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A report to the Commission pursuant to Specification 6.9 23(2) is required if the minimum instrument requirement cannot be met within 1h ds.ys. | A report to the Commission pursuant to Specification 6.9 23(2) is required if the minimum instrument requirement cannot be met within 1h ds.ys. | ||
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i 1479 i07 6 3-56 | i 1479 i07 6 3-56 | ||
TABLE 3.18-1 FIRE DETECTION INSTRUMENTS Total Nu=ber | TABLE 3.18-1 FIRE DETECTION INSTRUMENTS Total Nu=ber | ||
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3 18.h.1 The CO, syste= for the Cable Spreading Rcca shall be operable with a miniEun level corresponding to 8500 lbs and a minimu= pressure of l | 3 18.h.1 The CO, syste= for the Cable Spreading Rcca shall be operable with a miniEun level corresponding to 8500 lbs and a minimu= pressure of l | ||
300 psig in the associated storage tank (s). | 300 psig in the associated storage tank (s). | ||
With the CO2 system for the Cable Spreading Room inoperable establish a fire watch with backup fire suppression in the unprotected area (s), | With the CO2 system for the Cable Spreading Room inoperable establish a fire watch with backup fire suppression in the unprotected area (s), | ||
and i a. In POWER OPERATION, STARTUP, HOT STANDBY and HOT SHUTDOWI, restore the system to operable status within 7 days or be in at least HOT SHUTDCMI vithin 8 hours and in COLD SFUTDOEI within the following 2h hours and submit a report to the Cc=sission | and i a. In POWER OPERATION, STARTUP, HOT STANDBY and HOT SHUTDOWI, restore the system to operable status within 7 days or be in at least HOT SHUTDCMI vithin 8 hours and in COLD SFUTDOEI within the following 2h hours and submit a report to the Cc=sission | ||
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6.1h FIRE PROTECTION TUSPECTION | 6.1h FIRE PROTECTION TUSPECTION | ||
: 1. An independent fire protection and loss prevention shall be per-i formed annually utilizing either a qualified off-site _ licensee | : 1. An independent fire protection and loss prevention shall be per-i formed annually utilizing either a qualified off-site _ licensee personnel or an outside fire protection firm. | ||
personnel or an outside fire protection firm. | |||
: 2. An inspection and audit by an outside qualified fire consultant shall be perforned at intervals no greater than three years. | : 2. An inspection and audit by an outside qualified fire consultant shall be perforned at intervals no greater than three years. | ||
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Latest revision as of 06:46, 22 February 2020
ML19260A068 | |
Person / Time | |
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Site: | Three Mile Island |
Issue date: | 02/10/1977 |
From: | Arnold R METROPOLITAN EDISON CO. |
To: | |
Shared Package | |
ML19260A060 | List: |
References | |
NUDOCS 7910290692 | |
Download: ML19260A068 (20) | |
Text
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! M CPOLITAN EDISON COMPAIIY JERSEY CE:; TRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPAITY THREE MILE ISLAND NUCLEAR STATION UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Srecification Chance Recuest No. h6 This Technical Specification Change Request is submitted in support of Licensee's request to change to Operating License No. DPR-50 for Three Mile Island Nuclear Station Unit 1. As a part of this request, proposed replacement pages for Operating License No. DPR-50 are also included.
METROPOLITAN EDISON COMPANY By .)
Vice President - G'eneration Sworn and suscribed to me this /owf day of N t_ m.,7 , 1977.
g' 0 4 ~t - D /N' -/+v ~. i .
Notary Public RITA i F ^',', I R S
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<; ,vo . Berks Ca.
.', cxm s r en E.;.re.. -;;e, at 30. D7?
1479 103 4910290 7%
UNITED STATES OF AMERICA iUCLEAR REGULATORY CCG!ISSION IN THE MNITER OF DOCKET NO. 50-289 LICENSE N6. DPR-50
!!ETROPOLITAN EDISON COMPA:IY This is to certify that a copy of Technical Specification Change Request No. h6 to 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 Co=ission and been served on the chief executives of Londonderry Township, Dauphin County, Pennsylvania and Dauphin County, Pennsylvania by deposit in the United Sta+,es :: ail, addressed as follows:
Mr. Weldon B. Arehart Mr. Harry B. Reese, Jr.
Board of Supervisors of Board of County Comissioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Court House Middletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120 METROPOLITAN EDISON COMPA'iY p O 7 3y I, f
Vice Preildent-Ghention Dated: February 10, 1977 1479 104
Metropolitan Edison Cocpany (Met-Ed)
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Docket No. 50-289 Operating License DFR-50 Technical Specification Chance Request No. h6 In response to your letter of Dece=ber 2,1976, the licensee requests that the enclosed replace =ent pages be added to existing technical specifications and corresponding superseded pages be deleted. Pages provided assu=e approval of all previously requested changes. Those changes not yet approved are indicated by double =argin bars .
Our change request is different fro = the model technical specifications for the following reasons:
- 1. Increased clarity
- 2. Internal consistency 3 Avoidance of repetitious reports Our change request deletes the requirement for replacing / repacking seals and gaskets during each hose station inspection since it is not considered necessary to replace this =aterial at this frequency unless the inspection results warrant replacement.
- Specifications regarding Ealon syste= operability have been deleted, since this syste= is redundant with a deluge system.
Specifications regarding Fire Barrier Penetration Seals have been deleted pending co=pletion of our Fire Hazards Analysis which vill define these barriers.
It 16 not necessary to update the organization chart to account for fire protection since, as stated in our letter GQL 1656 of December 6, 1976, personnel
- designated for i=plementation of fire protection measures are included in present organization.
Specifications requiring shutdown due to inoperable deluge / sprinkler systens have been deleted since the backup equip =ent required by specification 3.18.3.1 provides adequate protection.
Reason For Change Recuest i
To i= prove fire protection =easures as requested in URC letter of December 2, 1976.
Safety Analysis of Chance Request Since all proposed technical specifications provide odditicnal assurance el fire detection and suppression equipment this thange request involves no threat to the health and safety of the public.
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1.6 POWER DISTRIBUTION 1.6.1 QUADRANT POWER TILT Quadrant power tilt is defined by the following equation and is expressed in percent.
100 Power in any core cuadrant -1 Average power of all quadrants The quadrant tilt limits are stated in Specification 3.5 2.h. I i
1.6.2 REACTOR POWER IMBALACE Reactor power imbalance is the power in the top half of the core minus the power in the bottom half of the core expressed as a percentage of rated power. Imbalance is monitored continuously by the RPS using input from the power range channels. Lnbalance limits are defined in Specification 2.1 and imbalance setpoints are defined in Specification 2.3 1.7 CONTAIMEff INTEGRITY Containment integrity exists when the following conditions are satisfied:
- a. The equipment hatch is closed and sealed and both doors of the personnel hatch and emergency hatch are closed and sealed except as in "b" below.
- b. At least one door on each of the personnel hatch and e=ergency hatch is closed and sealed during refuleing or personnel passage through these hatches.
- e. All nonautcmatic containment isolation valves and blind flanges are closed as required by the " Containment Integrity Check List" attached to the operating procedure " Containment Integrity and Access Li=its."
- d. All autc=atic containment isolation valves are operable or locked closed.
- e. The containment leakage deter =ined at the last testing interval 1
satisfiec Specification h.k.l.
1.8 FIRE SUPPRESSION WATER SYS"T4 A FIRE SUPPRESSION WATER SYSTEM shall consist of: a water source, gravity tank pump, and distribution piping with associated sectionalizing control or isolation valves. Such valves include yard hydrant curb valves, and the first valve upstream of the water flow alar: device en each snrinkler, hose standpipe or spray system riser.
1-5
- 1479 106
3.18 FIRE p?OTECTION 3.18.1 FIRE DETECTION INSTRUMENTATION Applicability: All reactor operating conditions.
Objective: To insure adequate fire detection capability.
Specification:
i l 3 18.1.1 The minimum fire detection instrumentation for each fire detection l
zone shown in Table 318-1 shall be operable or a fire watch patrol
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must be established to inspect the zone with the inoperable instrument (s) at least once per hour.
A report to the Commission pursuant to Specification 6.9 23(2) is required if the minimum instrument requirement cannot be met within 1h ds.ys.
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i 1479 i07 6 3-56
TABLE 3.18-1 FIRE DETECTION INSTRUMENTS Total Nu=ber
- Instrument Location of Detectors Minimum Instruments Operable Heat Smoke Heat Smoke l
- 1. Control Building Elev. 355'
, Control Room 0 h NA 2
- 2. Control Building Elev. 338'
. 1D h160 V SWGR 0 1 NA 1 1E h160 V SWGR 0 1 NA 1 ESAS Cabinets 0 1 NA 1 Cable Spreading h 1 2 1 8 3 Control St.11 ding Elev. 322' 1P h80 V SWGR 0 1 NA 1 1S h80 V SWGR 0 1 NA 1 Battery Room A 0 1 NA 1 Battery Room 3 0 1 NA 1 Inverter Room A 0 1 NA 1
. Inverter Room b 0 1 NA 1
! Remote Shutdown Panel 0 1 NA 1
- h. Diesel Generators Diesel A 0 1 NA 1 Diesel B 0 1 NA 1 5 Screen House 0 2 NA 1
- 6. Aux. and Fuel Handling Building 1 1 1 1 1479 108 3-ST
3.18.2 FIRE SUPPRESSION WATER SYSTE4 Applicability: All reactor operating conditions Ob.iective: To insure adequate fire suppression capability Scecification:
3.18.2.1 The Fire Suppression Water Syste= shall be operabic with:
- a. Three (3) high pressure pu=ps of the following four (k), shall be operable with their discharge aligned to the fire suppression header and automatic initiation logic operable. Any two of the pumps provide co=bined capacity greater than 3575 gal / min:
- 1. Circulating Watar Plume Diesel Fire Pu=p 1
- 2. River Water Diesel Fire Pump, Unit 1
- 3. River Water Diesel Fire Pump, Unit 2 I
- k. River Water Motor Fire Pu=p, Unit 1
- b. Two (2) separate water supplies of the following three (3):
- 1. 100,000 gallon altitude tank
- 2. Circulating Water Flu =e
- 3. Rive.-
3.18.2.2 The Fire Suppression Water Syste= shall normally have three (3) fire pu=ps operable for redundancy. With less than three (3) pumps operable:
e
- a. In POWER OPERATION, STARTUP, HOT STA?DBY or HOT SHUTDCWN:
e Restore a redundant high pressure fire pu=p to operable status within 7 days or be in at least HOT SHUTDOWN within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and in COLD SHUTDOWN vithin the following 2h hours, and submit a report to the Co==ission pursuant to Specification 6.9.2B(2).
- b. In COLD SHUTDOMI or REFUELING S'3JTDCE;:
r A report to the Co==ission pursuant to Specification 6.9.2B(2) is required if a third pu=p cannot be restored to operable status within 7 days.
e 3.18.2.3 If less than two (2) pu=ps are operable or if less than two (2) water supplies are available:
- a. In POWER OPERATION, STARTUP, HOT STA':03Y or HOT SHUTDOWN- -
3e in at least HOT SHUTDOWN vithin 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and COLD SHUTDOWN vithin the following 2h hours , and sub=it a report to the Co==ission pursuant to Specification 2 9 23(2), and
- b. In all reactor operating conditions:
Initiate and complete within 2h hours after deter =inatien of syste= inoperability the procedures to provide for a backup water <upply system to assure total syste= capacity greater than 3575 gal./ min.
3-88 1479 109
9 3.16.3 PELUGE/SPRI:rt:LER SYSTEMS Aeolicability: All reactor operating conditions.
Objective: To assure adequate fire suppression capability.
Specification:
3 18.3 1 The Deluge and/or Sprinkler Systems located in the following areas sh&ll be vperable.
- a. Diesel Generator and Radiator Rooms
- b. Diesel Gererator Combustion Air Intakes
- c. Diesel Generator Cooli..g Air Intake
- d. Control Building Filter (AH-F3A, AH-F3B) Booms
- e. Air Intake Tunnel (Deluge - 2 of the 3 zones)
- f. Cht.rcoal Filter (AH-F10, AH-Fil)
- g. Intake Screen Pump House With one of the above deluge and/or sprinkler systems inoperable:
- a. Establish a fire watch with backup fire suppression equipment in the unprotected area (s), and submit a report to the Commission pursuant to Specification 6 9 2B(2),
- b. If in COLD CHUTDOW:i vr REFiJELING SHUTDOWN, a report to the Commission pursuant to Specification 6.9 2B(2) is required if ,
the system is not restored to operable status within 7 days. j 1479 110 3-89
3 18.4 CO2 SYSTEM Acclicability: All Reactor Operating Conditions Objective: To insure adequate firc suppression capability.
j Scecification:
3 18.h.1 The CO, syste= for the Cable Spreading Rcca shall be operable with a miniEun level corresponding to 8500 lbs and a minimu= pressure of l
300 psig in the associated storage tank (s).
With the CO2 system for the Cable Spreading Room inoperable establish a fire watch with backup fire suppression in the unprotected area (s),
and i a. In POWER OPERATION, STARTUP, HOT STANDBY and HOT SHUTDOWI, restore the system to operable status within 7 days or be in at least HOT SHUTDCMI vithin 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and in COLD SFUTDOEI within the following 2h hours and submit a report to the Cc=sission
{ pursuant to Specification 6 9 2B(2).
I b. In COLD SHUTDOMI or REFUELING SHUTDOEI, a report to the Cc==ission g
pursuant to Specification 6.9 2B(2) is required if the system is not made operable within 7 days.
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1 i479 11i 3-90 1
3.18.5 FIRE HCSE STATIO:IS Aeolicability: All reactor operating conditions.
Objective: To insure adequate fire suppression capability.
SDecification:
3.18.5.1 The fire hose stations listed in table 3.18-2 shall be operable on an additional hose to the unprotected area uust be routed to the unprotected area frem an operable hose station.
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Table 3 18-2 HOSE STATIONS Intermediate Buildine
- 1. Fire hose near northeast piping chamber stairway at elev. 309'.
Auxiliarv Building
- 1. Fire hose near stairway at northeast end of bui . ding near valve room at elev. 285'.
- 2. Fire hose near vaste evaporator condensate tank and auxiliary steam condensate return unit elev. 285'.
3 Fire hose near stairway at northeast end of auxiliary building and en61 neered safeguards control center, elev. 309'.
- h. Fire hose near radioactive waste control center, elev. 309'. ,
i Turbine Building
- 1. Fire hose along vest side of building near 12th stage extraction fced-water heaters, elev. 326'.
- 2. Fire hose along vest side of building near 10th stage extraction feed-water heaters, elev. 359'.
I 1479 i13 l
> 3-92
- h. 7
_ FIRE PROTECTION SYSTB4S 4.1 T.1 FIRE PROTECTION INSTRDENTS Atelicability: Instruments listed in table 3.18-1 Objective: To insure operability of fire detection instruments.
h .17.1.1 Each of the fire detection instruments listed in table 3.18-1 shall be de=enstrated operable at least once per 6 months.
i l-f 1479 114 I
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h.17.2 FIRE SUPPRESSION WATER SYSTDI i Aeolicability: Fire Suppression Water System as defined in Specification 1.8.
Objective: To insure system operability.
Soecification:
i 4.17.2.1 The system shall be demonstrated operable:
- a. At least once per 2h hours by verifying 50,000 gallons of water in the altitude tank.
- b. At least cnce per =onth on a staggered test basis by starting each pump and operating it for 15 minutes on recirculation flow.
- c. At least once per 6 months run the full flow of one fire pu=p I
through all main header loops as a flush.
- d. At least once per year by perforsing a system functional test i which includes a simulated automatic actuation of the system (i.e. , punps start at set pressure).
j e. At lecst once per year by verifying that each pump will develop a flow of 2500 gpm at a total dynamic head no more than 10".
below that indicated on manufacturers curves.
I
- f. At least once per 3 years by verifying the capability of the system to deliver 2575 gal./ min. to the most remote deluge l system plus 1000 gal./ min. to hoses with no more than 25 psi pressure drop.
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1479 115
! h-73 l
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I h.17 3 DELUGE /SPRINKI.ER SYSTDiS Aorlicability: Deluge and Sprinkler Systems.
Ob.i ective : To insure system operability.
Suecification:
h.lT.3.1 The deluge and/or sprinkler syste=s listed in Specification 3.18.3 1 shall be de=cnstrated to be operable:
- a. At least once per month by a flush through the drain / test j valves at the inlet to each deluge valve.
- b. At least once per month by flowing water through the inspectors test connection on each vet sprinkler header to verify absence of header blockage.
- c. At least once per year by performing a system functional test which includes tripping detectors and verifying actuation of trip devices on associated deluge valves. This yearly func-tional test vill not normally involve flowing water through the sprinkler / deluge header. Deluge sprinkler valves will be i inspected internally to verify operability in all instances
) where header flooding during the test is undesirable.
I
- d. At least once per year by a visual inspection of spray headers to verify their integrity.
' e. At least once per year by visual inspection (from floor level) of each no::le to verify absence of blockage.
- f. At least once per 5 years by an air flow test of any open type sprinkler head to verify absence of blockage.
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. h.17.h CO2 SYSTEM i
Aeolicability: 002 System for the Cable Spreading Room.
Objective: To insure system operability.
Suecification:
L 1479 116 h.17.h.1 The CO2 system shall be demonstrated operable:
- a. At least once per week by verifying the CO2 storage tank level and pressure.
- b. At least once per year by verifying the system values and associated ventilation dampers actuate in response to an actuation signal. A brief flow test shall be made to verify flow from each no::le. (" Puff Test")
h-Th i
h .175 HOSE STATIONS Applicability: Hose stations listed in Table 3.18-2.
t Objective: To insure system operability.
f Stecification:
t i h.17 5 1 Each fire hose station shall be verified operable:
- a. At least once per veek by visual inspection of the station to assure all equipment is available and the pressure in the standpipe is within limits,
- b. At least once per year by removing the hose for inspection.
- c. At least once per 5 years, partially open hose station valves to verify valve operability and no blockage. ,
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h-75 1
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- b. Proposed tests and experiments, and to =ake an initial determination that "a" and "b" above do not constitute an unreviewed safety question.
NOTE: The Unit Superintendent shall report directly to the Manager-Generation Operations-Nuclear and is responsible to him for the administration, operation and =aintenance of Three Mile Island Nuclear Station Unit 1.
6.2 ORGANIZATION OFFSITE 6.2.1 The organization of the Met-Ed Corporate Technical Support staff for Station manage =ent and technical support shall be functionally as shown in Figure 6-1.
FACILITY STAFF 6.2.2 The organization within the station for operations, technical support, and maintenance shall be functionally as shomi in Figure 12-1 of the Final Safety Analysis Report,
- a. Each on-duty shift shall, as a minimum, be composed of the following shift crev:
Shift Supervisor or Shift Foreman (See Notes 1 & 3) 1 Control Room Operator (See Notes 2 & 3) 2 Auxiliary Operator (See Note 3) 2 Additional station personnel available to serve on the fire brigade 3 Men / Shift 8 !
- b. At least two licensed reactor operators shall be at the station, one of whom shall be in the Control Rocm at all times when there is fuel in the reactor vessel. One of these oper- ms shall hold a Senior Reacter Operator's License.
- c. At least two licensed Reactor Operators shall be present in the
, Control Rocs during reactor start-up, scheduled reactor shutdown and during recovery from reactor trips.
- d. At least one =echer of each operating shift shall be qualified to imple=ent necascary radiation protection procedures.
- e. A licensed Senior Reactor Cperator with no other concurrent operaticnal duties shall directly supervise: (a) irradiated fuel handling and transfer activities onsite, and (b) all unirradiated fuel handling and transfer activities to and frc=
the Reac:cr 7essel.
NOTES:
i 1. The Shift Supervisor, or the Shift Foreman if a 14 1.
ch.2.%uperviQcr e
is not assigned, shall have an NRC Senior Reactor Operator's Li ense.
6-2 l
- 2. Only one licensed Control Room Operator shall be required per shift during cold shutdown or refueling operations.
- 3. Shift Supervisor, control Room Operator and Auxiliary Operator refer to functions that are to be performed and do not refer to
' the title of the individual. These functions may be perforned by any individual possessing the necessary licenses and qualifications.
6.3 STATION STAFF OUALIFICATION 6.3.1 Comprising the static staff shall be supervisory and professional personnel encompassing the qualifications described in Section 4 of ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel."
6.h TRAINING 6.h.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Supervisor of Training and shall meet or exceed the requirements and reco==endations of Section 5 5 of ANSI N18.1-1971 and Appendix "A" of 10CFR Part 55 6.h.2 A training program for the Fire Brigade shall be maintained under the direction of the Supervisor of Training - Nuclear and shall meet or exceed the requirements of Section 27 of the NFPA Code - 1976.
- 6.5 REVIEW AND AUDIT 6.5.1 PIANT OPERATIONS REVIEW COntITTEE (PORC)
FUNCTION 6.5.1.1 The Plant Operations Review Co==ittee shall function to advise the Unit Superintendent on all matters related to nuclear safety.
CCMPOSITION 6.5.1.2 The Plant Operations Review Committee shall be composed of:
i a) Unit Superintendent b) Supervisor of Cperations c) Supervisor of Maintenance d) Unit Electrical Engineer e) Unit Mechanical Engineer f) Unit Nuclear Engineer 3 g) Unit Instrument and Control Engineer
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h) Supervisor of Radiatien Protection and Che=istry i) PORC Chairman j) Other plant engineers assigned by the Unit Superintendent The Unit Superintencent shall designate the =e=bers, the Chairman, and the Vice Chairman of the Plan + Operations ?eview Co==ittee.
m Es m rS I479 Il9 6.5.1 3 Alternate =e=ters shall be appointed in writing by the Unit Superintendent to serve on a temporary basis. For purposes of this l specification, a designated alterrate shall be considered to have the 1
6-3 i
- k. Periodically audit the areas listed below to verify compliance with the Three Mile Island Operating Quality Assurance Plan, Fire Protection Program Plan, internal rules and procedures, federal regualtions, and operating license provisions:
l
- 1) The 18 Criteria of 10CFR50, Appendix B
- 2) Normal Unit Operation 3', Inservice Inspection
- 4) Refueling
- 5) Radiological Controls
- 6) Station Maintenance
- 7) Technical Specifications
- 8) Training and Qualifications of Station Staff
- 10) Industrial Security Program
- 11) Fire Protection Program and implementing procedures i In performing these audits, written procedures and/or check-lists shall te used. As a minimum, each area shall be audited at least once every two years.
1479 120 f 6-6a i
6.8 PROCEDURES 6.8.1 Written procedures and administrative policies shall be establiched, imple=ented and maintained that meet or exceed the require =ents and recoc=endations of Secticas 5 1 and 5.3 of ANSI N18.7-1972 and Appendix "A" of USNRC Regulatory Guide 1 33 November 1972 except as provided in 6.8.2 and 6.8.3 below.
Implementation of the Fire Protection Progra= shall be by =eans of written procedures.
6.8.2 Each nuclear safety related procedure and aininistrative policy of 6.8.1 above, and changes thereto, shall be reviewed by the Plant Operations Review Co=mittee and approved by the Unit Superintendent
. Prior to imple=tntation and periodically as may be set forth in each document.
6.8.3 Temporary changes to procedures of 6.8.1 above may be =ade provided:
- a. The intent of the original procedure is not altered.
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- b. The change is approved by two members of the plant manage =ent staff, at least one of whom holds a Senior Reactor Operator's
, License on the unit affected.
- c. The change is documented, reviewed by the Plant Operations Review Co=mittee and approved by the Unit Superintendent within 7 days of i=plementation.
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6.1h FIRE PROTECTION TUSPECTION
- 1. An independent fire protection and loss prevention shall be per-i formed annually utilizing either a qualified off-site _ licensee personnel or an outside fire protection firm.
- 2. An inspection and audit by an outside qualified fire consultant shall be perforned at intervals no greater than three years.
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1479 122 6_26 I
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