ML070400006

Preliminary Work Product to Support Feb 13, 2007 Public Meeting - Rg 1.206 Sections 13.1 and 13.2

ML070400006
Person / Time
Issue date:	02/08/2007
From:	William Reckley NRC/NRO/DNRL/NGIF
To:
References
DG-1145, RG-1.206
Download: ML070400006 (11)

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Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & TrainingWordPerfect Document Compare SummaryOriginal document: C:\NRO RG1-206\DG1145 for compare\C-I-13-1 and 2.wpdRevised document:

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Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & TrainingC.I.13. Conduct of OperationsThe regulatory requirements for the content of an application for a combined license pursuant to10 CFR Part 52, Subpart C, are provided in §52.79.

Section 52.79(b) specifies further that theapplication must contain the technically relevant information required of applicants for an operatinglicense by 10 CFR 50.34. The requirements contained in 10 CFR 50.34 specify that each applicationshall include a final safety analysis report (FSAR) that provides information concerning facility design,construction, and operation. This chapter provides guidance on the information necessary in a combinedlicense application for the NRC to perform its review of proposed facility design, construction, andoperation in accordance with the regulatory requirements above.This chapter of the FSAR should provide information relating to the preparations and plans fordesign, construction, and operation of the plant. Its purpose is to provide adequate assurance that thecombined license applicant will establish and maintain a staff of adequate size and technical competenceand that operating plans to be followed by the licensee are adequate to protect public health and safety.

\ lApplicants have the choice of including information which is site specific or different from a generic lFSAR section 13.1 in this section or an appendix to this section.\

l13.1 Organizational Structure of Applicant13.1.1 Management and Technical Support OrganizationA combined license applicant should provide a description

[in this section ]

of the corporate orhome office organization, its functions and responsibilities, and the number and the qualifications ofpersonnel and should be directed to activities that include facility design, design review, design approval,construction management, testing, and operation of the plant.\ This information can be contained in this lsection or an appendix to this section.\

lThe descriptions of the design and constr uction and preoperational responsibilities shouldinclude the following:(1)how these responsibilities are assigned by the headquarters staff and implemented within theorganizational units(2)the responsible working- or performance-level organizational unit (3)the estimated number of persons to be assigned to each unit with responsibility for the project(4)the general educational and experience requirements for identified positions or classes of positions[(5)education and experience required for management and supervisory positions

](5)for identified positions or classes of positions that have functional responsibilities other than forthe COL application, the expected proportion of time assigned to the other activities(6)early plans for providing technical support for the operation of the facilityThe following specific information should be included.

13.1.1.1 Design, Construction and Operating ResponsibilitiesThe combined license applicant's past experience in the design, construction, and operation of Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Trainingnuclear power plants and past experience in activities of similar scope and complexity should bedescribed. The applicant's management, engineering, and technical support organizations should also bedescribed. The description should include organizational charts for the current headquarters andengineering structure and planned m odifications and additions to those organizations to reflect the addedfunctional responsibilities with the nuclear plant:(1)Design and Construction ResponsibilitiesThe extent and assignment of these activities are generally contractual in nature and determinedby the combined license applicant. The following aspects of the implementation or delegation ofdesign and construction responsibilities should be described (quality assurance aspects should be described in Chapter 17):(a)principal site-related engineering studies such as meteorology, geology, seismology,hydrology, demography, and environmental effects(b)design of plant and ancillary systems, including fire protection systems(c)review and approval of plant design features, including human factors engineering (HFE) considerations(d)site layout with respect to environmental effects and security provisions(e)development of safety analysis reports (f)review and approval of material and component specifications[(2)Pre-Operational Responsibilities A description of the proposed plans for the development and implementation of staff trainingprograms should be included and should be substantially accomplished before preoperationaltesting begins.

]([3]\2\)Technical Support for Operations lTechnical services and backup support for the operating organization should be available beforethe preoperational and startup testing program begins and continue throughout the life of theplant. The following are special capabilities that should be included:(a)nuclear, mechanical, structural, electrical, thermal-hydraulic, metallurgy and materials,and instrumentation and controls engineering(b)plant chemistry (c)health physics (d)fueling and refueling operations support (e)maintenance support (f)operations support (g)quality assurance (h)training (i)safety review Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Training(j)fire protection(k)emergency coordination (l)outside contractual assistance 13.1.1.2 Organizational ArrangementIn the FSAR, the description should include organization charts reflecting the currentheadquarters and engineering structure and any planned modifications a nd additions to reflect the added functional responsibilities (described in 13.1.1.1) associated with the addition of the nuclear plant to theapplicant's power generation capacity. The description should show how these responsibilities aredelegated and assigned or expected to be assigned to each of the working or performance level organizational units identified to implement these responsibilities.In the FSAR, the description should include organizational charts reflecting the current corporatestructure and the specific working or performance level organizational units that will provide technicalsupport for operation (Section 13.1.1.1, item 3). If these functions are to be provided from outside the corporate structure, the contractual arrangements should be described.The information submitted should include a description of the activity (including its scope), anorganizational description, with chart lines of authority and responsibility for the project, the number ofpersons assigned to the project, and qualification requirements for principal management positions forthe project. For NSSS and AE organizations with extensive experience, a detailed description of this experience may be provided in lieu of the details of their organization as evidence of technical capability. However, the applicant should describe how this experience will be applied to the project.The FSAR should provide the following information:(1)organizational charts of the applicant's corporate level management and technical supportorganizations(2)the relationship of the nuclear-oriented part of the organization to the rest of the corporateorganization(3)a description of the provisions for technical support for operationsFor new, multi-unit plant sites, the combined license applicant should describe the organizationalarrangement and functions to meet the needs of the multiple units. The applicant should include in thisdiscussion the extent to which the organizational arrangement and functions are shared between oramong the units addressed in the application and describe the organizational arrangement and functionaldivisions or controls that have been established to preserve integrity between individual units and/orprograms.For plant sites with existing, operating nuclear units, the applicant should include in thisdiscussion the extent to which the organizational arrangement and functions are shared between the newand existing units. In addition, the applicant s hould include a discussion of the organizationalarrangement and functional divisions or controls that have been established to preserve integrity betweenthe new and existing, operational units and/or programs.

Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Training 13.1.1.3 QualificationsThe FSAR should describe general qualification requirements in terms of educationalbackground and experience requirements for positions or classes of positions identified in 13.1.1.2. For identified positions or classes of positions that have functional responsibilities for other than the identified application, the expected proportion of time assigned to the other activities should be described.The FSAR should identify qualification requireme nts for headquarters staff personnel, whichshould be described in terms of educational background and experience requirements, for each identifiedposition or class of positions providing headquarters technical support for operations. In addition, theFSAR should include qualification requirements for individuals assigned to fulfill responsibilitiesidentified in item 3 of Section 13.1.1.1, including the job position that corresponds most closely to thatidentified as "engineer in charge."The FSAR should (1) give the approximate numbers of and describe educational and experiencerequirements for, each identified position or class of positions providing t echnical support for plant operations, and (2) include specific educational and experience requirements for individuals holding themanagement and supervisory positions in organizational units providing support in the areas identified below:(1)nuclear, mechanical, structural, electrical, thermal-hydraulic, metallurgical, materials, andinstrumentation and controls engineering(2)plant chemistry (3)health physics (4)fueling and refueling operations support (5)maintenance support (6)operations support (7)quality assurance (addressed in 17.5)

(8)training (9)safety review (10)fire protection (11)emergency coordination (12)outside contractual assistance13.1.2 Operating OrganizationThis section of the FSAR should describe the structure, functions, and responsibilities of theonsite organization established to operate and maintain the plant. It is recognized that during the earlystages of plant design and construction, many details of the plant organization and staffing have not beenfinalized and may be modified following issuance of a combined license, during construction orpreparation for plant operation. The organizational information provided as part of a combined licenseapplication should include the following elements:

Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Training(1)the applicant's commitment to meet the guidelines of Regulatory Guide 1.33 for its operatingorganization(2)the applicant's commitment to meet the guidelines of Regulatory Guide 1.33 for onsite review and rules of practice (addressed in 17.5)(3)the applicant's commitment to meet the applicable requirements for a Fire Protection Program(4)the applicant's commitment to meet the guidelines of Regulatory Guide 1.8 for its operatingorganization(5)the applicant's commitment to be consistent with one of the options in the Commission's PolicyStatement on Engineering Expertise on Shift(6)the applicant's commitment to meet TMI Action Plan items I.A.1.1 and I.A.1.3 of NUREG-0737 for shift [technical advisor and shift ]

staffing(7)a schedule, relative to fuel loading for each unit, for filling all positions(8)the applicant's commitment to meet the applicable requirements for a physical protectionprogram As applicable, the applicant should provide evid ence that the initial personnel selections conformto the commitments made in the application.

13.1.2.1 Plant OrganizationProvide an organization chart showing the title of each position, the minimum number of personsto be assigned to duplicate positions (e.g., technicians, shift operators, repair technicians), the number ofoperating shift crews, and the positions for which r eactor operator and senior reactor operator licensesare required. For multi-unit stations, the organization chart (or additional charts) should clearly reflectplanned changes and additions as new units are added to the station. The schedule, relative to the fuelloading date for each unit, for filling all positions should be provided.

13.1.2.2 Plant Personnel Responsibilities and AuthoritiesIn addition, the applicant should provide the following organizational information:(1)The functions, responsibilities, and authorities of the following plant positions or theirequivalents:(a)plant managers(b)operations supervisors (c)operating shift crew supervisors (d)shift technical advisors (e)licensed operators (f)non-licensed operators (g)technical supervisors (h)radiation protection supervisors (i)instrumentation and controls maintenance supervisors (j)equipment maintenance supervisors Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Training(k)fire protection supervisors(l)quality assurance supervisors (when part of the plant staff) (addressed in 17.5)For each position, where applicable, required interfaces with offsite personnel or positions identified in Section 13.1.1 should be described.

Such interfaces include defined lines ofreporting responsibilities (e.g., from the plant manager to the immediate supervisor), lines ofauthority, and communication channels.(2)The line of succession of authority and responsibility for overall station operation in the event ofunexpected contingencies of a temporary nature, and the delegation of authority that may begranted to operations supervisors and to shift supervisors, including the authority to issuestanding or special orders.(3)If the station contains, or there are plans that it contain, power generating facilities other than those specified in the application and including non-nuclear units, this section should alsodescribe interfaces with the organizations operating the other facilities. The description shouldinclude any proposed sharing of personnel between the units, a description of their duties, andthe proportion of their time they will routinely be assigned to non-nuclear units.

13.1.2.3 Operating Shift CrewsThe position titles, applicable operator licensing requirements for each, and the minimumnumbers of personnel planned for each shift should be described for all combinations of units proposedto be at the station in either operating or cold shutdown mode. Also describe shift crew staffing plansunique to refueling operations. In addition, the proposed means of assigning shift responsibility forimplementing the radiation protection and fire protection programs on a round-the-clock basis should be described.13.1.3 Qualifications of Nuclear Plant Personnel 13.1.3.1 Qualification RequirementsThis section of the FSAR should describe the education, training, and experience requirements(qualification requirements) established for each management, operating, technical, and maintenanceposition category in the operating organization described in Section 13.1.2. This includes personnel whowill do the preoperational and startup tests. Regulatory Guide 1.8, "Qualification and Training ofPersonnel for Nuclear Power Plants," contains guid ance on selection and training of personnel. TheFSAR should specifically indicate a commitment to meet the regulatory position stated in this guide orprovide an acceptable alternative. Where a clear correlation cannot be made between the proposed plantstaff positions and those referenced by Regulatory Guide 1.8, each position on the plant staff should belisted along with the corresponding position referenced by Regulatory Guide 1.8, or with a detailed

description of the proposed qua lifications for that position.

13.1.3.2 Qualifications of Plant PersonnelAs applicable, the qualification requirements of the initial appointees to (or incumbents of) plantpositions should be presented for key plant managerial and supervisory personnel through shiftsupervisory level. The qualification requirements should be identified by position, title and, as aminimum, formal education, training, a nd experience (including NRC licensing).

Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Training 13.1.4 References(1)10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities."(2)Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants."(3)Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)."(4)Regulatory Guide 1.68, "Initial Test Programs for Water-Cooled Nuclear Power Plants."(5)Regulatory Guide 1.114, "Guidance to Operators at the Controls a nd to Senior Operators in theControl Room of a Nuclear Power Unit."(6)NUREG-0694, "TMI-Related Requirements for New Operating Licenses."(7)NUREG-0711, "Human Factors Engineering Program Review Model."(8)NUREG-0718, "Licensing Requirements for Pending Applications for Construction Permits andManufacturing License."(9)NUREG-0737, "Clarification of TMI Action Plan Requirements."(10)NUREG/CR-6838, "Technical Basis for Regulatory Guidance for Assessing Exemption Requestsfrom the Nuclear Power Plant Licensed Operator Staffing Requirement s Specified in 10 CFR50.54(m)."(11)Generic Letter 86-04, "Policy Statement on Engineering Expertise on Shift," February 1986.

13.2TrainingThis section of the FSAR should c ontain the description and schedule of the training program for reactor operators and senior reactor operators. The licensed operator training program also includes therequalification programs as required in 10 CFR 50.54(i)(I-1) and 55.59.\ Within three (3) months after leither the issuance of an operating license or the date the Commission makes the finding under l§52.103(g) of this chapter for a combined operating license, as applicable, the licensee shall have in leffect an operator requalification program. \

lIn addition, this section of the FSAR should cont ain the description and schedule of the trainingprogram for nonlicensed plant staff.13.2.1 Plant Staff Training ProgramThe FSAR should provide a description of the proposed training program in nuclear technologyand other subjects important to safety for the entire plant staff. Regulatory Guide 1.8, "Qualification andTraining of Personnel for Nuclear Power Plants," provides guidance on an acceptable basis for relatingtraining programs to plant staff positions. The FSAR should indicate whether this guidance will befollowed. If such guidance will not be followed, specific alternative methods that will be used should bedescribed along with a justification for their use. A list of Commission regulations, guides, and reportspertaining to training of license d and unlicensed nuclear power plant personnel is provided in Section 13.2.[3]\2\.l13.2.1.1 Program DescriptionThe program description should include the following information with respect to the formaltraining program in nuclear technology and other subjects important to safety (related technical training)for all plant management and supervisory personne l, Licensed Senior Oper ator (SRO) and Licensed Operator (RO) candidates, technicians, and general employees.

Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Training[The training program descriptions for li censed plant staff should contain the followingelements:]

\l13.2.1.1.1 Licensed Plant Staff Training Program (To be verified during construction) l\l(1)A description of the proposed training program[, including the subject matter of each initiallicensed operator training course, the duration of the course (approximate number of weekspersonnel are in full-time attendance), the organization teaching the course or supervisinginstruction, and the titles of the positions for which the course is given. The programdescriptions should include a chart showing the proposed schedule for licensing personnel priorto criticality. The schedule should be relative to expected fuel loading and should display thepreoperational test period. The submittal should contain a commitment to conduct formallicensed operator, on-the-job training, and simulator training before initial fuel load. Theprogram should distinguish between formal instruction, on-the-job, and simulator training, beforeand after the initial fuel loading and it should include provisions for training on modifications toplant systems or functions.Contingency plans for additional training (i.e., requalification and/or retraining) for individualsto be licensed prior to criticality should be described in the event fuel loading is subsequentlydelayed until after the date indicated in the FSAR]

.(2)The subjects covered in the training programs should include, as a minimum, the subjects in10 CFR 55.31 (how to apply), 55.41 (written examination: operators), 55.43 (written examination: senior operators), 55.45 (operating tests), and Regulatory Guide 1.8 for reactor operators and senior reactor operators as appropriate. The training program should also includeprovisions for upgrading reactor operator licenses and for licensing senior reactor operators whohave not been licensed as reactor operators per Regulatory Guide 1.8. The training should bebased on use of the systems approach to training (SAT) as defined in 10 CFR 55.4.(3)The licensed operator requalification program should include the content described in 10 CFR55.59 or should be based on the use of a systems approach to training (SAT) as defined in 10 CFR 55.4\ to be verified during construction\

.l(4)The applicant should describe its program for providing simulator capability for its plants asdescribed in 10 CFR 55.31 (how to apply), 55.45 (operating tests), 55.46 (simulation facilities),50.34(f)(2)(I), and Regulatory Guide 1.149, and how its program meets these requirements and regulatory guidance. In addition, the applicant should describe how it will ensure that itsproposed simulator will correctly model its control room.(5)The applicant should describe the means for evaluating training program effectiveness for alllicensed operators, in accordance with a systems approach to training.(6)COL applicants should provide implementation milestones for the reactor operator trainingprogram[.The training program description for nonlicen sed plant staff should include the followingelements:]\ to be verified during construction.

ll13.2.1.1.2 Nonlicensed Plant Staff Training Program l\l(1)A detailed description of the training programs for nonlicensed personnel and the applicant'scommitment to meet the guidelines of Regulatory Guide 1.8 for nonlicensed personnel.(2)A detailed description of the training programs developed using a systems approach to training,as defined in 10 CFR 55.4, for all positions covered by 10 CFR 50.120[, and a commitment tomeet the requirements of 10 CFR 50.120 at least 18 months before fuel load]

.

Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Training (3)[For programs not covered under 10 CFR 50.120, the subject matter of each course, including asyllabus or equivalent course description, the duration of the course (approximate number ofweeks personnel are in full-time attendance), the organization teaching the course or supervisinginstruction, and the titles of the positions for which the course is given. ]The program is verifiedto distinguish between formal instruction and on-the-job training, before and after fuel loading. The description should include contingency plans for additional training (i.e., requalificationand/or retraining) in the event that fuel loading is significantly delayed until after the dateindicated in the FSAR. The program should also include provisions for training on modificationsto plant systems or functions.The COL applicant should identify any difference in the training programs for individuals basedon the extent of previous nuclear power plant experience. The structuring of training based onexperience groups should appropriately address the following categories of personnel experience:(a)individuals with no previous experience (b)individuals who have had nuclear experience at facilities not subject to licensing(c)individuals who have had experience at comparable nuclear facilities The program should include a commitment to conduct an onsite formal training program and on-the-job training such that sufficient plant staff to ensure safe plant operations will be qualifiedbefore the initial fuel loading.(4)A detailed description of the fire protection training and retraining for the initial plant staff andreplacement personnel and a commitment to conduct an initial fire protection training program. The program should address:(a)the training planned for each member of the fire brigade (b)the type and frequency of periodic firefighting drills, including during construction(c)the training provided for all remaining staff members, including personnel responsiblefor maintenance and inspection of fire protection equipment(d)the indoctrination and training provided for people temporarily assigned onsite dutiesduring shutdown and maintenance outages, particularly persons allowed unescorted access(e)the training provided for the fire protection staff members. The program description isverified to include the course of instruction, the number of hours of each course, and theorganization conducting the training.(f)provisions for indoctrination of construction personnel, as necessary(g)a commitment to verify that initial fire protection training will be completed prior to receipt of fuel at the site.(5)The applicant's plans for conducting a position task analysis to verify that the tasks performed by persons in each position are defined, and that the training, in conjunction with education andexperience, is identified to provide assurance that the tasks can be effectively carried out.(6)For all plant personnel identified in FSAR Section 13.1.2, the proposed subject matter of each course[, the duration of the course (approximate number of weeks personnel are in full-timeattendance), the organization teaching the course or supervising instruction,]

and the titles of thepositions for which the course is given.(7)A description of the provisions for training employees and nonemployees whose assistance may Preliminary Work Product to Support February 13, 2007 Public MeetingRG 1.206 Sections 13.1 and 13.2 - Organization & Trainingbe needed in a radiological emergency, as required by 10 CFR 50, Appendix E, Section II.F.(8)A description of the training program for the individual(s) responsible for the formulation andassurance of the implementation of the fire protection program.(9)The proposed means for evaluating the training program effectiveness for all employees \andlpersonnel covered by 10 CFR 50.120 \in accordance with the systems approach to training.

l(10)A description of the training program for employees and non-employees to assure the effectiveimplementation of the physical protection program.

13.2.1.2 Coordination with Preoperational Tests and Fuel LoadingThe FSAR should include a chart that shows the sche dule of each part of the training program foreach functional group of employees in the organizati on in relation to the schedule for preoperationaltesting, expected fuel loading, expected time for examinations prior to plant criticality for licensedoperators following plant criticality. In addition, the applicant should include contingency plans forindividuals applying for licenses prior to criticality in the event fuel loading is substantially delayed fromthe date indicated in the FSAR.13.2.2 Applicable NRC DocumentsThe NRC regulations, regulatory guides, and reports listed below provide information pertainingto the training of nuclear power plant personnel. The FSAR should indicate the extent to which theapplicable portions of the guidance provided will be used and should justify any exceptions. Materialdiscussed elsewhere in the FSAR may be referenced.(1)10 CFR Part 19, "Notices, Instructions and Reports to Workers: Inspections and Investigations."(2)10 CFR Part 26, "Fitness for Duty Programs."

(3)10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities."(4)10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production andUtilization Facilities."(5)10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and Combined Licenses forNuclear Power Plants."(6)10 CFR Part 55, "Operators' Licenses."

(7)Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants."(8)Regulatory Guide 1.149, "Nuclear Power Plant Simulation Facilities for Use in OperatorTraining and Licensing Examinations."(9)NUREG-0711, "Human Factors Engineering Program Review Model."(10)NUREG-1021, "Operator Licensing Examination Standards for Power Reactors."(11)NUREG-1220, "Training Review Criteria and Procedures."(12)Generic Letter 86-04, "Policy Statement on Engineering Expertise on Shift," February 1986.[(13)Regulatory Guide 1.134, "Medical Evaluation of Licensed Personnel at Nuclear Power Plants."

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