ML20003E969

Revised Tech Specs,App A,Section 6.0 for Administrative Controls

ML20003E969
Person / Time
Site:	Three Mile Island
Issue date:	04/10/1981
From:	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 8104170570
Download: ML20003E969 (27)

Text

O~ TABL'E OF CONTENTS Section P_a_ge 6 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6-1 6.2 ORGANIZATION 6-1 6.2.1 0FFSITE 6-1 6.2.2 UNIT STAFF 6-1 6.3 UNIT STAFF QUALIFICATIONS 6-3 6.4 TRAINING 6-3 6.5 REVIEW AND AUDIT 6-3 6.5.1 TECHNICAL REVIEW AND CONTROL 6-3 6.5.2 INDEPENDENT SAFETY REVIEW 6-4 6.5.3 AUDITS 6-6 6.5.4 INDEPENDENT ONSITE SAFETY REVIEW GROUP 6-7 6.5.5 GENERAL OFFICE REVIEW BOARD 6-9 6.6 REPORTABLE OCCURRENCE ACTION 6-10 6.7 OCCURRENCES INVOLVING A SAFETY LIMIT VIOLATION 6-10 6.8 PROCEDURES 6-11 6.9 REPORTING REQUIREMENTS 6-12 6.9.1 ROUTINE REPORTS 6-12 6.9.2 REPORTABLE OCCURRENCES 6-13 6.9.3 UNIQUE REPORTING REQUIREMENTS 6-17 6.9.4 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6-18 6.9.5 SEMI-ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT 6-18 6.10 RECORD RETENTION 6-20 6.11 RADIATION PROTECTION PROGRAM 6-22 6.12 HIGH RADIATION AREA 6-23 6.13 PROCESS CONTROL PROGRAM 6-23 6.14 0FFSITE DOSE CALCULATION MAhTAL (ODCM) 6-23 6-23 6.15 MAJOR CHANGES TO RADIOACTIVE WASTE TREATMEhT SYSTEMS 6.16 IODINE MONITORING PROGRAM 6-23 l -

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FIGURES TITLE 3.5-2F Deleted 3.5-2G LOCA Limited Maximum Allowable Linear Heat Rate - TMI-1 3.5-2H APSR Position Limits of operation from 0 EFPD to EOC 3.5-3 .

Incore Instrumentation Specification, TMI-1 6-1 Organization Chart GPU Nuclear Corporation 6-2 TMI-1 Onsite Organization 9

Amendment No. 59 (10-31-80) vii

6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Operations and Maintenance Director - TM1-1 shall be responsible for unit operations and shall delegate in writing the succession to this responsibility during his absence.

i 6.2 ORGANIZATION i J

CORPORATE 6.2.1 The organization of the GPU Nuclear Corporation (GPUNC) for management and technical support shall be functionally as shown in Figure 6-1.

UNIT STAFF 6.2.2 The organization within the unit for ranagement , operat ions , t echnical support , and maintenance shall be functionally as shown in Figure 6-2.

a. Each on duty shif t shall be composed of at least the minimum shif t crew composition shown in Table 6.2-1.

b. At least one licensed Reactor Operator shall be in the control

room when fuel is in the reactor.

, c. At least two licensed Reactor Operaters shall be present in the control room during reactor startup, scheduled reactor shutdown and during recovery from reactor trips,

d. A licensed senior reactor operator (SRC) shall be in the control room at all times other than cold shutdown conditions (T average.

<2000F) when he should be onsite.

e. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor.

f. A licensed Senior Reactor Operator with no other concurrent operational duties shall directly supervise: (a) irradiated l fuel handling and transfer activities onsite, and (b) all unirradiated fuel handling and transfer activities to and fro the Reactor Vessel. .

g. A Site Fire Brigade of at least 5 members shall be maintained onsite at all times. The Site Fire Brigade shall not include members of the

- minimum shif t crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency.

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TABLE 6.2-1 MINIMUM SHIFT CREk' CCFPOSITION#

LICENSE CATEGORY QUALIFICATIONS Tave > 2000 Tave < 2000 SRO* 1 1**

R0 1 1 Non-Licensed Auxiliary 2 1 Operator Shift Technical Advisor 1*** None Required

• Includes the Licensed Senior Reactor Operator serving as the Shif t Supervisor.

• • Does not include the Licensed Senior R;> actor Operator or Senior Reactor Operator Li=ited to Fuel Handling, supervising (a) irradiated fuel handling and transfer activities onsite, and (b) all unirradiated fuel handling and transfer activities to and fro = the Reactor Vessel.

• x*May be on a different shift rotation than licensed personnel.

1. Shift crew co=positien may be one less than the =ini=u= require =ents for a period of ti=e not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to acco==odate unexpected' absence of on-duty shift crew =e=bers provided i==ediate action is taken to restore the shift crew co= position to within the =ini=u= require =ents of Table 6.2-1. This provision does not permit any shift crew position to be un=anned upon shift change due to an encoming shift crew =an being late or absent.

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6.3 UNIT STAFF QUALIFICATIONS

6. 3.3.1 Comprising the unit staff shall be supervisory and professional personnel encompassing the qualifications described in Regulatory Guide 1.8 of 1977.

6.3.3.2 The Manager-Radiological Controls or the Deputy shall meet or exceed the qualifications of Regulatory Guide 1.8 of 1977. Each Radiological Controls Technician / 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-l Radiation Controls training program. All Radio-logical 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.

6.3 . 3. 3 Tne Shif t Technical Advisors shall have a bachelor's degree or equiva-lent in a scientific or engineering discipline with specific training in unit design and response and analysis of the unit for transients and accident s.

6.4.4 TRAINING 6.4.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Manager - Training -

TMI-1 and shall meet or exceed the requirements and recommendations of Regulatory Guide 1.8 of 1977 and Appendix "A" of 10CFR Part 55.

6.4.4.2 A training program for the Fire Brigade shall be maintained under the direction of the Manager - Training - TMI-1 and shall meet or exceed the requirements of Section 27 of the NFPA Code - 1976.

6.5 REVIEW AND AUDIT 6.5.1 TECHNICAL REVIEW AND CONTROL The Vice President of each division within GPU Nuclear Corporation as indicated in Figure 6-1, shall be responsible for ensuring the prepara-tion, review, and approval of documents required by the activities described in 6.5.1.1 through 6.5.1.5 within his functional area of

- res pons ib ili ty.

ACTIVITIES 6.5.1.1 Each procedure required by Technical Specification 6.8 and other procedures including those for tests and experiment s which are Unpor-tant to safety, and changes thereto which are important to safety, shall be prepared by a designated individual (s)/ group knowledgeable in 6-3

the areas affected by the procedure. Each such procedure, and changes thereto, shall be reviewed for adequacy by an individual (s)/ group other than the preparer, but who may be from the same organization as the individual who prepared the procedure or change.

6.5.1.2 Proposed changes to the Appendix "A" Technical Specifications shall be reviewed by a knowledgeable individual (s)/ group other than the preparer, but who may be from the same division as the individual who prepared the change.

6.5.1.3 Proposed modifications to unit structures, systems, and components important to safety shall be designed by an individual / organization knowledgeable in the areas affected by the proposed modification.

Each such modification shall be reviewed by an individual / group other than the individual / group which designed the modification but may be from the same division as the individual who designed the modification.

6.5.1.4 Individuals responsible for reviews performed in accordance with 6.5.1.1, 6.5.1.2 and 6.5.1.3 shall include a determination of whether or not additional cross-disciplinary review is necessary. If deemed necessary, such review sball be performed by the appropriate personnel.

6.5.1.5 Events requiring written notification to the NRC and all violations of Technical Specifications Limiting Conditions for Operation shall be investigated and a teport prepared which evaluates the occurrence and which provides recommendations to prevent recurrence.

RECORDS 6.5.1.6 Written records of activities performed under specifications 6.5.1.1 through 6.5.1.5 shall be maintained.

6.5.2 INDEPENDENT SAFETY REVIEW FUNCTION 6.5.2.1 The Vice-President of each division within GPU Nuclear Corporation as indicated in Figure 6-1 shall be responsible for ensuring the periodic independent safety review of the subjects described in 6.5.2.5 within his assigned area of safety review responsibility.

6.5.2.2 Independent safety review shall be completed by an individual / group not having direct responsibility for the performance of the activities under review, but who may be from the same functionally cognizant organization as the individual / group performing the original work.

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6.5.2.3 GPU Nuclear Corporation shall collectively have or have access to the experience and competence required to independently review subjects in the following areas:

a. Nuclear power plant operations, j

b. Nuclear engineering

c. Chemistry and radiochemistry

d. Metallurgy

e. Nondestructive testing

f. Instrumentation and control

g. Radiological safety

h. Mechanical engineering

i. Electrical engineering f

j. Administrative controls and quality assurance practices,

k. Emergency plans and related organization, procedures and equipment.

1. Other apr. opriate fields associated with the unique character-istics of TMI-1.

6.5.2.4 Consultants may be utilized as determined by the cognizant Vice-President to provide expert advice.

RESPONSIBILITIES 6.5.2.5 The following subjects shall be independently reviewed by the functionally assigned divisions:

a. Violations, deviations, and reportable events which require reporting to the NRC in writing. Such reviews are performed af ter the fact. Review of events covered under this subsection shall include results of any investigations made and the recommen-dations resulting from such investigations to prevent or reduce the probability of recurrence of the event.

b. Written summaries of audit reports in the areas specified in section 6.5.3 and involving safety related functions.

c Any other matters involving safe operation of the nuclear power plant which a reviewer deems appropriate for consideration, or which is referred to the independent reviewers.

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6.5.2.6 QUALIFICATIONS The independent reviewer (s) shall have a Bachelor's Degree in Engine-ering or the Physical Sciences and three (3) years of professional level experience in the area being reviewed or 8 years of appropriate experience in the field of his specialty. An individual performing reviews may possess competence in more than one specialty area. Credit toward experience will be given for advanced degrees on a one-for-one basis up to a maximum of two years.

RECORDS _

6.5.2.7 Reports of reviews encompassed in Section 6.5.2.5 shall be prepared and transmitted to the cognizant division Vice President.

6.5.3 AUDITS 6.5.3.1 Audits of unit activities shall be performed by the Quality Assurance Department in accordance with the TMI-1 Operational Quality Assurance Plan.

These audits shall encompass:

a. The conformance of unit operations to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.

b. The performance, training and qualifications of the entire unit staf f at least once per 12 months.

c. The result of actions taken to correct deficiencies occurring in un it equipment, structures, systems or methods of operation that affect nuclear safety at least once per 6 months.

d. The performance of activities required by the Operational Quality Assurance Plan to meet the criteria of Appendix "B",10 CFR 50, at least once per 24 months.

e. The Emergency Plan and implementing procedures at least once per 24 months.

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f. The Security Plan and implementing procedures at least once per 24 months.

g. The Fire Protection Program and Unplementing procedures at least once per 24 months.

h. The Offsite Dose Calculation Manual and implementing procedures at least once per 24 months.

i. The Process Control Program and implementing procedures for solid-ification of radioactive wastes at least once per 24 months.

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j. The performance of activities required by the Quality Assurance Program to meet criteria of Regulatory Guide 4.15, December,1977 at least once per 12 months.

k. Any other area of unit operation considered appropriate by the GORB or the Office of the President-GPUNC.

6.5.3.2 Audits of the following shall be performed under the cognizance of the Vice President - Technical Functio.ns:

a. An independent fire protection and loss prevention program inspection and audit shall be performed annually utilizing either qualified of fsite licensee personnel or an outside fire protection fi nn.

b. An inspection and audit of the fire protection and loss prevention program, by an outside qualified fire consultant at intervals no greater than 3 years.

RECORDS 6.5.3.3 Audit reports encompassed by sections 6.5.3.1 and 6.5.3.2 shall be forwarded for action to the management positions responsible for the areas audited within 60 days af ter completion of the audit.

6.5.4 INDEPENDENT ONSITE SAFETY REVIEW GROUP (IOSRG)

FUNCTION 6.5.4.1 The 10SRG shall be a full-time group of engineers, independent of the unit st af f, and located onsite.

ORGANIZATION 6.5.4.2 The 10SRG shall consist of the Safety Review Manager and a staf f of engineers, each of whom shall have an academic degree in engineering or a physical science field.

6.5.4.3 The 10SRG shall report to the Nuclear Safety Assessment Department i

Director.

REVIEW FUNCTIONS 6.5.4.4 a) The 10SRG shall independently review the following:

1) Written safety evaluations of changes in the facility as described in the Safety Analysis Report, of changes in procedures as described in the Safety Analysis Report, and of tests or experi-ment s not described in the Safety Analysis Report, which are completed without prior NRC approval under the provisions of 6-7

10CFR 50.59(a) (1). This review is to verify that such changes, tests or experiments did not involve a change in the Technical Specifications or an unreviewed safety question as defined in 10CFR 50.59(a) (2). Such reviews need not be performed prior to hnpleme nt at ion.

2) Proposed changes in procedures, proposed changes in the facility, or proposed tests or experiment s, any of which involves a change in the Technical Specifications or an unreviewed safety question as defined in 10CFR 50.59(c). Matters of this kind shall be reviewed prior to submittal to the NRC.

3) Proposed changes to Technical Specifications or license amendments related to nuclear safety shall be reviewed prior to submittal to the NRC for approval.

6.5.4.4 b) The periodic review functions of the 10SRG shall include the following on a selective and overview basis:

1). Evaluation for technical adequacy and clarity of procedures impo rt ant to the safe operation of the unit.

2) Evaluation of unit operations from a safety perspective.

3) Assessment of unit safety prugrams.

4) Assessment of the unit performance regarding conformance to requirements related to safety.

5) Any other matter involving safe operation of the nuclear power plant that the Safety Review Manager deems appropriate for consid era t ion.

AUTHORITY 6.5.4.5 The IOSRG shall have access to the unit and unit records as necessary

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to perform its evaluations and assessments. Based on it s reviews,

[ the IOSRG shall provide recommendations to the management positions responsible for the areas reviewed.

6.5.4.6 QUALIFICATIONS The IOSRG engineers shall have a Bachelor's Degree in Engineering or the Physical Sciences and three (3) years of professional level

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experience in the nuclear power field including tech'nical supporting

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functions or 8 years of appropriate experience in the field of his specialty. Credit toward experience will be given for advance degrees on a one-to-one basis up to a maximum of two years.

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RECORDS 6.5.4.7 Reports of evaluations and assessments encompassed in Section 6.5.4.4 shall be prepared, approved, and transmitted to the Nuclear Safety Assessment Department Director, the Chairman of GORB, the cognizant division Vice President, and the management positions responsible for the areas reviewed.

6.5.5 GENERAL OFFICE REVIEW BOARD (CORB)

FUNCTION AND RESPONSIBILITY 6.5.5.1 The GORB is to consider potentially significant nuclear and radiation safety matters and to advise the President of GPUNC. The GORB review function shall include the evaluation of the effectiveness of the TMI-l quality assurance program.

COMPOSITION 6.5.5.2 The GORB shall have a minimum of seven members, including the Chairman and the Vice-Chairman. One member shall be from the unit operatons group, another member shall be from an engineering group responsible for modific ations pertinent to the unit. No more than two members of the GORB shall have line responsibility for operation of the unit. At least three members shall be from outside the GPU system.

QUALIFICATIONS 6.5.5.3 GORB members shall be representative of a wide range of expertise, examples being: nuclear station design, operations, materials, engineering, instrumentation and control, quality assurance, t raining, human factors analysis, safety analysis and accident control, and l

- radiation safety. The GORE will involve additional expertise on an ad hoc basis, as needed.

MEETING FREQUENCY

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6.5.5.4 The GORB shall meet a minimum of once per calendar quarter.

QUORUM i

6.5.5.5 The quorum of the GORB shall consist of a majority of the members, including either the Chairman or the Vice-Chairman.

RECORDS l

6.5.5.6 The records of GORB activities shall be maintained by the Chairman's Of fice and distributed to members and corporate of ficials, as l

i appropr iat e.

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6.6 REPORTABLE OCCURRENCE ACTION 6.6.1 The following actions shall be taken in the event of a reportable occurrence requiring prompt notification with written follow-up:

a. Each occurrence shall be reported immediately to the cognizant manager and the cognizant division Vice President and the Vice President TMI-1. Tne functionally cognizant division staff shall prepare a written report for each occurrence which shall include a description of the occurrence, the cause of the occurrence and recommendations for appropriate corrective action to prevent or minimize the probability of a repetition of the occurrence. Copies of all such reports shall be submitted to the functionally cognizant division Vice President and the Vice President TMI-1.

b. The Nuclear Regulatory Commission shall be notified in accor-dance with the requirements of Technical Specification 6.9.2. A.

6.6.2 The following actions shall be taken in the event of a reportable occurrence requiring a thirty-day written report.

a. Each such occurrence shall be reported promptly to the cog-nizant manager and the cognizant Vice President and the Vice President TMI-1. A written report for each occurrence shall be prepared by the functionally cognizant division staff snd shall include a description of the occurrence, the cause of the occurrence, and appropriate corrective action to prevent or minimize the probability of repetition of the occurrence.

Copies of all such reports shall be submitted to the func-tionally cognizant division Vice President and the Vice-Presi-dent TMI-1.

b. The Nuclear Regulatory Commission shall be notified in accor-dance with the requirements of Technical Specification 6.9.2.B.

6.7 OCCURRENCES INVOLVING A SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a safety limit I is violated:

i L The reacter shall be shut down and operation shall not be f resumed until authorized by the Nuclear Regulatory Commission.

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b. An immediate report shall be made to the Operations and Maintenance Director, and Vice President TMI-1, and the occurrence shall be promptly reported to the Nuclear Regulatory Commission in accordance with Technical Specification 6.9.2.A.

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c. A complete analysis of the circumstances leading up to and resulting from the occurrence shall be prepared by the unit staff. This report shall include analysis of the effects of the occurrence and recommendations concerning operatirn of the unit and prevention of recurrence. This report s': 11 be submitted to the Operations and Maintenance Director and the Vice President TMI-1. Appropriate analysis of repotts will be submitted to the Nuclear Regulatory Commission in accordance with Technical Specificati.on 6.9.2.A.

6.8 PROCEDURES 6.8.1 Written procedures important to safety shall be established, implemented and maintained covering the items referenced below:

a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

b. Surveillance and test activities of equipment important to safety and radioa:tive waste management equipment.

c. Refueling Operations

d. Security Plan Implementation ,

e. Fire Protection Program Implementation

f. Emergency Flan Implementation

g. Process Control Program Implementation

h. Of fsite Dose Calculation Manual Implementation i

i. Quality Assurance Program for ef fluent and environmental monitoring using the guidance in Regulator.y Guide 4.15.

6.8.2 Further, each procedure required by 6.8.1 above, and changes I

thereto which are important to safety, shall be reviewed and approved as described in 6.5.1.1 prior to implementation and shall f be reviewed periodically as set forth in administrative procedures.

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o.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 GPUNC knowledgeable in j

the area af fected by the procedure. For changes to procedures whici. may affect the operational status of unit systems or equipment, at least one of these individuals shall be a member of unit management or supervision holding a Senior Reactor i

Operator's License on the unit; changes to radiological controls procedures shall be documented by the Radiological l 6-11

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Controls Department, reviewed by Radiological Engineering and approved by the Manager Radiological Controls or his Deputy; and

c. The change is documented, reviewed and approved as described in 6.8.2 within 30 days of implementation.

6.9 REPORTING REQUIREMENTS In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following identified reports shall be submitted to the Director of the Region 1 Of fice of Inspection and Enforce-ment unless otherwise noted.

6.9.1 Routine Reports A. Startup Report. A summary report of plant st artup and power escalation testing shall be submitted following (1) receipt l of an operating license, (2) amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. The report shall address each of the tests identified in the FSAR and shall in general include a description of the measured values of the operating condi-tions or characteristics obtained during the test program and a comparison of these values with design predictions and speci fic ations . Any corrective actions that were required to obtain satisfactory operation shall also be described.

Any additional specific details required in license conditions based on other commitments shall be included in this report.

J Startup reports shall be submitted within (1) 90 days following completion of the startup test program, (2) 90 days following i

resumption or commencement of commercial power operation, or l

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(3) 9 months following initial criticality, whichever is earliest. If the Startup Report does not cover all three events (i.e. , initial criticality, completion of startup test f program, and resumption or commencement of commercial power l operation), supplementary reports shall be submitted at least every three months until all three events have been completed.

B. Annual Reports. Annual reports covering the activities of the unit as described below during the previous calendar year shall be submitted prior to March 1 of each year. Reports j required on an annual basis shall include:

(A single submittal may 5a made for the station. The submittal f

should combine those sec; .ons that are common to both units at the station).

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1. A tabulation on an annual basis of tha numbsr of stction, utility and othar personnel (including contractors) rscaiving exposures and their associated man rec exposure according to work,and job functions, (e.g., reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste 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 20% of the, individual total dose need not be accounted for.

In the aggregate, at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions. (This tabulation supplements the requirements of Section 20.407 of 10CFR Part 20).

2. The following information on aircraft movements at the Harrisburg International Airport:

a. The total number of aircraft movements (takeoffs and landings) at the Harrisburg International Airport for the previous twelve-month period.

b. The total number of movements of aircraft larger than 200,000 pounds, based on a current percentage estimate provided by the airport manager.

! 3. The following information from the periodic Leak Reduction Program tests shall be reported:

a. Results of leakage measurements,

b. Results of visual inspections, and

c. Maintenance undertaken as a result of Leakage Reduction Program tests or inspections.

4. The following information regarding pressurizer power operated relief valve and pressurizer safety valve challenges shall be reported:

a. Date and time of incident,

b. Description of occurrence, and

- c. Corrective measures taken if incident resulted

! from an equipment failure.

C. Monthly Operating Reports. Routine reports of operating statistics I

and shutdown experience shall be submitted on a monthly basis to l the Of fice of Inspection and Enforcement, U. S. Nuclear Regulatory l Commission, Washington, D.C. with a copy to the Region I Office no later than the fif teenth of each month following the calendar month covered by the report.

1 6.9.2 Reportable Occurrences Reportable Occurrences, including corrective actions and =casures to prevent recurrence, shall be reported to the NRC. Supplemental reports may be 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. (These reporting requirements apply enly to Appendix A Technical Specifications.)

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A. Prompt Notification With Written Follow-Up The types of events listed below shall be reported as expeditiously as possible, but within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed by telegraph, mailgram, telecopy or f acsimile transmission to the Director of the appropriate Regional Of fice, or his designate no later than the first working day following tne event, with a written follow-up report within two weeks. The written follow-up report shall include material to provide complete explanat ion, cause of the event, the circumstances surrounding the event, any corrective action, and component failure data.

1. Failure of the reactor protection system or other systems subject to limiting safety system settings to initiate the required protective function by the time a monitored parameter reaches the setpoint specified as the limiting safety system setting in the Technical Specifications or failure to complete the required protective function.

Note: Instrument drift discovered as a result of testing need not be reported under this item but may be reportable under it ems 6.9.2. A.5, 6.9.2. A.6, or 6.9.2.B.1 below.

2. Operation of the unit or affected systems when any parameter or operation subject to a limiting condition is less conservative than the least conservative aspect of the limiting condition for operation established in the Technical Specifications.

Note: If specified action is taken when a system is found to be operating between the most conservative and the least conservative aspects of a limiting condition for operation listed in the Technical Specifications, the limiting condition for operation is not considered to have been violated and need not be reported under this item, but it may be reportable under item 6.9.2.B.2 below.

3. Abnormal degradation discovered in fuel cladding, reactor coolant pressure boundary, or primary containment.

Note: Leakage of valve packing or gaskets within the limits for identified leakage set forth in the Technical Spec-ifications need not be reported under this item.

4. Reactivity anomalies involving disagreement with the predicted value of reactivity balance under steady state conditions during power operation greater than or equal to 1% A k/k; a calculated reactivity balance indicating a shutdown margin less conservative than specified in the Technical Specifications; short term reactivity increases 6-14

that correspond to a reactor period of less than 5 seconds or, if sub-critical, an unplanned reactivity insertion of more than 0.5% Ak/k;~ or occurrence of any unplanned criticality.

5. Failure or malfunction of one or more components which prevents or could prevent, by itself, the fulfillment of the functional requirements of system (s) used to cope with accidents analyzed in the FSAR.

6. Personnel error or procedural inadequacy which prevents or could prevent, by itself, the fulfillment of the functional requirements of systems required to cope with accidents analyzed in the FSAR.

Note: For items 6.9.2. A.5 and 6.9.2. A.6 reduced redundancy that does not result in a loss of system function need not be reported under this section but may b.3 reportable under it ems 6.9.2.B.2 and 6.9.2.B.3.

7. Conditions arising from natural or man-made events that, as a direct result of the event required plant shutd own ,

operation of safety systems, or other protective measures required by Technical Specifications.

8. Errors discovered in the transient or accident analyses or in the methods used for such analyses as described in the FSAR or in the bases for the Technical Specifica-tions that have or could have permitted reactor operation in a manner less conservative than assumed in the safety analyses.

I t 9. Performance of structures, systems, or components that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses in the FSAR or Technical Specifications bases; or discovery during plant life of conditions not specifically considered in the FSAR I

or Technical Specifications that require remedial action or corrective measures to prevent the existence or develop-ment of an unsafe condition.

Note: This item is intended to provide for reporting of potentially generic problems.

( 10. Failure or malfunction of the pressurizer power operated l relief valve or pressurizer safety valves which prevents l or could prevent, by itself, the fulfillment of the functional requirements of system (s) used to cope with accidents analyzed in the FSAR or as specified in the basis of Technical Specifications.

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11. Offsite releases of radioactive materials in liquid and gaseous ef fluents which exceed the limits of Technical Specification 3.22.1.1 or 3.22.2.1.

12. Exceeding the limits in Technical Specification 3.22.2.7 for the storage of radioactive materials in the listed tanks.

B. Thirty Day Written Reports. The reportable occurrences discussed below shall be the subject of written reports to the Director of the appropriate Regional Office within thirty days of occurrence of the event. The written report shall include narrative caterial to provide a complete explanation of the cause of the event, circumstances surrounding the event, any corrective action, and component failure data.

1. Reactor protection system or engineered safety feature instrument settings which are found to be less conservative than those established by the Technical Specifications but which do not prevent the fulfillment of the functional requirements of affected systems.

2. Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation.

Note: Routine surveillance testing, instrument calibrat ion ,

or preventive maintenance which require system configurations as described in items 6.9.2.B.1 and 6.9.2.B.2 need not be reported except where test results themselves reveal a degraded mode as described above .

3. Observed inadequacies in the Laplementation of admin-istrative or procedural controls which threaten to cause reduction of degree of redundancy provided in reactor protection systems or engineered safety feature systems.

4 Abnormal degradation of systems other than those specified in it ems 6.9.2. A.3. designed to contain radioactive material resulting from the fission process.

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NOTE: Sealed sources or calibration sources are not included under this item. Leakage of valve packing or gaskets within the limits for identified leakage set forth in Technical Specifications need not be reported under this ite=.

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6. An unplanned of fsite release of 1) more than 1 curie of radioactive material in liquid ef fluents, 2) more than 150 curies of noble gas in gaseous effluents, or 3) more than 0.05 curies of radioiodine in gaseous ef fluents.

7. Measured levels of radioactivity in an environmental sampling medium determined to exceed the reporting icvel values of Table 3.12.2 When averaged over any calendar quarter sampling period.

6.9.3 Unique Reporting Requirements A. Special reports shall be submitted to the Director of the Of fice of Inspection and Enforceaent Region 1 Office within the time period specified for each report. These reports shall be submitted covering the activities identified below:

Tests Submittal Dates a

(1) Containment Structural Within 3 months after Integrity Test - Tendon performance of sur-Surveillance Program veillance program.

(2) Steam Generator Tube Within 3 months after Inspection Program completion of inspection.

f (See Section 4.19.5)

(3) Containment Integrated Within 6 months after Leak Rate Test completion of test.

(4) Inservice Inspection Within 6 months after

' Program five years of operation.

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6.9.4 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT Note: A single submittal may be made for the station. The submittal should combine those sections that are common to both units at the station however, for units with separate radwaste systems, the submittal shall specify the release of radioactive material from each unit.

6.9.4.1 Routine radiological environmental operating reports covering the operation of the unit during the previous calendar year shall be submitted prior to May 1 of each year.

6.9.4.2 The annual radiological environmental operating reports shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activi-ties for the report period, including a comparison with preopera-tional studies, operational controls (as appropriate), and previous environmental surveillance reports and an assessment of the observed impacts of che plant operation on the environment. The reports shall also include the results of the land use censuses required by Technical Specification 3.12.2. If harmful ef fects or evidence of irreversible damage are detected by the monitoring, the report shall provide an analysis of the problem and a planned course of action to alleviate the problem.

I The annual radiological environmental operating reports shall include summarized and tabulated results in the format of Regulatory Guide 4.8, December 1975 of all radiological environmental samplea taken during the report period. In the event th at some results 1

are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report.

The reports shall also include the following: a summary description of the radiological environmental monitoring program; a map of l all sampling locations keyed to a table giving distances and

' directions from one reactor; and the results of licensee partici-l pation in the Interlaboratory Comparison Program, required by Technical Specification 3.12.3.

6.9.5 Semiannual Radioactive Ef fluent Release Report t

Note: A single submittal may be made for the station. The submittal should combine those sections that are common to both units at the station however; for units with separate radwaste sys. ems, the submittal shall specify the release of radioactive material from each unit.

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6.9.5.1 Routine radioactive ef fluent release reports covering the opera-tions of the unit during the previous 6 months of operation shall be submitted within 60 days after January 1 and July 1 of each ye ar .

6.9.5.2 The radioactive ef fluent release reports shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21, " Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Ef fluents from Light-Water-Cooled Nuclear Power Plant s," Revision 1, June 1974, with data summarized on a quarterly basis following the format of Appendix B thereof.

The radioactive ef fluent release report to be submitted 60 days af ter January 1 of each year shall include an annual summary of hourly meteorological data collected over the previous year.

This annual summary may be either in the form of an nourly-by-hourly listing of wind speed, wind direction, atmospheric stability, and precipitation (if measured) on magnetic tape, or in the form of joint frequency distribution of wind speed, wind direction, and atmospheric stability. This same report shall include an assessment of the radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. This same report shall also include an assessment of the radiation doses from radioactive liquid and gaseous effluents to individuals due to their activities inside the site boundary (Figures 5.1-3 and 5.1-4) during the report period. All assumptions used in making these assessments (i.e.,

specific activity exposure time and location) shall be included in these report s. The meteorological conditions concurrent with the time of release of radioactive materials in gaseous effluents (as determined by sanpling frequency and measurement) shall be used for determining the gaseous pathway doses. The assessment of radiation doses shall be performed in accordance with the Offsite l Dose Calculation Manual (ODCM).

The radi active effluent release report to be submitted 60 days after January 1 of each year shall also include an assessment of radiation doses to the likely and most exposed real individual from l

reactor releases and other nearby uranium fuel cycle sources (including doses from primary ef fluent pathways and direct radiation) for the previous 12 consecutive months to show conformance with 40 l

CFR 190 " Environmental Radiation Protection Standards for Nuclear l Power Operat ion." Acceptable methods for csiculating the dose l

contributions from liquid and gaseous effluents are given in l Regulatory Guide 1.109, Rev. 1.

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The radioactive effluent release reports shall include the following information for each type of solid waste shipped offsite during the repo rt period:

a. container volume,

b. total curie quantity (specify whether determined by measure-ment or estimate),

c. principal radionuclides (specify whether determined by measure-ment or estimate),

d. type of waste (e.g. spent resin, compacted dry waste, evaporator bottoms),

e. type of container (e.g. , LSA, Type ' A, Type B, Large Quantity) and

f. solidification agent ( e. g . , c ement , urea formaldehyde).

The radioactive effluent release reports shall include a summary of unplanned releases from the site to unrestricted areas of radioattive materials in gaseous and liquid effluents on a quarterly basis.

The radioactive effluent release reports shall include any changes to the Process Control Program (PCP) made during the reporting pe riod.

6.10 RECORD RETENTION 6.10.1 The following records shall be retained for at least five years:

a. Records of normal station operation including power levels and periods of operation at each power level,

b. Records of principal maintenance activities, including inspection, repairs, substitution, or replacement of principal items of equipment important to safety.

c. Records of reportable occurrences.

d. Records of periodic checks, tests, and calibrations

e. Records of reactor physics tests and other special tests important to safety.

f. Changes to operating procedures important to safety,

g. Records of solid radioactive shipments, i I

i 6-20 l

h. By product material inventory records and source leak test res ult s .

i. Special nuclear material inventory records.

6.10.2 The following records shall be retained for the duration of Operating License DPR-50.

a. Record and drawing changes reflecting f acility design modifications made to systems and equipment described in the Final Safety Analysis Re po r t .

b. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

c. Routine unit radiation surveys and monitoring records.

d. Records of radiation exposure history and radiation exposure status of personnel, including all contractors and unit visitors who enter radioactive material areas.

e. Records of radioactive liquid and gaseous wastes released to the environment, and records of environmental monitoring surveys.

f. Records of transient or operational cycles for those facility _

components important to safety for a limited number of transients or cycles as defined in the Final Safety Analysis Report.

g. Records of training and qualification for current members of the unit staff.

h. Records of in-service inspections performed pursuant to these Technical Specifications.

i. Records of Quality Assurance activities required by the Operational Quality Assurance Plan.

! j. Records of reviews performed for changes made to procedures or i equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

k. Records of reviews by the Independent Onsite Safety Review Group, and General Office Review Board minutes.

I 1. Records of analyses required by the radiological environmental monitoring program.

m. Records of the service lives of all hydraulic snubbers listed on Table 3.16.1 including the date at which the service life commences and associated installation and maintenance records.

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6.11 RADIATION PROTECTION PROGRAM Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.12 HIGH RADIATION AREA ,

6.12.1 In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c)(2) of 10 CFR 20:

a. Each High Radiation Area shall be barricaded and conspicuously posted as a High Radiation Area, and personnel desiring entrance shall obtain a Radiation Work Permit (RWP). Any individual entering a High Radiation Area shall (a) use a continuously indicating dose rate monitoring device or (b) use a radiation dose rate integrating device which alarms at a preset dose level, or (c) assure that a radiological control technician provides periodic radiation surveillance with a dose rate mon-itoring instrument.

b. Any area accessible to personnel where a major portion of the body could receive in any one hour a dose in excess of one thousand mrem shall be locked or guarded to prevent unauthorized entry. The keys to these locked barricades shall be maintained under the admin-istrative control of the Radiological Controls Foreman on duty.

The Radiation Work Permit is not required by Radiological Controls personnel during the performance of their assigned radiation pro-tection duties provided they are following radiological control procedures for entry into High Radiation Areas.

6.13 PROCESS CONTROL PROGRAM (PCPI 6.13.1 The PCP shall be approved by the NRC prior to Unplementation.

6.13.2 GPU Nuclear Corporation initiated changes to the PCP:

1. Shall be submitted to the NRC in the Semiannual Radio-i active Ef fluent Release Report for the period in which the i

ch ange s we re made . This submittal shall contain:

a. suf ficiently detailed inforcation to justify the changes without benefit of additional or supplemental information; 6-22

b. a determination that the changes did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and

c. documentation that the changes have been reviewed and approved pursuant to 6.8.2.

2. Shall become ef fective upon review and approval by GPUNC.

6.14 0FFSITE DOSE CALCULATION MANUAL (ODCM) 6.14.1 The ODCM shall be approved by th'e NRC prior to Urplementation.

l 6.14.2 GFU Nuclear Corporation initiated changes to the ODCM:

1. Shall be submitted to the NRC in the Semiannual Radioactive Ef fluent Release Report for the period in which the changes were made. This submittal shall contain:

a. suf ficiently detailed information to justify the changes without benefit of additional or supplemental information;

b. a determination that the changes did not reduce the accuracy or reliability of dose calculations or setpoint determinations; and

c. documentation that the changes have been reviewed and approved pursuant to 6.8.2.

2. Shall become ef fective upon review and approval by GPUNC.

6.15 MAJOR CHANGES TO RADIOACTIVE WASTE TREATMENT SYSTEMS 6.15.1 GPU Nuclear Corporation initiated safety related changes to the radio-active waste system (liquid, gaseous and solid):

1. Shall be reviewed and reported to the NRC in accordance with 10 CFR 50.

2. Shall be ef fective upon review and approval by the Vice President of the division within GPU Nuclear Corporation responsible for the

! activities being reviewed.

l 6.16 IODINE MONITORING PROGRAM A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions shall be implemented. This program shall include the following:

1. Training of personnel. I 1

2. Procedures for monitoring, and I

3. Provisions for maintenance of sampling and analysis equipment.

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