training Effectiveness Following selected courses, or training cycles, trainees have the opportunity to provide comments regarding the effectiveness of the instructional methods and content relevancy to their jobs. These comments are used in the evaluation of both instruction and content of the training program.
13.2.5.3 Review for Effectiveness of Instructional Techniques and Materials Training material and instructional aids are assessed for clarity and applicability. Observations of instructors in the teaching environment are conducted by this qualified individual to monitor classroom performance. Full time instructors receive basic indoctrination in instructional techniques as soon as practicable after assuming instructional duties. The educational specialist conducts periodic seminars in instructional techniques, discussing areas where group performance could be improved and recommends innovative techniques observed at this or other power stations.
13.2.6 Combined License Information Item The training programs for plant personnel, including the training program for the operations personnel who participate as subjects in the human factors engineering verification and validation and the scope of licensing examinations, as well as new training requirements, are addressed in Section 13.2.
13.2.7 References 13.2-1. 10 CFR 19, "Notices, Instructions, and Reports to Workers; Inspection and Investigations" 13.2-2. 10 CFR 26, "Fitness for Duty" 13.2-8 Revision 6
VEGP 3&4 - UFSAR 13.2-3. 10 CFR 50.47, "Emergency Plans" 13.2-4. 10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel" 13.2-5. 10 CFR 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities" 13.2-6. 10 CFR 52.78, "Contents of Applications; Training and Qualification of Nuclear Power Plant Personnel" 13.2-7. 10 CFR 55, "Operator's Licenses" 13.2-8. 10 CFR 55.4, "Definitions" 13.2-9. 10 CFR 55.41, "Written Examinations: Operators" 13.2-10. 10 CFR 55.43, "Written Examinations, Senior Operators" 13.2-11. 10 CFR 55.45, "Operating Tests" 13.2-12. 10 CFR 55.46(c), "Plant-Referenced Simulators" 13.2-13. 10 CFR 55.59, "Requalification" 13.2-14. American National Standards Institute, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," ANSI/ANS-3.1-1993 13.2-15. National Fire Protection Association, "Standard on Industrial Fire Brigade," NFPA Standard 600, 2005 Edition 13.2-16. U.S. Nuclear Regulatory Commission, "Qualification and Training of Personnel for Nuclear Power Plants," Regulatory Guide 1.8, Revision 3, May 2000 13.2-17. U.S. Nuclear Regulatory Commission, "Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements," Regulatory Guide 1.149, Revision 4, April 2011 13.2-18. U.S. Nuclear Regulatory Commission, "Instruction Concerning Prenatal Radiation Exposure," Regulatory Guide 8.13, November, 1980.
13.2-19. U.S. Nuclear Regulatory Commission, "Clarification of TMI Action Plan Requirements", NUREG-0737, Revision 3, June 1999 13.2-20. U.S. Nuclear Regulatory Commission, "Policy Statement on Engineering Expertise on Shift", GL 86-04 201. Westinghouse, "Designer's Input to the Training of the Human Factors Engineering Verification and Validation Personnel," WCAP-14655, Revision 1, August 1996.
202. NEI 06-13A, Template for an Industry Training Program Description, Nuclear Energy Institute, Revision 2, March 2009.
13.2-9 Revision 6
VEGP 3&4 - UFSAR 13.2A Cold License Training Plan LICENSED OPERATOR TRAINING PROGRAM PRIOR TO COMPLETION OF THE FIRST REFUELING OUTAGE Prior to operation, plant experience requirements specified in Regulatory Guide 1.8 (Revision 3) and ANSI/ANS 3.1-1993 cannot be met. Additionally, other standard guidance for operator selection, training, and qualification cannot be met.
Cold licensing of operators provides the method for operations personnel to acquire the knowledge and experience required for licensed operator duties during the unique conditions of new plant construction and initial operation.
Persons eligible for the cold license process shall meet the following requirements:
Candidates for a Reactor Operator license shall have a High School Diploma or equivalent as required by R.G. 1.8 Revision 3.
Candidates for a Senior Reactor Operator license shall have at least one of the following qualifications:
- Previously held a Senior Reactor Operator license for an operating nuclear power plant.
- Previously held a Reactor Operator license for an operating nuclear power plant.
- Bachelor's Degree in engineering or science as defined by R.G. 1.8 Revision 3.
- Experience as a licensed operator training instructor with an SRO certification. This experience will be evaluated and approved on a case by case basis by the NRC.
- Two years military experience in a position equivalent to a reactor operator.
The provisions in this section are applicable to each unit of a multiple unit site separately.
The cold licensing process for the selection, training and licensing of Operations personnel for the new nuclear plants adheres to current industry guidance for operating plants with exemptions and alternatives in the following areas.
13.2A.1 Licensed Operator Experience Requirements Prior To Commercial Operation Licensed operator candidates need not satisfy the experience requirements prior to entering a licensed operator training program. Experience and plant evolution requirements that have not been met at the time the licensed operator examination is administered shall be met prior to issuing the individual's NRC operator license. In such a case, the Licensee will notify the NRC when the candidate meets the experience and plant evolution requirements.
The methods listed below provide the licensed operator candidate with meaningful experience on the reactor for which the license is sought. Methods for gaining meaningful experience include completing systematically designed training courses, and participating in practical work assignments such as preoperational testing, procedure development and validation, human factors engineering activities, task analysis verification, or conducting licensed operator classroom or simulator training.
Additionally, for these activities to be considered meaningful, they must be associated with safety significant, defense-in-depth, or other major plant components or systems. All cold licensed operator candidates will:
13.2A-1 Revision 1
VEGP 3&4 - UFSAR Complete a systematically designed site layout course.
Complete a site-specific non-licensed operator on-the-job training program on selected non-licensed operator tasks. The selected non-licensed operator tasks are those tasks that are important to plant operation with regard to nuclear safety, defense-in-depth, or that are risk significant.
Participate in practical work assignments for a minimum of six months that includes preoperational testing, and one or more of the following:
- Procedure development and validation
- Human factors engineering activities
- Task analysis verification
- Licensed operator classroom presentations or simulator training implementation Senior reactor operator cold license candidates will complete a site-specific reactor operator and senior reactor operator training course.
Senior reactor operator cold license candidates without "hot" plant experience will complete a plant operational excellence course that is conducted in a plant simulator or they will observe control room activities at an operating nuclear plant for at least six weeks. The course and the observation activity are designed to familiarize the candidate with the operational interfaces encountered by decision makers in a nuclear plant control room.
Hot plant experience is defined as performance of senior reactor operator duties for at least six months including:
At least 6 weeks of operation above 20 percent power A startup from subcritical to 20 percent power A shutdown from above 20 percent power to cold (less than 212°F) and subcritical Startup preparations following a fueling or refueling outage The startup, shutdown, and startup preparations may have been performed at an operating plant or a plant simulator.
Table 13.2A-201, Comparison of Hot and Cold License Guidance, shows the current experience requirement and the associated cold license experience method. Table 13.2A-202, Illustration of Cold Licensing Plan by Candidate Type, shows education and experience methods for each licensed operator candidate type.
13.2A.2 Crew Experience Requirements during First Year of Operation Each operating crew's cumulative nuclear power plant experience shall be > 6 years; and the crew's cumulative power plant experience shall be > 13 years.
The crew's cumulative nuclear power plant experience is gained by working at nuclear power plants and military nuclear propulsion plants, conducting licensed operator training, participating in new nuclear plant construction and testing, and completing academic degree requirements. The 13.2A-2 Revision 1
VEGP 3&4 - UFSAR cumulative crew nuclear power plant experience is the sum of each individual's experience after applying weighting factors and maximum credit limits in Table 13.2A-201, Cumulative Nuclear Power Plant Operating Crew Experience Equivalencies.
When determining cumulative nuclear power plant experience, all 6 years shall not be attributed from one crew member.
The crew's cumulative power plant experience is the sum of each individual's power plant experience. Power plant experience, for example, is experience gained by working at nuclear power plants, conventional power plants, and military propulsion plants. Cumulative power plant experience does not involve weighting factors or maximum credit limits.
In addition to the experience requirement mentioned above, each operating crew shall be staffed with a senior reactor operator with hot plant experience (previously defined in 1.1, Licensed Operator Experience Requirements Prior to Commercial Operation). If a senior reactor operator with hot plant experience is not available, then a shift advisor may be substituted. The shift advisor will have at least one year of on-shift licensed senior reactor operator experience at a similar type (PWR/BWR) operating plant, and will have completed a training program on the design for which they are advising. While observing crew performance, the shift advisor will make recommendations to the shift manager only, and will not interfere with the licensed responsibilities of the operating crew. The shift advisor will have direct access to plant senior management to resolve issues. Shift advisor duties include, but are not limited to the following:
Monitor procedure adherence Observe the conduct of prejob briefs shift turnover, plant evolutions, non- licensed operator rounds, plant tours, and post job debriefs Monitor overall station risk Weighting factors and maximum credit limits for determining cumulative nuclear power plant operating crew experience are shown in Table 13.2A-203, Cumulative Nuclear Power Plant Operating Crew Experience Equivalencies.
13.2A.3 Conduct of On-the-Job Training (OJT)
Until plant construction is completed, acceptable methods for the conduct of on-the-job training include discussion, simulation, and use of mockup equipment and virtual reality technology.
13.2A.4 Use of Part-Task/Limited Scope Simulators Part-task or limited scope simulators may be used during licensed operator training.
13.2A.5 Licensed Operator Continuing Training Licensed operator continuing training begins within 90 days following the issuance of the first operator license. Continuing training content is systematically determined to maintain operator knowledge of plant operation.
13.2A.6 Cold Licensing Process Applicability and Termination The cold licensing process described in this document may be applied to each unit of a multi-unit site.
13.2A-3 Revision 1
VEGP 3&4 - UFSAR Cold license guidance items 1 through 9 on Table 13.2A-201 will apply to any licensed operator training class started prior to initial fuel load.
Cold license guidance items 3 through 9 on Table 13.2A-201 will apply to any licensed operator training class started after initial fuel load and before completion of the first refueling outage. Items 1 and 2 cold license guidance are no longer allowable after initial fuel load.
The cold licensing process will terminate after completion of the first refueling outage.
As plant systems, components, and structures are completed, and as integrated plant operations begin, the systematic approach to training process will be used to adjust cold license class training methods and settings used to implement the guidance in Table 13.2A-201 items 1 through 9. The purpose is to optimize student learning using actual in-plant training and experience opportunities as they become available.
13.2A.7 Initial Licensed Operator Examination Schedule Administration of licensed operator examinations begins approximately 18 months prior to fuel load.
13.2A.8 References 13.2-201. Nuclear Energy Institute (NEI), "Technical Report on a Template for an Industry Training Program Description," NEI 06-13A 13.2A-4 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-201 Comparison of Hot and Cold License Guidance Current Hot License Guidance Applicable Position References Cold License Guidance ANSI 3.1-1993; 4.4.1 4.4.2 Six months practical work assignments
- 1. Six months on-site at reactor for 4.5.1.
All and which license is sought.
Regulatory Guide 1.8 Rev 3:
Complete a site layout course 2.8 2.10.
NUREG 1021 Rev 9 ES-202 Six months practical work assignments ANSI 3.1-1993:
and 4.5.1. Complete a site layout course and
- 2. One year on-site at the reactor for Regulatory Guide 1.8 Rev 3: Complete a site-specific non-licensed which the license is sought with Reactor operator operator training program for selected six months as a nonlicensed 2.10. nonlicensed operator tasks operator.
NUREG 1021 Rev 9 ES-202 13.2A-5 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-201 Comparison of Hot and Cold License Guidance Current Hot License Guidance Applicable Position References Cold License Guidance
- 3. Pre-requisite experience NUREG 1021 Rev 9 ES-202 Applicable experience requirements shall requirements must be met to All be met prior to NRC license issuance.
enter training program.
Section D.
ANSI 3.1-1993:
Six months practical work assignments
- 4. Three years power plant 4.5.1 experience at least one of which and Reactor operator should have been at the plant for Regulatory Guide 1.8 Rev 3:
which the license is sought. Cumulative operating crew experience 2.10 requirements apply NUREG 1021 Rev 9 ES-202 Complete a site layout course and Regulatory Guide 1.8 Rev 3:
- 5. Reactor operator license Complete a site-specific non-licensed Senior reactor operator actively involved in the operator training program for selected 2.8 performance of licensed duties nonlicensed operator tasks (Non-degreed) for at least one year.
NUREG 1021 Rev 9 ES-202 and Complete a reactor operator and senior reactor operator training course 13.2A-6 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-201 Comparison of Hot and Cold License Guidance Current Hot License Guidance Applicable Position References Cold License Guidance Complete a site layout course and Regulatory Guide 1.8 Rev 3:
Complete a site-specific non-licensed Senior reactor operator
- 6. At least three years of responsible operator training program for selected 1.3 nuclear power plant experience. nonlicensed operator tasks (Degreed) 2.8 and Complete a reactor operator and senior reactor operator training course
- 7. At least six weeks of operation Cumulative Operating Crew Experience above 20% power, and startup requirements apply from subcritical to 20% power, Shift Supervisor ANSI 3.1-1993:
and shutdown from above 20%
and power to cold (less than 212°F)
(Shift Manager) 4.4.1 and subcritical, and startup Complete a Plant Operational Excellence preparations following a fueling Course or plant observation activity or refueling outage.
13.2A-7 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-201 Comparison of Hot and Cold License Guidance Current Hot License Guidance Applicable Position References Cold License Guidance Cumulative Operating Crew Experience requirements apply ANSI 3.1-1993:
- 8. At least six weeks of operation Senior reactor operator and above 20% power.
4.4.2 Complete a Plant Operational Excellence Course or plant observation activity ANSI 3.1-1993 Six months practical work assignments 4.4.1
- 9. Three years power plant and experience and three years Senior reactor operator 4.4.2 nuclear power plant experience Regulatory Guide 1.8 Rev 3:
Cumulative Operating Crew Experience requirements apply 2.8 NUREG 1021 Rev 9 ES-202 13.2A-8 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-202 Illustration of Cold Licensing Plan by Candidate Type Plant Operational Six Months Site Layout NLO Task SRO Excellence Course License Candidate Education RO Training Practical Work Course Training Training or Observation Assignments (1)
Activity Reactor operator High school diploma Yes Yes Yes N/A N/A Yes Senior reactor operator Bachelor of Science or
- degreed manager or equivalent in engineering, Yes Yes Yes Yes Yes Yes degreed nonlicensed engineering technology, or operator or technical staff physical science Senior reactor operator High school diploma Yes Yes Yes Yes Yes (2) Yes
- previous license or military equivalent Senior reactor operator High school diploma Yes Yes Yes Yes Yes Yes
- certified instructor (1): practical work assignments includes activities such as participating in preoperational testing, procedure development and validation, human factors engineering activities, and task analysis verification, or conducting licensed operator classroom or simulator training (2): No, if candidate has hot license experience 13.2A-9 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-203 Cumulative Nuclear Power Plant Operating Crew Experience Equivalencies (1)
Type of Experience Weighting Factor Max Credit Justification Task Analysis for same type plant are essentially the same
- 1. Commercial Nuclear Plant RO/SRO on same type plant 1.00 No Limit (PWR/BWR)
Task Analysis demonstrates that 75% of PWR/BWR tasks are similar
- 2. Commercial Nuclear Plant RO/SRO from different type plant 0.75 No Limit (PWR/BWR)
For these military nuclear propulsion plant watch qualifications,
- 3. Military Nuclear Propulsion Plant Experience (Propulsion approximately 50% of the job tasks are Plant Watch Officer, Engineering Watch Supervisor, Reactor similar 0.5 36 months Operator, Engineering Officer of the Watch, Propulsion Plant Watch Supervisor)
For these (other) watch qualifications, a range of similarities between job tasks (25-75%) exists, so a conservative
- 4. Military Nuclear Propulsion Plant Experience (Other than value of 25% is credited watch qualifications in 3 above such as Machinist Mate, 0.25 36 months Electricians Mate, Engineering Laboratory Technician, or Electronics Technician) 13.2A-10 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-203 Cumulative Nuclear Power Plant Operating Crew Experience Equivalencies (1)
Type of Experience Weighting Factor Max Credit Justification Industry analysis demonstrated that activities completed in a simulator, compare to an operating Control Room, occur in a ratio of approx. 400/1
- 5. Reference Plant Simulator 5.00 12 months Similar to Reference Plant
- 6. Limited Scope Simulator 3.00 9 months Approximately 25% of the tasks during construction testing in preparation for system turnover to operations is similar to an operating facility
- 7. Actual nuclear plant experience during construction 0.25 12 months 75% of tasks during pre- operational testing are similar to an operating
- 8. Actual nuclear plant experience during pre-operational 0.75 12 months facility testing Tasks during initial startup are similar to
- 9. Actual nuclear plant experience during fuel load and startup operating facility 1.00 12 months testing 13.2A-11 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-203 Cumulative Nuclear Power Plant Operating Crew Experience Equivalencies (1)
Type of Experience Weighting Factor Max Credit Justification Theory of ops and specific plant design knowledge is critical to an operators success
- 10. License Classroom training 0.25 9 months Task similarities
- 11. Participation in operator duties at another commercial nuclear 0.75 12 months facility. This includes nonlicensed operator duties Procedure writing, facility operation (water plant and other support facilities,
- 12. Other Nuclear Plant experience 0.25 12 months etc)
Instructors will have participated in a train-the- trainer program that includes simulator, classroom (systems, theory).
- 13. Licensed operator instructor 0.50 12 months College work (in these fields) gives student an understanding of the fundamentals of plant operations
- 14. Bachelors Degree in an Engineering, Science or Technical n/a 24 months field 13.2A-12 Revision 1
VEGP 3&4 - UFSAR Table 13.2A-203 Cumulative Nuclear Power Plant Operating Crew Experience Equivalencies (1)
Type of Experience Weighting Factor Max Credit Justification Student gains knowledge of
- 15. Associates Degree (technical) n/a 6 months fundamentals (1): Weighting factors and max credit values based on those in Industry Evaluation of Operating Shift Experience Requirements By: J.H. Miller Jr. 2/24/1984, and endorsed by Generic Letter number 84-16, Adequacy of On-Shift Operating Experience For Near Term Operating License Applicants, except for shaded rows which are added experience types based on new technology or additional analysis.
13.2A-13 Revision 1
VEGP 3&4 - UFSAR 13.3 Emergency Planning See the Emergency Plan for the locations of the Technical Support Center and the Operations Support Center. See Subsection 1.2.5 for the location of the decontamination facilities. See Section 9.4 for a description of the HVAC systems for the main control room/control support area and the annex building. See Section 18.8 for the high level requirements for the technical support center and the operations support center. See Section 7.5 for identification of plant variables that are provided for interface to the emergency planning areas.
Communication interfaces among the main control room, the technical support center and the emergency planning centers are discussed below and in the Emergency Plan.
Staffing of the emergency operations facility occurs consistent with current operating practice and with revision 1 of NUREG-0654/FEMA-REP-1.
The emergency planning information is submitted to the Nuclear Regulatory Commission as a separate licensing document and is incorporated by reference. (see Table 1.6-201).
Post-72 hour support actions, as discussed in Subsections 1.9.5.4 and 6.3.4, are addressed in Subsections 6.2.2, 8.3, and 9.1.3. Provisions for establishing post-72 hour ventilation for the main control room, instrumentation and control rooms, and dc equipment rooms are established in operating procedures.
The emergency plan describes the plans for coping with emergency situations, including communications interfaces and staffing of the emergency operations facility.
Table 13.4-201 provides milestones for emergency planning implementation.
13.3.1 Combined License Information Item Emergency planning including post-72 hour actions and its communication interface are addressed in Section 13.3.
Activation of the emergency operations facility consistent with current operating practice and NUREG-0654/FEMA-REP-1 is addressed in Section 13.3 and in the Emergency Plan.
13.3-1 Revision 4
VEGP 3&4 - UFSAR 13.4 Operational Programs Operational programs are specific programs that are required by regulations. Table 13.4-201 lists each operational program, the regulatory source for the program, the section of the FSAR in which the operational program is described, and the associated implementation milestone(s).
13.4.1 Combined License Information Item Operational programs are addressed in Section 13.4.
13.4.2 References 201. ASME Boiler and Pressure Vessel Code (B&PVC),Section XI - Rules for Inservice Inspection of Nuclear Power Plant Components.
202. ASME OM Code for the Operation and Maintenance of Nuclear Power Plants.
13.4-1 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 1 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement
- 1. Inservice Inspection Program 10 CFR 50.55a(g) 5.2.4, Prior to Commercial service 10 CFR 50.55a(g),
5.4.2.5, ASME XI IWA-2430(b) 6.6 (Reference 201)
- 2. Inservice Testing Program 10 CFR 50.55a(f); 3.9.6, After generator online on nuclear 10 CFR 50.55a(f),
10 CFR Part 50, 5.2.4 heat(a) ASME OM Code Appendix A (Reference 202)
- 3. Environmental Qualification Program 10 CFR 50.49(a) 3.11 Prior to initial fuel load License Condition
- 4. Preservice Inspection Program 10 CFR 50.55a(g) 5.2.4, Completion prior to initial plant 10 CFR 50.55a(g);
5.4.2.5, start-up ASME XI IWB-2200(a) 6.6 (Reference 201)
- 5. Reactor Vessel Material Surveillance 10 CFR 50.60; 5.3.2.6 Prior to initial criticality License Condition Program 10 CFR 50.61; 10 CFR Part 50, Appendix H
- 6. Preservice Testing Program 10 CFR 50.55a(f) 3.9.6 Prior to initial fuel load License Condition 13.4-2 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 2 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement
- 7. Containment Leakage Rate Testing Program 10 CFR 50.54(o); 6.2.5.1 Prior to initial fuel load License Condition 10 CFR 50, Appendix A (GDC 52);
- 8. Fire Protection Program 10 CFR 50.48 9.5.1.8 Prior to receipt of fuel onsite License Condition Prior to initial fuel load (portions applicable to radioactive material) 10 CFR 30.32 Prior to initial receipt of byproduct, 10 CFR 30.32(a) 10 CFR 40.31 source, or special nuclear 10 CFR 40.31(a) 10 CFR 70.22 materials (excluding Exempt 10 CFR 70.22(a)
Quantities as described in 10 CFR 30.18)
- 9. Process and Effluent Monitoring and Sampling Program:
Radiological Effluent Technical 10 CFR 20.1301 and 11.5 Prior to initial fuel load License Condition Specifications/Standard Radiological 20.1302; Effluent Controls 10 CFR 50.34a; 10 CFR 50.36a; 10 CFR 50, Appendix I, Section II and IV Offsite Dose Calculation Manual Same as above 11.5 Prior to initial fuel load License Condition 13.4-3 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 3 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement Radiological Environmental Monitoring Same as above 11.5 Prior to initial fuel load License Condition Program Process Control Program Same as above 11.4 Prior to initial fuel load License Condition
- 10. Radiation Protection Program 10 CFR 20.1101 12.1 License Condition (including ALARA principle) 10 CFR 20.1406 12.5 10 CFR Part 37 11.4
- Radioactive Source Control 1. Prior to initial receipt of by-(assignment of RP Supervisor) product, source, or special nuclear materials (excluding
- Assignment of RP Supervisor Exempt Quantities as
- Minimization of Contamination described in 10 CFR 30.18)
- Personnel Dosimetry 2. Prior to receipt of fuel onsite
- Radiation Monitoring and Surveys
- Radiation Work Permits
- Assignment of RP Manager 3. Prior to initial fuel load
- Respiratory Protection
- Bioassay 13.4-4 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 4 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement
- Effluents and Environmental Monitoring and Assessment
- Job Coverage
- Radioactive Waste Shipping 4. Prior to first shipment of radioactive waste
- 11. Non Licensed Plant Staff Training Program 10 CFR 50.120 13.2 18 months prior to scheduled date 10 CFR 50.120(b) of initial fuel load (portions applicable to radioactive material) 10 CFR 30.32 Prior to initial receipt of byproduct, 10 CFR 30.32(a) 10 CFR 40.31 source, or special nuclear 10 CFR 40.31(a) 10 CFR 70.22 materials (excluding Exempt 10 CFR 70.22(a)
Quantities as described in 10 CFR 30.18)
- 12. Reactor Operator Training Program 10 CFR 55.13; 13.2 18 months prior to scheduled date License Condition 10 CFR 55.31; of initial fuel load 10 CFR 55.41; 10 CFR 55.43; 10 CFR 55.45
- 13. Reactor Operator Requalification Program 10 CFR 50.34(b); 13.2 Within 3 months after the date the 10 CFR 50.54 (i-1) 10 CFR 50.54(i); Commission makes the finding 10 CFR 55.59 under 10 CFR 52.103(g) 13.4-5 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 5 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement
- 14. Emergency Planning 10 CFR 50.47; 13.3 Full participation exercise 10 CFR Part 50, 10 CFR 50, conducted within 2 years of Appendix E, Section Appendix E scheduled date for initial loading of IV.F.2.a(ii) fuel.*
Onsite exercise conducted within 1 10 CFR Part 50, year before the schedule date for Appendix E, Section initial loading of fuel IV.F.2.a(ii)
Applicants detailed implementing 10 CFR Part 50, procedures for its emergency plan Appendix E,Section V submitted at least 180 days prior to scheduled date for initial loading of fuel
- 15. Security Program:
Physical Protection Program (applicable to 10 CFR 73.1 13.5.2.2.8 Prior to initial receipt of special 10 CFR 73.1(a) protection of special nuclear material prior to 10 CFR 73.67 13.6 nuclear material 10 CFR 73.67 the protected area being declared operational)
Physical Security Program 10 CFR 73.55(b); 13.6 Prior to receipt of fuel onsite 10 CFR 73.55(a)(4) 10 CFR 73.55(c)(3); (protected area) 10 CFR 73.56; 10 CFR 73.57;
- License Amendments 95 and 94 for VEGP Units 3 and 4, respectively, approved a change such that the VEGP 3 and 4 exercises will be partial participation exercises. As permitted by 10 CFR Part 50, Appendix E, Section IV.F.2.a(iii), the full participation exercise requirement will be satisfied by the biennial exercise conducted for VEGP Units 1 and 2. VEGP Unit 4 is exempt from the requirement to perform the partial participation exercise, because the exercise is duplicative of the Unit 3 exercise. (See exemption ML20126G297 granted by the NRC on 07-21-2020).
13.4-6 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 6 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement Safeguards Contingency Program 10 CFR 73.55(c)(5); 13.6 Prior to receipt of fuel onsite 10 CFR 73.55(a)(4) 10 CFR 73.55(k); (protected area) 10 CFR Part 73, Appendix C Training and Qualification Program 10 CFR 73.55(c)(4); 13.6 Prior to receipt of fuel onsite 10 CFR 73.55(a)(4) 10 CFR 73.55(d)(3); (protected area) 10 CFR Part 73, Appendix B
- 16. Quality Assurance Program - Operation 10 CFR 50.54(a); 17.5 COL issuance 10 CFR 50.54(a)(1) 10 CFR Part 50, Appendix A (GDC 1);
- 17. Maintenance Rule 10 CFR 50.65 17.6 Prior to fuel load authorization per 10 CFR 50.65(a)(1) 10 CFR 52.103(g)
- 18. Motor-Operated Valve Testing 10 CFR 50.55a(b)(3)(ii) 3.9.6 Prior to initial fuel load License Condition 13.4-7 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 7 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement
- 19. Initial Test Program 10 CFR 50.34; 14.2 Prior to the first preoperational test License Condition 10 CFR 52.79(a)(28) for the Preoperational Test Program Prior to initial fuel load for the Startup Test Program
- 20. Fitness for Duty (FFD) Program for 10 CFR 26.4(f) 13.7 Prior to initiating 10 CFR Part 26 10 CFR Part 26, Construction (workers and first-line construction activities Subpart K supervisors)
FFD Program for Construction 10 CFR 26.4(e) 13.7 Prior to initiating 10 CFR Part 26 10 CFR Part 26, (management and oversight personnel) construction activities Subparts A - H, N, and O 13.4-8 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 8 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement FFD Program for Security Personnel 10 CFR 26.4(e)(1) 13.7 Prior to initiating 10 CFR Part 26 10 CFR Part 26, construction activities Subparts A - H, N, and O Prior to the earlier of:
10 CFR 26.4(a)(5) or A. Licensees receipt of SNM in 10 CFR Part 26, 26.4(e)(1) the form of fuel assemblies, or Subparts A - I, N, and O B. Establishment of a protected area, or C. The 10 CFR 52.103(g) finding FFD Program for FFD Program personnel 10 CFR 26.4(g) 13.7 Prior to initiating 10 CFR Part 26 10 CFR Part 26, construction activities Subparts A, B, D - H, N, O, and C per licensees discretion FFD Program for persons required to 10 CFR 26.4(c) 13.7 Prior to the conduct of the first full- 10 CFR Part 26, physically report to the Technical Support participation emergency Subparts A - I, N, and O, Center (TSC) or Emergency Operations preparedness exercise under except for §§ 26.205 -
Facility (EOF) 10 CFR Part 50, App. E, Section 209 F.2.a 13.4-9 Revision 6
VEGP 3&4 - UFSAR Table 13.4-201 (Sheet 9 of 9)
Operational Programs Required by NRC Regulations Implementation Program Source Item Program Title (Required by) FSAR Section Milestone Requirement FFD Program for Operation 10 CFR 26.4(a) and (b) 13.7 Prior to the earlier of: 10 CFR Part 26, A. Establishment of a protected Subparts A - I, N, and O, area, or except for individuals B. The 10 CFR 52.103(g) finding listed in § 26.4(b), who are not subject to
§§ 26.205 - 209
- 21. Cyber Security Program 10 CFR 73.54(b); 13.6 Prior to receipt of fuel onsite 10 CFR 73.55(a)(4) 10 CFR 73.55(b)(8); (protected area) 10 CFR 73.55(c)(6)
- 22. SNM Material Control and Accounting 10 CFR 74, Subpart B 13.5.2.2.9 Prior to receipt of special nuclear License Condition Program (§§ 74.11 - 74.19, excl. material
§ 74.17)
- 23. 10 CFR Part 37 Physical Protection Program 10 CFR 37 Subparts A, B, 13.5.2.2.8, Prior to possession of aggregated 10 CFR Part 37 C, D, F 13.5.2.2.10 category 1 or category 2 quantity 13.6, 11.4 of radioactive material (a) Inservice Testing Program will be fully implemented by generator on line on nuclear heat. Appropriate portions of the program are implemented as necessary to support the system operability requirements of the technical specifications.
13.4-10 Revision 6
VEGP 3&4 - UFSAR 13.5 Plant Procedures This section describes the administrative and other procedures that the operating organization (plant staff) uses to conduct the routine operating, abnormal, and emergency activities in a safe manner.
The Quality Assurance Program Description (QAPD), as discussed in Section 17.5, describes procedural document control, record retention, adherence, assignment of responsibilities, and changes.
Procedures are identified in this section by topic, type, or classification in lieu of the specific title and represent general areas of procedural coverage.
Procedures are issued prior to fuel load to allow sufficient time for plant staff familiarization and to develop operator licensing examinations.
The format and content of procedures are controlled by the applicable AP1000 Writers Guideline.
Upon site acceptance of these procedures, the format and content will be controlled per plant specific administrative procedures.
Each procedure is sufficiently detailed for an individual to perform the required function without direct supervision, but does not provide a complete description of the system or plant process. The level of detail contained in the procedure is commensurate with the qualifications of the individual normally performing the function.
Procedures are developed consistent with guidance described in Section 18.9, Procedure Development and with input from the human factors engineering process and evaluations.
References to applicable combined license information are included in Section 1.8. This includes, for example, reference to guidelines on inservice inspection in Chapters 3 and 8, and initial testing in Chapter 14. Operational experience and the resolution of generic issues to be considered in the preparation of plant procedures are outlined in Section 1.9. Procedures to perform rod control system surveillance tests specified in WCAP-13864, Revision 1 (Reference 7), at the beginning of each fuel cycle will be provided as discussed in Subsection 13.5.1. All portions of the safety-related logic circuitry will be adequately covered in the surveillance procedures as described in Generic Letter 96-01 (Reference 8).
The acceptability of the computerized procedure system, and its backup, for application to the AP1000 design will be determined as outlined in Section 18.8.
The development of plant specific refueling plans (Appendix 19E provides input for refueling plans) is as discussed in Subsection 13.5.2.1.
Outage plans are discussed in Subsection 13.5.2.1 and should as a minimum address the following elements:
An outage philosophy, which includes safety as a primary consideration in outage planning and implementation, Separate organizations responsible for scheduling and overseeing the outage; provisions for an independent safety review team that would be assigned to perform final review and grant approval for outage activities, Control procedures, which address both the initial outage plan and all safety-significant changes to schedule, 13.5-1 Revision 5
VEGP 3&4 - UFSAR Provisions to ensure that all activities receive adequate resources, Provisions to ensure defense-in-depth during shutdown and ensure that margins are not reduced; an alternate or backup system must be available if a safety system or a defense-in-depth system is removed from service, and Provisions to ensure that all personnel involved in outage activities are adequately trained; this should include operator simulator training to the extent practicable; other plant personnel, including temporary personnel, should receive training commensurate with the outage tasks they will be performing.
If freeze seals are to be used, plant-specific guidelines will be developed to reduce the potential for loss of RCS boundary and inventory when they are in use.
13.5.1 Administrative Procedures This section describes administrative procedures that provide administrative control over activities that are important to safety for the operation of the facility.
Procedures outline the essential elements of the administrative programs and controls as described in ANSI/ANS 3.2-1988 (Reference 201) and in Section 17.5. These procedures are organized such that the program elements are prescribed in documents normally referred to as administrative procedures. Regulatory and industry guidance for the appropriate format, content and typical activities delineated in written procedures is implemented as appropriate.
Administrative procedures contain adequate programmatic controls to provide effective interface between organizational elements. This includes contractor and owner organizations providing support to the station operating organization.
A Writers Guideline promotes the standardization and application of human factors engineering principles to procedures. The Writers Guideline establishes the process for developing procedures that are complete, accurate, consistent, and easy to understand and follow. The Writers Guideline provides objective criteria so that procedures are consistent in organization, style, and content. The Writers Guideline includes criteria for procedure content and format including the writing of action steps and the specification of acceptable acronym lists and acceptable terms to be used.
Procedure maintenance and control of procedure updates are performed in accordance with the QAPD, as discussed in Section 17.5.
The administrative programs and associated procedures developed in the pre-COL phase are described in Table 13.5-201 (for future designation as historical information).
The plant administrative procedures provide procedural instructions for the following:
Procedures review and approval.
Equipment control procedures - These procedures provide for control of equipment, as necessary, to maintain personnel and reactor safety, and to avoid unauthorized operation of equipment.
Control of maintenance and modifications.
13.5-2 Revision 5
VEGP 3&4 - UFSAR Crane Operation Procedures - Crane operators who operate cranes over fuel pools are qualified and conduct themselves in accordance with ANSI B30.2 (Chapter 2-3), Overhead and Gantry Cranes (Reference 202).
Temporary changes to procedures.
Temporary procedure issuance and control.
Special orders of a temporary or self-canceling nature.
Standing orders to shift personnel including the authority and responsibility of the shift manager, licensed senior reactor operator in the control room, control room operator and shift technical advisor.
Manipulation of controls and assignment of shift personnel to duty stations per the requirements of 10 CFR 50.54 (i), (j), (k), (l), and (m) including delineation of the space designated for the At the Controls area of the control room.
Shift relief and turnover procedures.
Control Room access.
Working hour limitations.
Feedback of design, construction, and applicable important industry and operating experience.
Shift Manager administrative duties.
Verification of correct performance of operational activities.
A vendor interface program that provides vendor information for safety related components is incorporated into plant documentation.
Fire protection program implementation.
A process for implementing the safety/security interface requirements of 10 CFR 73.58.
13.5.2 Operating and Maintenance Procedures 13.5.2.1 Operating and Emergency Operating Procedures The process to manage the development, review, and approval of AP1000 Normal Operating, Abnormal Operating, Emergency Operating, Refueling and Outage Planning, Alarm Response, Administrative, Maintenance, Inspection, Test, and Surveillance Procedures, as well as the procedures which address the operation of post-72 hour equipment, is delineated in APP-GW-GLR-040 (Reference 10). In addition, APP-GW-GLR-040 provided to the NRC the Writers Guidelines for Normal Operating and Two-Column Format Procedures, APP-GW-GJP-100 and APP-GW-GJP-200, respectively.
13.5-3 Revision 5
VEGP 3&4 - UFSAR Upon site review and acceptance of the procedures delineated above, these procedures become site specific. The development, review, and approval of these site specific procedures will be controlled per plant specific processes/procedures.
13.5.2.2 Maintenance and Other Operating Procedures The QAPD, as described in Section 17.5, provides guidance for procedural adherence. Regulatory and industry guidance for the appropriate format, content, and typical activities delineated in written procedures is implemented as appropriate.
13.5.2.2.1 Plant Radiation Protection Procedures The plant radiation protection program is contained in procedures. Procedures are developed and implemented for such things as: maintaining personnel exposures, plant contamination levels, and plant effluents ALARA; monitoring both external and internal exposures of workers, considering industry-accepted techniques; routine radiation surveys; environmental monitoring in the vicinity of the plant; radiation monitoring of maintenance and special work activities; evaluation of radiation protection implications of proposed modifications; establishing quality assurance requirements applicable to the radiation protection program; and maintaining radiation exposure records of workers and others.
13.5.2.2.2 Emergency Preparedness Procedures A discussion of emergency preparedness procedures can be found in the Emergency Plan.
13.5.2.2.3 Instrument Calibration and Test Procedures The QAPD, as discussed in Section 17.5, provides a description of procedural requirements for instrumentation calibration and testing.
13.5.2.2.4 Chemistry Procedures Procedures provided for chemical and radiochemical control activities include the nature and frequency of sampling and analyses; instructions for maintaining fluid quality within prescribed limits; the use of control and diagnostic parameters; and limitations on concentrations of agents that could cause corrosive attack, foul heat transfer surfaces or become sources of radiation hazards due to activation.
Procedures are also provided for the control, treatment, and management of radioactive wastes and control of radioactive calibration sources.
13.5.2.2.5 Radioactive Waste Management Procedures Procedures for the operation of the radwaste processing systems provide for the control, treatment, and management of on-site radioactive wastes. Procedural controls are in place for radiological releases.
Operating procedures to limit the total cumulative radioactive inventory of unpackaged wastes located in the radwaste building will be developed, implemented, and maintained prior to initial fuel load. These operating procedures are based on monitoring and controlling the radioactive inventory of unpackaged wastes so that the Regulatory Guide 1.143 unmitigated radiological release criteria of 5 rem to site personnel, and the 10 CFR Part 20.1301 dose limits of 100 millirem at the protected area boundary for members of the public, are not exceeded. These administrative controls limit the radionuclide inventory to less than the A2 limit specified in Appendix A to 10 CFR Part 71 in the 13.5-4 Revision 5
VEGP 3&4 - UFSAR radwaste building. Further details regarding administrative controls of unpackaged radioactive waste located in the radwaste building are described in Section 11.2.
13.5.2.2.6 Maintenance, Inspection, Surveillance, and Modification Procedures 13.5.2.2.6.1 Maintenance Procedures Maintenance procedures describe maintenance planning and preparation activities. Maintenance procedures are developed considering the potential impact on the safety of the plant, license limits, availability of equipment required to be operable, and possible safety consequences of concurrent or sequential maintenance, testing or operating activities.
Maintenance procedures contain sufficient detail to permit the maintenance work to be performed correctly and safely. Procedures include provisions for conducting and recording results of required tests and inspections, if not performed and documented under separate test and inspection procedures. References are made to vendor manuals, plant procedures, drawings, and other sources as applicable.
Instructions are included, or referenced, for returning the equipment to its normal operating status.
Testing is commensurate with the maintenance that has been performed. Testing may be included in the maintenance procedure or be covered in a separate procedure.
The preventive maintenance program, including preventive and predictive procedures, as appropriate for structures, systems and components, prescribes the frequency and type of maintenance to be performed. An initial program based on service conditions, experience with comparable equipment and vendor recommendations is developed prior to fuel loading. The program is revised and updated as experience is gained with the equipment. To facilitate this, equipment history files are created and kept current. The files are organized to provide complete and easily retrievable equipment history.
13.5.2.2.6.2 Inspection Procedures The QAPD, as discussed in Section 17.5, provides a description of procedural requirements for inspections.
13.5.2.2.6.3 Modification Procedures Plant modifications and changes to setpoints are developed in accordance with approved procedures. These procedures control necessary activities associated with the modifications such that they are carried out in a planned, controlled, and orderly manner. For each modification, design documents such as drawings, equipment and material specifications, and appropriate design analyses are developed or the as-built design documents are utilized. Separate reviews are conducted by individuals knowledgeable in both technical and QA requirements to verify the adequacy of the design effort.
Proposed modification(s) which involve a license amendment or a change to Technical Specifications are processed as proposed license amendment request(s).
Plant procedures impacted by modifications are changed prior to declaring the system operable to reflect revised plant conditions; and cognizant personnel who are responsible for operating and maintaining the modified equipment are adequately trained.
13.5-5 Revision 5
VEGP 3&4 - UFSAR 13.5.2.2.7 Material Control Procedures The QAPD, as discussed in Section 17.5, provides a description of procedural requirements for material control.
13.5.2.2.8 Security Procedures A discussion of security procedures is provided in the Security Plan.
The Special Nuclear Material (SNM) Physical Protection Program describes the 10 CFR Part 70 required protection program in effect for the period of time during which new fuel as SNM is received and stored in a controlled access area (CAA), in accordance with the requirements of 10 CFR 73.67.
Fleet procedures address the applicable 10 CFR 73.67 requirements in the event that unirradiated new fuel assemblies or components are returned to the supplying fuel manufacturer(s) facility.
A 10 CFR Part 37 Physical Protection Program addresses the applicable 10 CFR Part 37 requirements to provide physical protection for an aggregated category 1 or category 2 quantity of radioactive material.
13.5.2.2.9 Special Nuclear Material (SNM) Material Control and Accounting Procedures A material control and accounting system consisting of special nuclear material accounting procedures is utilized to delineate the requirements, responsibilities, and methods of special nuclear material control from the time special nuclear material is received until it is shipped from the plant.
These procedures provide detailed steps for SNM shipping and receiving, inventory, accounting, and preparing records and reports.
13.5.2.2.10 10 CFR Part 37 Physical Protection Program Procedures A 10 CFR Part 37 Physical Protection Program consisting of procedures is utilized to delineate the requirements, responsibilities, and methods associated with the physical protection of an aggregated category 1 or category 2 quantity of radioactive material. These procedures provide the detailed steps for receipt, use, storage, transport and preparation of records and reports.
13.5.3 Combined License Information Item The plant procedures are addressed in APP-GW-GLR-040 (Reference 10), and the applicable changes are incorporated into the UFSAR, and in Section 13.5.
13.5.4 References
- 1. Not used.
- 2. Not used.
- 3. Not used.
- 4. Not used.
- 5. Not used.
- 6. Not used.
13.5-6 Revision 5
- 7. WCAP-13864, Rod Control System Evaluation Program, Revision 1-A, November 1994.
- 8. USNRC Generic Letter 96-01, Testing of Safety-Related Logic Circuits, January 10, 1996.
- 9. Not used.
- 10. APP-GW-GLR-040, Plant Operations Maintenance and Surveillance Procedures, Westinghouse Electric Company LLC.
201. ANSI/ANS 3.2-1988, Administrative Control and Quality Assurance for the Operational Phase of Nuclear Power Plants.
202. ANSI B30.2 (Chapter 2-3), Overhead and Gantry Cranes.
13.5-7 Revision 5
VEGP 3&4 - UFSAR Table 13.5-201 Pre-COL Phase Administrative Programs and Procedures (This table is included for future designation as historical information.)
- Design/Construction Quality Assurance Program
- Reporting of Defects and Noncompliance, 10 CFR Part 21 Program
- Design Reliability Assurance Program 13.5-8 Revision 5
VEGP 3&4 - UFSAR 13.6 Security The Security Plan consists of the Physical Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan. The Security Plan was submitted to the Nuclear Regulatory Commission as a separate licensing document in order to fulfill the requirements for 10 CFR 52.79(a)(35) and 10 CFR 52.79(a)(36) and is incorporated by reference (see Table 1.6-201). The Security Plan meets the requirements of 10 CFR 73.55 and is maintained in accordance with the requirements of 10 CFR 52.98(c). The plan is designated as Safeguards Information and is withheld from public disclosure pursuant to 10 CFR 73.21.
The footprint area for the two new Westinghouse AP1000 units is west of, and adjacent to, the existing two units on the VEGP site. A Protected Area encompasses the new and existing units and provides a physical boundary that serves to control access to the entire VEGP site in accordance with 10 CFR 73.55. Additional elements of the physical protection program that meet the requirements of 10 CFR 73.55 include the screening of plant personnel upon entrance to the Protected Area for contraband or explosives; the detection and assessment of intrusion into the Protected Area; the operation, maintenance, and testing of security equipment; the installation of station features that deter or delay potential intrudes; the placement and protection of security personnel for response to a land-based threat against the site; the placement of a vehicle barrier system around the site to protect against a vehicle bomb threat; and liaison with local law enforcement personnel. These and other elements of the physical protection program are described within the Physical Security Plan.
Additionally, the AP1000 Interim Compensatory Measures Report (Reference 2), the AP1000 Enhancement Report (Reference 3), and the AP1000 Safeguards Assessment Report (Reference 4) were submitted to the Nuclear Regulatory Commission as separate licensing documents to establish the design basis of the AP1000 Standard Plant Security Systems. Each document is designated as Safeguards information and is withheld from public disclosure pursuant to 10 CFR 73.21. Subsequently, applicable information from References 2, 3, and 4 were incorporated into the Security Plan, which therefore constitutes the current licensing basis.
The characteristics of the VEGP Units 3 and 4 footprint are such that implementation of the applicable requirements of 10 CFR 73.55, Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage, and NRC Regulatory Guide 4.7, General Site Suitability Criteria for Nuclear Power Stations, as well as the post-9/11 NRC Orders, are met.
The VEGP site is sufficiently large to provide adequate distances between structures and the location of the security boundaries to allow interdiction and neutralization of threats.
The VEGP site is bordered on the east by the Savannah River. For the existing units, SNC has an approved security program in place in compliance with the post-9/11 NRC Orders and in accordance with NEI 03-12, Template for Security Plan and Training and Qualification Plan. In the event that new units are added to the VEGP site, those program requirements would continue to be met and would be extended to include the new units.
The final design of the VEGP Units 3 and 4 power block and supporting buildings utilizes design features as appropriate to assure that the existing security spatial distances outlined in the regulations above, as well as the Design Basis Threat requirements, are adequate. In accordance with 10 CFR 100.21(f), SNC maintains site characteristics adequate to implement security plans and measures.
There are no security hazards in the vicinity of the VEGP site. The VEGP site is located in Burke County in the State of Georgia. Written letters of agreement with the Burke County Sheriff and the Georgia State Patrol are maintained to establish for law enforcement response in the event of a VEGP security (or radiological) emergency. Examples are identified in Reference 201; 13.6-1 Revision 3
VEGP 3&4 - UFSAR Reference 202. Burke County has mutual aid agreements with surrounding counties in place, if necessary, to provide support during VEGP emergencies.
A 10 CFR Part 37 Physical Protection Program is established, implemented, and maintained in order to protect an aggregated category 1 or category 2 quantity of radioactive material from theft or diversion per 10 CFR Part 37 requirements.
The Cyber Security Plan was submitted to the Nuclear Regulatory Commission as a separate licensing document to fulfill the requirements contained in 10 CFR 52.79(a)(36) and 10 CFR 73.54 and is incorporated by reference (see Table 1.6-201). The Cyber Security Plan is maintained in accordance with the requirements of 10 CFR 52.98. The Plan is designated as Security-Related Information and is withheld from public disclosure pursuant to 10 CFR 2.390.
Table 13.4-201 provides milestones for security program, 10 CFR Part 37 physical protection program, and cyber security program implementation.
13.6.1 Combined License Information Item Information for the Security Plan is addressed in Section 13.6.
Information for the Physical Security ITAAC is addressed in Subsection 14.3.2.3.2.
Information for the cyber security program is addressed in Section 13.6.
13.6.2 ESP COL Action Items The specific access control measures to address the existing rail spur are addressed in Part 8, Physical Security Plan, Section 11.3.
13.6.3 References
- 1. Not used.
- 2. APP-GW-GLR-067, AP1000 Interim Compensatory Measures Report, Westinghouse Electric Company LLC.
- 3. APP-GW-GLR-062, AP1000 Enhancement Report, Westinghouse Electric Company LLC.
- 4. APP-GW-GLR-066, AP1000 Safeguards Assessment Report, Westinghouse Electric Company LLC.
201. (Burke County Sheriff 2004) Burke County Sheriffs Office letter of agreement for law enforcement support for VEGP security and radiological emergencies, dated April 15, 2004.
202. (Georgia State Patrol 2004) Georgia State Patrol letter of agreement for law enforcement support for VEGP security and radiological emergencies, dated April 22, 2004.
13.6-2 Revision 3
VEGP 3&4 - UFSAR 13.7 Fitness for Duty The Fitness for Duty Program (FFD) is implemented and maintained in multiple and progressive phases dependent on the activities, duties, or access afforded to certain individuals at the construction site. In general, two different FFD programs will be implemented: a construction FFD program and an operations FFD program. The construction and operations phase programs are illustrated in Table 13.4-201.
The construction FFD program is consistent with NEI 06-06 (Reference 201), as endorsed by NRC Regulatory Guide 5.84, Revision 0, as amended by the exceptions documented in Appendix 1A, and the pre-access provisions for reinstatement described in 10 CFR 26.65. NEI 06-06 applies to persons constructing or directing the construction of safety- and security-related structures, systems, or components performed onsite where the new reactor will be installed and operated. Management and oversight personnel, as further described in NEI 06-06, and security personnel prior to the receipt of special nuclear material in the form of fuel assemblies (with certain exceptions) will be subject to the operations FFD program that meets the requirements of 10 CFR Part 26, Subparts A through H, N, and O. At the establishment of a protected area, all persons who are granted unescorted access will meet the requirements of an operations FFD program. The NRC endorsed NEI 06-06 (Reference 201) and the FFD program subject to Subpart K was revised to reflect the changes.
The following site-specific information is provided:
The construction site is defined in the Physical Security Plan, Appendix E and is under the control of SNC. The 10 CFR Part 26 requirements are implemented for the construction site area based on the descriptions provided in Table 13.4-201.
Construction Workers & First Line Supervisors are covered by the SNC FFD Program (elements Subpart K) except when escorted by a construction escort.
Control of construction visitors and construction escorts is described in the Appendix 1A entry for Regulatory Guide 5.84.
SNC employees and personnel contracted for construction management and oversight are covered by the SNC FFD Program (elements Subpart A - H, N and O).
Security personnel are covered by the SNC FFD Program (elements Subpart A - H, N and O). This coverage is applicable from the start of construction activities to the earlier of (1) the receipt of SNM in the form of fuel assemblies, (2) the establishment of a protected area, or (3) the 10 CFR 52.103(g) finding.
FFD Program personnel are covered by the SNC FFD Program (elements Subpart A, B, D -
H, N, O, and C per licensees discretion).
Security personnel protecting fuel assemblies, or the established protected area, or the facility following the 10 CFR 52.103(g) finding are covered by the SNC FFD Program (elements Subpart A - I, N and O).
Personnel required to physically report to the Technical Support Center (TSC) or Emergency Operations Facility (EOF) when that requirement is in effect are covered by the SNC FFD Program (elements Subpart A - I, N, and O, except for §§ 26.205 - 209).
The operations phase FFD program is consistent with the applicable subparts of 10 CFR Part 26 (elements Subpart A - I, N, and O, except for individuals listed in §26.4(b), who are not subject to
§§ 26.205 - 209.
13.7-1 Revision 6
VEGP 3&4 - UFSAR 13.7.1 References 201. Nuclear Energy Institute Fitness for Duty Program Guidance for New Nuclear Power Plant Construction Sites, NEI 06-06, Revision 6, April 2013 (ML13093A342).
13.7-2 Revision 6
VEGP 3&4 - UFSAR Appendix 13AA Construction-Related Organization The information in this appendix is included for future designation as historical information.
Paragraphs are numbered to be subsequent to Subsection 13.1.1.1 13AA.1.1.1.1 Design and Construction Activities The Westinghouse Electric Company (WEC) was originally selected to design, fabricate, deliver, and install the AP1000 advanced light water pressurized water reactors (PWR) and to provide technical direction for installation and startup of this equipment. However, during construction, Southern Nuclear Company (SNC) made a transition and is now resonsible for installation and startup of this equipment. Subsection 1.4.1 provides detailed information regarding WEC past experience in design, development, and manufacturing of nuclear power facilities. Operating experience from design, construction, and operation of earlier WEC PWRs is applied in the design, construction, and operation of the AP1000 as described in numerous locations throughout (e.g., Subsections 3.6.4.4, 3.9.4.2.1, 4.2.3.1.3).
Westinghouse provides plant construction support and additional design activities for selected site specific portions of the plant.
Other design and construction activities are generally contracted to qualified suppliers of such services. Implementation or delegation of design and construction responsibilities is described in the subsections below. Quality assurance aspects of these activities are described in Chapter 17.
13AA.1.1.1.1.1 Principal Site-Related Engineering Work The principal site engineering activities accomplished towards the construction and operation of the plant are:
- a. Meteorology Information concerning local (site) meteorological parameters is developed and applied by station and contract personnel to assess the impact of the station on local meteorological conditions. An onsite meteorological measurements program is employed by station personnel to produce data for the purpose of making atmospheric dispersion estimates for postulated accidental and expected routine airborne releases of effluents. A maintenance program is established for surveillance, calibration, and repair of instruments. More information regarding the study and meteorological program is found in Section 2.3.
- b. Geology Information relating to site and regional geotechnical conditions is developed and evaluated by utility and contract personnel to determine if geologic conditions could present a challenge to the safety of the plant. Items of interest include geologic structure, seismicity, geological history, and ground water conditions. During construction, foundations within the power block area are mapped or visually inspected and photographed. Section 2.5 provides details of these investigations.
- c. Seismology Information relating to seismological conditions is developed and evaluated by utility and contract personnel to determine if the site location and area surrounding the site is appropriate from a safety standpoint for the construction and operation of a nuclear power plant. Information regarding tectonics, seismicity, correlation of seismicity with tectonic structure, characterization of seismic 13AA-1 Revision 7
VEGP 3&4 - UFSAR sources, and ground motion are assessed to estimate the potential for strong earthquake ground motions or surface deformation at the site. Section 2.5 provides details of these investigations.
- d. Hydrology Information relating to hydrological conditions at the plant site and the surrounding area is developed and evaluated by utility and contract personnel. The study includes hydrologic characteristics of streams, lakes, shore regions, the regional and local groundwater environments, and existing or proposed water control structures that could influence flood control and plant safety. Section 2.4 includes more detailed information regarding this subject.
- e. Demography Information relating to local and surrounding area population distribution is developed and evaluated by utility and contract personnel. The data is used to determine if requirements are met for establishment of exclusion area, low population zone, and population center distance. Section 2.1 includes more detailed information regarding population around the plant site.
- f. Environmental Effects Monitoring programs are developed to enable the collection of data necessary to determine possible impact on the environment due to construction, startup, and operational activities and to establish a baseline from which to evaluate future environmental monitoring.
13AA.1.1.1.1.2 Design of Plant and Ancillary Systems Responsibility for design and construction of systems outside the power block such as circulating water, service water, switchyard, and secondary fire protection systems are delegated to qualified contractors.
13AA.1.1.1.1.3 Review and Approval of Plant Design Features Design engineering review and approval is performed in accordance with the reactor technology vendor QA program and Section 17.1. The reactor technology vendor is responsible for design control of the power block. Verification is performed by competent individuals or groups other than those who performed the original design. Design issues arising during construction are addressed and implemented with notification and communication of changes to the engineering director for review. As systems are tested and approved for turnover and operation, control of design is turned over to plant staff. The Engineering Director, along with functional managers and staff, assumes responsibility for review and approval of modifications, additions, or deletions in plant design features, as well as control of design documentation, in accordance with the Operational QA Program. Design control becomes the responsibility of the Engineering Director prior to loading fuel.
During construction, startup, and operation, changes to human-system interfaces of control room design are approved using a human factors engineering evaluation addressed within Chapter 18.
See Organization Charts, Figure 13.1-202, and the Nuclear Development Quality Assurance Manual for reporting relationships.
13AA.1.1.1.1.4 Site Layout with Respect to Environmental Effects and Security Provisions Site layout was considered when determining the expected environmental effects from construction.
The Physical Security Plan is designed with provisions that meet the applicable NRC regulations.
Site layout was considered when developing the Security Plan.
13AA-2 Revision 7
VEGP 3&4 - UFSAR 13AA.1.1.1.1.5 Development of Safety Analysis Reports Information regarding the development of the Final Safety Analysis Report is found in Chapter 1.
13AA.1.1.1.1.6 Review and Approval of Material and Component Specifications Safety-related material and component specifications of structures, systems, and components designed by the reactor technology vendor are reviewed and approved in accordance with the reactor technology vendor quality assurance program and Section 17.1. Review and approval of items not designed by the reactor vendor are controlled for review and approval by Section 17.5 and the Quality Assurance Program Description.
13AA.1.1.1.1.7 Procurement of Materials and Equipment Procurement of materials and equipment (modules, engineered components, ASME III materials, and highly engineered materials) during the construction phase is the responsibility of the reactor technology vendor and constructor. Procurement of all other materials and equipment during the construction phase is the responsibility of SNC. The process is controlled by the construction QA program of Westinghouse. Oversight of the inspection and receipt of materials and equipment process is the responsibility of the manager in charge of quality assurance.
13AA.1.1.1.1.8 Management and Review of Construction Activities Overall management and responsibility for construction activities is assigned to the Executive Vice President of Vogtle 3&4 who directs the organizations responsible for construction oversight.
Monitoring and review of construction activities by utility personnel is a continuous process at the plant site. SNC performance is monitored to provide objective data to utility management in order to identify problems early and develop proper corrective actions and solutions. Monitoring of construction activities verifies that contractors are in compliance with contractual obligations for quality, schedule, and cost. Monitoring and review of construction activities is divided functionally across the various disciplines of the utility construction staff, e.g. electrical, mechanical, instrument and control, etc., and tracked by schedule based on system and major plant components/areas. For construction oversight positions and functional area descriptions reporting to the Executive Vice President of Vogtle 3&4 during the construction phase, see Section 17.5 and the Nuclear Development Quality Assurance Manual.
After each system is turned over to plant staff, the construction organization relinquishes responsibility for that system. At that time they will be responsible for completion of construction activities as directed by plant staff and available to provide support for preoperational and start-up testing as necessary.
Periodic assessment involving both the construction and operations organizations continues to identify SSCs that could reasonably be expected to be impacted by scheduled construction activities.
Appropriate administrative and managerial controls are then established as necessary. Specific hazards, impacted SSCs, and managerial and administrative controls are reviewed on a recurring basis and, if necessary, controls are revised/developed and implemented and maintained current as work progresses on site. For example, prior to construction activities that involve the use of large construction equipment such as cranes, managerial and administrative controls are in place to prevent adverse impacts on any operating unit(s) overhead power lines, switchyard, security boundary, etc., by providing the necessary restrictions on the use of large construction equipment.
13AA-3 Revision 7
VEGP 3&4 - UFSAR 13AA.1.1.1.2 Preoperational Activities The Executive Vice President of Vogtle 3&4 is responsible for the activities required to transition the unit from the construction phase to the operational phase. These activities include turnover of systems from construction, preoperational testing, schedule management, procedure development for tests, fuel load, integrated startup testing, and turnover of systems to plant staff.
During construction and initial testing, SNC is responsible for equipment maintenance. To ensure equipment operability and reliability, plant maintenance programs such as preventive and corrective maintenance are developed prior to system turnover and become effective as each system is turned over to the plant staff with approved administrative procedures under the direction of the managers in charge of maintenance, engineering, and work control. For positions and functional area descriptions, see the Nuclear Development Quality Assurance Manual.
13AA.1.1.1.2.1 Development of Human Factors Engineering Design Objectives and Design Phase Review of Proposed Control Room Layouts Human factors engineering (HFE) design objectives are initially developed by the reactor technology vendor in accordance with Chapter 18. As a collaborative team, personnel from the reactor technology vendor design staff and personnel, including licensed operators, engineers, and instrumentation and control technicians from owner and other organizations in the nuclear industry, assess the design of the control room and man-machine interfaces to attain safe and efficient operation of the plant. See Section 18.2 for additional details of HFE program management.
Modifications to the certified design of the control room or man-machine interface described in the Design Control Document are reviewed per engineering and site support procedures, as required by Section 18.2, to evaluate the impact to plant safety. The engineering director is responsible for the human factors engineering (HFE) design process and for the design commitment to HFE during construction and throughout the life of the plant as noted in Subsection 13.1.1.2.1. The HFE program is established in accordance with the description and commitments in Chapter 18.
13AA.1.1.1.2.2 Preoperational and Startup Testing Preoperational and startup testing is conducted by the Initial Test Program (ITP) organization. The ITP organization, functions, and responsibilities are addressed in Section 14.2. Sufficient numbers of personnel are assigned to perform preoperational and startup testing to facilitate safe and efficient implementation of the testing program. Plant-specific training provides instruction on the administrative controls of the test program. To improve operational experience, operations and technical staff are used as support in conducting the test program and in reviewing test results.
13AA.1.1.1.2.3 Development and Implementation of Staff Recruiting and Training Programs Staffing plans are developed based on operating plant experience with input from the reactor technology vendor for safe operation of the plant as determined by HFE. See Section 18.6. These plans are developed under the direction and guidance of the Executive Vice President of Vogtle 3&4.
Staffing plans are completed and necessary manager level positions are filled prior to start of preoperational testing. Personnel selected to be licensed reactor operators and senior reactor operators along with other staff necessary to support the safe operation of the plant are hired with sufficient time available to complete appropriate training programs, and become qualified, and licensed, if required, prior to fuel being loaded in the reactor vessel. See Figure 13AA-202 for an estimated timeline of hiring requirements for operator and technical staff relative to fuel load.
13AA-4 Revision 7
VEGP 3&4 - UFSAR Because of the dynamic nature of the staffing plans and changes that occur over time, it is expected that specific numbers of personnel on site will change; however, Table 13.1-201 includes the initial estimated number of staff for selected positions and the estimated number of additional positions required for a second unit. Recruiting of personnel to fill positions is the shared responsibility of the manager in charge of human resources and the various heads of departments. The training program is described in Section 13.2.
13AA-5 Revision 7
VEGP 3&4 - UFSAR Figure 13AA-201 Deleted 13AA-6 Revision 7
VEGP 3&4 - UFSAR Q-23 Q-22 Q-21 Q-20 Q-19 Q-18 Q-17 Q-16 Q-15 Q-14 Q-13 Q-12 Q-11 Q-10 Q-9 Q-8 Q-7 Q-6 Q-5 Q-4 Q-3 Q-2 Q-1 Q-1 Q-2 Q-3 Q-4 Q-5 Fuel Load Note: Durations, starts, and Hire Operator Candidates for Licensing finishes are initial estimates relative to the Fuel Load milestone.
Operator Licensing Training - 1st Class Operator Licensing Training - 2nd Class Operator Licensing Training - 3rd Class Operator Licensing Training - 4th Class Operator Licensing Training - 5th Class Operator Licensing Training - 6th Class Operator Licensing Training - 7th Class Spin Up and NRC Operator License Exams Limited Scope Simulator Installation and Testing ANS 3.5 Simulator Upgrade and Testing Hire Technical Support Staff and Non-licensed Operators Train Non-licensed Operators, Technical, and Support Staff Figure 13AA-202 Hiring Schedule for Plant Staff 13AA-7 Revision 7