ML20041E678

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Tech Spec Change Request 28 for Tech Specs 6.3,6.4 & 6.5 Removing Radiation Controls Technician from Cognizance of Supervisor-Station Training
ML20041E678
Person / Time
Site: Crane 
Issue date: 03/05/1982
From:
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20041E675 List:
References
NUDOCS 8203110235
Download: ML20041E678 (3)


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

Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Request No. 28 The Licensee requests that the attached change page, 6-3, of the TMI-II proposed Interim Recovery Tech. Specs., Appendix A, be substituted in the existing Technical Specifications.

Reason for Change In February 1980, the Proposed Interim Recovery Technical Specifications were issued.

Section 6.4.1 required a training and replacement training program under the direction of the Supervisor-Station Training to meet or exceed the requirements and recommendations of Section 5.5 of ANSI N.18.1-1971 and Appendix "A" to 10CFR55.

Since it was not clear that Rad. Con.

Tech. training was within the scope of the referenced ANSI standard, the discrepancy with the Tech. Spec. was not recognized. This was brought to the Licensee's attention via Inspection Report 50-320/80-17 issued by the NRC on March 20, 1981. To correct this situation, this change request is being submitted as stated in our response to the referenced Inspection Report, to remove Rad. Con. Tech. training from the cognizance of the Supervisior-Station Training as presently required in the TMI-2 Tech. Specs.

This change will allow the continuance of the increased management attention and commitment afforded by the Rad. Con. Department direction of Rad. Con.

Tech. Training.

Justification for the Change In order to improve the qualifications of the TMI-2 Radiological Controls Technicians (Rad. Con. Tech.) a Rad. Con. Tech. Training / Qualification program was established under the direction of the newly formed Unit 2 Radiological Control Training Department in November 1979. This was in response to both company and NRC concerns and also recommendations by an independent consultant in November 1979. This concept of having the training program under the direction of the Radiological Controls Department was endorsed by the Report of the Special Panel in December 1979 (NUREG 0640).

It also affords the training program the benefit of Supervisory and manage-ment expertise in the radiological area which is a positive aid in assuring an adequate Rad. Con. Tech. training program.

Amendment Class 10 CFR 170)

The Licensee has determined that because the amendment request involves a pro forma change and not a safety concern, it represents a Class II License Amendment (per 10 CFR 170.22). Therefore, enclosed please find a check in the amount of $1,200.00.

8203110235 820305 PDR ADOCK 05000320 P

PDR

ADMINISTRATIVE CONTROLS 6.3 UNIT STAFF QUALIFICATI0h6 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N 18.1 of 1971 for comparable positions unless otherwise noted in the Technical Specifications.

6.3.2 The Manager-Radiological Controls shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

Each Radiological Controls Technician in responsible positions / Foreman shall meet or exceed the qualifications of ANSI 18.1-1971, paragraph 4.5.2/4.3.2, or be formally qualified through an NRC approved TMI-2 Radiation Controls training program.

Individuals who do not meet ANSI 18.1-1971 Section 4.5.2 are not considered technicians for purposes of determining qualifications but are permitted to perform work for which qualification has been demonstrated.

All Radiological Controls Technicians will be qualified through training and examination in each area or specific task related to their radiological controls functions prior to their performance of those tasks.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Plant Training Manager - TMI-2 and shall meet or exceed the requirements and recommendations of Regulatory Guide 1.8 of 1977 and Appendix "A" of 10CFR Part 55 except that Radiological Controls training may be under the direction of the Vice President -

Radiological and Environmental Controls.

6.4.2 A training program for the Fire Brigade shall be maintained under the direction of the Plant Training Manager - TMI-2 and shall meet or exceed the requirements of Section 27 of the NFPA Code - 1976.

6.5 REVIEW AND AUDIT 6.5.1 PLANT OPERATIONS REVIEW COMMITTEE (PORC)

FUNCTION 6.5.1.1 The Plant Operations Review Committee (PORC) shall function to advise the Director Site Operations on all matters related to nuclear safety and radioactive waste safety.

COMPOSITION 6.5.1.2 The Plant Operations Review Committee shall be composed of the:

a.

Chairman -

who shall have an academic degree in engineering or physical science field and a minimum of five years of applicable experience, b.

1 Member -

who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

THREE MILE ISLAND - UNIT 2 6-3 PROPOSED

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ADMINISTRATIVE CONTROLS c.

7 Members -

who shall meet or exceed the qualifications of Section 4.4 of ANSI N18.1 - 1971.

The Director Site Operations shall designate the Chairman and the Vice Chairman from among the members of the Plant Operations Review Coanittee.

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THREE MILE ISLAND - th T.

2 6-3a PROPOSED

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