ML23317A355
| ML23317A355 | |
| Person / Time | |
|---|---|
| Site: | 99902056 |
| Issue date: | 11/13/2023 |
| From: | NRC |
| To: | NRC/NRR/DNRL |
| References | |
| Download: ML23317A355 (5) | |
Text
From:
Allen Fetter Sent:
Monday, November 13, 2023 3:12 PM To:
Schiele, Raymond Joseph; Montague, Kelvin Jevon; kecasey@tva.gov Cc:
Sean Gallagher; Greg Cranston; ClinchRiver-CPSafDocsPEm Resource; Jesse Seymour
Subject:
Initial Observations PSAR 13.1, 13.2 & 13.5_Readiness Assessment_Phase 1.pdf Attachments:
Initial Observations PSAR 13.1, 13.2 & 13.5_Readiness Assessment_Phase 1.pdf Good Afternoon, Attached are initial NRC staff observations on draft PSAR Sections 13.1, 13.2 and 13.5 that staff viewed in TVAs electronic reading room as part of Phase 1 of the Readiness Assessment of the draft Clinch River CP application.
After all six phases of the Readiness Assessment are completed, NRC will transmit, via letter, a compilation of all final Readiness Observations on the Clinch River CP PSAR chapters and sections. The nomenclature initial is being used to account for potential TVA updates to the PSAR before the end of the Readiness Assessment.
If TVA makes any future updates to the draft PSAR chapters and sections for follow up observations by NRC staff, please contact me, Greg Cranston or Sean Gallagher.
- Thanks, Allen H. Fetter, Senior Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of New and Renewed Licenses New Reactor Licensing and Infrastructure Branch Washington, D.C.
301-415-8556 (Office) 301-385-5342 (Mobile)
Hearing Identifier:
ClinchRiver_CPSafDocs_Public Email Number:
4 Mail Envelope Properties (MW4PR09MB939670D01373EB2733713D9685B3A)
Subject:
Initial Observations PSAR 13.1, 13.2 & 13.5_Readiness Assessment_Phase 1.pdf Sent Date:
11/13/2023 3:12:05 PM Received Date:
11/13/2023 3:12:07 PM From:
Allen Fetter Created By:
Allen.Fetter@nrc.gov Recipients:
"Sean Gallagher" <Sean.Gallagher@nrc.gov>
Tracking Status: None "Greg Cranston" <Gregory.Cranston@nrc.gov>
Tracking Status: None "ClinchRiver-CPSafDocsPEm Resource" <ClinchRiver-CPSafDocsPEm.Resource@nrc.gov>
Tracking Status: None "Jesse Seymour" <Jesse.Seymour@nrc.gov>
Tracking Status: None "Schiele, Raymond Joseph" <rjschiele@tva.gov>
Tracking Status: None "Montague, Kelvin Jevon" <kjmontague@tva.gov>
Tracking Status: None "kecasey@tva.gov" <kecasey@tva.gov>
Tracking Status: None Post Office:
MW4PR09MB9396.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1084 11/13/2023 3:12:07 PM Initial Observations PSAR 13.1, 13.2 & 13.5_Readiness Assessment_Phase 1.pdf 75006 Options Priority:
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Readiness Assessment - Phase 1 Initial Readiness Assessment Observationsi on draft PSAR Section 13.1, Organizational Structure; 13.2, Training; and 13.5, Plant Procedures Clinch River CP application November 13, 2023 Basis for Observation/Comment Readiness Assessment Observations PSAR Section 13.1, Organizational Structure 50.34(a)(6) - A preliminary plan for the applicant's organization, training of personnel, and conduct of operations. 50.34(a)(9) - The technical qualifications of the applicant to engage in the proposed activities in accordance with the regulations in this chapter. 1)
NUREG-0800 Section 13.1.1, Management and Technical Support Organization (Revision 6), Criterion III.1(a)(vii),
states As demonstrated on organizational charts, in descriptions of organizational functions and responsibilities, and in descriptions of position functions and responsibilities, the applicanthas described how the organization will carry out its responsibilities to control major contractors and has committed to consider safety first, with due consideration of risk insights, in design and construction of the facility and during the transition from construction through testing to operation 2) NUREG-0800 Section 13.1.1, Criterion III.1(b), states The corporate officer responsible for nuclear activities should be identified and a commitment made by the applicant that this individual will have no ancillary responsibilities that might detract attention from nuclear safety matters. 3)
NUREG-0800 Section 13.1.1, Criterion III.1(d), states Management and organizational responsibilities are clearly defined to address HFE considerations. 4)
NUREG-0800 Section 13.1.1, Criterion III.1(e), states The organizational units involved in the design and construction of the project communicate among each other in a searchable and retrievable documented form, and management clearly and unambiguously controls the project and its documentation. Clear management control and effective lines of authority and communication exist among the organizational units involved in managing, operating, and providing technical support for the facility.
There is clear management control of the organizational units involved in operating and providing technical support for the facility, and there are clear lines of authority between management and these groups and effective communication among them and with management.
- 1) While organizational experience is discussed in the PSAR, there is no discussion of the role and use of risk insights in risk-informed evaluations and decision-making within the project. 2) While several corporate officer positions are described in the PSAR (e.g.,
President/CEO, Senior Vice President, New Nuclear Projects, etc.), it is, there is no associated commitment made regarding a specific corporate officer with responsibility for nuclear activities that will have no ancillary responsibilities that might detract attention from nuclear safety matters. 3) Discussion of the HFE component of the organization, including its management and organizational interface, is not discussed in PSAR chapter 13.
Additionally, the staff expect that the PSAR will address the application of the state-of-the-art human factors principles to the control room design in a manner consistent with 50.34(f)(2)(iii),
including what standards will be applied during the design process to achieved that. 4) The PSAR does not describe how the communications between the organizational units involved in the design and construction of the project will be captured in a searchable and retrievable documented format.
Readiness Assessment - Phase 1 Basis for Observation/Comment Readiness Assessment Observations PSAR Section 13.2, Training 50.34(a)(6) - A preliminary plan for the applicant's organization, training of personnel, and conduct of operations. 50.34(a)(9) - The technical qualifications of the applicant to engage in the proposed activities in accordance with the regulations in this chapter. 1)
NUREG-0800 Section 13.2.1, Reactor Operator Requalification Program and Training (Revision 4),
Criterion III.1(a) states The applicant has committed to RG 1.8, "Qualification and Training of Personnel for Nuclear Power Plants. RG 1.8 endorses American National Standards Institute /American Nuclear Society (ANSI/ANS)-3.1-1993, Selection, Qualification, and Training of Personnel for Nuclear Power Plants. Criterion III.1(e)(1) states For nuclear power plant license applicants, the technical submittal shall demonstrate that a licensed operator training program will be established implemented, and maintained by 18 months prior to fuel load by means of the following The applicant has described how the licensed operator training program conforms to RG 1.8, Qualification and Training of Personnel for Nuclear Power Plants Criterion III.1(e)(2) states For nuclear power plant license applicants, the technical submittal shall demonstrate that a licensed operator training program will be established implemented, and maintained by 18 months prior to fuel load by means of the following The subjects covered in the licensed operator training program should include, as a minimum, the subjects in 10 CFR 55.31, How to Apply, 10 CFR 55.41, Written examination: Operators; 10 CFR 55.43, Written examination: Senior operators; 10 CFR 55.45, Operating tests; and RG 1.8 for reactor operators and senior reactor operators, as appropriate 2) NUREG-0800 Section 13.2.1, Reactor Operator Requalification Program and Training (Revision 4), Criterion III.1(b) states that The applicant has committed to NEI 06-13A, Template for an Industry Training Program Description.
NEI 06-13A describes a training program that the staff has found as a way to describe an acceptable licensed operator training program. Criterion III.1(e)(3) states For nuclear power plant license applicants, the technical submittal shall demonstrate that a licensed operator training program will be established, implemented, and maintained by 18 months prior to fuel load by means of the following the applicant has described how the licensed operator training program conforms to NEI 06-13A, Template for an Industry Training Program Description.
- 1) The NRC staff note that the current revision of RG 1.8 no longer addresses licensed operator qualifications and training. Specifically, RG 1.8 revision 4 notes that the NRC removed the applicability of 10 CFR Part 55 from this revision of RG 1.8 so that NRC guidance for operator license qualifications will be located solely in NUREG-1021, which references the [National Academy for Nuclear Training (NANT)] qualification standards.
The PSAR should describe how this is area will be addressed in light of this change. The NANT qualification standards and, more broadly, training program accreditation by the Institute of Nuclear Power Operations (INPO),
represent one method that the NRC recognizes for meeting these qualification and training program criteria; facility license applicants may propose other approaches as well. Facility licensees seeking to use alternatives to National Nuclear Accrediting Board (NNAB) accreditation should submit their initial licensing training program to the NRC operator licensing program office for review and acceptance as a Commission-approved training program. 2) The NRC staff note that the draft PSAR does not reference NEI 06-13A or any other approach for cold-plant operator licensing.
Readiness Assessment - Phase 1 NUREG-0800 Section 13.2.2, Non-Licensed Plant Staff Training (Revision 4), Criterion III.1(b) states that The applicant has committed to NEI 06-13A, Template for an Industry Training Program Description. NEI 06-13A describes a training program that the staff has found as a way to describe an acceptable non-licensed plant staff training program. Criterion III.1(c)(ii) states that For nuclear power plant applicants, the technical submittal shall demonstrate that the non-licensed plant staff training program will be established, implemented, and maintained by 18 months prior to fuel load by means of the following the applicant has described how the non-licensed plant staff programs conform to NEI 06-13A.
PSAR Section 13.5, Plant Procedures 50.34(a)(6) - A preliminary plan for the applicant's organization, training of personnel, and conduct of operations. 50.34(a)(9) - The technical qualifications of the applicant to engage in the proposed activities in accordance with the regulations in this chapter. 1)
NUREG-0800 Section 13.5.1.1, Administrative Procedures - General (Revision 2), Criterion III.1(g) states Administrative procedures to provide feedback on operation, design, and construction of the facility should comply with 10 CFR 50.34(f)(3)(i) and with NUREG-0737, Clarification of TMI Action Plan Requirements, Task Action Plan Item I.C.5. 50.34(f)(3)(i) states Provide administrative procedures for evaluating operating, design and construction experience and for ensuring that applicable important industry experiences will be provided in a timely manner to those designing and constructing the plant. 2) NUREG-0800 Section 13.5.1.1, Criterion III.1(h),
states Administrative controls governing crane operations must include a requirement that the operators of cranes over fuel pools be qualified and conduct themselves in accordance with the guidelines of ANSI-B30.2-1976, "Overhead and Gantry Cranes." 3) NUREG-0800 Section 13.5.1.1, Criterion III.1(i), states A vendor interface program should ensure that vendor information for safety related components is incorporated into plant documentation as described in Generic Letter (GL) 90-03, Relaxation of Staff Position in Generic Letter 83-28.
- 1) The PSAR does not describe how administrative procedures are provided for evaluating operating, design and construction experience to ensure that applicable important industry experiences will be provided in a timely manner to those designing and constructing the plant. 2) The PSAR does not discuss whether the administrative controls governing crane operations will include a requirement that the operators of cranes over fuel pools be qualified and conduct themselves in accordance with the guidelines of ANSI-B30.2-1976, "Overhead and Gantry Cranes." 3)
The PSAR does not discuss whether a vendor interface program will ensure that vendor information for safety related components is incorporated into plant documentation as described in Generic Letter (GL) 90-03, Relaxation of Staff Position in Generic Letter 83-28.
i Input provided by from NRR/DRO/IOLB