Archive-Name: gov/us/fed/nara/fed-register/1999/jun/03/64FR29922/part1
Posting-number: Volume 64, Issue 106, Page 29922, Part 1

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[Federal Register: June 3, 1999 (Volume 64, Number 106)]
[Notices]               
[Page 29922-29931]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr03jn99-111]

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NUCLEAR REGULATORY COMMISSION


Proposed Revision to Standard Review Plan (NUREG-0800), Chapter 
13, ``Conduct of Operations, Sections 13.1.1, ``Management and 
Technical Support Organization,'' and 13.1.2-1.3, ``Operating 
Organization''

AGENCY: Nuclear Regulatory Commission.

ACTION: Notice of opportunity for public comment.

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SUMMARY: The Nuclear Regulatory Commission (NRC) has prepared a 
revision to NUREG-0800, ``Standard Review Plan for the Review of Safety 
Analysis Reports for Nuclear Power Plants--LWR Edition,'' Chapter 13, 
``Conduct of Operations,'' sections 13.1.1, ``Management and Technical 
Support Organization,'' and 13.1.2-1.3, ``Operating Organization.'' The 
Standard Review Plan (SRP) contains guidance used by the staff to 
review safety analysis reports for light water reactor commercial 
nuclear power plants. The proposed revision incorporates changes that 
have been made since the sections were last revised in April, 1996, and 
publically noticed in the Federal Register, Vol. 61, No. 162, Tuesday, 
August 20, 1996. There were no public comments received to these 
sections. The proposed revision addresses 10 CFR 50.80 requirements for 
``Transfer of Licenses.'' Specifically, the staff has revised Chapter 
13, ``Conduct of Operations,'' sections 13.1.1, ``Management and 
Technical Support Organization,'' and 13.1.2-1.3, ``Operating 
Organization'' of the SRP as they relate to 10 CFR 50.80 requirements 
for the applicant's technical qualifications. The April, 1996 revision 
of these SRP sections did not include guidance for the staff to review 
the technical qualifications of applicants for license transfer.
    The purpose of this notice is to solicit specific public comment on 
whether the revised text accurately and fully reflects the established 
NRC staff positions and existing regulations. The SRP is made available 
to the public as part of the NRC's policy to inform the nuclear 
industry and the general public of regulatory procedures and policies. 
The SRP is not a substitute for regulatory guides or NRC regulations. 
Compliance with the SRP is not required. The published SRP will be 
revised periodically, as appropriate, to accommodate comments and 
reflect new information and experience. The NRC encourages comment from 
all interested parties; however, public

[[Page 29923]]

review is not intended to reopen a dialogue on the merits of the 
requirements themselves but, rather, should be focused on the 
previously stated purpose.

DATES: The comment period expires July 6, 1999. Comments received after 
this date will be considered if it is practical to do so, but the 
Commission is able to assure consideration only for comments received 
on or before this date.

ADDRESSES: Mail comments to: Chief, Rules Review and Directives Branch, 
Division of Freedom of Information and Publications Services, Mail Stop 
T-6D59, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. 
Comments may be hand delivered to 11545 Rockville Pike, Maryland, 
between 7:45 a.m. and 4:15 p.m., on Federal workdays.

FOR FURTHER INFORMATION CONTACT: James P. Bongarra, Jr., U.S. NRC, 
Office of Nuclear Reactor Regulation, Mail Stop O9D24, Washington, DC, 
20555; telephone (301) 415-1046; e-mail:jxb@nrc.gov.

SUPPLEMENTARY INFORMATION: The proposed revised text to NUREG-0800, 
``Standard Review Plan for the Review of Safety Analysis Reports for 
Nuclear Power Plants--LWR Edition,'' is the work of the NRC staff. It 
has received review by the Director, Division of Inspection Program 
Management, Office of Nuclear Reactor Regulation, and the NRC's Office 
of General Counsel. A final revision will be published upon resolution 
of public comments and review by the Director, Office of Nuclear 
Reactor Regulation, the NRC's Committee to Review Generic Requirements 
(CRGR), and the Advisory Committee on Reactor Safeguards (ACRS).
    The proposed revision to NUREG-0800, ``Standard Review Plan for the 
Review of Safety Analysis Reports for Nuclear Power Plants--LWR 
Edition,'' Chapter 13, ``Conduct of Operations,'' sections 13.1.1, 
``Management and Technical Support Organization,'' and 13.1.2-1.3, 
``Operating Organization,'' follows:

NUREG-0800--Standard Review Plan, Chapter 13, Conduct of Operations

13.1.1  Management and Technical Support Organization

Review Responsibilities

Primary--Human Performance Branch
Secondary--None

I. Areas of Review

    The branch with primary responsibility for reviewing human 
performance will review the corporate level management and technical 
organization of the applicant for a construction permit (CP), operating 
license (OL), combined license (COL), or license transfer. The review 
will also include the applicant's major contractors including the 
nuclear steam supply system (NSSS) vendor, and architect/engineer (A/E) 
for the project. The technical resources to support the nuclear power 
plant design, construction, testing, and operation are reviewed. The 
review for a CP or COL will include an examination of the 
responsibilities, technical staff, interface arrangements, and 
management controls used to ensure that the design and construction of 
the facility will be performed in an acceptable manner. The review for 
an OL or COL will examine the applicant's corporate organization and 
technical staff that will provide support for safe plant operation. The 
review for license transfer will examine the acceptability of any 
changes to the technical organization or personnel qualifications 
proposed as a result of a license transfer under 10 CFR 50.80.
    The objective of this review is to ensure that the corporate 
management is involved with, informed of, and dedicated to the safe 
design, construction, test and operation of the nuclear plant. In 
addition, the review is to ensure that sufficient technical resources 
have been, are being and will continue to be provided to adequately 
accomplish these objectives.
A. Reviews of Initial Construction Permit (CP) and Early Stage Combined 
License (COL) or Reviews of Transfer of Construction Permits (CP) and 
Early Stage Combined License (COL)
    The applicant's past experience in the design and construction of 
nuclear power plants, and past experience in activities of similar 
scope and complexity should be described. The applicant's management, 
engineering, and technical support organization should also be 
described. The description should include organizational charts for the 
current headquarters and engineering structure, as well as planned 
modifications and additions to those organizations to reflect the added 
functional responsibilities associated with the nuclear plant.
1. Design and Construction Responsibilities
    A description of the implementation or delegation of design and 
construction responsibilities should be included for the following:
    a. Principal site-related engineering work such as meteorology, 
geology, seismology, hydrology, demography, and environmental effects.
    b. Design of plant and ancillary systems, including fire protection 
systems.
    c. Review and approval of plant design features, including human 
factors engineering (HFE) considerations.
    d. Site layout with respect to environmental effects and security 
provisions.
    e. Development of safety analysis reports (SARs).
    f. Material and components specification review and approval.
    g. Procurement of materials and equipment.
    h. Management of construction activities.
2. Preoperational Responsibilities
    A description of the proposed plans for the management organization 
related to the initial test program should include the following:
    a. Development of plans for the preoperational and startup testing 
of the facility.
    b. Development and implementation of staff recruiting and training 
programs.
    c. Development of plant maintenance programs.
    The descriptions of the design and construction and preoperational 
responsibilities should include the following:
    a. How these responsibilities are assigned by the headquarters 
staff and implemented within the organizational units;
    b. Identification of the responsible working or performance level 
organizational unit;
    c. An estimate of the number of persons expected to be assigned to 
each of the various units with responsibility for the project;
    d. The general educational backgrounds and experience requirements 
for qualification in identified positions or classes of positions;
    e. The role of the applicant's management in interfacing with the 
NSSS and A/E organizations;
    f. Specific educational and experience background for assigned 
management and supervisory positions; and
    g. The required review of contractor work by the applicant's staff.
    h. For identified positions or classes of positions that have 
functional responsibilities other than the CP or COL application, the 
expected proportion of time assigned to the other activities should be 
described.
    i. The early plans for providing technical support for the 
operation of the facility should be described.

[[Page 29924]]

    The CP- or COL-stage review of the NSSS and A/E organizations 
includes an evaluation of the ability of the technical staff of each 
organization to support or perform the activities specified in the 
application, as applicable. The information submitted should include a 
description of the specific activity (including scope) to be engaged 
in, organizational description and charts reflecting organizational 
lines of authority and responsibility for the project, the number of 
persons assigned to the project, and qualification requirements for 
principal management positions related to the project. For those NSSS 
and A/E organizations with extensive experience, a detailed description 
of this experience may be provided in lieu of the details of their 
organization as evidence of technical capability. However, a specific 
description should be provided of how this experience will be applied 
to the particular project.
B. Operating License (OL and COL) Reviews
    The SAR should provide the following information:
    1. Organizational charts of the applicant showing the corporate 
level management and technical support;
    2. The relationship of the nuclear oriented portions of the 
structure to the rest of the corporate organization;
    3. A description of the specific provisions which have been made 
for technical support for operations; and
    4. The organizational unit and any augmenting organizations, or 
other personnel who will manage or execute any phase of the test 
program, including the responsibilities and authorities of principal 
participants.
    Technical services and backup support for the operating 
organization should become available in advance of the conduct of the 
preoperational and startup testing program and continue throughout the 
life of the plant.
    The SAR should (1) Describe approximate numbers, educational 
background, and experience requirements for each identified position or 
class of positions providing technical support for plant operations, 
and (2) include specific educational and experience background for 
individuals holding the management and supervisory positions providing 
support in the areas identified below.
    The special capabilities that should be included in the support for 
the operation of the plant are:
    1. Nuclear, mechanical, structural, electrical, thermal-hydraulic, 
metallurgical and materials, and instrumentation and controls 
engineering.
    2. Plant chemistry.
    3. Health physics.
    4. Fueling and refueling operations support.
    5. Maintenance support.
    6. Operations support.
    7. Quality assurance.
    8. Training.
    9. Safety review.
    10. Fire protection.
    11. Emergency organization.
    12. Outside contractual assistance.
C. Reviews of Transfer of Operating License (OL) and Late Stage 
Combined License (COL)
    An applicant for transfer of an operating license should provide a 
description of the organization to support plant operations. The 
description should include:
    1. Organizational charts showing the corporate level management and 
technical support organization and emphasizing the changes to be made 
as a result of the transfer;
    2. The relationship of the nuclear oriented portions of the 
organization to the rest of the corporate organization; and
    3. A description of the specific provisions which have been made 
for technical support for operations.
D. Review Interfaces
    The branch with primary responsibility for human performance 
reviews performs the following reviews under the SRP sections 
indicated:

SRP Sections 13.1.1 through 13.1.3--for organizational structure, 
personnel qualifications and experience
SRP Section 13.2.1--for training for licensed operators
SRP Section 13.4--for organizational provisions for independent reviews 
and verifications
SRP Section 13.5.2--for procedure adequacy
SRP Section 18.0--for use of human factors engineering principles

    The branch with primary responsibility for human performance will 
coordinate evaluations and reviews by other branches that interface 
with the overall review of the management and technical support 
organization as follows:
    1. With the branch responsible for Emergency Preparedness and 
Radiation Protection, as part of its primary review responsibility for 
SRP section 13.3, for the acceptability of the emergency organization 
and as part of its primary review responsibilities for SRP section 
12.5, for the acceptability of the radiation protection organization.
    2. With the branch responsible for Safeguards as part of its 
primary review responsibility for SRP section 13.6 for the 
acceptability of the applicant's plans and provisions for security, 
including the security organization.
    3. With the branch responsible for Quality Assurance, as part of 
its primary review responsibility for SRP chapter 17, for the 
acceptability of the quality assurance organization and, as part of its 
primary review responsibilities for SRP section 13.4, for the 
acceptability of the organization of the independent safety engineering 
group (ISEG).
    4. With the branch responsible for Plant Systems, as part of its 
primary review responsibility for SRP section 9.5.1, for the 
acceptability of the organization responsible for fire protection.
    For those areas of review identified above as being part of the 
review under other SRP sections, the acceptance criteria necessary for 
the review and their methods of application are contained in the 
referenced SRP sections.

II. Acceptance Criteria

A. General Guidance
    The applicant's description of its resources to deal with safety-
related problems connected with the proposed addition of nuclear 
generating capacity should provide contributory evidence as to the 
technical qualifications of the applicant, as required by 10 CFR 
50.40(b) and 10 CFR 50.80, as applicable.
    In the review and evaluation of the subject matter of this section 
of the SAR, the following points should be taken into consideration.
    1. The corporate level management and technical support structure, 
as demonstrated by organizational charts and descriptions of functions 
and responsibilities, should be free of ambiguous assignments of 
primary responsibility.
    2. A corporate officer should be clearly responsible for nuclear 
activities, without having ancillary responsibilities that might 
detract attention to nuclear safety matters.
    3. Design and construction responsibilities should be reasonably 
well defined in both numbers and experience of persons required to 
implement their responsibilities.
    4. Similarly, management and organizational responsibilities should 
be clearly defined with regard to human factors engineering (HFE) 
considerations in the management of human-system interface issues. This 
subject is addressed in more detail in NUREG-

[[Page 29925]]

0711 and in SRP Chapter 18 (DRAFT, April 1996).
B. Specific Criteria
    Specific criteria which contribute to meeting 10 CFR 50.40(b) with 
respect to the CP, OL, or COL reviews and 10 CFR 50.80 with respect to 
license transfer reviews are described below.

For Review of Initial Construction Permit (CP) and Early Stage Combined 
License (COL) or for Review of Transfer of Construction Permit (CP) and 
early Stage Combined License (COL)

    1. The applicant has identified and functionally described the 
specific organizational groups responsible for implementing 
responsibilities for the project.
    2. The applicant has described the method of implementing its 
responsibilities for dealing with the safety-related aspects of the 
design and construction of the project and the transition to operation 
of the facility, including control of major contractors.
    3. Clear, unambiguous management control and communications exist 
between the organizational units involved in the design and 
construction of the project.
    4. Substantive breadth and level of experience and availability of 
manpower exist to implement the responsibility for the project.
    5. The applicant has clearly described the role and function of the 
A/E and NSSS vendor during both design and construction and has 
demonstrated appropriate control over the project-related activities of 
the A/E and NSSS vendor.
    6. The applicant has designated the responsible organizations that 
will participate in the test program and early plans indicate 
reasonable assurance that such designated organizations can 
collectively provide the necessary level of staffing with suitable 
skills and experience to develop and conduct the test program.
    7. The applicant plans to utilize the plant operating and technical 
staff in the development and conduct of the test program and in the 
review of test results.
    8. For COL applicants subject to 10 CFR 50.34(f), the applicant has 
identified plans for the organization and staffing to oversee design 
and construction of the nuclear facility in accordance with the 
guidelines of Item II.J.3.1 of NUREG-0718 as related to the 
requirements of 10 CFR 50.34(f)(3)(vii). As reflected in SRP Section 
18.0, (DRAFT, April 1996) the review criteria for the human factors 
engineering (HFE) design team is provided in NUREG-0711, Chapter 2, 
``Element 1--HFE Program Management.''
    Although the requirements of 10 CFR 50.34(f) apply only to the 
specific applicants listed in that section, OL applicants should 
include information related to the organizational and management 
structure responsible for the design and construction of the proposed 
plant to ensure that the staff has complete and accurate information 
for its review.

For Review of Operating License (OL) and Later Stage Combined License 
(COL)

    The review and evaluation of management and technical 
organizational structure for OL and COL applicants is based on the 
guidelines of TMI Action Plan Item I.B.1.2 originally described in 
NUREG-0694. Specific criteria are as follows:
    1. The applicant has identified and described the organizational 
groups responsible for implementing the initial test program, and 
technical support for the operation of the facility.
    2. The applicant has described the method of implementing its 
responsibilities for dealing with the initial test program, technical 
support, and operation of the facility.
    3. The organizational structure provides for the integrated 
management of activities that support the operation and maintenance of 
the facility.
    4. Clear management control and effective lines of authority and 
communications exist between the organizational units involved in the 
management, operation, and technical support for the operation of the 
facility.
    5. Substantive breadth and level of experience and availability of 
manpower exist to implement the initial test program and technical 
support for the operation of the facility. The need to supplement the 
corporate structure with additional experienced personnel for the 
initial years of operation will be determined on case-by-case basis.
    6. Qualifications of members of the technical support organization 
should meet or exceed those endorsed by Regulatory Guide 1.8.
    7. The technical staff will be utilized in the initial test program 
to the maximum extent practicable. Participants in the test program 
should receive plant-specific training/indoctrination in the 
administrative controls for the test program prior to the start of 
testing. The level of staffing should be adequate based on the 
reviewer's judgment.

For Review of Transfer of Operating License (OL) and Later Stage 
Combined License (COL)

    The criteria for the review and evaluation of management and 
technical organizational structure for license transfer applicants are 
as follows:
    1. The applicant has identified and described the organizational 
groups responsible for the technical support for the operation of the 
facility.
    2. The applicant has described the method for implementing the 
technical support and operation of the facility.
    3. The organizational structure provides for the integrated 
management of activities that support the operation and maintenance of 
the facility.
    4. Clear management control and effective lines of authority and 
communications exist between the organizational units involved in the 
management, operation, and technical support for the operation of the 
facility.
    5. Substantive breadth and level of experience and availability of 
manpower exist to implement the technical support for the operation of 
the facility.
    6. Qualifications of members of the technical support organization 
should meet or exceed those endorsed by Regulatory Guide 1.8.
C. Technical Rationale
    The technical rationale for application of the above acceptance 
criteria to the review of the management and technical support 
organization is discussed in the following paragraphs.
    1. Compliance with the relevant requirements of 10 CFR 50.40(b) 
requires that the applicant be technically qualified to engage in 
activities associated with the design, construction, and operation of a 
nuclear power plant in accordance with the regulations in 10 CFR 50. 
Similarly, 10 CFR 80 requires that the applicant for the transfer of a 
license be technically qualified to be the holder of the license.
    The management and technical support organization established by 
the applicant to oversee the design and construction of a nuclear power 
plant provides valuable insight into the corporate management's 
understanding of its safety role in the design, construction, 
operation, and maintenance of the facility. This information 
contributes to the determination that an applicant is technically 
qualified by ensuring that appropriate considerations were used in the 
establishment of general qualification requirements and staffing levels 
for all key positions on which the safety of the facility will depend.

[[Page 29926]]

    Meeting the requirements of 10 CFR 50.40(b) and 10 CFR 80, as 
applicable, provides assurance that the applicant is technically 
qualified to engage in the proposed activities and has established the 
necessary management and technical support organization to safely 
operate the proposed facility.

III. Review Procedures

    Preparation for reviewing the application should include 
familiarization with the documents listed as references in this SRP 
section.
    Each element of the application information is to be reviewed 
against this SRP section. The reviewer's judgment during the review is 
to be based on an inspection of the material presented, whether items 
of special safety significance are involved, and the magnitude and 
uniqueness of the project. Any exceptions or alternatives are to be 
carefully reviewed to ensure that they are clearly defined and that an 
adequate basis exists for acceptance.
    The applicant should identify the applicable version of references, 
Regulatory Guides, and Codes and Standards used. The reviewer should 
identify the applicable version of references, Regulatory Guides, and 
Codes and Standards used in the review.
    In the review and evaluation of the information related to this 
section of the management and technical support organization, the 
following points should be taken into consideration:
    A. In the early construction stage, the applicant's plans for 
headquarters staffing to provide technical support when operating may 
not yet be firm. It is acceptable, therefore, if these plans are not 
fully specific in terms of numbers of people, provided the commitment 
made is sufficiently firm to ensure the responsibility can be met.
    B. The reviewer must recognize that there are many acceptable ways 
to define and delegate job responsibilities. Variations in staffing may 
also be expected between applicants with and without prior experience 
in nuclear plant design, construction, or operation. The reviewer must 
be convinced that an applicant has not underestimated the magnitude of 
the task. The reviewer should be alert to the possibility that 
excessive workloads may be placed upon too small a number of 
individuals. Interface arrangements and controls between the applicant 
and major contractors (NSSS vendors, architect/engineers, constructors) 
should be examined to ensure that the applicant will be in charge of 
and responsible for design and construction activities.
    If the application involves the addition of more than one unit, the 
reviewer should ensure that headquarters staffing plans take this fact 
into account. This is particularly important if additional units are 
scheduled to come on line at intervals of about one year or less, since 
the shakedown period for the operation of a new plant can be expected 
to produce quite heavy workloads. In some of these cases the applicant 
may plan to bolster the plant staff organization during such periods so 
that it is necessary to evaluate headquarters staffing plans in 
conjunction with those for the plant staff organization.
    C. The reviewer should assess the degree of participation during 
the design and construction phases by the headquarters group that 
typically has plant operating (generating) responsibility. Interfaces 
between such a group and those with project engineering 
responsibilities should be examined.
    D. At the time of this review, if the applicant has had experience 
in the operation of a previously licensed nuclear power plant, the 
reviewer may seek independent information about headquarters staffing 
and qualifications through the appropriate NRC Regional Office.
    The review procedure for this section consists, therefore, of the 
following:
    1. An examination of the information submitted to determine that 
all areas identified in subsection I, ``Areas of Review,'' above have 
been addressed.
    2. A comparison of the information with the acceptance criteria of 
subsection II, Review Criteria,'' above.
    3. Review of information provided by the NRC Regional Office 
position statement on the applicant's organizational and administrative 
commitments made in the SAR, if applicable.
    4. Verification of the implementation of the management structure 
and technical resources based on visits to corporate headquarters and 
the site, if applicable.
    The reviewer then determines, based on the foregoing, the overall 
acceptability of the applicant's management and technical support 
organization and staffing plans.
    For OL and late stage COL license transfer under 10 CFR Part 50, 
the existing organization was found acceptable for operations as part 
of the initial licensing review. Therefore, the review in support of a 
license transfer should be focused on the organizational changes 
proposed as a result of that transfer. The reviewer should ensure that 
the proposed changes will result in an organization that will continue 
to meet the relevant review criteria.
    For Standard Design Certification under 10 CFR Part 52, the 
procedures above should be followed, as modified by the procedures in 
SRP Section 14.3, (DRAFT, April 1996) to verify that the design set 
forth in the standard safety analysis report, including inspections, 
tests, analysis, and acceptance criteria (ITAAC), site interface 
requirements and combined license action items, meet the acceptance 
criteria given in subsection II. SRP Section 14.3 (DRAFT, April 1996) 
contains procedures for the review of certified design material (CDM) 
for the standard design, including the site parameters, interface 
criteria, and ITAAC.

IV. Evaluation Findings

    The reviewer verifies that the information presented supports 
conclusions of the following type to be used in the staff's safety 
evaluation report:
    The staff concludes that the management and technical support 
organization is acceptable and meets the requirements of 10 CFR 50.40. 
This conclusion is based on the following:
A. For a Safety Evaluation Report of an Initial CP or COL or for a 
Transfer of CP or COL
    The applicant has described clear responsibilities and associated 
resources for the design and construction of the facility and has 
described its plans for management of the project and for utilization 
of the NSSS vendor and A/E. These plans have been reviewed and give 
adequate assurance that an acceptable organization has been established 
and that sufficient resources are available to satisfy the applicant's 
commitments for the design and construction of the facility. These 
findings contribute to the judgment that the applicant complies with 
the requirements of 10 CFR 50.40(b) and 10 CFR 50.80, as applicable; 
i.e., that the applicant is technically qualified to engage in design 
and construction activities.
B. For a Safety Evaluation Report of an Initial OL or Late Stage COL
    The applicant has described its organization for the management of, 
and its means for providing technical support for the plant staff 
during operation of the facility. These measures have been reviewed and 
it is concluded that the applicant has an acceptable organization and 
adequate resources to provide offsite technical support for the 
operation of the facility under both normal and off-normal conditions.

[[Page 29927]]

C. For a Safety Evaluation Report of a Transfer of an OL or Late Stage 
COL License
    The applicant has described its organization for the management of, 
and its means for providing technical support to the plant staff for 
operation of the facility after the license transfer. These measures 
have been reviewed and it is concluded that the applicant has an 
acceptable organization and adequate resources to provide offsite 
technical support for the operation of the facility under both normal 
and off-normal conditions.
D. For Design Certification
    For design certification reviews, the findings will also summarize, 
to the extent that the review is not discussed in other safety 
evaluation report sections, the staff's evaluation of inspections, 
tests, analyses, and acceptance criteria (ITAAC), including design 
acceptance criteria (DAC), site interface requirements, and combined 
license action items that are relevant to this SRP section.
    In addition to the finding based on the type of application, the 
safety evaluation report should also address the following:
    These findings contribute to the judgment that the applicant 
complies with the requirements of 10 CFR 50.40(b) and 10 CFR 50.80, as 
applicable (that the applicant is technically qualified to operate a 
nuclear power plant); that the applicant will have the necessary 
managerial and technical resources to provide assistance to the plant 
staff in the event of an emergency; and that the applicant has 
identified the organizational positions responsible for fire protection 
matters and the authorities that have been delegated to these positions 
to implement fire protection requirements.

V. Implementation

    The following is intended to provide guidance to applicants and 
licensees regarding the NRC staff's plans for using this SRP section.
    This SRP section will be used by the staff when performing safety 
evaluations of license applications submitted by applicants pursuant to 
10 CFR 50 or 10 CFR 52 and for transfer of a license pursuant to 10 CFR 
50.80. Except in those cases in which the applicant proposes an 
acceptable alternative method for complying with specified portions of 
the Commission's regulations, the method described herein will be used 
by the staff in its evaluation of conformance with Commission 
regulations.
    The provisions of this SRP section apply to reviews of applications 
docketed six months or more after the date of issuance of this SRP 
section.
    Implementation schedules for conformance to parts of the method 
discussed herein are contained in the referenced regulatory guides and 
NUREGs.

VI. References

1. 10 CFR Part 50, ``Domestic Licensing of Production and 
Utilization Facilities.''
2. Regulatory Guide 1.8, ``Qualification and Training of Personnel 
for Nuclear Power Plants.''
3. Regulatory Guide 1.68, ``Initial Test Programs for Water-Cooled 
Nuclear Power Plants.''
4. NUREG-0694, ``TMI-Related Requirements for New Operating 
Licenses.''
5. NUREG-0711, Human Factors Engineering Program Review Model.
6. NUREG-0718, ``Licensing Requirements for Pending Applications for 
Construction Permits and Manufacturing License.''
7. NUREG-0737, ``Clarification of TMI Action Plan Requirements.

NUREG-0800--Standard Review Plan, Chapter 13, Conduct of Operations

13.1.2-13.1.3  Operating Organization

Review Responsibilities

Primary--Human Performance Branch
Secondary--None

I. Areas of Review

    The applicant's operating organization, as described in its safety 
analysis report (SAR), is reviewed. This section of the SAR should 
describe the structure, functions, and responsibilities of the onsite 
organization established to operate and maintain the plant.
A. Reviews of Initial Construction Permit (CP) and Early Stage Combined 
License (COL) or Reviews or Transfer of CP and Early Stage COL
    During the early stages of construction or plant design it is 
recognized that many details of the plant organization and staffing 
have not been finalized. The organizational information provided at 
this time should include the following elements:
    1. The applicant's commitment to meet the guidelines of Regulatory 
Guide 1.33 for the Operating Organization.
    2. The applicant's commitment to meet the guidelines of Regulatory 
Guide 1.33 for Onsite Review and Rules of Practice.
    3. The applicant's commitment to meet Branch Technical Position 
SPLB 9.5-1.
    4. The applicant's commitment to meet the guidelines of Regulatory 
Guide 1.8 for the Operating Organization.
    5. The applicant's commitment to be consistent with the options in 
the Commission Policy Statement on Engineering Expertise on Shift.
    6. The applicant's commitment to meet TMI Action Plan items I.A.1.1 
and I.A.1.3 of NUREG-0737 for Shift Technical Advisor and Shift 
Manning.
    7. A schedule, relative to fuel loading for each unit, for filling 
all positions.
B. Review of Operating License (OL) and Later Stage Combined License 
(COL)
    During the later stages of construction, plant design, and 
licensing, the applicant should provide evidence that the initial 
personnel selections conform to the commitments made in the early 
stages of licensing.
    The organizational information provided by the applicant should 
include the following elements:
    1. An organization chart should have the following elements:
    a. The title of each position,
    b. The minimum number of persons to be assigned to common or 
duplicated positions,
    c. The number of operating shift crews, and
    d. The positions for which reactor operator and senior reactor 
operator licenses are required.
    For multi-unit stations, the organization chart (or additional 
charts) should clearly reflect changes and additions as new units are 
added to the station.
    2. The personnel resumes for those selected for management and 
supervisory positions down through the shift supervisor.
    3. The functions, responsibilities, and authorities of plant 
positions corresponding to the following should be described:
    a. Overall plant management.
    b. Operations supervision.
    c. Operating shift crew supervision.
    d. Shift technical advisors.
    e. Licensed operators.
    f. Non-licensed operators.
    g. Technical supervision.
    h. Radiation protection supervision.
    i. Instrumentation and controls maintenance supervision.
    j. Equipment maintenance supervision k. Fire protection 
supervision.
    l. Quality assurance supervisor (when part of the plant staff).
    For each position, where applicable, required interfaces with 
offsite personnel or positions identified in SAR Section 13.1.1 should 
be described. Such interfaces include defined lines of reporting 
responsibilities, e.g., from the plant manager to the immediate

[[Page 29928]]

superior, as well as functional or communication channels.
    4. The line of succession of authority and responsibility for 
overall station operation in the event of unexpected contingencies of a 
temporary nature, and the delegation of authority that may be granted 
to operating supervisors and to shift supervisors, including the 
authority to issue standing or special orders.
    5. The extent and nature of the participation of the plant 
operating and technical staff in the initial test program.
    6. If the station contains or is planned to contain power 
generating facilities other than those relating to the application in 
question and including fossil-fueled units, this section should also 
describe interfaces with the organizations operating such other 
facilities. The description should include any proposed sharing of 
persons between the units, a description of their duties, and the 
proportion of their time they will routinely be assigned to non-nuclear 
units
    7. The position titles, applicable operator licensing requirements 
for each, and the total number of people planned to man each shift 
should be described for all combinations of units proposed to be at the 
station in either operating or cold shutdown modes. Shift crew staffing 
plans unique to refueling operations should be described. The proposed 
means of assigning shift responsibility for implementing the radiation 
protection and fire protection programs on a round-the-clock basis 
should also be described.
    8. The education, training, and experience requirements 
(qualification requirements) established by the applicant for filling 
each management, operating, technical, and maintenance position 
category in the operating organization above should be described. This 
includes those persons who will conduct preoperational and startup 
tests. Consequently, the information to be reviewed should demonstrate 
an understanding of and commitment to the acceptance criteria below.
C. Review of a Transfer of Operating License (OL) or Late Stage 
Combined Operating License (COL)
    The initial operating organization was found acceptable as part of 
the initial licensing review. Subsequent safety-related changes to the 
operating organization should have been evaluated with an appropriate 
methodology and, therefore, the existing organization remains 
acceptable. The review to support a license transfer should focus on 
evaluating any changes to the operating organization that are being 
proposed as a result of the transfer.
D. Review Interfaces
    The primary Human Performance review branch performs the following 
reviews under the SRP sections indicated:

SRP Sections 13.1.1 through 13.1.3,--for organizational structure, 
personnel qualifications and experience
SRP Section 13.2.1--for training for licensed operators
SRP Section 13.4--for organizational provisions for independent reviews 
and verifications
SRP Section 13.5.2--for procedure adequacy
SRP Section 18.0--for use of human factors engineering principles

    The primary Human Performance review branch will coordinate 
evaluations and reviews by other branches that interface with the 
overall review of the operating organization as follows:
    1. With the branch responsible for Emergency Preparedness and 
Radiation Protection, as part of its primary review responsibility for 
SRP Section 13.3, for the acceptability of the emergency organization 
and as part of its primary review responsibilities for SRP Section 
12.5, for the acceptability of the radiation protection organization.
    2. With the branch responsible for Safeguards as part of its 
primary review responsibility for SRP Section 13.6 for the 
acceptability of the applicant's plans and provisions for security, 
including the security organization.
    3. With the branch responsible for Quality Assurance, as part of 
its primary review responsibility for SRP Chapter 17, for the 
acceptability of the quality assurance organization.
    For those areas of review identified above as being part of the 
review under other SRP sections, the acceptance criteria necessary for 
the review and their methods of application are contained in the 
referenced SRP sections.

II. Acceptance Criteria

A. General Criteria
    This section of the SAR should demonstrate the applicant's 
commitment to and implementation of plans to staff the onsite operating 
organization and to define and delegate responsibilities to provide 
assurance that the plant can be operated safely.
    In the review and evaluation of the subject matter in this section 
of the SAR, the following points should be taken into consideration:
    1. Plant staff organizational structures are not rigidly fixed. 
However, experience has shown that certain components are common to and 
necessary for all plants. Among these are operational, onsite technical 
support, and maintenance groups, under the direction and supervision of 
a plant manager.
    2. The operating organization should be free of ambiguous 
assignments of primary responsibility. Operating responsibilities 
should be reasonably well defined in both numbers and experience of 
persons required to implement their responsibilities.
    3. The total on-shift manpower available should include a 
sufficient number of full operating shift crews so that excessive 
overtime is not routinely scheduled.
    The staff acceptance criteria are designed to produce reasonable 
assurance of applicant compliance with the relevant requirements of the 
following regulations:
    1. 10 CFR 50.40(b) as it relates to demonstrating in conjunction 
with other reviews that the applicant is technically qualified to 
engage in nuclear activities licensed under these regulations.
    2. 10 CFR 50.54(j), (k), (l), and (m) as they relate to operator 
requirements during the operation of the facility, the responsibility 
for directing activities of licensed operators, and the senior operator 
availability during reactor operations and other specific reactor 
conditions or modes of operation.
    3. 10 CFR 50.80 as it relates to demonstrating in conjunction with 
other reviews that the applicant for the transfer of a license is 
technically qualified to be the holder of a license.
B. Specific Criteria
    Specific criteria necessary to meet the relevant requirements of 10 
CFR 50.40(b), 10 CFR 50.80, and 10 CFR 50.54(j), (k), (l), and (m) as 
follows:
    1. The requirements of ANSI N18.7/ANS-3.2, Section 3.4, ``Operating 
Organization,'' as endorsed by Regulatory Guide 1.33, should be met. In 
addition, the following characteristics should be satisfied:
    a. The reporting responsibility and authority of the functional 
areas of radiation protection, quality assurance, and training should 
ensure independence from operating pressures. In utilities with large 
commitments to nuclear power plants, overall management and technical 
direction in these areas may be concentrated at the home office.
    b. There should be clear lines of authority to the Plant Manager.

[[Page 29929]]

    c. Responsibility for all activities important to the safe 
operation of the facility should be clearly defined.
    d. Distinct functional areas should be separately supervised and/or 
managed.
    e. Sufficient managerial depth should be available to provide 
qualified backup in the event of the absence of the incumbent.
    2. Responsibilities and authorities of operating organization 
personnel should conform to the requirements of ANSI N18.7/ANS-3.2, 
Section 5.2, ``Rules of Practice''; Section 4.4, ``Onsite Review,'' as 
endorsed by Regulatory Guide 1.33; Branch Technical Position SPLB 9.5-
1; and Regulatory Guide 1.8 for the ``Operating Organization.'' In 
addition, the organization should reflect the staff position in TMI 
Action Plan Item I.C.3 of NUREG-0694, by having the responsibilities of 
the shift supervisor clearly establish the command duties of that 
position and emphasize the primary management responsibility for the 
safe operation of the plant.
    3. Assignments of onsite shift operating crews shall be made in 
accordance with 10 CFR 50.54(j), (k), (l), and (m). In addition, the 
staffing should reflect the staff positions of TMI Action Plan items 
I.A.1.1 and I.A.1.3 of NUREG-0737 as follows:
    a. A shift supervisor with a senior reactor operator's license, who 
is also a member of the station supervisory staff, shall be onsite at 
all times when at least one unit is loaded with fuel.
    b. In addition to the licensed personnel specified in 10 CFR 
50.54(m), as a minimum, an auxiliary operator (non-licensed) shall be 
assigned to each reactor and an additional auxiliary operator shall be 
assigned for each control room from which a reactor is operating. These 
operators shall be properly qualified to support the unit to which 
assigned.

    Note: The shift composition described above is shown in tabular 
form in Table 1.

    c. To meet TMI Action Plan item I.A.1.1 of NUREG-0737, engineering 
expertise shall be onsite at all times a licensed nuclear unit is being 
operated in Modes 1-4 for a PWR or in Modes 1-3 for a BWR. This 
engineering expertise should be consistent with the options presented 
in the Commission Policy Statement on Engineering Expertise on Shift.
    d. A health physics technician shall be onsite at all times when 
there is fuel in a reactor.
    e. A rad/chem technician shall be onsite at all times when a 
licensed nuclear unit is being operated in Modes 1-4 for a PWR or in 
Modes 1-3 for a BWR.
    f. Assignment, stationing, and relief of operators and senior 
operators within the control room shall be as described in Regulatory 
Guide 1.114.
    4. Total complement of licensed personnel and unlicensed personnel 
for on-site shift operating crews should be sufficient to avoid the 
routine heavy use of overtime.

    Note: SRP Section 13.5.1 contains guidance on work hour 
limitations.

To meet this policy, staffing plans should provide for no less than the 
number required for five shift rotations.
    5. The plant operating and technical staff should be used to the 
maximum extent possible in the facility initial test program.
    6. Assignments of persons to implement the fire brigade 
requirements of the fire protection program should meet the guideline 
of SRP Section 9.5.1, including the following:
    a. The responsibilities of the fire brigade members under normal 
conditions should not conflict with their responsibilities during a 
fire emergency.
    b. The minimum number of fire brigade members available onsite for 
each shift operation crew should be consistent with the activities 
required to combat the most significant fire. The minimum size of the 
fire brigade shift should be five persons unless a specific site 
evaluation has been completed and some other number justified.
    7. Regulatory Guide 1.8, ``Qualification and Training of Personnel 
for Nuclear Power Plants,'' sets forth the staff position on plant 
personnel qualifications and training.
    In addition, although the qualification levels of the standards are 
endorsed as acceptable minimums for each position, it is expected that 
the collective qualifications of the plant staff will be greater than 
the sum of the minimum individual requirements described in the 
standard, particularly in the area of nuclear power plant experience 
and in supervisory and management positions involved in the operational 
aspects of the facility. In those cases where the collective 
qualifications do not exceed the sum of the minimums for individual 
positions, additional technical support for the plant staff may be 
required. These will be determined on a case-by-case basis.

                                                     Table 1
----------------------------------------------------------------------------------------------------------------
                                                                 Shift Staffing **
                                  ------------------------------------------------------------------------------
                                     One unit, one control     Two units, one control    Two units, two control
                                              room                      room                      rooms
----------------------------------------------------------------------------------------------------------------
One Unit Operating *.............  1 SS (SRO)                 1 SS (SRO)                1 SS (SRO)
                                   1 SRO                      1 SRO                     1 SRO
                                   2 RO                       3 RO                      3 RO
                                   2 AO                       3 AO                      3 AO
Two Units Operating *............  NA                         1 SS (SRO)                1SS (SRO)
                                                              1 SRO                     2 SRO
                                                              3 RO                      4 RO
                                                              3 AO                      4 AO
All Units Shutdown...............  1 SS (SRO)                 1 SS (SRO)                1 SS (SRO)
                                   1 RO                       2 RO                      2 RO
                                   1 AO                       3 AO                      3 AO
SS (SRO).........................
2 RO.............................
3 AO.............................
----------------------------------------------------------------------------------------------------------------
SS--Shift Supervisor.
SRO--Licensed Senior Reactor Operator.
RO--Licensed Reactor Operator.
AO--Auxiliary Operator.

[[Page 29930]]


Notes:
1. In order to operate or supervise the operation of more than one unit, an operator (SRO or RO) must hold an
  appropriate, current license for each such unit.
2. In addition to the staffing requirements indicated in the table, a licensed senior operator will be required
  to directly supervise any core alteration activity.
* Modes 1 through 4 for PWRs. Modes 1 through 3 for BWRs.
** Shift staffing of unlicensed personnel for special cases such as 3 units, operating from 1 or 2 control
  rooms, etc. will be determined on a case-by-case basis, based on the principles defined in item II.B.3. of
  this SRP section. Shift staffing of licensed personnel for special cases including temporary deviations and
  staffing for 3 units must meet the requirements of 10 CFR 50.54(m), however.

C. Technical Rationale
    The technical rationale for application of these acceptance 
criteria to reviewing the operating organization is discussed in the 
following paragraphs:
    1. Compliance with the relevant requirements of 10 CFR 50.40(b) 
requires that the applicant be technically qualified to engage in the 
proposed activities in accordance with the regulations in Chapter 50. 
Similarly, 10 CFR 50.80 requires that an applicant for the transfer of 
a license be technically qualified to be the holder of a license.
    A review of the operating organization established by the applicant 
to oversee operation of a nuclear power plant provides valuable insight 
into corporate management's understanding of its safety role in the 
operation and maintenance of the facility. This information contributes 
to the determination that an applicant is technically qualified to 
engage in the proposed nuclear activities by ensuring that appropriate 
considerations were used in the establishment of general qualification 
requirements and staffing levels for all key positions on which the 
safety of the facility will depend.
    Meeting the requirements of 10 CFR 50.40(b) and 10 CFR 50.80, as 
applicable, provides assurance that the applicant is technically 
qualified to engage in the proposed activities and has established the 
necessary management and technical support organization to safely 
operate the proposed facility.
    2. Compliance with 10 CFR 50.54(j), (k), (l), and (m) requires the 
applicant to demonstrate that its operating organization satisfies 
minimum requirements for operator supervision and the availability of 
licensed senior operators and licensed operators during reactor 
operations and other specific reactor conditions or mode of operation.
    These are key positions for ensuring the safe operation of the 
plant. A staffing review of the operating organization provides 
valuable insight regarding the determination that an applicant is 
technically qualified to operate the facility.

III. Review Procedures

    Preparation for reviewing the SAR or license transfer applilcation 
should include familiarization with the documents listed as references 
to this SRP section.
    Each element of the SAR or transfer application information is to 
be reviewed against this SRP section. The reviewer's judgement during 
the review is to be based on an inspection of the material presented, 
whether items of special safety significance are involved, and the 
uniqueness of the facility. Any exceptions or alternatives are to be 
carefully reviewed to ensure that they are clearly defined and that 
adequate basis exists for acceptance.
    The applicant should identify the applicable version of references, 
Regulatory Guides, and Codes and standards used. The reviewer should 
identify the applicable version of references, regulatory guides, and 
Codes and standards used in the review.
    In the review and evaluation of the information related to the 
operating organization, the following points should be taken into 
consideration:
    A. During the early stages of construction or plant design, the 
applicant will generally not have made selections for plant staff 
positions. The review procedure, therefore, is to examine this section 
of the SAR for a commitment on the part of the applicant to conform to 
the stated acceptance criteria.
    B. The reviewer must recognize that there are many acceptable ways 
to define and delegate job responsibilities. Variations in staffing may 
also be expected between applicants with and without prior experience 
in nuclear plant operation. It is important that the reviewer verify 
that applicants lacking in experience do not underestimate the 
magnitude of the task and that all applicants adequately consider the 
potential effects of human error. Guidance on human error 
considerations may be found in NUREG-0711, Chapter 7, ``Element 6--
Human Reliability Analysis.'' The reviewer should be alert to the 
possibility that excessive workloads may be placed upon too small a 
number of individuals.
    The reviewer should also consider that the structure of onsite 
technical support and maintenance groups may depend somewhat on 
headquarters staffing and the division of effort between onsite and 
offsite personnel.
    C. During the later stages of construction, plant design, and 
licensing, the review consists first of the same examination as made 
for the early stages of construction or plant design, and secondly, of 
an analysis of each resume. The reviewer should make an explicit 
comparison of the educational and experience records obtained from each 
resume with the corresponding endorsed consensus standards requirements 
and regulatory positions set forth for the applicable position in 
Regulatory Guide 1.8 or other approved qualifications. ``Applicable 
experience'' should be judged in the light of the position 
responsibility. Credit for experience, which may not be entirely 
applicable, should be weighed to a degree commensurate with its 
applicability.
    Where a clear comparison cannot be made between the proposed plant 
staff positions and those defined in the standards endorsed in 
Regulatory Guide 1.8, the applicant should list each position on its 
plant staff and designate the corresponding position of these 
standards, or describe in detail the proposed qualification 
requirements for each position on its plant staff.
    In addition, if the applicant, as of the time the review takes 
place, has had experience in the operation of previously licensed 
nuclear power plants, the reviewer may seek independent information 
relative to plant staffing and qualifications through the appropriate 
Regional Office, e.g., by discussion with inspection personnel or 
review of inspection reports.
    D. For onshift persons, the total manpower available should be 
reviewed to ensure that a sufficient number of full operating shift 
crews are planned so that excessive overtime is not routinely scheduled 
for these crews. Additional staffing guidance may be found in NUREG-
0711, Chapter 6, ``Element 5--Staffing.'' For multi-unit sites, overall 
site responsibilities should be checked for clarity during those 
periods of time when senior level supervision is not onsite.
    The review procedure for this SRP section consists, therefore, of 
the following:
    1. An examination of the information submitted to determine that 
all subject