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Section 4.1.3, Organization

The application should describe:

·       the applicant’s organizational structure and resources, including:

·       verification that adequate organizational structures and resources will be in place to meet the nuclear safety management needs of the licensed facility or activity

·       top-level organizational charts with references to the full organizational charts (including the staffing levels)

·       the relationship between the applicant and any other organization with which significant interactions will occur (such as partners or contractors), including:

·       information on how potential effects on nuclear safety management from each relationship will be recognized and addressed

·       confirmation that the applicant is in control of the licensed facility and activities and will not be subject to undue influence by any other organization

·       the design principles used to develop the organizational structure; some examples of design principles are:

·       number of layers of hierarchy

·       length of decision-making chains

·       scope of managerial control

·       policy for the use of contracted resources to supplement in‑house capability

·       the approach taken to ensure the applicant has all the capabilities necessary to provide nuclear safety and ensure the integrity of the safety case, including how the applicant will retain sufficient in‑house core capability to:

·       manage the licensed facility and activities

·       prevent degradation of the in‑house core capability through over-reliance on contractors

·       maintain technical subject matter expertise for all topics necessary for nuclear safety, including “intelligent customer” roles where expertise is contracted out

·       be an “intelligent customer” for items or services procured from the supply chain

·       how the organization will ensure it has sufficient numbers of qualified workers, using the organizational charts:

·       as a vehicle to identify the nuclear safety related positions and underpinning role

·       as a reference to arrangements to control organizational changes and maintain the organizational charts as evergreen documents

·       to set out the resource strategy to:

·       ensure the right resources are available at the right time with the right skills and experience to meet the core capabilities of the organization at all stages of the reactor facility’s lifecycle

·       describe arrangements to review its implementation and ongoing review

·       to describe how aspects of the organization that may lead to vulnerabilities (such as reliance on scarce or singular areas of expertise) are identified and mitigated

The application should describe the resource strategy, indicating the quantity of resources and the mix of disciplines and skills required as construction progresses through the various phases of the project (that is, design, pre‑construction, construction, commissioning and operation).

Where project work is being implemented, the application should show how the applicant’s resource strategy will be proactively managed to ensure that resource profiles and organizational arrangements remain fit for purpose.

In most cases, the applicant is also the responsible organization that will later operate the reactor facility. Where this is not the case, the responsibility for the reactor facility and its safety continues to reside with the applicant, who must supervise the construction and commissioning activities.

For more information on organizational responsibilities, see appendix E of REGDOC‑2.3.1, Conduct of Licensed Activities: Construction and Commissioning Programs [8].

Oversight of contracted work

The applicant shall ensure that, as a contractual obligation:

  • the applicant and the CNSC will have right of access to the premises of any supplier to the construction program (including off-site testing)
  • all sub‑suppliers will provide right of access to their premises by those clients who are suppliers to the construction program (including off-site testing)

The application should describe how the applicant will ensure contracted work (design, procurement and manufacturing, construction and commissioning) is carried out to the required level of safety and quality. Some considerations are:

  • establishing an effective commercial or supply chain strategy to enable delivery of safety case requirements
  • maintaining an “intelligent customer” capability for all work that may affect nuclear safety that is carried out on its behalf by any of the Tier 1 (main) contractors and suppliers (that is, engineering, procurement and construction (EPC); engineering, procurement and construction management (EPCM); and project management consultants and contractors (PMC+C))
  • ensuring the EPC, EPCM or PMC+C contractor maintains an “intelligent customer” capability for all work carried out by the contractor’s supply chain that may affect nuclear safety; for example, where a Tier 2 contractor (subcontractor) may use its own supply chain to meet the needs of its Tier 1 customer, and will need to procure items or services appropriately
  • issuing specifications that adequately describe the items or services, meet the safety case requirements and identify the required level of quality assurance; some examples are:
  • procurement specification
  • commissioning specification
  • design clarification
  • codes and standards requirements
  • description of any operational constraints
  • review of the specifications and the results of the commissioning activities
  • disposition and resolution of any design-related performance issues with the structures, systems and components (SSCs), in accordance with a formal design change process
  • for work with nuclear safety significance, and before placing any contract, evaluating and confirming that EPC, EPCM or PMC+C contractors and suppliers have the organizational, technical and project management capability, capacity and culture to deliver items or services to the specification
  • ensuring suppliers have quality management arrangements that are appropriate and consistent with the safety significance of the procured items or services
  • ensuring suppliers identify and categorize any deviations from specified requirements, and refer the deviations to the design authority and the authority having jurisdiction for assessment
  • ensuring suitable arrangements to mitigate the risk of counterfeit, fraudulent and suspect items (CFSI) entering the supply chain
  • ensuring arrangements are in place to capture and act on operational experience feedback from the safety case and supply chain management activities, sharing learning as appropriate within the organization and wider industry
  • conducting effective oversight and assurance of the supply chain, including the acceptance of items or services for work with nuclear safety significance

For more information on design and engineering activities, see section 5.1 of REGDOC‑2.5.2, Design of Reactor Facilities: Nuclear Power Plants [9]. In addition to describing how the expectations in that regulatory document will be met, this application should describe the following elements of the design authority:

  • design authority for each lifecycle phase up to and including commercial operation
  • other organizations with responsibility for the design of specific parts of the nuclear facility
  • the relationship, including authorities, accountabilities, roles and responsibilities between the design authority and the:
  • applicant
  • major technical support organizations
  • prime contractor and sub‑contractors
  • procurement organizations
  • commissioning and operations organizations
  • prerequisites for transferring the design authority to the operating organization, to ensure the recipient of the design authority has the requisite knowledge, expertise and resources to assume this responsibility

For more information on procurement, manufacturing, construction and commissioning, see REGDOC‑2.3.1, Conduct of Licensed Activities: Construction and Commissioning Programs [8].

Readiness for operation 

The application should describe the applicant’s management system and organizational arrangements for the transition from construction to commissioning to operation. This transition plan should:

·       include provisions for recruiting, training, assigning and retaining the required numbers of workers for optimal staffing levels, in a manner consistent with schedules for implementation and workloads

·       describe the policies, programs and processes to manage the key functions important to safety, with the timeline and milestones for their development and implementation; some examples of key functions are operations, maintenance and engineering

·       describe the arrangements for managing the information, such as an electronic document management system or a paper document management system

·       describe the arrangements for the transition or transfer where a contractor’s construction and commissioning management system is to be adopted, in whole or in part

·       identify the beginning of applicability and the point at which full implementation and control will occur, in line with the transition or transfer of SSCs

·       include measures for assessing the suitability and effectiveness of the elements of the transition plan during all stages of the transition

Detailed information on programs pertaining to operation is not needed for a licence to construct; however, the applicant must provide sufficient information to show that adequate provisions have been made in the design to address readiness for operation. This level of detail is intended to facilitate commissioning before fuel load, and to prepare the applicant for the transition to fuel‑in commissioning and operation upon receipt of a licence to operate.

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