ML19260A139

Tech Spec Change Request 46,Amend A,Supporting Licensee Request to Change App a of DPR-50 Re Justification for Differences Between Proposed Changes & Model Tech Specs on Fire Protection Systems.Certificate of Svc Encl

ML19260A139
Person / Time
Site:	Three Mile Island
Issue date:	08/12/1977
From:	Arnold R METROPOLITAN EDISON CO.
To:
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ML19260A138	List: ML19260A137 ML19260A139
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NUDOCS 7910290754
Download: ML19260A139 (26)

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METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Scecification Change Recuest No. h6, Amendment A This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear Station Unit 1. As a part of this request, proposed replacement pages for Appendix A are also included.

METROPOLITAN EDISON CCMPANY By O,

,' fice President A

Sworn and subscribed to me this IA day of AW/ , 1977.

O Notary Pub 1f'c NOTARY PUBLIC Reading. Berks County, Pa.

My Ccmmission Expires Nov. 19. 1979 1480 178

$ 910 290 73 7

UNITED STATES OF A! ERICA NUCLEAR REGULATORY COMMISSION IN THE MAnu 0F DOCKET NO. 50-289 LICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY This is to certify that a copy of Technical Specification Change Request No. h6, Anendment A, to Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 1, has, on the date given below, been filet with the U. S. Nuclear Regulatory Consission and been served on the chief executives of Londonderry Township, Dauphin County, Pennsylvania and Dauphin County, Pennsylvania by depesit in the United States nail, addressed as follows:

Mr. '4eldon B. Arehart Mr. Harry B. Reese, Jr.

Board of Supervisors of Board of County Consissioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Court House Middletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120 METROPOLITAIT EDISON COMPANY

/

By / h/' d41 7 Vice President Dated:

77 1480 179

Metropolitan Edison Ccepany (Met-Ed)

Three Mile Island Nuclear Station Unit 1 (TMI-1)

Docket No. 50-289 Operating License DPR-50 Technical Snecification Chance Reauest No. h6 Amendment A In response to your letter of June 16, 1977, the licensee requests that the enclosed replacement pages be added to existing technical specifications and corresponding superseded pages be deleted. Pages provided assume approval of all previously requested changes. Those changes not yet approved are indicated by double margin bars.

As requested by your letter of June 16, 1977, following please find a listing of our justifications for differences between this proposed changes and the model technical specifications.

a) Throughout the change request when a report is required because the inoperable instr =nents were not repaired within lh days ve changed the section to report the occurrence from 6.9.2 to each specific paragraph of the fire protection section because Chapter 6 reporting requirements do not apply to fire protection syste=s. The reporting time was changed from 10 days to lh days to be consistent with other reporting requirements and to allow time to pre, pare an accurate and

' concise report.

b) Reference Model T.S. h.3 3.8.2 We have no Class A supervised circuits. This surveillince does not apply to TMI-1.

c) Reference Model T.S. h.7.11.1.c We have no valves which are considered testable. This surveillance c.os not apply to TMI-1.

d) Reference ModelT.S. h.7.ll.1.d We are following NFPA regulations by performing a system flush each 12 cenths.

e) Reference Model T.S. h.7.11.2.a We do not have any valves of this type. This surveillance does not apply to TMI-1.

f) Reference Model T.S. 3.7.11.3.A Weconsiderthedual,independentmonitoringsystemforf.ettm bb d smoke, in the cable spreading room, cepable of registering any occurrence. However, we vill have the area checked cnce each hour.

g) Reference Model T.S. h.7.11.h.a We are following NFPA regulations by verifying each Halon storage tank veight each 12 months.

h) Referaae Model T.S. h.7.11.h.b.2 We have no headers and nozzles in this system. This surveillance does not apply to TMI-1.

1) Reference Model T.S. 3.7.11.5 ,

A more realistic time to accomplish the necessary cation requires 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, versus one hour as stated in the Reference Model T.S.

j) Reference Model T.S. h.7.12.2 We have no penetration fire barriers that perform a pressure sealing function. This surveillance does not apply to DII-1.

k) Reference Model T.S. 6.2-1, 6.2-2, 6.h.2 These directives were accomplished by our Fire Hazards Analysis and the Fire Protection Program Plan.

t Reason For Change Recuest To improve fire protection measures as requested in NRC letter of December 2, 1976 and June 16, 1977 Safety Analysis of Change Reauest Since all proposed technical specifications provide additional assurance of fire detection and suppression equipment this change request involves no threat to the health and safety of the public.

1480 181 2

1.6 POWER DISTRIBUTION 1.6.1 QUADRANT POWER TILT Quadrant power tilt is defined by the following equation and is expressed in percent.

100 Power in any core cuadrant

-1 Average power of all quadrants The quadrant tilt limits are stated da Specification 3.5 2.h.

1.6.2 REACTOR POWER IMBALANCE Reactor power imbalance is the power in the top half of the core minus the power in the bottom half of the core expressed as a percentage of rated power.

Imbalance is monitored continuously by the RPS using input from the power range channels. Imbalance limits are defined in Specification 2.1 and imbalance setpoints are defined in Specification 2.3 1.T CONTAIINENT INTEGRITY Containment integrity exists when the following conditions are satisfied:

, a. The equipment hatch is closed and sealed and both doors of the personnel hatch and emergency hatch are closed and sealed except as in "b" below.

b. At least one door on each of the personnel hatch and emergency hatch is closed and sealed during refueling or personnel passage through these hatches.

c. All nonautomatic containment isolation valves and blind flanges are closed as required by the " Containment Integrity Check List" attached to the operating procedure " Containment Integrity and Access Limits."

d. All automatic containment isolation c.1ves are operable or locked closed, or the redundant valve is c.'.ased within the time specified in Specification 3.6.6.

e. The contain=ent leakage determined at the last testing interval satisfies Specification L.h.1.

1.8 FIRE SUPPRESSION WATE? SYSTDI A FIRE SUPPRESSION WATER SYSTEL! shall consist of: a water source, gravity tank or punp and distribution piping with socceiated sectionalising centrol or isolation valves. Such valves include yard tydrant curb valves, and the first alve upstream of the water flow alarm device on each sprinkler, hose standpipe or spray system riser.

1480 182 1-5

3.18 FIRE PROTECTION 3.18.1 FIRE DETECTION INSTRUE'iTATION Antlicability: At all times when equipment in that fire detection zone is required to be operable.

O_bj ective : To insure adequate fire detection capsbility.

Suecification:

3.18.1.1 The minimum fire detection instrumentation for each fire detection zone shown in Tsble 3.18-1 shall be operable.

3.18.1.2 With the number of OPERABLE fire detection int.truments less than required by Table 3.18-1.

a. Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, estsblish a fire watch patrol to inspect the zone with the inoperable instrn=ent(s) at least once per hour, and

b. Restore the inoperable instrument (s) to OPERABLE status within 14 days or prepare and submit a special report to the Cc==ission within tha next lh days outlining the cause of the malfunction and the plans for restoring the instrument (s) to OPERABLE status.

Bases OPERABILITY of the fire detection instrumentation ensures that adequate warning capability is available for the prompt detection of fires. This capability is required in order to detect and locate fires in their early stages. Prompt detection of fires vill reduce the potential for damage to safety related equipment and is al integral element in the overall facility fire protection program.

In the event that a portion of the fire detection instrumentation is inoperable, the establishment of frequent fire patrols in the affected areas is required to provide detection capsbility until the inoperable instru=entation is returned to service.

1480 183 3-86

TABLE 3 19,_1 FIRE DETECTION INSTRUME'iTS Total Number Instrument Location of Detectors Minimum Inscruments Operable Heat S=oke Heat Smoke

1. Control Building Elev. 355' Control Rocs 0 h NA 2 Computer Room 0 h NA 2

2. Control Building Elev. 338' 1D 4160 V SWGR 0 1 NA 1 1E h160 V SWGR 0 1 NA 1 ESAS Cabinets 0 1 NA 1 Cable Spreading h 1 2 1 3 Control Building Elev. 322' 1P h80 V SWGR 0 1 NA 1 1S h80 V SWGR 0 1 NA 1 t Battery Rocm A 0 1 NA 1 Battery Room B 0 1 NA 1 Inverter Room A 0 1 NA 1 Inverter Rocm B 0 1 NA 1 Re=cte Shutda'm Panel 0 1 NA 1

h. Diesel Generators Diesel A 1 0 1 NA Diesel B 1 0 1 NA 5 Screen House 0 2 NA 1

6. Aux and Fuel Handling Building 1 1 1 1 1480 184 3-87

3.18.2 FIRE SUFFRESSION WATER SYSTE4 Arolicability: All operating conditions Objective: To insure adequate fire suppression capability Scecification:

3.18.2.1 The Fire Suppression Water System shall be operable with:

a. Two (2) high pressure pumps of the following four (h), shall be operable with their discharge aligned to the fire suppression header and automatic initiation logic operable. Any two of the pumps provide combined capacity greater than 3575 gal / min:

1. Circulating Water Flume Diesel Fire Pump

2. River Water Diesel Fire Pump, Unit 1

3. River Water Diesel Fire Pump, Unit 2

h. River Water Motor Fire Pump, Unit 1

b. Two (2) separate water supplies of the fo11cving four (h) each containing a minimum of 90,000 gallons:

1. Altitude Tank

2. Circulating Water Flume

3. Unit I River Water Intake

h. Unit II River Water Intake 3 18.2.2

a. With less than the above required equipment, restore the inoperable equipment to OPERABLE status within 7 days or prepare and submit a Special Report to the Ccamission rithin the next 1h days outlining the plans and procedures to be used to provide for the loss of redundancy in this system.

b. With no FIRE SUPPRESSION WATER SYSTE4 OPERABLE vithin 2h hours;

1. Establish a backup FIRE SUPPRESSION WATER SYSTEM.

2. Notify the Commission outlining the actions taken and the plans and schedule for restoring the system to OPERABLE status.

3 Restore the FIRE SUPPRESSICU WATER SYSTEM to OPERABLE status within 1h days or prepare and submit a Special Report to the r_cmission within the next 1h days outlining the cause of the malfunction and th, plans for restoring the system to OPERABLE status.

1480 i85 3-85

3.18.3 DELUGE / SPRINKLER SYSTE:G Acclicability: At all times when equipment in the area is required to be operable.

Objective: To assure adequate fire suppression capability.

Specification:

3.18.3.1 The Deluge and/or Sprinkler Systems located in the following areas shall be operable.

a. Diesel Generator and Radiator Rooms

b. Diesel Generator Combustion Air Intakes

c. Diesel Generator Cooling Air Intake

d. Control Building Filter (AH-F3A, AH-F3B) Rooms

e. Air Intake Tunnel (Deluge - 2 of the 3 zones)

f. Charcoal Filter (AH-F10, AH-Fil)

g. Intake Screen Pump House 3.18.3.2 With one of the above deluge and/or sprinkler systems inoperable:

a. Establish a continuous fire vatch with backup fire suppression equipment for the unprotected area (s), within one hour except that no fire watch is required in the air intake tunnel.

v.

b. Restore the system to OPERABLE status within 1h days or prepare and submit a Special Report to the Cc= mission within the next 14 days outlining the cause of inoperability and the plans for restoring the system to OPERABLE status.

1480 186 3-89

3.18.h CO2 SYSTEM Aeolicability: At all times when the equipment in the area is required to be operable.

Objective: To insure adequate fire suppression capability.

Specification:

3.19.4.1 The CO2 system for the Cable Spreading Room shall be operable with a minimum level corresponding to 8500 lbs and a minimum pressure of 300 psig in the associated storage tank (s).

3.18.h.2 With the CO2 system for the Cable Spreading Room inoperable:

a. Within one hour, establish a fire watch patrol to inspect the Cable Spreading Room at least once per hour,

b. Restore the system to OPERABLE status within 1h days or prepare and submit a Special Report to the Cem=ission within the next lh days outlining the cause of inoperability and the plans for restoring the system to OPERABLE : tatus.

n 1480 187 3-90

3.18.5 HALON SYSTDi Anulicability: At all times except when the Control Building ventilation is on recirculation.

Objective: To assure adequate fire suppression for the Air Intake tunnel.

3.18.5 1 The Halon Systems for the air intake tunnel shall be operable except for testing or maintenance that requires the air tunnel to be occupied.

The Halen storage tanks shall have at least 90% of full charge pressure and 95% full charge weight.

3.18.5.2 If the Halen systems are inoperable:

a. The Air Intake Tunnel Deluge system shall be in service unless the tunnel is occupied.

b. Restore the system to OPERABLE status within lh days or prepare and submit a Special Report to the Co==ission within the next lh days outlining the cause of the inoperability and the plans for restoring the system to operable status.

f 1480 188 3-91

i e

l 3.18.6 FIRE HOSE STATIONS '

Anulicability: At all times when the equipment in the area is required to be operable.

Objective: To insure adequate fire suppression capability.

Specification:

3.18.6.1 The fire hose stations listed in Table 3.18-2 anall be operable or an additional hose must be routed to the unprotected area from ca operable hose station within two (2) hours.

r 1480 189 3-92

Table 3.18-2 H')SE STATIONS Intermediate Building

1. Fire hose near northeast piping chamber stairway at elev. 309'.

Auxiliary Building

1. Fire hose near stairway at northeast end of building near valve room at elev. 285'.

2. Fire hose near vaste evaporator condensate tank and auxiliary steam condensate return unit elev. 285'.

3. Fire hose near stairway at northeast end of auxiliary building and engineered safeguards control center, elev. 309'.

h. Fire hose near radioactive vaste control center, elev. 309'.

Turbine Building

1. Fire hose along vest side of building near 12th stage extraction feed-water heaters, elev. 326'.

' 2. Fire hose along vest side of building near loth stage extraction feed-water heaters , elev. 359'.

i480 190 3-93

3.18.7 Fire Barrier Penetration Fire Barriers Acclicability: Applies to fire barriers in:

a. Control Building

b. Fuel Handling Building

c. Intermediate Building

d. Screen House

e. Diesel Building Objective: To assure the integrity of the existing fire barrier penetrations.

Specification _:

3.18.7.1 All penetration fire barriers protecting safety related areas shall be functional.

3.18.7 2 With a penetration fire barrier non-functional within one hour establish a fire watch patrol to inspect at least one side of the affected barrier at least once per hour.

1480 191 3-9h

h .17 FIRF PROTECTION SYSTEMS h.17 1 FIRE FROTECTION INSTRUMENTS Apolicability: Instrunents listed in Table 3 18-1 Objective: To insure operability of fire detection instruments.

Specification:

h.17 1.1 Each of the fire detection instruments listed in Table 318-1 shall be demonstrated operable:

a. Once each 6 months by a Channel Functional Test, and

b. Once per year by performance of a Channel Cal'bration.

1480 192 h-72

h.17 2 FIRE SUPPRESSION WATER SYSTDI Atelicability: Fire Suppression Water System as defined in Specification 1.8.

Objective: To insure system operability.

Scecification:

h.17 2.1 Thp system shall be demonstrated operable:

a. Once per 7 days by verifying 90,000 gallons of water in the altitude tank, equivalent level in the circulating water flume, and/or equivalent level in the river.

b. Once per month on a staggered test basis by starting each pump and operating it for 15 ninutes on recirculation flow.

c. Once per 12 months flush each =ain header loop.

d. Once per 18 months by performing a system functional test which includes a simulated automatic actuation of the system (i.e.

pumps start at set pressure).

I

e. Once per 18 months by verifying that each pu=p will develop a flow of 2500 gpm at a total dynamic head no more than 10% below that indicated on manufacturers curves.

f. Once per 3 years by verifying the capability of the system to deliver 2575 gal./ min. to the most remote deluge system with no more than 25 psi pressure drop (between the pump discharge and I the most remote deluge system) and with 1000 gal./ min to hoses. i 1480 193

h.17.3 DELUGE /SPRIUKLER SYSTE:IS Acolicability: Deluge and Sprinkler Systems.

Objective: To insure syscem operability.

Specification:

h.17.3.1 The deluge and/or sprinkler systems listed in Specification 3 18.3.1 shall be demonstrated to be operable:

a. Once per month by a flush through the drain / test valves at the inlet to each deluge valve.

b. Once per month by flowing vater through the inspectors test connection on each vet sprinkler header to verify absence of header blockage.

c. Once per 18 months by performing a system functional test v1'ch includes tripping detectors and verifying actuation of trip devices on associated deluge valves. This functional test vill not normally involve flowing water through the sprinkler / deluge header. Deluge sprinkle 1 valves will be inspected internally to verify operability in all instances where header flooding during the test is undesirable.

I

d. Once per 18 months a visual inspection of deluge headers to verify their integrity,

e. Once per 18 months by visual inspection (from floor level) of each nozzle to verify absence of spray pattern blockage.

f. Once per 3 years by a gas or water flow test of any open type deluge head to verify absence of blockage.

h.17.h CO2 SYSTEM Apelicability: CO2 System for the Cable Spreading Rocm.

Objective: To insure system operability.

Specification:

h.17.h.1 The CO2system shall be demonstrated operable:

a. Once per week by verifying the CO2 stcrage tank level and pressure,

b. Once per 18 months by verifying the system valves and associated ventilation danpers actuate in response to an actuation signal, A brief flow test shall be nade to verify flow from each nozzle.

(" Puff Test")

1480 194 h-Th

h.17.5 Halen Systems Anolicab.i'_ity : Halon Systems described in Specification 3 18.5 Objective: To insure system oper wility.

Suecification:

h.lT.5 1 The Halon System shall be verified operable:

a. Once per 3 months by verifying pressure in each Halon storage tank.

b. Once per 12 =cnths by verifying each Halen storage tank veight.

c. At least once per 18 months by:

1. Verifying that the syatet, including associated ventilation dampers, actuates autecatically to a simulated test signal.

2. Functional test the ultraviolet detectors, test of the pressure valve detectors, and replacettnt of the explosive actuators.

t 1480 i95 h-75

h.17.6 HOSE STATIONS Apnlicabilit1: Hose stations listed in Table 3 18-2. l Objective: To insure system operability.

Specification:

h.17.6.1 Each fire hose station shall be verified operable:

a. Once per month by visual inspection of the station to assure all equipment is available and the pressure in the standpipe is-vithin limits.

b. Once per 18 months by removing the hose for inspection and replacing all gaskets in the couplings that are degraded.

c. Once per 3 years, partially open hose station valves to verify valve operability and no blockage.

r 1480 196 h_7C

k.17.7 Fire Barrier Penetration Fire Barriers Aeolicability: Fire Barrier Penetration Barriers Objective: To verify integrity of the Barriers.

Stecification:

h.17 7.1 The fire barriers penetration seals shall be verified to be functional by a visual inspection;

a. Once per 18 months, and

b. Following repairs or maintenance I

i 1480 197 h-77

b. Proposed tests and experiments, and to make an initial determination that "a" and "b" above do not constitute an unreviewed safety question.

N0'rE: The Unit Superintendent shall report directly to the Station Super-intendent/ Senior Unit Superintendent and is responsible to him for the administration, operation and =aintenance of Three Vdle Island Nuclear Station Unit 2.

6.2 ORGANIZATION OFFSITE 6.2.1 The organization of the Met-Ed Corporate Technical Support staff for Station manage =ent and technical support shall be functionally as shown in Figure 6-1.

STATION / UNIT STAFF 6.2.2 The organization within the station for operations, technical support, and =aintenance shall be functionally as shown in Figure 6-1.

a. Each on-duty shift shall, as a mini =um, be ec= posed of the following shift crew:

Shift Supervisor or Shift Foreman (See Notes 1 & 3) 1 Control Roc = Operator (See Notes 2 & 3) 2

' Auxiliary Ope.ator (See Note 3) 2 Additional station personnel available to serve on the fire brigade (See Note h) j[

Men / Shift 8

b. At least two licensed Reactor Operators shall be at the station, one of whom shall be in the Control Room at all times when there is fuel in thb reactor vessel. One of these operators shall hold a Senior Reactor Operator's License,

c. At least two licensed Reactor Operators shall be present in the Control Room during reactor start-up, scheduled reactor shutdown and during recovery from reactor trips.

d. At least one member of each operating shift shall be qualified to implement necessary radiation protection procedures.

e. A licensed Senior Reactor Operator with no other concurrent operational duties shall directly supervise: (a) irradiated fuel handling and transfer activities onsite, and (b) all unirradiated fuel handling and transfer activities to nnd frc=

the Reactor Vessel.

NOTES:

1. The Shift Supervisor, or the Shift Fore =an if a Shift Supervisor is not assigned, shall have an NRC Senior Reactor Operator's License.

6-2 1480 198

2. Only ol licensed Control Room Operator tall be required per shift during cold shutdown or refueling operations.

3. Shift Supervisor, Control Room Operator and Auxiliary Operator refer to functions that are to be performed and do not refer to the title of the individual. These functions may be performed by any individual possessing the necessary licenses and qualifications.

h. The same 3 personnel on the fire brigade can satisfy the require =ents on Units 1 and 2.

6.3 STATION / UNIT STATF QUALIFICATIONS 6.3.1 Comprising the station staff shall be supervisory and professional personnel encompassing the qualifications described in Section h of ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel."

6.h TRAINING 6.h.1 A retraining and replacement training program for the station staff shall be maintained under the direction of the Supervisor of Training and shall meet or exceed the requirements and recccmendations of Section 5 5 of ANSI N18.1-1971 and Appendix "A" of 10CFR Part 55 6.h.2 A training program for the Fire Brigade shall be maintained under the direction of the Supervisor of Training - Nuclear and shall meet or exceed the requirements of Section 27 of the NFPA Code - 1976.

6.5 REVIEW A*TD AUDIT I

6.5.1 PLAN

• OPEREIONS REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The Plant Operations Review Committee shall function to advise the Unit Superintendent en all matters related to nuclesr safety.

COMPOSITION 6.5.1.2 The Plant Operations "-tiew Committee shall be composed of:

a) Unit Superintendent b) Supervisor of Operations e) Supervisor of Maintenance d) Unit Electrical Engineer e) Unit Mechanical Engineer f) Unit Nuclear Engineer g) Unit Instrument and Control Engineer h) Supervisor of Radiation Protection and Chemistry i) PORC Chairman j) Station engineers assigned by the Unit Superintendent The Unit Superintendent shall designate the members, the Chairman, and the Vice Chairman of the Plant Operations Review Committee.

AtTERNATSS 1480 199 6.5.1.3 Alternate members shall te appointed in writing by the Unit Superintendent to serve on a temporary basis. For purposes of this specification, a desi6nated alternate shall be considered to have the A_,

k. Periodically audit the areas listed belev to verify compliance with the Three Mile Island Operating Quality Assurance Plan, j Fire Protection Program Plan, internal rules and procedures, I federal regulations, and operating license provisiens:

1) The 18 Criteria of 10CFR50, Appendix 3

2) Normal Unit Operatien

3) Inservice Inspectica h) Refueling

5) Radiological Centrols

6) Station Maintenance

7) Technical Specifications

8) Training and Qualifications of station staff

9) Industrial Security Precram

10) Fire Protection Progra= and implementing procedures

' In performing these audits, written procedures and/or check-lists shall be used. As a minimum, each area shall be audited at least once every two years.

6-6a 1480 200

6.8 PROCEDURES 6.8.1 Written procedures and administrative policies shall be established, implemented and maintained that meet er exceed the requirements and recccmendations of Sections 5 1 and 5 3 of ANSI N18.7-1972 and Appendix "A" of USNRC Regulatory Guide 1.33 November 1972 except as provided in 6.8.2 and 6.8.3 below.

Imp.lementation of the Fire Protection Program shall be by means of written procedures.

6.8.2 Eacu nuclear safety related procedure and administrative policy of 6.;.1 above, and changes thereto, shall be reviewed by the Plant Operations Review Cccaittee and approved by the Unit Superintendent prior to implementation and periodically as =ay be set forth in ecch document.

6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:

a. The intent of the original procedure is not altered.

b. The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.

c. The chan6e is documented, reviewed by the Plant Operations Review Committee and approved by the Unit Superintendent within 7 days of implementatien.

1480 201 6-11

6.9.1 REPORTING REQUIRE: TENTS (cont'd)

(3) A tabulation on an annual basis of the number of station, utility and other personnel (including contractors) receiving exposures greater than 100 mres/yr and their associated man rem exposure according to work and job functions, 5/ e.g. , reactor operations and surveillance inservice inspection, routine maintenance, special maintenance (describe maintenance), vaste processing, and refueling. The dose assignment to various duty functions may be estimates based on pocket dosimeter, TLD, or film badge measurements. Small exposures totalling less than 207. of the individual total dose need not be accounted for. In the aggregate, at least 807. of the total whole body dose received from external sources shall be assigned to specific major work functions.

(h) Indications of failed fuel resulting from irradiated fuel examinations, including eddy current tests, ultrasonic tests, or visual examinations completed during the report period.

6.9 2 Reportable Occurrencesl /

Reportable occurrences, including corrective actions and measures to prevent recurrence, shall be reported to the NRC. Supplemental reports may te required to fully describe final resolution of an occurrence. In case of corrected or supplemental reports, reference shall be made to the original report date.

The following reporting requirements do not apply to Section 3.18, Fire Protection, except events reportable under 6.9.2.A (2). All other reports shall be submitted in accordance with the requirements specified in Section 3.18.

1480 202 6-lh

6.1h FIRE PROTECTICIJ I?!SPECTIO:I

1. An independent fire protection and loss prevention, inspection and audit shall be performed annually utflizing either a qualified off-site licensee personnel or an outside fire protection firm.

2. An inspection and audit by an outside qualified fire consultant .

I shall be perfor=ed at intervals no greater than three years.

i 1480 203 6-26