ML081760279

Submittal of Technical Specification Change Request No. 86 to Delete Technical Specification Section 6.5, Review and Audit

ML081760279
Person / Time
Site:	Three Mile Island
Issue date:	06/11/2008
From:	Hagan J GPU Nuclear
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
5928-08-20046
Download: ML081760279 (37)

Text

• U GPU Nuclear, Inc.

(OGPv Route 441 South Post Office Box 480 NUCLEAR Middletown, PA 17057-0480 Tel 717-944-7621 June 11,2008 5928-08-20046 10CFR50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 THREE MILE ISLAND NUCLEAR STATION, UNIT 2 (TMI-2)

POSSESSION ONLY LICENSE NO. DPR 73 DOCKET NO. 50-320 TECHNICAL SPECIFICATION CHANGE REQUEST (TSCR) NO. 86

SUBJECT:

DELETION OF TECHNICAL SPECIFICATION SECTIONS 6.5, REVIEW AND AUDIT In accordance with 10 CFR 50.4(b)(1), enclosed is TMI Unit 2 Technical Specification Change Request (TSCR) No. 86. The proposed change will delete the TMI-2 Technical Specification (TS) section 6.5, Review and Audit. TS 6.5.1 Technical Review and Control requirements and TS 6.5.3 Audits requirements will be implemented by the current and proposed changes to the GPU Nuclear Post-Defueling Monitored Storage Quality Assurance Plan for Three Mile Island Unit 2 (PDMS QAP). TS 6.5.2 Independent Safety Review Function requirements will be deleted with no replacement.

Using the standards in 10 CFR 50.92, GPU Nuclear has concluded that this proposed change does not constitute a significant hazards consideration, as described in the enclosed analysis performed in accordance with 10 CFR 50.91 (a)(1).

Enclosure 1 provides the list of regulatory commitments for this request. Enclosure 2 provides the Safety Evaluation and No Significant Hazards Consideration Analysis. Enclosures 3 and 4 provide the revised and marked-up TS pages, respectively. Enclosures 5 and 6 provide the marked-up PDMS QAP pages and the Exelon/AmerGen Station Qualified Review procedure AD-AA-102, respectively, for information only.

Pursuant to 10 CFR 50.91 (b)(1), a copy of this TSCR is provided to the designated official of the Commonwealth of Pennsylvania, Bureau of Radiation Protection, as well as the chief executives of the township and county in which the facility is located.

GPU Nuclear requests that the review and approval of this request be coordinated with a similar Emergent proposal for TMI-1, dated November 13, 2007 (ML073240040) so that the implementation of the amendment requests can be coordinated simultaneously at both TMI-1 and TMI-2.

There is one regulatory commitment contained in the enclosure to this letter. Please contact Adam Miller of TMI-1 Regulatory Assurance at (717) 948-8128 if you have any questions.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 11 th day of June, 2008.

Very truly yours, Joseph J. Hagan President and Chief Nuclear JJH/awm

Enclosures:

1) List of Regulatory Commitments

2) Safety Evaluation and No Significant Hazards Consideration Analysis

3) TMI-2 Technical Specifications Revised Pages

4) Markup of TMI-2 Technical Specifications Revised Pages

5) Markup of TMI-2 PDMS QAP Revised Pages

6) Exelon/AmerGen Procedure, AD-AA-102, Station Qualified Review cc: USNRC Region I Administrator USNRC TMI-2 Senior Project Manager USNRC TMI Senior Resident Inspector Chairman, Board of Supervisors of Londonderry Township Chairman, Board of County Commissioners of Dauphin County Director, Bureau of Radiation Protection, PA Department of Environmental Resources File No. 08020

Enclosure 1 List of Regulatory Commitments The following table identifies those actions committed to by GPU Nuclear in this document. Any other statements in the submittal are provided for information purposes and are not considered to be regulatory commitments.

COMMITMENT TYPE COMMITTED DATE ONE-TIME PROGRAMMATIC ACTION (Yes/No)

(Yes/No)

GPU Nuclear commits to revising the applicable GPU Nuclear PDMS QAP for the Three Mile Island Unit 2 sections Implement with Yes No 3.3 and 5.2 as described in this amendment submittal (Enclosure 5) for independent technical reviews (Station Qualified Reviews)

Enclosure 2 TMI Unit 2 Technical Specification Change Request No. 86 Safety Evaluation and No Significant Hazards Consideration Analysis

5928-08-20046 Enclosure 2 Page 1 of 8 1.0 Technical Specification Change Request (TSCR) No. 86 GPU Nuclear requests that the revision for Table of Contents page vi, and pages 6-2 through 6-6 be inserted into the existing TMI-2 Technical Specifications (TS).

The revised pages (showing the change location with a vertical bar on the right side of the page) are provided in Enclosure 3. Enclosure 4 provides a markup of the current pages. Enclosure 5 provides a markup of the proposed changes to the GPU Nuclear Post-Defueling Monitored Storage Quality Assurance Plan for Three Mile Island Unit 2 (PDMS QAP) (Reference 1) for information only. Enclosure 6 provides the Exelon/AmerGen procedure for performing independent technical reviews, AD-AA-1 02, "Station Qualified Review," for information only. GPU Nuclear plans to use elements of this procedure to perform independent technical reviews for TMI-2.

2.0. Description of Proposed Change The proposed changes will specifically delete the Technical Specification (TS) 6.5.1 requirements for Technical Review and Control, utilizing instead the Technical Review and Control and Design Control requirements of the NRC-approved GPU Nuclear Post-Defueling Monitored Storage Quality Assurance Plan for Three Mile Island Unit 2 (PDMS QAP) (Reference 1) and proposed changes to the PDMS QAP. The proposed changes will delete the TS 6.5.2 requirements for the Independent Safety Review (ISR) Function process with no replacement process. The proposed changes will also delete the TS 6.5.3 requirements for Audits, utilizing instead the Audit process described in Section 18 and Appendix A of the PDMS QAP.

3.0 Background AmerGen has submitted a TMI Unit 1 Technical Specification Change Request (TSCR)

No. 330, "Deletion of Technical Specification Requirements for Review and Audit, and Additional Administrative Changes," on November 13, 2007 (Reference 2). Part of this TSCR will remove the Responsible Technical Reviewer (RTR) and Independent Safety Review (ISR) programs for TMI-1. TMI-2 also uses the same RTR and ISR programs and qualified personnel for technical review and audit activities performed on TMI-1.

GPU Nuclear wants TMI-2 to maintain consistent technical review and audit programs and personnel similar to TMI Unit-1 and, therefore, is submitting a similar TSCR.

4.0 Technical Analysis The proposed TS changes conform to NRC regulatory guidance presented in the Review and Audits and Procedure Review Process sections of Administrative Letter 95-

06. Accordingly, a technical specification/process matrix has been developed containing the existing TS requirements and a reference to an existing section of the PDMS QAP.

No relocation of deleted TS requirements to the PDMS QAP is necessary since the applicable Technical Review and Control and Audit deleted TS requirements are contained in existing PDMS QAP requirements and proposed changes associated with this submittal (Enclosure 5) and are equivalent to the TS requirements being deleted; except for the ISR program, which is being deleted. Therefore, no "relocation" of these

5928-08-20046 Enclosure 2 Page 2 of 8 deleted TS to the PDMS QAP is required. Future changes to the technical review and audit requirements of the PDMS QAP are governed by regulation 10CFR50.54(a).

The regulation governing TS requirements is 10 CFR 50.36 and it states for administrative controls that they are "the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." The specific content of the administrative controls section of the TS is, therefore, that information which the NRC deems essential for the safe operation of the facility, and which is not already adequately covered by other regulations. Accordingly, the NRC has determined that requirements that are not specifically required under 50.36(d)(5), and are not otherwise necessary to obviate the possibility of an abnormal situation, or event, giving rise to an immediate threat to the public health and safety, can be removed from the administrative controls section of the Technical Specifications. The scope of this license amendment includes deletion of the Technical Review and Audit sections from the TMI-2 TS.

Accordingly, the proposed TS changes meet the above requirements in that the subject sections are not otherwise necessary to obviate the possibility of an abnormal situation or event, giving rise to an immediate threat to the public health and safety. The proposed removed sections involve procedure preparation, review and approval activities, design control, independent safety reviews and specification of activities required for audits.

In addition, the Standard Technical Specification (STS) Administrative Control sections

-do not contain the amount of detail for Review and Audit as found in the TMI-2 TS 6.5 sections. The NRC has approved NUREG-1430, Standard Technical Specifications -

Babcock and Wilcox Plants. The Standard Technical Specifications were developed based on the criteria in the "Final Commission Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors," dated July 22, 1993, and subsequently codified in 10 CFR 50.36. The preface to these documents encourages licensees to adopt some or all of the improved TS into their existing TS. The TS sections proposed herein for deletion do not appear in the improved STS presented in NUREG-1430, and accordingly, are not required to be in the TS.

The technical review RTR program will be replaced by the technical review program known as the Station Qualified Review (SQR) program (Enclosure 6). The SQR program will be implemented through station qualified reviewers (SQRs). The RTRs and SQRs have similar qualification requirements. The SQRs' qualification requirements meet the appropriate sections of the ANSI/ANS-3.1 revision that is committed to for TMI-2, which is ANSI/ANS 3.1-1978. Under the new proposal, TMI-2 SQRs will not have the alternate qualification path of seven years experience in lieu of meeting the ANSI 3.1 standard, as the current TS afford. The PDMS QAP Section 3.3 will be revised to state that design verification shall be performed by competent and qualified individuals(s) other then those who performed the original design and completed prior to relying upon the component, system, structure, or computer program to perform its function. The PDMS QAP Section 5.2 will be revised to state that independent technical reviews shall be in accordance with TMI approved procedures and that procedures within the scope of the PDMS QAP shall be independently technically reviewed prior to implementation by a qualified individual knowledgeable in the area affected. The technical reviewer shall be an individual other than the originator.

5928-08-20046 Enclosure 2 Page 3 of 8 The ISR Function TS requirements and associated ISR program are being deleted with no replacement process. The need for the ISR Function originated from the post TMI Unit 2 accident and TMI-1 restart period and is no longer required because there are no longer any operational systems classified as safety related systems. TMI-2 was originally designed and constructed in compliance with appropriate 10CFR50 Codes and Standards. Due to the non-operating and defueled status ofTMI-2 during the PDMS phase, there are no structures, systems and components that perform a safety function.

Therefore, technically, there cannot be independent safety reviews. TMI-2 TS do identify certain structures, systems and components required to be operable and require the application of design and procedure controls on a graded basis should modifications or new/revised procedures be required. The requirements of the PDMS QAP Section 3.0, Design Control, and Section 5.0 Instructions, Procedures, and Drawings, provide for adequate design and procedure controls and thus ISR requirements are no longer applicable and need to be deleted from the TS.

Revisions to the administrative controls section of the TMI-2 TS are currently subject to a no significant hazards consideration determination pursuant to 10 CFR 50.92. This determination is oriented to the design and operational requirements described in the TS. The administrative controls selected for deletion are considered by the NRC in the above referenced AL 95-06 to be quality assurance requirements, and therefore qualify for incorporation into documents describing the licensee's quality assurance program.

As stated in AL 95-06,10 CFR 50.54(a) and 10CFR50.59 are the appropriate regulations for controlling changes to these and other quality assurance program requirements.

Future changes to the PDMS QAP and the independent technical review process, as described in the PDMS QAP, are controlled by 10CFR 50.54(a) process. Prior NRC approval is required of any changes to the quality assurance program that reduce the commitments in the program description as accepted by the NRC. Accordingly, the proposed license amendment removing these administrative requirements from the TS while utilizing documents subject to the controls of 10 CFR 50.54(a), results in an equivalent level of regulatory authority while providing for a more appropriate change control process.

Technical Specification/Process Matrix TMI TS Section TS Topic PDMS QAP Evaluation Section 6.5 Review and Audit 6.5.1 Technical Review & 5 Equivalent Control 6.5.1.1 TS 6.7 Procedures 5 Equivalent 6.5.1.2 TS Appendix A 5 Note 1 6.5.1.3 Test & Experiments 14 Equivalent 6.5.1.4 Modifications 3 Note 2 6.5.1.5 TS Violations 5 Note 1 6.5.1.6 Reportable Events 5 Note 1

5928-08-20046 Enclosure 2 Page 4 of 8 6.5.1.7 Cross-Disciplinary 5 Note 1 Reviews 6.5.1.8 Written records for 5 and 17 Equivalent Technical Reviews 6.5.1.9 Qualifications for 5 Note 3 Responsible Technical Reviewers (RTRs) 6.5.2 Independent Safety Review (ISR) 6.5.2.1 Director responsibilities Deleted 6.5.2.2 Independence for ISRs Deleted 6.5.2.3 a through j Technical Experience Deleted areas 6.5.2.4 Technical Consultants Deleted 6.5.2.5 Scope of ISR Deleted 6.5.2.5.a UFSAR Changes Deleted 6.5.2.5.b Safety-Related Deleted Procedure Changes 6.5.2.5.c TS changes & License Deleted Amendments 6.5.2.5.d Violations, Deviations Deleted and Reportable Events 6.5.2.5.e Audit Report Summaries Deleted 6.5.2.5.f Other matters involving Deleted plant 6.5.2.6 Qualifications for ISRs Deleted 6.5.2.7 ISR Records Deleted 6.5.3 Audits 6.5.3.1 Audits performed in 18 & Appendix A Equivalent accordance with PDMS QAP 6.5.3.1 .a Conformance to TS & 18 & Appendix A Equivalent License 6.5.3.1 .b PDMS QAP activities 18 & Appendix A Equivalent 6.5.3.1.c Radiation protection Plan 18 & Appendix A Equivalent 6.5.3.1 .d Fire Protection Program 18 & Appendix A Equivalent 6.5.3.1 .e Independent Fire 18 & Appendix A Equivalent protection and loss prevention program-licensee personnel 6.5.3.1 .f Independent Fire 18 & Appendix A Equivalent protection and loss prevention program-outside consultant 6.5.3.1 .g ODCM 18 & Appendix A Equivalent 6.5.3.1 .h Other areas of unit 18 & Appendix A Equivalent operation I 6.5.3.2 Audits report records 18 & Appendix A Equivalent

5928-08-20046 Enclosure 2 Page 5 of 8 Note 1: The change is equivalent with the proposed changes to PDMS QAP Section 5.2.

The scope of, and requirements for, technical reviews and independent technical reviews are described in the SQR program implemented by Exelon/AmerGen Procedure AD-AA-1 02, "Station Qualified Review" (Enclosure 6). GPU Nuclear plans to use the elements of this procedure to perform independent technical reviews for TMI-2.

Note 2: The change is equivalent with the proposed changes to PDMS QAP Section 3.3 Note 3: SQRs are qualified to the education and experience requirements of ANSI/ANS-3.1 1978 to which the TMI station (Units 1 and 2) are committed.

5.0 Regulatory Analysis 5.1 No Significant Hazard Consideration GPU Nuclear has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

No physical changes to the TMI-2 Facility, will occur as a result of this proposed amendment. The proposed changes will not alter the physical design or operational procedures associated with any plant structure, system, or component. As such, the change is administrative in nature and does not affect initiators of analyzed events or assumed mitigation of accidents.

The proposed changes involve the deletion of several administrative requirements from the Technical Specifications (TS). The TS requirements involve Technical Review and Control and Audits that are now controlled under the TMI-2 Post Defueling Monitored Storage Quality Assurance Plan (PDMS QAP).

In accordance with the guidance provided in NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls related to Quality Assurance," the proposed changes are an acceptable method for removing technical specification quality assurance requirements.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

5928-08-20046 Enclosure 2 Page 6 of 8 The proposed changes are administrative in nature. The proposed changes do not alter the physical design, safety limits, or safety analysis assumptions associated with the operation of the plant. Accordingly, the changes do not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant structure, system, or component to perform their safety function.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes conform to NRC regulatory guidance regarding the content of plant Technical Specifications. The guidance is presented" in Administrative Letter 95-06 and NUREG-1430. The relocation of these administrative requirements to the PDMS QAP will not reduce the quality assurance commitments as accepted by the NRC, nor reduce administrative controls essential to the safe operation of, the plant. Future changes to these administrative requirements will be performed in accordance with NRC regulation 10 CFR 50.54(a), consistent with the guidance identified above. Accordingly, the replacement of TS requirements by existing proposed TMI-2 PDMS QAP requirements results in an equivalent level of regulatory control.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, GPU Nuclear concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria 10CFR 50.36, Technical specifications 10 CFR 50.36, "Technical specifications," provides the regulatory requirements for the content required in a licensee's TS. 10 CFR 50.36(d)(5), Administrative Controls states:

Administrative controls are the provisions relating to the organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

The NRC provided guidance for the content of TS in its "Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors", 58 FR 39132, July 22, 1993. In particular, the NRC indicated that certain items could be relocated from the TS to licensee-controlled documents, and identified criteria to be used to determine the functions to be included in the TS. The NRC's policy statement provides that particular details of administrative controls may be relocated to licensee-controlled documents where section 50.54, 50.59, or other regulations provide adequate regulatory control.

The NRC adopted revisions to 10 CFR 50.36, "Technical Specifications," pursuant to

5928-08-20046 Enclosure 2 Page 7 of 8 which the rule was revised to codify and incorporate these criteria. In adopting the revision of the rule, the NRC indicated that the intent of these criteria could be utilized to identify the optimum set of administrative controls in the TS. The NRC further concluded that the specific content of the administrative controls section of the TS is, therefore, that information which the Commission deems essential for the safe operation of the facility and which is not already adequately covered by other regulations.

Accordingly, the NRC has determined that requirements that are not specifically required under 50.36(d)(5), and are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety can be removed from TS administrative controls.

Consistent with this policy position, the NRC staff issued Administrative Letter (AL) 95-06, December 12, 1995, identifying TS administrative control requirements that qualify for relocation to licensee quality assurance control documents subject to the controls of 10 CFR 50.54(a). Requirements identified by AL 95-06 included review and audit, procedure review and approval, and record retention requirements. The scope of changes proposed herein conforms to the NRC staff position presented in AL 95-06.

NRC approved NUREG-1430, Standard Technical Specifications - Babcock and Wilcox Plants were developed based on the criteria in the "Final Commission Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors," dated July 22, 1993, and subsequently codified in 10 CFR 50.36. The preface to these documents encourages licensees to adopt some or all of the improved TS into their existing TS.

The TS sections proposed herein for relocation do not appear in the improved Standard Technical Specification (STS) presented in NUREG-1430, and accordingly, are not required to be in the TS.

The proposed license amendment to remove these administrative requirements while utilizing documents subject to the controls of 10 CFR 50.54(a) conforms to NRC guidance as stated above, and results in an equivalent level of regulatory control.

GPU Nuclear has determined that the proposed changes do not require any exemptions or relief from regulatory requirements and do not affect conformance with any General Design Criteria.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 Environmental Consideration The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(1 0).

Therefore, pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

5928-08-20046 Enclosure 2 Page 8 of 8 7.0 References

1) GPU Nuclear Post-Defueling Monitored Storage Quality Assurance Plan for Three Mile Island Unit 2 Revision 11, dated May 12, 2008

2) Letter from Pamela B. Cowan (AmerGen) to U.S.Nuclear Regulatory Commission, " Oyster Creek Technical Specification Change Request No.

336, TMI Unit 1 Technical Specification Change Request No. 330, Deletion of Technical Specification Requirements for Review and Audit, and Additional Administrative Changes," dated November 13, 2007 (ML073240040) 8.0 Precedence

1) Oyster Creek Nuclear Generating Station (OCNGS), and Three Mile Island Nuclear Generating Station, Unit 1 (TMI-1) Re: Amendments to Relocate the Independent Onsite Safety Review Group Function to the Quality Assurance Topical Report (TAC NOS. MC2406 and MC2407), dated November 8, 2004 (ML042710014).

Enclosure 3 TMI-2 Technical Specifications Revised Pages

TABLE OF CONTENTS ADMINISTRATIVE CONTROLS SECTION TITLE PAGE 6.0 ADMINISTRATIVE CONTROLS 6-1 6.1 RESPONSIBILITY 6-1 6.2 ORGANIZATION 6-1 6.2.1 GPU NUCLEAR ORGANIZATION 6-1 6.2.2 TMI-2 ORGANIZATION 6-1 6.3 UNIT STAFF QUALIFICATIONS 6-1 6.4 DELETED 6-1 6.5 DELETED 6-2 6.5.1 DELETED 6-2 DELETED 6-2 DELETED 6-3 DELETED 6-3 6.5.2 DELETED 6-3 DELETED 6-3 DELETED 6-4 DELETED 6-5 DELETED 6-5 6.5.3 DELETED 6-5 DELETED 6-6 6.5.4 DELETED 6-6 6.6 REPORTABLE EVENT ACTION 6-7 Three Mile Island - Unit 2 vi Amendment 48, 59-,

ADMINISTRATIVE CONTROLS 6.5 DELETED 6.5.1 DELETED DELETED Three Mile Island - Unit 262Amn 6-2 et4, Amendment 4 48,54-,

ADMINISTRATIVE CONTROLS DELETED DELETED 6.5.2 DELETED DELETED Three Mile Island - Unit 2 6-3 Amendment 50,-54,5-7,,

ADMINISTRATIVE CONTROLS DELETED Three Mile Island - Unit 2 6-4 Amendment 4 8, 54, 57,

ADMINISTRATIVE CONTROLS DELETED DELETED 6.5.3 DELETED Three Mile Island - Unit 2 6-5 Amendment 52,

ADMINISTRATIVE CONTROLS DELETED 6.5.4 DELETED Three Mile Island - Unit 2 6-6 Amendment 52,-54, 59,

Enclosure 4 Markup of TMI-2 Technical Specifications Revised Pages

TABLE OF CONTENTS ADMINISTRATIVE CONTROLS SECTION TITLE PAGE 6.0 'ADMINISTRATIVE CONTROLS 6-1 6.1 RESPONSIBILITY 6-1 6.2 ORGANIZATION 6-1 6.2.1 GPU NUCLEAR ORGANIZATION 6-1 6.2.2 TMI-2 ORGANIZATION 6-1 6.3 UNIT STAFF QUALIFICATIONS 6-1 6.4 DELETED 6-1 6.5 REVIEW AND AUDIT DELETED 6-2 6.5.1 TECHNICAL REVIEW AND CONTROLDELETED 6-2 ACTIVITIESDELETED 6-2 REGORDSDELETED 6-3 QUALI FI!CCATIONSDELETED 6-3 6.5.2 INDEPENDENT SAFETY REVIEW DELETED 6-3 FUNGTIONDELETED 6-3 RESPONSI BIL!TI!ESDELETED 6-4 QUALI FICATIONSDELETED 6-5 REGORDSDELETED 6-5 6.5.3 AUI-T-SDELETED 675 RECORDSDELETED 6-6 6.5.4 DELETED 6-6 6.6 REPORTABLE EVENT ACTION 6-7 Three Mile Island - Unit 2 vi Amendment 48, 59

ADMINISTRATIVE CONTROLS 6.5 DELETED REVIEW AND AUDIT 6.5.1 DELETED TECHNICAL REVIEW AND CONTROL The GPUI Nuclear Cognizant Officer shall be recponsiblo, through it;r ontracted agent, the T-MI 1 icense.Pqp held& for ensuring the preparation reiw1n approval of documnents required by the activities described in Sections 6.5.1.1 truh651 .7-as assigned in the TIVI review and approval m atr*i xWthnR his area orDos;*ponsyl rfunctfioRnI of assigned in the GPUrN Review and Approval Matrix. Im*plemenn**, g approvals shall be poerm..ed at the cogniZan manager level or above.

DELETED AGT4VtTIES 6.5.1-.1 Each procedure required by Sectin 6.7 and other proccduro, including those for tests and experiments and SUB3ST-ANT-IVE CNGSthereto shall be prepared by-a designated i;ndvidual(s) or group knowledgeable I i the area affected by the procedu*re Each such procedure, and SUBSTANTIVE CHANGES thereto, shall be given a technical review by an *,dividwals(s) or group other than the preparer, but who may be from the same organization as the individual who prepared the propedurwe or c-hange.

6.5.1.2 Proqposed changes to the T-echnical Specifications shall be reviewed by a-knowledgeable individual(s) or group other than the individual(s) Or group Who prepared the. change.

6.5.1.3 Proposed tests and experim~ents Ash;;" be reviewed by a knowledgeable individual(s) or group other than the preparer but who may be from the same divisn*; as the individul who prepared- the tests a-nd expevriFmfent.

6.5.1.4 Prps dmodfications to unit 6tructuros, systems, and compnPGents nocessar, t mananthe PDMVS conditi0on as described in; the PDMVS SAR shall be designed by an individual/organization knowledgoablo in the areas affected by the proposed, modifitin., such m-odificatiwon

,Each ,h-.all bhe techRGcally reviewed by an individual/group other than the individal/,group which designRed the mondification but ma" be from the sam:e group as the indivi.Xdu'al.w..ho- designed the mo-d-ificr-ationA.

6.5 1.5 Investigation of all violations of the T-echnical SpecificationS including the proparation and erxrdigof repeotS covering evaluation and recommendations to prevent recurrene, shall be reviewed by a kRowledgeable individual(s)group otheFr than the inRdividual/group which p9efGFmed the finvestigation.

66.5 1.6 All REPORTABLE EVENTS shall be reviewed by an individual/group other than the individul/group which prepared the repe.*-"

6.5.1.7 lndividuals responsible for reviews pe-Ffrmed iR accordanRc with SeGt*iR 6.5.1 .1 through 6.5.1.6 shall include9 a determinatio of whether or net additiRo.l creos disiplinar,' reie is nessary. if deemed nocessar,', such review Rhall Three Mile Island - Unit 2 6-2 Amendment48,54

ADMINISTRATIVE CONTROLS be porformed by the appropriate personnmel. Individuals responsible for review conSied unde I rGF Sections, 6.5.1.1, 6.5.1.3, and 6.5.-1.1 hl re-nder dtriain Rwriting With regard to whether or net NRC approval isrequired pursuant to 10 Dn DELETED PRGORDS 6-5.1-8 Wr~itton records of activities performned in accordance-A with Setos6511through 6.5.1.7 shall be ma-intained in accord;iance wvith Sec-tion 60.9.

DELETED QUALIFICATIONS 651.0 6sponsible TcnalReviewxersA shall meet Or exceed the qualific-atlions of ANSIRANIS 3.1 of 1I7 octienR 1.6 or 1.4 for applicable disciplines, or have 7-years of appropriate experience in the fiold of his or her specialty. Credit towwrd experiene will ,begiveR for advanred degrees oR a one to nenbasis up to a maxwimu,,m. of two years. Responsible Technical Reviewe9rs shall be designated in 6.5.2 DELETED INDEPENDENT SAFET REVIEW DELETED FNCT_.N 6.5.2.1 The GPU11 Nuclear Cogniz-nt Offir.*-shall be reSponsibl9, throWuh its ontr*a*ted agent, the TMIVI 1 ~icense holder, for ensuring the independent safety review of the subjects desrcribe*d in Section 6.5.2.5, as assigned iR the TMI Review.' andl ppreval Mat~x 6.5.2.2 In.dependet safety review. shall be completed by an individual Or Group not having direct responsblR o h performanc9-eof the ac~tivities under review, but who may be from the same funtoal cgnqizant organization as, the idividual or grou1p perfrm;iRg the r;igiRal weok.

6.5.2.3 Q1U2r Inc. shall colleGt6vely have access to the expe;ioh an;-d competence required to independntly review subjectv in the following aFreas a.Nuclear Unit E~peratiens6

b. Nuclear engineering Chem*Istry

1. and-radoc;mst-d- Metalawgy Three Mile Island - Unit 2 6-3 Amendment 50,4,5

ADMINISTRATIVE CONTROLS

e. Instrumentation and control

f. R-adiological safety,

g. Mechanical engineering h.PElectrical engineering AdMiRistrative controls aRd quality assuranc practic I. Other appropriate fields uca.. ra;dCioctiV WAstR mana.gement oper.ations ass9ocated with the uni~que' cactrtisOf TMI12-.

i mi * *I i L E I A 6i.5.2.4 Uonsouitans m~ay Pe utmlzea as aeterminea by theO Q11 rGcearl;~nZant V U-flicr-,-

to p....oi.e exper. a..ce.

DELETED RESPONSIBILITIES 6.5.2-5 TheI fomlloinalg 6u1l3jectr, snail

, o1inerpendently rev'ieed 1,Y InldepeRnet- bc.1.

IReviqAewer (ISRs):

a. WrFlten evaluations Of changesF- in the f-;ac*iity as descr*-ibed inthe Safety Analysis Rleport, of change inpoeures as described in the Safetyx Analysirs Report, and-of t~esots orF experiments neAt- descuribed- inAthe Safety Analysis Report, which are comnpleted without prior NRC approv al u nder the provisions,of 10-CFPR 50.59(G) (1). This review is, to verif' th-at sc changes, tests or experim~ents- did net involve -A c-hange in the Techmnial Specif icationso reursNRCapproval pursuant to10 C=R 50.59 Such rGeviws need not be pe~fermed prior toipeenain

b. Proposed change in proedrs, proposed changes in the facility, or pro~poe-Ad- tessts:or cxperFimentG, any Of which involves, a change in the Techncal pecifications oreuesNRC approval pursuant to 10 CFR 50).59(c). MaR#ers of this, knshale reviewed priort sbifa to the NRG.

G. Proposed changes to T-echnical Specificationsr or"liense amendments, shall be reviewed prior to submittal to the NRC for approval-.

d. Volatonsdeviations, and reportable events wic require reporting to the NSRC inwriting. Such reviews are pe~rmeaed- after the fac-t. Revi.Xew of evens cverd uner hissubsectAion srhall include results of any investigations.m.ade8 -andthe reco~mmnendations resulting from suc~h inRvestigations to prevent orreuc the probability of recu1rrence of the event.

Three Mile Island - Unit 2 6-4 Amendment 48, 54, 57

ADMINISTRATIVE CONTROLS p.Wri#ttn summaries ofaadit repo~ts in the areas specified in Soction 6.5.3.

f. AnY other m~atters involving the plant which a reViewer dooms appropriate for conideatin o whch s rforodto-the independent rvoos DELETED QUALIFICATIONS 6.5.2.6 The ISRS srhall Rpithor h-avo- a-BRac-holors Degree inEngineering or the Physical S;iences and five years of professional level expIienR e i the area beiRg reviewed orr have nine years, f app*r*Friate experienRe inth field Of his or her specialty. An individual perfoFrming reviews may posse coptne in Mere than one specialty area. Credit toward exeiec ill be given for advanc~ed degrees- on a one for one basis, up to a maximum of two "ears.

DELETED PREGOR 6.5.2.7- Repets of reiesncopasse6d in Section 6-3.5.22.5- shall be m-aint-ained in accordance with Section 6.9.

6.5.3 DELETED AUPDITS 6.5.3.1 Audt of untactivites shall b6 performed in accordance with the TMVI -2 PDMVS QA Plan These-, auddits, shall encompass:

a. The -onforrnmance of unRit operatfionG to prvsoscnandwithin the Technical Specifications,and applicable-li-enpsecodtns bh. The performance ofatvte eurdby the PIDMVS QA Plan.

c.The Radiation Protection Plan and applicable implementfing procedures.

d. The Fire Protpec-tion Program and implementing procedIures.

e.An independent fire protection and lo6s prevention programn inspection and technical audit shall be performed- utilizing either quialified- licvensee pcrsonnel or an outside fire lprotection firm.

f. An. inspection and audit

of the fire protection and loss prevention program by an outside qualified fire con-suwltant.

Three Mile Island - Unit 2 6-5 Amendment 52

ADMINISTRATIVE CONTROLS g.The ODOMV and irnp9omonting procoduro-S.

h. AnY o-therF arF-Reaf unit operationcosdee appropriate by the PDMVS Manager Or the GPU1 Nuc'lear Cognizant Omeffcr.

DELETED REZORDS 6.5.3.2 Audit repFns encompassed by Section, 6952.1 h*All bo f'.i ard- d for actigonh to the management positions responsible for the areas audited- and- the G2PU ucea Cognizant Officer within 60 days after completion of theaaudit. Upper managemenRt shall1 be inomdin acodac ith the TMINA2 P-DMS QA Plan.

6.5.4 DELETED Three Mile Island - Unit 2 6-6 Amendment 62,-64,59

Enclosure 5 Markup of TMI-2 PDMS QAP Revised pages

Document Type: Number:

(GONUCLEAR U

• Plan 1000-PLN-7200.04

Title:

Revision: Page:

GPU Nuclear Post-Defueling Monitored Storage 11 18 of 44 Quality Assurance Plan for Three Mile Island Unit 2 3.0 DESIGN CONTROL

.3.1 TMI-2 was originally designed and constructed in compliance with appropriate 10 CFR 50 Codes and Standards. Due to the non-operating and defueled status of TMI-2 during PDMS, there will no longer be any structures, systems, or components which perform a safety function. However, the TMI-2 Technical Specifications do identify certain structures, systems, and components required to be operable. Such structures, systems, and components are considered within PDMS QA Plan Scope and, thus, require the application of design controls on a graded basis should modifications be required. Systems and major components within PDMS QA Plan Scope are identified in a Component Record List (CRL) document.

3.2 To the extent defined in Section 2.0, measures shall be established for PDMS to ensure design criteria are included or correctly translated into design documents. These measures, as a minimum, shall ensure that applicable design inputs are identified and documented. Changes from approved design inputs shall be identified, approved, documented, and controlled. Inputs shall be translated into design output documents containing the teclmical and quality requirements that must be satisfied.

3.3 To the extent necessary, design control measures shall be implemented by controlled written procedures. Such procedures may address the following design activities:

3.3.1 The organizational structure, authority, and responsibility of personnel involved in preparing, reviewing, and approving design documents.

3.3.2 Design input requirements necessary to permit the correct performance of design process activities. ALARA considerations, if appropriate, shall be specified.

3.3.3 Design process activities sufficient to ensure that design inputs are correctly translated into specifications, drawings, procedures, or instructions.

3.3.4 Internal and external design interface controls and lines of communication among participating design organizations and across technical disciplines.

3.3.5 Hiay be performed .), an) .mpat.nt pally net . rea.. n.ibl. f"r the er-igiael design.Design control measures shall be applied to verify the adequacy of design, such as by one or more of the following:

• Performance of design reviews,

• Use of alternate calculations,

• Performance of qualification tests.

The results of design verification shall be documented including the identification of the verifier. Design verification shall be performed by competent and qualified individual(s) other then those who performed the original design, but may be from the same organization. This verification may be performed by the originator's supervisor,

Docunmenl Type: Ntmber:

PU Plan I 000-PLN-7200.04 EOL/AR --.....

Title; Revision: Page:

GPU Nuclear Post-Defueling Monitored Storage 11 19 of 44 Quality Assurance Plan for Three Mile Island Unit 2 provided the supervisor did not establish the design approach, rule out certain design considerations, did not establish the design inputs used in the design, or the supervisor is the only individual in the organization competent to perform the review. In all cases, the design verification shall be completed prior to relying upon the component, system, structure, or computer program to perform its function.

The extent of the design verification required is a function of the importance of the function, the complexity of the design, the degree of standardization, the state of the art, and the similarity with previously proven designs.

3.3.6 Design and specification changes, including field changes, subject to design control measures.

3.3.7 Records of design activities shall be generated in sufficient detail to permit Nuclear Safety Assessment auditing as required by this Plan.

Document Type: Number:

Plan I1 000-PLN-7200.04 NUCLEAR4

'rifle: Revision: Page:

GPU Nuclear Post-Defueling Monitored Storage 11 22 of 44 Quality Assurance Plan for Three Mile Island Unit 2 5.0 INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS 5.1 During the PDMS period, activities within PDMS QA Plan Scope shall be prescribed by and accomplished in accordance with written instructions, procedures, or drawings of a type appropriate to the circumstances. Procedural adherence shall be mandatory.

5.2 Standard guidelines for the format, content, review, and approval of instructions, procedures, and drawings shall be specified in division/department administrative procedures. Procedural documentation shall be prepared, reviewed, and approved by individuals knowledgeable in the area affected by the procedure. Technical and independent reviews shall be in accordance with TMI Review and Appreval Mat:riApproved Procedures; Procedures within the scope of this quality assurance plan and changes to those documents shall be independently technically reviewed prior to implementation by a qualified individual knowledgeable in the area affected. The technical reviewer shall be an individual other than the originator. The reviewer shall determine if additional cross-disciplinary reviews are required to ensure all applicable technical disciplines are included in the review. The independent technical review shall ensure technical accuracy, compliance to regulatory requirements, and shall verify the originator's determination to whether items reviewed constitute a change to any licensing basis document.

Technical reviewers shall be trained and qualified to perform the technical reviews. Technical reviewers shall have the experience and training required by applicable standards. Technical reviewers shall have experience in areas such as:

o Chemistry o Instrumentation and controls

• Mechanical and electrical systems 0 Nuclear power technology

• Radiological controls o Operations o Engineering 5.3 Typical procedure types that shall be established, as necessary, are:

5.3.1 Administrative Procedures - Organizational responsibilities, interface relationships, and general plant administrative implementation controls are specified.

5.3.2 Operating Procedures - Provide instructions in sufficient detail to safely operate plant systems and components required to be operable per the PDMS Technical Specifications.

5.3.3 Surveillance and Test Procedures - Provide detailed instructions for implementing PDMS Technical Specification surveillance and test requirements.

5.3.4 Maintenance Procedures - These include both corrective and preventive maintenance. Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineation in written procedures.

Enclosure 6 Exelon/AmerGen Procedure, AD-AA-102, Station Qualified Review

F990 M'AD-AA-1 02 Revision 5 Page 1 of 6 Nuc]ear Level 3 - Information Use STATION QUALIFIED REVIEW

1. PURPOSE 1.1. This procedure establishes the requirements for the site review and approval of procedures and other documents using the Station Qualified Reviewer (SQR) and Site Functional Area Manager (SFAM)/Plant Manager.

1.1.1. This procedure by means of this statement, transitions all individuals qualified under the Independent Technical Review (ITR) program or Responsible Technical Reviewer (RTR) program to comparable qualifications in the Station Qualified Reviewer (SQR) program.

1.1.2. This procedure replaces the Independent Technical Review and Responsible Technical Review programs and shall be used in lieu of either review when ITR or RTR is specifically called for.

1.2. This' procedure applies to:

1.2.1. Technical Review of administrative and implementing procedures at the stations.

1.2.2. The review of the Offsite Dose Calculation Manual (ODCM), Core Operating Limits Report (COLR) and the Technical Requirements Manual (TRM).

1.2.3. Proposed changes to the Technical Specifications, their Bases, and the Operating License.

1.3. This procedure does not apply to procedures within the Human Resources (HR),

Business Operations (BO) categories, or technical welding procedures approved by the corporate welding engineer.

2. TERMS AND DEFINITIONS 2.1 SQR Review: A review performed by the SQR that is separate from the preparer that ensures that the document is technically and functionally accurate.

2.2 Cross-Disciplinary Review: A review of a document performed by one or more qualified individuals that have technical expertise in the areas addressed by the procedure. The intent of this review is to identify impacts on other organizations and ensure that the document is technically and functionally accurate relative to the Cross Disciplinary Reviewer's area of expertise.

2.3 Document

Generic terminology used throughout this procedure to refer to Procedures and other documents (TS, COLR, TRM, etc.) that are subject to SQR review.

AD-AA-102 Revision 5 Page 2 of 6

3. RESPONSIBILITIES 3.1. Licensing SFAM

- Certifies SQR candidates.

3.2. Plant Manager

- Approves the appointment and designates qualified SQRs.

3.3. Site Functional Area Manager (SFAM)

- Authorizes documents reviewed and approved by the SQR unless PORC and

/ or Plant Manager authorization is required.

- Ensures an adequate complement of SQRs exist within functional area.

- Ensures that the change documentation package includes necessary elements (e.g. 50.59 / 50.54 / 72.48 reviews, documentation of cross-disciplinary reviews, etc).

- Approves/Authorizes editorial procedure changes.

3.4. Station Qualified Reviewer

- Performs the SQR review of new or revised documents and approves them if appropriate.

Specifies the required reviews.

- Ensures that an appropriate cross-disciplinary review(s) of the procedure is performed by qualified individual(s).

- Determines who is qualified to perform cross-disciplinary review.

- Reviews the documentation package.

- Notifies the Licensing SFAM upon a job transfer to a new functional area in order to re-apply for SQR qualification for the new area.

Exelon NDE Level IIl Functions as SQR Reviewer for technical procedures in area of certification.

PerfOrms the SQR review of new or revised NDE documents in area of certification and approves them if appropriate.

Ensures that an appropriate cross-disciplinary review of the procedure is performed as necessary.

AD-AA-102 Revision 5 Page 3 of 6

4. MAIN BODY 4.1. Station Qualified Review (SQR) Qualification Requirements 4.1.1. MEET the requirements of the appropriate sections of ANSI/ANS-3.1 (or equivalent ANS/ANSI qualification requirements: e.g. ANSI N18.1-1971) that is committed to for the site.

Clinton MAINAIN ogicSystem Functional/System Functional review qualifications for 7

[ perain nstrumentation and Control, and Electrical disciplines. (CM-1

1. COMPLETE a Station Qualified Reviewer Candidate Qualification Application (AD-AA-1 02-1002, Station Qualified Reviewer Qualifications).

4.1.2. If an SQR transfers into a different Functional Area Group, then the SQR shall NOTIFY the Licensing SFAM.

1. COMPLETE a Station Qualified Reviewer Candidate Qualification Transfer Application (AD-AA-1 02-1002, Station Qualified Reviewer Qualifications).

4.1.3. Licensing SFAM shall ENSURE that appropriate qualification re-evaluations are performed prior to reassigning the SQR to a different functional area.

4.2. Station Qualified Review Scope 4.2.1. The SQR shall only approve documents that they are qualified to review/approve.

4.2.2. The following items require Station Qualified Review:

- Administrative and implementing procedures for the station required by the stations' Technical Specifications and Quality Assurance Program.

- Offsite Dose Calculation Manual (ODCM), Core Operating Limits Report (COLR) and the Technical Requirements Manual (TRM).

- Proposed changes to the Technical Specifications, their Bases, and the Operating License

1. If a procedure is determined to require PORC review in accordance with the current approved PORC procedure, then the SQR shall APPROVE the document, however, PORC shall review / recommend the document for approval as appropriate.

4.2.3. Editorial changes to procedures do not require SQR review/approval.

AD-AA-102 Revision 5 Page 4 of 6 4.3. SQR Review 4.3.1. The SQR shall not be the same individual as the preparer of the document.

4.3.2. The SQR and the SFAM may be the same individual.

4.3.3. PROVIDE the review, confirmation, and/or substantiation of the appropriateness of a proposed document change activity including adherence to regulatory, quality, and Exelon Nuclear requirements.

4.3.4. RENDER a determination of whether or not a cross-disciplinary review(s) of the document change activity is necessary.

1. ENSURE that adequate cross-disciplinary review(s) have been performed by qualified individual(s), to ensure that the document is appropriate for the intended application.

2. The cross-disciplinary reviewer(s) should inform the SQR of any previous involvement with the document change activity under review so that the SQR can knowledgably use the cross-disciplinary review to support approval or require a different cross-disciplinary reviewer.

4.3.5. When revisions involve interpretation, changes in technical specifications, or are complicated changes, CONSIDER consulting with a peer.

4.4. Site Functional Area Manager (SFAM) Authorization 4.4.1. ENSURE that the documentation package for the activity is complete including appropriate regulatory reviews (e.g. 10CFR50.59 I 10CFR 72.48 / 10CFR 50.54) and other review documentation.

5. DOCUMENTATION 5.1. Completed change documentation package is a quality record.

5.2. Completed SQR qualifications are placed in the candidates training record until such time as those training records are archived by Records Management.

6. REFERENCES 6.1. Commitments 6.1.1. Clinton CM -1, Licensee Event Report 1997-031, Condition Reports 1-97-12-304, and 1 07-064 (Clinton Station Specific portion of step 4.1.1.)

AD-AA-102 Revision 5 Page 5 of 6 6.2. User References 6.2.1. LGS / PBAPS UFSAR section 13 6.2.2. Quality Assurance Program 6.2.3. TVA plants, SER Tac Nos, 5105, 5106, 5107, 5054, 5055, and 5056, dated August 26, 1999

6.2.4. Procedures

1. AD-AA-101, Processing of Procedures

2. LS-AA-1 04, Exelon 50.59 Review Process 6.2.5. Training & Reference Material:

1. AD-AA-102-1001, SQR Reviewers Guide

2. AD-AA-102-1002, SQR Qualifications 6.3. Writer's Reference 6.3.1. ANSI/ANS-3.1 6.3.2. Regulatory Guide 1.33 6.3.3. ANSI N18.1-1971

7. ATTACHMENTS 7.1 Attachment 1, SQR Process Flowchart

AD-AA-102 Revision 5 Page 6 of 6 ATTACHMENT I SQR Process Flowchart Page 1 of I Document Written licable procmss