ML20032D827
| ML20032D827 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/31/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20032D824 | List: |
| References | |
| NUREG-0800, NUREG-0800-13.1.1, NUREG-800, NUREG-800-13.1.1, SRP-13.01.01, NUDOCS 8111180013 | |
| Download: ML20032D827 (8) | |
Text
NU REG-0800 (Form;rly NUREG 75/087)
U.S. NUCLEAR REGULATORY COMMISSION Chi STANDARD REVIEW PLAN doe OFFICE OF NUCLEAR REACTOR REGULATION e....
13.1.1 MANAGEMENT AND TECHNICAL SUPPORT d'RGANIZATION
~
REVIEW RESPONSIBILITIES Primary - Licensee Qualification Branch (LQB) l Sect.ndary - Hone I.
AREAS OF REVIEW The LQB will review the corporate level management and technical organizations of the applicant for a CP and OL and its major contractors, including the nuclear steam supply system (NSSS) vencor, and architect / engineer (A/E) for the project; including the technical resources to support the nuclear power plant design, con-struction, testing, and operation.
The review for a construction permit will include an examination of the utility's responsibilities, technical staff and the interface arrangements and management controls used to assure that the design and construction of the facility will be performed in an acceptable manner.
The review for an operating license will examine the applicant's corporate organization and technical staff which will be in place to provide support for safe plant operation.
The objective of this review is to assure that the corporate management is involved with, informed about, and dedicate.d to the safe design, construction, test and operation of the nuclear plant and that rufficient technical resources have or are being and will be provided to adequately accomplish these objectives.
Part A below describes in detail the areas of review for a CP and Part B below describes in detail the areas of review for an OL.
A.
Construction Permit The applicant's past experience in the design and construction of nuclear power plants, and past experience in activities of similar scope and complex-ity should be described.
The coplicant's (utility's) management, engineering, and technical support organization, including organizational charts reflecting the applicant's current headquarters and engineering structure and planned modi-fications and additions to it to reflect the added functional responsibilities I
Rev. 2 - Julv 1981
"[
USNRC STANDARD REVIEW PLAN standard review plans are prepared for the guidance of the office of Nuclear Reactor Pegulation staff responsible for the review of 00 applications to construct and operate nuclear power plants. These documents are made available to the public as part of the 00 Commission's policy to inform the nuclear industry and tne general public of regulatory procedures and policies, standard review XM plans are not substitutes for regulatory guides or the Commission's regulations and compliance with them is not required. The G
standard review plan sections are keyed to the standard Format and Content of safety Analysis Reports for Nuclear Power Plants.
O Not all sections of the standard Format have a corresponding review plan.
[,
Published standard review plans will be revised periodically, as appropriate, to accommodate comments and to.eflect newinforme.
00 tion and emperience.
"O &
- Uwe Comments and suggestions for improvement will be considered and should be sent to the U.s. Nuclear Regulatory Commissior).
2 0' Office of Nuclear Reactor Regulation, Washington. D.C. 20555.
- associated with the addition of the nuclear plant shtuld also bs described.
These adifed responsibilities should be identified and should include items
- 1isted in 1 and 2 below.
~
- 1.
Design and Construction Responsibilities A description of the implementation or delegation of the following areas of responsibility should be included, Principal site-related engineering work such as meteorology, a.
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.
d.
Site layout with respect to environmental effects and security provisions.
e.
Development of safety analysis reports.
f.
Material and components specification review and ap' proval.
g.
Procurement of. materials and equipment.
h.
Management of construction activities.
2.
Preoperational Responsibilities The proposed plans for the management organization in regard to the following ite:1s of the initial test program should be described:
Davelopment of plans for the preoperational and startup testing a.
of the facility.
b.
Development and implementation of staff recruiting and training programs.
c.
Development of plant maintenance programs.
In regard to items 1 and 2 abov.e, the description should include how these responsibilities are delegated and implemented within and from the head-quarters staff and should identify the working or performance level and responsible organization unit, in::1uding an estimate of the number of persons expected to be assigned to each of the various units with responsi-bility for the project.
In addition describe the role the utility manage-i ment will have in interfacing with the nuclear steem system suppliers and the architect / engineer, including the required review of contractor work l
by the utility staff.
The PSAR should also identify general qualification requirements in terms of numbers, educational backgrounds, and experience for identified positions
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or classes of positions; and specific educational and experience background
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for assigned management and supervisory positions relative to items 1 and 2' above.
13.1.1-2 Rev. 2 - July 1981
. associated with the addition of the nuclear plant should also ba described.
These added responsibilities should be identified and should include items
_ listed in 1 and 2 below.
[-
~
(
- 1.
Design and Construction Responsibilities A description of the implementation or delegation of the following areas of responsibility should be included.
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.
d.
Site layout with respect to environmental effects and security provisions.
e.
Development of safety analysis reports.
~
f.
Material and components specification review and ap~ proval.
.g.
Procurement of. materials and equipment.
h.
Management of construction activities.
2.
Preoperational Responsibilities The proposed plans for the management organization in regard to the following items of the initial test program should be described:
Development of plans for the preoperational and startup testing a.
of the facil,ity.
b.
Development and implementation of staff recruiting and training programs.
c.
Development of plant maintenance programs.
In regard to items 1 and 2 abov.e, the description should include how these responsibilities are delegated and implemented within and from the head-quarters staff and should identify the working or performance level and responsible organization unit, including an estimate of the number of persons expected to be assigned to each of the various units with responsi-bility for the project.
In addition describe the role the utility manage-ment will have in interfacing with the nuclear steam system suppliers and the architect / engineer,..cluding the required review of contractor work by the utility staff.
The PSAR should also identify general qualification requirements in terms of numbers, educational backgrounds, and experience for identified positions
(.
or classes of positions; and specific educational and experience background
\\,'
for assigned management and supervisory positions relative to items 1 and 2' above.
13.1.1-2 Rev. 2 - July 1981
- For identified positions or classes of positions that have functional
- f-responsibil'ities for other than that of the CP application, the expected l
1{-
. proportion of time assigned to the other activities should be described.
In addition, the early plans for providing technical support for the operation of the-facility should be described.
i The CP-stage review (PSAR) of the'NSSS and A/E organizations includes a review ~of-their technical staff to perform the activity related to the application.
The information submitted should include a description of-l 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 exten-sive 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 of how this experience will
. -be applied to the particular utility project should be provided.
I B.
Operating License The FSAR should provide the following information:
(1) organizational charts of the applicant showing the corporate level management and technical support structure, including the relationship of the nuclear oriented.
portions of the structure to the rest of the corporate organization, and 4
I a description of the specific provisions which have been made for technical support for operations, (2) the organizational unit and any augmenting organizations, or other personnel that will manage or execute.any phase i
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 FSAR should (1) identify in terms of numbers, educational background and experience requirements for each identified position cr 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 q
13.1.1-3 Rev. 2 July 1981 L.....
For icentified positions or classes of positions that have functional responsibil'ities for other than that of the CP application, the expected l
(
. proportion of time assigned to the other activities should be described.
In addition, the early plans for providing technical support for the operation of the facility should be described.
The CP-stage review (PSAR) of the NSSS and A/E organizations includes a review of their technical staff to perform the activity related to the application.
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 requiremints for principal management positions related to the project.
For those NSSS and A/E organizations with exten-sive 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 of how this experience will be applied to the particular utility project should be provided.
B.
Operating License The FSAR should provide the following information:
(1) organizational charts of the applicant showing the corporate level management and technical support structure, including the relationship of the nuclear oriented portions of the structure to the rest of the corporate organization, and a description of the specific provisions which have been made for technical support for operations, (2) the organizational unit and any augmenting organizations, or other personnel that 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 FSAR should (1) identify in terms of 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 13.1.1-3 Rev. 2 - July 1981 e
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4.
. Fueling and refueling operations support 5.
Maintenance support 6.
Operations support 7.
Quality assurance 8.
Training 9.
Safety review 10.
Fire protection
=
11.
Outside contractual assistance
'In addition, LQB will coordinate other branches evaluations that interface with the overall review of the management and technical support organization as follows:
the Emergency Preparedness Licensing Branch (EPLB). reviews the acceptability of the emergency organization as part of its primary review responsibility for SRP Section 13.3; the Quality Assurance Branch
-(QAB) reviews the acceptability of the detailed quality assurance organiza-tion as part of its primary review responsibility for SRP Section 17.0; the Radiological Assessment Branch (RAB) reviews the acceptability of the radiation protection organization as part of its primary review'responsibi-lity for SRP Section 12.5.
For those areas of review identified above as being reviewed as part of
^
the primary review responsibility of other branches., the acceptance criteria necessary for the review and their methods of application are contained in the referenced SRP section of the corresponding primary branch.
II.
ACCEPTANCE CRITERIA 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 Part 50, S50.40(b).
Specific criteria which contributed to meeting S50.40(b) with respect to the CP
. review and OL review are described below in A and B, respectively.
A.
Construction Permit 1.
The applicant has identified and functionally described the specific organizational groups responsible for implementing responsibilities l
for the project (CP).
l l
2.
The applicant has described the method of implementing its responsibi-i lities 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.
i l
l 3.
Clear unambiguous management control and communications exist between the organizational units involved in the design and construction of the project.
l 13.1.1-4 Rev. 2 - July 1981
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4.
. Fueling and refueling operations support 5.
Maintenance support 6.
Operations support i
i 7.
Quality assurance
- 8.
Training 9.
Safety review 10.
Fire protection
=
11.
Outside contractual assistance
~In addition, LQB will coordinate other branches evaluations that interface with the overall review of the management and technical support organization as follows:
the Emergency Preparedness Licensing Branch (EPLB) reviews the acceptability of the emergency organization as part of its primary review responsibility for SRP Section 13.3; the Quality Assurance Branch
-(QAB) reviews the acceptability of the detailed quality assurance organiza.
tion as part of its primary review responsibility for SRP Section 17.0; the Radiological Assessment Branch (RAB) reviews the acceptability of the
-radiation protection organization as part of its primary review'responsibi-lity for SRP Section 12.5.
For those areas of review identified above as being reviewed as part of
^
the primary review responsibility of other branches., the acceptance criteria necessary for the review and their methods of application are contained in the referenced SRP section of the corresponding primary branch.
II.
ACCEPTANCE CRITERIA 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 Part 50, S50.40(b).
. Specific criteria which contributed to meeting S50.40(b) with respect to the CP review and OL review are described below in A and B, respectively.
A.
Construction Permit 1.
The applicant has identified and functionally described the specific organizational groups responsible for implementing responsibilities for the project (CP).
2.
The applicant has described the method of implementing its responsibi-
~
lities 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.
13.1.1-4 Rev. 2 - July 1981
4.
. Fueling and refueling operations support 5.
Maintenance support 6.
Operations support i
7.
Quality assurance
- 8.
Training 9.
Safety review '
~
10.
Fire protection 11.
Outside contractual assistance
~In addition, LQB will coordinate other branches evaluations that interface with the overall review of the management and technical support organization as follows:
the Emergency Preparedness Licensing Branch (EPLB) reviews the acceptability of the emergency organization as part of its primary review responsibility for SRP Section 13.3; the Quality Assurance Branch
.(QAB) reviews the acceptability of the detailed quality assurance organiza.
tion as part of its primary review responsibility for SRP Section 17.0; the Radiological Assessment Branch (RAB) reviews the acceptability of the radiation protection organization as part of its primary review'responsibi-lity for SRP Section 12.5.
For those areas of review identified above as being reviewed as part of
^
the primary review responsibility of other branches., the acceptance criteria necessary for the review and their methods of application are contained in the referenced SRP section of the corresponding primary branch.
II.
ACCEPTANCE CRITERIA The applicant's description of its resources to deal with safety-relsted 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 Part 50, S50.40(b).
. Specific criteria which contributed to meeting 950.40(b) with respect to the CP review and OL review are described below in A and B, respectively.
A.
Construction Permit 1.
The applicant has identified and functionally described the specific organizational groups responsible for implementing responsibilities for the project (CP).
2.
The app 1'icant has described the method of implementing its responsibi-lities 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.
13.1.1-4 Rev. 2 - July 1981
. 4.,
Substantive breadth and level of' experience and availability of min-poker exist to implement the responsibility for the project.
~
l 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 utility control over the decisions of the.A/E and NSSS vendor.
6.
Theapplicanthasdesignatedtheresponsibleorganizatiobs'thatwili'
~
participate in the test program and early plans indicate reasonable assurance that such. designated' organizations can collectively provide, the necessary 1evel 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.
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.
B.
-Operating License ~
~
The review and evaluation of management and technical organizational structure for Operating License Applicants is based on meeting the guidelines.of TMI Action Plan Item I.B.1.2 of.NUREG-0694 as augmented.
Specific criteria are as follows:
(
1.
The applicant has identified and described the organizational groups responsible for implementing responsibiliti'es for the initial test s-program, and technical support for the operation of the facility.
2.
The applicant has described the method of implementing its responsibi-lities 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 communica-tions exist between the organizational units involved in the management, operation, and technical support for~the operation of the facility (OL).
5.
Substantive breadth and level of experience and availability of manpower exist to implement the responsibility for 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 a case-by-case basis.
6.
Qualifications of the " Engineer in Charge" should meet or exceed those given in Section 4.6.1 of ANSI N18.1, cs endorsed by Regulatory l
Guide 1.8.
v Rev. 2 - July 1981 13.1.1-5 e
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Substentive breadth and level of' experience and availability of min-power exist to implement the responsibility for the project.
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5.
The applicant has clearly described the role and function of the A/E and NSSS venoor during both design and construction and has demonstrated
, utility control over the decisions of the A/E and NSSS vendor.
6.
TheapplicanthasdesignatedtheresponsibleorganizationsthatwilU
~
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.
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.
B.
Operating License
~
The review and evaluation of management and technical organizational structure for Operating License Applicants is based on meeting the guidelines.of-TMI Action Plan Item I.B.1.2 of NUREG-0694 as augmented.
Specific criteria are as follows:
(
1.
The applicant has identified and described the organizational groups responsible for implementing resp.wibilities for the initial test s
program, and technical support for the operation of the facility.
2.
The applicant has described the method of implementing its responsibi-lities 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.
f 4.
Clear management control and effective lines of authority and communica-tions exist between the organizational units involved in the management, operation, and technical support for'the operation of the facility i
(0L).
l S.
Substantive breadth and level of experience and availability of manpower exist to implement the responsibility for the initial test program and technical support for the operation of the facility.
The need to supplement the corporate structure with additional experienced personnel fer the initial years of operation will be determined on a l
case-by-case basis.
l 6.
Qualifications of the " Engineer in Charge" should meet or exceed those given in Section 4.6.1 of ANSI N18.1, as endorsed by Regulatory i
Guide 1.8.
i 13.1.1-5 Rev. 2 suly 1981
7.
Respansibilities for fire protecticn should conform to BTP CHEB 9.5-1 attached to SRP Section 9.5.1.
' 8.
The technical staff will be util.ized in the initial test program to the maximum extent practicable.
Participants in the test program should receive plant-specific training / indoctrination in the adminis-
~
2' trative controls for the test program prior to the start of testing.
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The level of staffing should be adequate based on the reviewer's judgment.
r...
~III. REVIEW PROCEDURES Each element of the SAR informat'un 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.
Ar.y exceptions or alternatives are to be carefully reviewed to assure 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 subject matter of this section of the SAR, the following points should be taken into consideration.
- ~The corpor, ate 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.
A corporate officer should clearly be responsible for nuclear activities, without heving ancillary responsibilities that might detract from his attention to nuclear safety matters.
Design and construction responsibilities,should be reasonably well defined in both numbers and experience of persons required to implement their responsibilities.
The reviewer must recognize that there are many accept-able ways to define and delegate job responsibilities.
At the CP stage, with respect to technical support for operations, the applicant's plans for head-quarters staffing 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 assure the responsibility can be met.
Variations in staffing may also be expected between applicants who lack prior experience with nuclear plant operation and those who have such experience.
It is important that the reviewer assure himself that applicants in the former category do not underestimate 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, con-structors) should be examined to assure 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 assure 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 abo'ut 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 organi-zation during such periods so that it is necessary to evaluate headquarters staffing plans in conjunction with those for the plant staff organization.
13.1.1-6 Rev. 2 - July 1981
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The reviewsr should assess the dagree of participation'during the design and
' construction phases.by that headquarters group that typically has plant operating r
.(generating) responsibility.
Interfaces between such a group and those with C project engineering responsibilities should be examined.
- The review procedure for this section consists, therefore', of:
1.
An examination of the information submitted to determine that all subject matter identified in subsection I above has been addressed.
L 2.
A comparison of the information with the acceptance criteria of subsection II above in the light of the additional points set forth earlier in this
__ _ SRP section.
l 3.
Review of information provided by the Office of Inspection and Enforcement position statement on the applicant's organizational and administrative I
t commitments made in the SAR.
-4.
Corporate headquarters and site visits by one or more members of the LQB' to review, discuss, and verify implementation of the management structure' "
.and technical resources.
With respect to site visits, in addition to LQB
~
members, review teams may include personnel from the Office of Inspection.
and Enforcement and the Division of Licensing.
In addition, if the applicant, as of the time the review takes place, has had experience in the operation of a previously licensed nuclear power plant, the/.-
reviewer may seek independent information relative to headquarters staffing and qualifications through the Office of Inspection and Enforcement, e.g., by
/
discussion with inspection personnel or review of inspection reports.
' ('
The reviewer then determines, based on the foregoing, the overall acceptability of the applicant's management and technical support organ'ization and staffing
- 'l an s.
s IV.
EVALUATION FINDING a
The reviewer verifies that the information presented and the review of that information support conclusions of the following type to be used in the staff's safety evaluation report:
A.
CP Sar~ety Evaluation Report The applicant has described clear responsibilities and associated resources for the design and construction of the facility and has described its 0 % s for management of the project and for utilization of the NSSS and A/t.
These plans have been reviewed and give adequate assurance that an acceptable organization and staff resources have been established to satisfy the appli-cant's commitments for the design and construction of the facility.
These findings contribute to the requirements of 10 CFR Part 50, 650.40(b); i.e.,
that the applicant is technically qualified to engage in design and con-struction activities.
B.
OL Safety Evaluation Report The applicant has described its organization for the management of, and its means for providing technical support for the plant staff during operation 13.1.1-7 Rev. 2 - July 1981
~ of ths ftcility.
These measur./ havs been reviewed and we conclude th:t
- the app,licant has an acceptabh arganization and adequate resources to provide offsite technical support for the operation of the facility under both normal and off-normal conditions.
These findings contribute to the sta'ff's collective judgment that the applicant complies with the requirements of 950.40(b) (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; that'the applicant has identified the organizational positions responsible for fire protection matters and the author-ities'that have been delegated to these positions to implement fire protection responsibilities, in accordance with the guideline of BTP CMEB 9.5-1.
V.
IMPLEMENTATION The following is intended to provide guidance to applicants and licensees re,garding the NRC staff's plans for using this SRP section.
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.
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, 650.40(b), " Common Standards." -
2.
Regulatory Guide 1.8, " Personnel Selection and Training."
3.
Regulatory Guide 1.68, " Initial Test Programs for Water-Cooled Nuclear Power Plants."
4.
Standard Review Plan Section 9.5.1, " Fire Protection Program."
5.
NUREG-0694, "TMI-Related Requirements for New Operating Licenses."
'6.
NUREG-0718, " Licensing Requirements for Pending Applications for Construct',n Permits and Manufacturing License."
7.
NUREG-0737, " Clarification of TMI Action Plan Requirements."
13.1.1-8 Rev. 2 - July 1981