ML20140D813

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Proposed Tech Specs Re SRC Audit Requirements & Mgt Title Change
ML20140D813
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 04/14/1997
From:
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20140D795 List:
References
NUDOCS 9704240133
Download: ML20140D813 (16)
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Text

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. h.'                                                                                   I' dp ATTACHMENT I TO JPN-97-016 PROPOSED TECHNICAL SPECIFICATION CHANGES ASSOCIATED WITH                    l SRC AUDIT REQUIREMENTS AND A MANAGEMENT TITLE CHANGE                   -l (JPTS-97-001) j l

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NEW YORK POWER AUTHORITY t JAMES A. FITZPATRICK NUCLEAR POWER PLANT  ! DOCKET NO. 50-333 DPR-59 i I 

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9704240133 970414 PDR ADOCK 05000333 P PDR

1 L ? . f. 1b i JAFNPP ) 6.5.1.3 Altemates 1 Altemative members shall be appointed in writing by the PORC Chairman to serve on a l temporary basis. 6.5.1.4 Meeting Frequency , Meetings will be called by the Chairman as the occasions for review or investigation arise. Meetings will be no less frequent than once a month. 

!         6.5.1.5 Quoru-i

. A quorum of the PORC shall consist of the Chairman or a Vice-Chairman and five members 4 including designated altemates. Vice-Chairmen may act as members when not acting as 

;                 . Chairman. A quorum shall contain no more than two attemates.

l 6.5.1.6 Responsibilities j The PORC shall be responsible for the: ! a. Review of 10 CFR 50.59 safety and environmental impact evaluations associated with procedures and programs required by Specification 6.8, and changes thereto. j b. Review of proposed tests and experiments that affect nuclear safety.

c. Review of proposed changes to the Operating License and Technical Specifications.
d. Review of proposed changes or modifications to plant systems or equipment that affect j nuclear safety.
e. Investigation of violations of the Technical Specifications. The PORC shall prepare and i present a report covering the evaluations and recommendations to prevent recurrence j to the Site Executive Officer, who will then forward the repost to the Chief Nuclear i Officer, the Director Regulatory Affairs and Special Projects, and to the Chairman of the l Safety Review Committee.
f. Review of plant operations to detect potential safety hazards.
g. Performance of special reviews and/or investigations at the request of the Site

[ Executive Officer.

h. Review of all reportable events.

l i. Review of the Process Control Program and the Offsite Dose Calculation Manual j (ODCM) and changes thereto. } j. Review the FitzPatrick Fire Protection Program and implementing procedures and changes thereto. l i i ] Amendment No. 22,57,94,170,210,220,222,220, i i 249 1

_ . _ _ __._.~ _. _ . _. _ _ _ . . . _ . . . _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ . _ f, 4 4 JAFNPP s , f. Radiological safety

g. Mechanical engineering i h. Electricalengineering
1. Administrative controls and quality assurance practices i J. Environment 4
k. Civil / Structural Engineering l I. Nuclear Licensing I
m. Emergency Planning I
n. Other appropriate fields associated with the unique characteristics of a nuclear power plant 1 CHARTER 6.5.2.2 The conduct of the SRC will be in accordance with a charter approved by the Chief Nuclear l
                             ' Officer. The charter will define the SRC's authority and establish the mechanism for carrying            '

out its responsibilities. MEMBERSHIP 6.5.2.3 The SRC shall be composed of at least six individuals including a Chairman and a Vice Chairman. Members shall be appointed by the Director Regulatory Affairs and Special l Projects and approved by the Chief Nuclear Officer. SRC members and attemates shall have an academic degree in engineering or a physical science, or the equivalent, and shall have a minimum of five years technical experience in one or more areas listed in Section 6.5.2.1. ALTERNATES 6.5.2.4 Altemates for the Chairman, Vice Chairman and members may be appointed in writing by the Director Regulatory Affairs and Special Projects and approved by the Chief Nuclear Officer. l CONSULTANTS 6.5.2.5 . Consultants may be used as determined by the SRC Chairman and as provided for in the charter. MEETING FREQUENCY 6.5.2.6 The SRC shall meet at least once per six months. I 1 1 1 

                                                                                                                                     .I l

l Amendment No. 00, 00, 05, 70, 04,100,105,120, 202, 220, 220, . 1 251

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L JAFNPP QUORUM 4 6.5.2.7 A quorum shall consist of at least a majority of the appointed individuals (or their alternates) and the Chairman (or the designated alternate). No more than two alternates may participate as SRC voting members at any one time. No more than a minority of the quorum shall have l direct line responsibility for the operation of the plant. REVIEW , l 6.5.2.8 The SRC shall review:

a. The safety evaluation for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision of Section 50.59,10 CFR, to verify that such actions did not constitute an unreviewed safety question.

1

b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety i question as defined in Section 50.59,10 CFR.
c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59,10 CFR.
d. Proposed changes to Technical Specifications of this Operating License.
e. Violations of code, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
f. Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.

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g. All Reportable Events.

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h. All recognized indications of an unanticipated deficiency in some aspect of design or operation ,

of safety related structures, systems or components. l

1. Reports and meetings minutes of the Plant Operating Review Committee. l l J. Plant staff performance. l AUDIT 6.5.2.0 Audits of facility activities shall be performed under the cognizance of the SRC. These audits l
shall encompass
;                 a. The conformance of faci lity operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
b. The training and qualifications of the entire facility staff at least once per 12 months. l l

i Amendment No. 50,00,05,100,110,220, 252

f 3_ *) Y. < l JAFNPP j 6.6 REPORTABLE EVENT ACTION i I l The following actions shall be taken for Reportable Events: l (A) The Commission shall be notified and a report submitted pursuant to the L requirements of Section 50.73 to 10 CFR Part 50, and I j (B) Each Reportable Event shall be reviewed by the PORC, and the results of this review j shall be submitted to the Chief Nuclear Officer, the Director Regulatory Affairs and l , l Special Projects, and the Chairman of the SRC.  ; 6.7 SAFETY LIMIT VIOLATION (A) If a safety limit is exceeded, the reactor shall be shut down and reactor operation shall i only be resumed in accordance with the provisions of 10 CFR 50.36, (c)(1)(i). (B) An immediate report of each safety limit violation shall be made to the NRC by the Site Executive Officer. The Chief Nuclear Officer, the Director Regulatory Affairs and l

Special Projects, and the Chairman of the SRC will be notified within 24 hours.

! l

(C) The PORC shall prepare a complete investigative report of each safety limit violation

, and include appropriate analysis and evaluation of: (I) applicable circumstances

preceding the occurrence, (2) effects of the occurrence upon facility component i systems or structures and (3) corrective action required to prevent recurrence. The  !
Site Executive Officer shall forward this report to the Chief Nuclear Officer, the

! Director Regulatory Affairs and Special Projects, the Chairman of the SRC, and the l l NRC. ! .) 6.8 PROCEDURES < l 5 (A) Written procedures and administrative policies shall be established, implemented, !. and maintained that: I

1. meet or exceed the requirements and recommendations of Section 5 of )
ANSI 18.7-1972 " Facility Administrative Policies and Procedures." l L i I 2. are recommended in Appendix A of Regulatory Guide 1.33, November 1972. )
3. implement the Fire Protection Program.

]

4. include programs specified in Appendix B of the Radiological Effluent  !

l Technical Specifications, Section 7.2. l (B) Each procedure of Specification 6.8.(A), and changes thereto, shall be approved

prior to implementation by the appropriate responsible member of management as
i. specified in Specification 6.5.0.

i s i ) Amendment No. 50,00,05,70,^0,110,220,222,220, t 253

v a ATTACHMENT ll TO JPN-97-016 SAFETY EVALUATION OF

PROPOSED TECHNICAL SPECIFICATION CHANGES ASSOCIATED WITH l- SRC AUDIT REQUIREMENTS AND A MANAGEMENT TITLE CHANGE (JPTS-97-001) 4 NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 DPR-59 l

l l

q Attachment il JPN-97-016 Page 1 of 9 SAFETY EVALUATION RELATED TO PROPOSED TECHNICAL SPECIFICATION CHANGES ASSOCIATED WITH SRC AUDIT REQUIREMENTS AND.' MANAGEMENT TITLE CHANGE Section 1 - Description of Chanaes This application for amendment seeks to revise Appendix A (Section 6) ci the James A. FitzPatrick Technical Specifications. These changes will enable the SRC to review rather than audit plant staff performance by deleting the plant staff performance audit requirement from Section 6.5.2.9.b, and incorporating a plant staff performance review requirement in Section 6.5.2.8. Additionally, this amendment application replaces the position title of Vice President Regulatory Affairs and Special Projects with Director Regulatory Affairs and Special Projects. The following is a list detailing the revisions.

1. Technical Specification paae 252 Add the following to Section 6.5.2.8:
                   "j. Plant staff performance."

Replace 6.5.2.9.b with: 

                   "b. The training and qualifications of the entire facility staff at least once per 12  1 months."
2. Technical Specification paaes 249. 251. and 253 l

l The title of"Vice President Regulatory Affairs and Special Projects" has been replaced with " Director Regulatory Affairs and Special Projects." Section ll- Purpose of Proposed Channes Sections 6.5.2.8 and 6.5.2.9 of the James A. FitzPatrick Technical Specifications contain a listing i of the required Safety Review Committee (SRC) reviews and audits. The SRC has delegated the l audit requirements in Section 6.5.2.9 to the Appraisal and Compliance Department (Reference 1). Section 6.5.2.9.b requires an audit of the performance, training and qualification of the entire facility staff at least once per 12 months. Currently, FitzPatrick meets this requirement to audit plant staff performance by performing the following activities.

  • SRC assesses the plant staff performance on a continual basis as part of its oversight function conducted at each scheduled meeting.

l 

            .      Quality Assurance (QA) and the Operations Review Group (ORG) prepare a quarterly

! trending report which identifies actual quality performance issues through the issuance I

3 Attachment ll JPN-97-016 Page 2 of 5 of a quarterly report. This report is distributed to all SRC members and discussed at SRC meetings. 

             .       QA conducts an annual evaluation of the facility staff.

A review of the 1995 and 1996 QA evaluations of the facility staff (annual audits) shows that no findings related to plant staff performance were issued. This indicates that the quarterly trend reports and SRC review of plant staff performance provide an adequate mechanism to ensure I plant staff performance is monitored and, therefore, completion of the annual QA audit is redundant. The time spent by the QA department to prepare this annual report could be better spent on othei uditing activities. Therefore, this proposed amendment requests that the Technical Specification requirement to audit facility staff performance be replaced with a requirement for SRC to revievw facility staff performance. This review will be accomplished as described above, except that the QA annual evaluation will not be performed. Any changes to 3 this review process will be evaluated in accordance with Authority procedures and policies. , The replacement of the Technical Specification requirement for SRC to audit plant staff performance with a requirement for SRC to review plant staff performance is consistent with NUREG-1433, Revision 0 (Reference 2). As part of the improved Technical Specification program discussed in Reference 3, the SRC review and audit requirements will be relocated to a properly controlled plant document, consistent with NUREG-1433, Revision 1 (Reference 4). In addition, Section 6 of Appendix A is being revised to reflect the change from Vice President Regulatory Affairs and Special Projeck to Director Regulatory Affairs and Special Projects. This 4 change is an administrative title change only as the responsibilities and reporting chain for this position remain the same (Reference 5). l Section 111 - Safety implications of the Proposed Channes i , There are no safety implications associated with the proposed changes. ) The proposed changes to Sections 6.5.2.8.j and 6.5.2.9.b allow the Safety Review Commides (SRC) and Quality Assurance (QA) department to stop performing redundant tasks. Currenuf, i the SRC has delegated to QA the audit requirements listed in Section 6.5.2.9.~ In addition to the

annual audit of plant staff performance completed by QA, SRC also reviews plant staff performance at each scheduled meeting and reviews the quarterly trend reports of plant staff performance written by QA/ORG. Therefore, the Technical Specification requirement to perform an annual audit of facility staff performance is a redundant task and does not add any value. The time spent by QA to prepare this report could be better spent on auditing other plant activities.

The proposed change from Vice President Regulatory Affairs and Special Projects to Director Regulatory Affairs and Special Projects is administrative as the responsibilities and reporting chain for this position remain the same.

s' lz ( 

    ,    .                                                                                   Attachment ll       I JPN-97-016          i Page 3 of 5        I Section IV - Evaluation of No Sionificant Hazards Consideration                                       j
         ' Consistent with the criteria of 10 CFR 50.92, the enclosed application is judged to involve no        j
         . significant hazards based on the following information.
                                                                                                                 )

(1) Does the proposed license amendment involve a significant increase in the probability or i consequences of an accident previously analyzed? l Response: R This amendment application does not involve a significant increase in the probability or ) consequences of an accident previously analy2.ed. The proposed changes allow the SRC to perform a review, rather than an audit, of plant staff performance. This change does not diminish the SRC's effectiveness. A review of the 1995 QA audit of plant staff j performance shows that no findings related to plant staff performance were issued. This indicates that the other review mechanisms currently in place are sufficient to ensure that plant staff performance is monitored. The position title change of VP-RASP to Director-RASP is an administrative change as all previously performed functions are being maintained. Therefore, the proposed changes do not affect the probability or consequences of any previously analyzed accident, j (2) Does the proposed license amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response

4 l This amendment application does not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed changes affect an SRC i audit requirement and a management position title. These changes do not affect plant equipment or the way the plant operates. Therefore, they cannot create a new or j different kind of accident. (3)_ Does the proposed amendment involve a significant reduction in a margin of safety?

Response

This amendment application does not involve a significant reduction in a margin of safety. The requested Technical Specification revisions require the SRC to review rather than audit facility staff performance and will not diminish the effectiveness of the SRC. A review of the 1995 audit confirms that performance of the annual audit is redundant as no findings or recommendations concerning plant staff performance were made. The QA/ORG quarterly trend reports and SRC review of facility staff performance  ! are adequate to ensure that plant staff performance is properly monitored. I 

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               ,                                                                                     Attachment 11

, JPN-97-016 Page 4 of 5 i The position title change (VP-RASP to Director-RASP) is an administrative change as all previously performed functions are being maintained. Therefore, the proposed changes e do not involve a significant reduction in a margin of safety. l Section V -Implementatign_of the Proposed Channes 4 1 This amendment request meets the eligibility criteria for categorical exclusion set forth in 10 CFR ' 51.22(c)(I s follows: (i) be amendment involves no significant hazards consideration. 1

i As demonstrated in Section IV of this evaluation, the proposti change involves no significant hazards conn
eration.

l (ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

i The proposed changes do not involve a physical alteration to the plant or revisions to any plant operating procedures. The changes are administrative in nature and do not affect the amounts of any effluents that may be released offsite.

(iii) there is no significant increase in individual or cumulr.ive occupational radiation exposure. The proposed changes do not alter plant operating or surveillance procedures, and therefore will not change individual or cumulative occupational radiation exposure. j Based on the above, it is concluded that there will be no impact on the environment resulting from the proposed changes and the proposed changes meet the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission. Additionally, implementation of the proposed changes will not adversely alter or affect the ALARA program or the Fire Protection  ! Program. ) Section VI - Conclusion Based upon the discussion in previous sections, the change to SRC audit requirements and position title change will not decrease the effectiveness of the SRC or the overall organization. The Plant Operating Review Committee (PORCj and SRC have reviewed these proposed changes and have concluded that the changes do not involve an unreviewed safety question or a significant hazard consideration as defined in 10 CFR 50.92, and do not endanger the health and safety of the public. t-a 

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                    ,                                                                                 Attachment !!                 1 JPN-97-016 Page 5 of 5                   ,

I Section Vll - References

. 1. NuAP 1.7, " Safety Review Committee."

l 2. NUREG-1433, Revisinn 0, " Standard Technical Specifications - General Electric Plants, L BWR/4 Specificatione' April 1992. I' 3. NYPA letter to NRC (IPN-96-115), " Improved Technical Specifications," November 5, 1996.

4. NUREG-1433, Revision 1, " Standard Technical Specifications - General Electric Plants, BWR/4 Specifications" April 1995.

l S. JAF-SE-95-050, " Management Position Title Changes: Changes to the Management l Position Titles of Vice President Regulatory Affairs and Special Projects, and Vice l President-Nuclear Engineering," October 10,1995. i I l i l l l i

I 3
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  ^  .

ATTACHMENT !!! TO JPN-97-016 l l MARK-UP OF TECHNICAL SPECIFICATION PAGES 1 ASSOCIATED WITH SRC AUDIT REQUIREMENTS AND TITLE CHANGES ) 

                                                  - (JPTS-97-001) l NOTE 1:    Deletions are shown in strikeout, and additions are shown in bold.                      l NOTE 2:    Previous amendment revision bars are not shown.

NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 DPR-59 l.

J.  % JAFNPP 

    ~

6.5.1.3 Altemates Altemative members shall be appointed in writing by the PORC Chairman to serve on a temporary basis. 6.5.1.4 Meeting Frequency Meetings will be called by the Chairman as the occasions for review or investigation arise. Meetings will be no less frequent than once a month. 6.5.1.5 Quorum A quorum of the PORC shall consist of the Chairman or a Vice-Chairman and five members including designated altamates. Vice-Chairmen may act as members when not acting as Chairman. A quorum shall contain no more than two attemates. 6.5.1.6 Responsibilities The PORC shall be responsible for the:

a. Review of 10 CFR 50.5g safety and environmental impact evaluations associated with procedures and programs required by Specification 6.8, and changes thereto,
b. Review of proposed tests and experiments that affect nuclear safety,
c. Review of proposed changes to the Operating License and Technical Specifications.
d. Review of proposed changes or modifications to plant systems or equipment that affect nuclear safety.
e. Investigation of violations of the Technical Specifications. The PORC shall prepare and present a report covering the evaluations and recommendations to prevent recurrence to the Site Executive Officer, who will then forward the report to the Chief Nuclear Officer, the Vice4Nesnient Director Regulatory Affairs and Special Projects, and to the Chairman of the Safety Review Committee.
f. Review of plant operations to detect potential safety hazards,
g. Performance of special reviews and/or investigations at the request of the Site Executive Officer.
h. Review of all reportable events.
i. Review of the Process Control Program and the Offsite Dose Calculation Manual (ODCM) and changes thereto.

J. Review the FitzPatrick Fire Protection Program arviimplementing procedures and changes thereto. Amendment No. 22,07,04,170,210,220,222,228 249 

 . - . - . - .               . _ - - .         .  ..         - -.    . - - - . . - - -        .       - _ ~ . . . - - . - . . - . - - - . - .

3- s JAFNPP 

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f. Radiological safety i g. Mechanical engineering i h. Electricalengineering l 1. Administrative controls and quality assurance practices
                          . J. Environment                                                                                                       j
k. Civil / Structural Engineering  !
                           . 1.        Nuclear Licensing                                                                                         i
m. Emergency Planning l
n. Other appropriate fields assc ciated with the unique characteristics of a nuclear power  ;

plant CHARTER 1 i 6.5.2.2 The conduct of the SRC will be in accordance with a charter approved by the Chief Nuclear  ; Officer. The charter will define the SRC's authority and establish the mechanism for 

                                                                                                                                                 ]

carrying out its responsibilities. ' MEMBERSHIP 6.5.2.3 The SRC shall be composed of at least six individuals including a Chairman and a Vice Chairman. Mernbers shall be appointed by the 7,ee i'reeMer,; Director Regulatory Affairs and Special Projects and cpproved by the Chief Nuclear Officer. SRC members and altemates shall have an academic degree in enginearing or a physical science, or the equivalent, and shall have a minimum of five years technical experience in one or more areas listed in Section 6.5.2.1. ALTERNATES 6.5.2.4 Altemates for the Chairman, Vice Chairman and members may be appointed in writing by the Vice43resedent Director Regulatory Affairs and Special Projects and approved by the Chief Nuclear Officer. CONSULTANTS 1 6.5.2.5 Consultants may be used as determined by the SRC Chairman and as provided for in the charter. MEETING FREQUENCY l l 6.5.2.6 The SRC shall meet at least once per six months. 1 l Amendment No. 50, 00, 05, 70, 04,100,100,120, 202, 200, 228 251

.,)  % JAFNPP QUORUM h 6.5.2.7 A quorum shall consist of at least a majority of the appointed individuals (or their alternates) and the Chairman (or the desi0nated alternate). No more than two alternates may participate as SRC voting members at any one time. No more than a minority of the quorum shall have direct line responsibility for the operation of the plant. REVIEW 6.5.2.8 The SRC shall review: i

a. The safety evaluation for 1) changes to procedures, equipm3nt or systems and 2) tests or  !

experiments completed under the provision of Section 50.59,10 CFR, to verify that such  ! actions did not constitute an unreviewed safety question. ,

b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59,10 CFR.
c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59,10 CFR.
d. Proposed changes to Technical Specifications of this Operating License.
e. Violations of code, regulations, orders, Technical Specifications, license requirements, or of l Intemal procedures or instructions having nuclear safety significance.  :
f. Significant operating abnormalities or deviations from normal and expected performance of  :

plant equipment that affect nuclear safety. ,

g. All Reportable Events.  ;
h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety related structures, systems or components,
l. Reports and meetings minutes of the Plant Operating Review Committee.

J. Plant staff performance. AUDIT 6.5.2.9 Audits of facility activities shall be performed under the cognizance of the SRC. These audits shall encompass:

a. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months,
b. The i;et.T.e..;e, training and qualiiiestions of the entire facility staff at least once per 12 months.

Amendtr.ent No. 00,00,07,,100,110,220 252

A . 1 JAFNPP 6.6 REPORTABLE EVENT ACTION j The following actions shall be taken for Reportable Events: (A) The Commission shall be notified and a report submitted pursuant to the requirements of Section 50.73 to 10 CFR Part 50, and - ] 4 l (B) Each Reportable Event shall be reviewed by the PORC, and the results of this review l 

!                                   shall be submitted O the Chief Nuclear Officer, the Vice Preenient Diroc.or              e i

i Regulatory Affairs and Special Projects, and the Chairman of the SRC. j 6.7 SAFETY LIMIT VIOLATION , ? (A) If a safety limit is exceeded, the reactor shall be shut down and reactor operation shall only be resumed in accordance with the provisions of 10 CFR 50.36, (c)(1)(i).

(B) An immediate report of each safety limit violation shall be made to the NRC by the Site Executive Officer. The Chief Nuclear Officer, the V;;e P.e;Zent Director 4

Regulatory Affairs and Special Projects, and the Chairman of the SRC will be notified l within 24 hours. (C) The PORC shall prepare a complete investigative report of each safety limit violation and include appropriate analysis and evaluation of: (I) applicable circumstances

preceding the occurrence, (2) effects of the occurrence upon facility component j i

systems or structures and (3) corrective action required to prevent recurrence. The i l Site Executive Officer shall forward this report to the Chief Nuclear Officer, the Vice

Preenient Director Regulatory Affairs and Special Projects, the Chairman of the  !

SRC, and the NRC.  ! 6.8 PROCEDURES [ (A) Written procedures and administrative policies shall be established, implemented, j and maintained that: l

1. meet or exceed the requirements and re' immendations of Section 5 of ANSI 18.7-1972 " Facility Administrative i ilicies and Procedures."
2. are recommended in Appendix A of Regulatory Guide 1.33, November 1972.
3. implement the Fire Protection Program.
4. include programs specified in Appendix B of the Radiological Effluent I Technical Specifications, Section 7.2.

(B) Each procedure of Specification 6.8.(A), and changes thereto, shall be approved  ; prior to implementation by the appropriate responsible member of management as l specified in Specification 6.5.0. Amendment No. 50,00,05,70,00,110,220,222,228 253}}

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