ML19322D558

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Forwards Mods to Tech Specs 6.0 Re Administrative Controls
ML19322D558
Person / Time
Site: Crane 
Issue date: 02/08/1980
From: Wilson R
METROPOLITAN EDISON CO.
To: Vollmer R
NRC - TMI-2 OPERATIONS/SUPPORT TASK FORCE
Shared Package
ML19322D559 List:
References
NUDOCS 8002150253
Download: ML19322D558 (2)


Text

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g Metropolitan Edison Company g

Post Office Box 480 Middletown, Pennsylvania 17057 717 9444041 Wnter's Direct Dial Number February 8, 1980 TLL 037 TMI Support Attn:

R. Vollmer, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Sir:

Three Mile Island Nuclear Station, Unit II (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Modifications of Technical Specifications Section 6 Enclosed please find modifications to Section 6.0 of the proposed Technical Specifications. Your letter of January 15, 1980 concluded that the previous modification to this Technical Specification was unacceptable since no basis or analysis was previded to justify that the proposed modification would " provide an equivalert or greater degree of assurance that the health and safety of the pub.'ic would be protected."

We have subsequently made additional modifications to the subject document which we feel will alleviate your concern. The basis for these modifications follows.

The TMI Operational Quality Assurance Program and Technical Specifications are being upgraded to comply with the regulatory positien in Regulatory Guide 1.33 Revision 2.

This regulatory guide endorses ANSI N18.7-1976.

Our present Plant Operations Review Committee (PORC) procedure review requirements have been the subject of an internal evaluation. Currently, PORC review is required for all procedures and instructions which are important to safety. The large number of procedures and instructions requiring FORC review is not conducive to achieving the timely, detailed safety evaluation desired by the licensee. Consequently, the effectiveness of the PORC is diluted. To alleviate this situation, we plan to limit the procedure review requirements of PORC to those reviews required by Regulatory Guide 1.33 Revision 2.

We feel that the procedure review requirements specified in Regulatory Guide 1.33 Revision 2 are adequate to meet the intent of 10CFR50 Appendix B.

These requirements provide the levels of review necessary to insure affected

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documents comply with appropriate policies and regulations. Unreviewed s

lll 800223o 2 "5 3 Metrocontan Ed. son Corrcany ;s a '.temce if the Generai Puonc Ut t.es System t

c February 8, 1980 R. Vollmer TLL 037 i

4 safety questions and technical specification changes will receive adequate reviews by safety review committees. We have also revised section 6.3 Unit Staff Qualifications so that the personnel requirement of meeting Regulatory Guide 1.8 is consistent with the Three Mile Island Nuclear Station, Unit II Radiation Protection Plan.

Additionally, in response to your letter of January 14, 1980, concerning the Organization Plan, we are requesting that Section 2.1.3 of the plan be revised to state: " Changes to the Organization Plan shall be reviewed with the NRC prior to implementation."

neepely,

. F.

1 son Director, TMI-II RFW:CFM: hah Attachments cc:

J. T. Collins d

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