ML20003E966

Application for Amend to License DPR-50 Submitted as Tech Spec Change Request 100 to Revise App A/B Sections Re Administrative Control,Incorporating Changes Required by NUREGs-0680,0737,0578 & 0600.Certificate of Svc Encl

ML20003E966
Person / Time
Site:	Three Mile Island
Issue date:	04/10/1981
From:	Hukill H METROPOLITAN EDISON CO.
To:
Shared Package
ML20003E963	List: ML20003E961 ML20003E966 ML20003E969 ML20003E970
References
RTR-NUREG-0578, RTR-NUREG-0600, RTR-NUREG-0680, RTR-NUREG-0737, RTR-NUREG-578, RTR-NUREG-600, RTR-NUREG-680, RTR-NUREG-737 NUDOCS 8104170565
Download: ML20003E966 (6)

Text

Q METROPOLITAN EDISON COMPAhT JERSEY CENTRAL POWER & LIGHT COMPAhT AND PENNSYLVANIA ELECTRIC COMPAhY THREE MILE ISLAND NUCLEAR STATION, UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No.100 This Technical Specification Change Request is submitted in support of Licensee's request to change Appendi>I A/B 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/B are also included.

METROPOLITAN EDISON COMPAhT By 3Direc6or, TMI-1

11. D. Hukill Sworn and subscribed to me this / d day of O/M , 1981.

I n $

Not hi9dt.c FAVELA JOY LUE Fa.

.; hm C;My.

c 125 Ig at Di M 8104170 5 $

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET No. 50-289 LICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY This is to certify that a copy of Technical Specification Change Request No.100 to Appendix A/B of the Operating License for Three Mile Island Nuclear Station Unit 1, has, on the date given below, been filed with the U. S. Nuclear Regulatory Commission and been served on the chief executives of Londonderry Township, Dauphin County, Pennsylvania and Dauphin County, Pennsylvania by deposit in the United States mail, addressed as follows:

Mr. Donald Hoover, Chairman Mr. John E. Minnich, Chairman Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County R.D. #1, Geyers Church Road Dauphin County Courthouse Middletown, PA 17057 Harrisburg, PA 17120

)

l METROPOLITAN EDISON COMPANY l

l By \

Diredtor, TMI-l H. D. Hukill i

i l

i

' Dated: April 10, 1981 l

l l

l L

I. TECHNICAL SPECIFICATION CHANGE REOUEST NO. 100 The Licensee requests that the attached revised pages replace the following pages of the existing Technical Specifications.

A. Appendix A l

, Replace page iv I

Replace page vii '

Replace pages 6-1 thru 6-26 Replace Figure 6-1 (pages 1-4)

B. Appendix B Replace pages 11 and v j

Replace pages 58 thru 66 II. REASON FOR THE CHANGE REOUEST The attached changed pages represent a complete rewrite of the administrative sections of the Technical Specifications (Appendix-A & B). This change reflects a resolution of many of the recommendations of:

i The President's Committee The Rogavin Committee The Hart Committee NTOL Inspection PAS Inspection

_. _ _-._ _ _ The TMI,.1_ Hearings Advisory Committee on Reactor Safeguards and other co==ittees as a i

result of the Accident at Three Mile Island, Unit 2.

l Additionally, the changc incorporates those changes required by the following i documents in support of the Restart of TMI-1.

NuReg 0680 NuReg 0578 NuReg 0600 NuReg 0737 NuReg 0680 l

Major section changes are su=marized below:

Section 6.1 Responsibility Has been revised to reflect current wording used in standardized Technical Specification and reflects the GPU Nuclear Corporation Title.

Section 6.2 Organization Has been revised to show the CPU Nuclear Corporation which was the subject of TSCR No. 98. The single organization chart has becoce two and now reflects i

the corporate and unit staff distinctly. Additionally, l the minimum shift crew composition has been updated to l

include more standardized wording and the requirecents l for a Shift Technical Advisor (STA) (NuReg 0737).

l The unit staff qualifications have been upgraded to l

Reg Guide 1.8 - 1977 and the Radiological Controls Technicians / Foreman qualification program and STA program is addressed.

Sections 6.3 & 6.4 Have been deleted because they are now included in Section 6.2.

Section 6.5 Review and Audit Has been conceptually revised to provide for independent review using individuals / groups rather than committees.

These individuals / groups perform an independent review of

all proposed changes to procedures, the facility, the Technical Specifications, and proposed license amendments.

Additionally, they conduct a continuing review of overall

plant performance and identify trends. The review of i trends includes consideration of violation of requirements, significant operating abnormalities or deviations from expected plant behavior, and events requiring notifica-tion of the NRC. Results of the reviews are made directly available to the TMI-l management organization. Use of the GPU Nuclear divisions in this manner accomplishes the -intent of Section 4.3 and 4.4 of ANS 3.2 (Draft 5) l and will eliminate the need for the currently established Plant Operations Review Committee (PORC).

The replacement of the PORC will enable plant staff super-visory personnel to devote their time to their primary duties without the time-consuming need for participation in PORC meetings, which, under t? present organization i requires much of the supervisors' time.

The proposed Independent Onsite Safety Review Group (IOSRG) will satisfy the requirements for an independent, full-time, safety engineering staff to be located onsite. The 10SRG will be a group of technical personnel who are assigned onsite at TMI, but who report to the corporate level Nuclear Assurance Division. The IOSRG will conduct an ongoing program to evaluate the technical adequacy and clarity of procedures important to safe operation of the plant (not

necessarily a pre-implementation evaluation). The IOSRG

l. will evaluate TMI-l operations from a safety perspective.

This group will also review when a change in Technical Specifications or unreviewed safety question.

Members of the Nuclear Safety Assessment Department (NASD) of the Nuclear Assur'ance Divisich serve as the staff for the General Of fice Review Board (GORB). The GORB is a senior level overview group charged with responsibility to consider

potentially significtnt nuclsar and rs.distion problars, and to recommend to the Office of the President how they may be avoided or mitigated. The GORB has a permanent, full-time chairman, a permanent Vice Chairman who is the Director of the NSAD, and approximately nine additional members whose areas of expertise embrace all aspects of nuclear power plant operation. The Chairman and Vice Chairman also serve in similar capacities on the GORE 3 for TMI-2 and Oyster Creek. The NSAD conducts assessments of all aspects of nuclear power plant design and operation, considers their potential for compromising nuclear safety, and recommends necessary improvements.

Audits of unit activities are performed by the Quality Assurance Department in accordance with the Operational Quality Assurance Plan except for those in the area of fire protection.

Section 6.6 Reportable Occurrence 1 Hasnotbeenrevised}otherthantitlechanges.

Section 6.7 Safety Limit Violations e

Has not been revised other than title changes.

~

Section 6.8 Procedures _,

Has been revised to include the requirements of the RETS and various station plans. Additionally, a section has been added concerning temporary changes to Radiological Controls procedures.

Section 6.9 Reporting Requirements Has been revised to include the requirements of the RETS and the unique reporting requirements of NuReg 0737.

i Section 6.10 Record Retention

~1 - Has been revised to reflect current wording used in

'_T ~C standardized Technical Specifications.

Section 6.11 Radiation Protection Program No change.

Section 6.12 High Radiation Area Has been revised to reflect lessons learned f rom the accident at TMI-2.

Section 6.13 Process Control Program (PCP)

Has been revised to include the requirements of the RETS.

Section 6.14 Offsite Dose Calculation Manual (ODCM)

Has been revised to include the requirements of the RETS.

i Section 6.15 Major Changes to Radwaste Traatment System 2 Has been revised to include the requirements of the RETS.

Section 6.16 Iodine Monitoring Program Has been added to reflect the requirements of NuReg 0578.

4 III. Safety Evaluation Justifying Change

! This change describes the administrative structure and control of the GPU Nuclear Corporation as required by Technical Specifications. This change enhances the independent review process and incorporates recommendation of

various committees and groups as a result of the accident at TMI-2.

Furthermore, it has been determined that:

1. The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not

! increased.

2. The possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not increased.

3. The margin of safety defined in the basis of any Technical Specification is not reduced.

IV. Amendment Classification (10CFR 170.22)

This change, although administrative in nature, requests changes in the administrative controls associated with safety reviews and is therefore considered a Class III License Amendment. Therefore, enclosed please find i the prescribed remittance of $4,000.

L V. Implementation Period l

In order to finalize the necessary procedures and train personnel an i=plementation period of 4 months from the date of receipt of the applicable a=endment is requested.

d 1

I i

'.- _ _ _ _ . _ , _ . , _ _ . _ _ _ , _ - . _ ~ _ - . _ , . _ . , . _ . _ . - _ . _ . . _ _ _ . _