ML20207G811

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Proposed Tech Specs,Consisting of Tech Spec Change Request 60,revising Requirements for TMI-2 Safety Review Group to Reflect Current & Changing Configuration of Plant
ML20207G811
Person / Time
Site: Crane Constellation icon.png
Issue date: 08/15/1988
From:
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20207G801 List:
References
NUDOCS 8808240245
Download: ML20207G811 (15)


Text

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INDEX.

ADMINISTRATIVE CONTROLS SECTION PAGE 6.0 ADMINISTRATIVE CONTR0LS..........................................

6-1 6.1 RESPONSIBILITY...................

6-1 6.2 ORGANIZATION

'6.2.1 GPUNC Organization.........................................

6-1 6.2.2 TMI-2 Organization.........................................

6-1 6.3 UNIT STAFF 0VALIFICATIONS........................................

6-3 6.4 TRAINING.........................................................

6-3 6.5 REVIEW AND AUDIT 6.5.1 TECHNICAL REVIEW AND CONTR0L...............................

6-3 6.5.1.10 Records....................................................

6-5 6.5.1.11 Qualifications.............................................

6-5 6.5.2 INDEPENDENT SAFETY REVIEH..................................

6-5 6.5.2.1 Function...................................................

6-5 6.5.2.5 Responsib111 ties...........................................

6-6 6.5.2.7 Records....................................................

6-7 6.5.2.8 Qualifications for Indepenent Safety Reviewers (Mode 3 Only) 6-7 6.5.3 AUDITS.....................................................

6-7 6.5.3.2 Records...................

6-8 6.5.4 SAFETY REVIEW GROUP (SRG)..................................

6-8 6.5.4.1 Function...................................................

6-8 6.5.4.2 Organization...............................................

6-8 6.5.4.3 Responsibility.............................................

6-9 6.5.4.6 Authority..................................................

5-9 6.5.4.7 Qualifications.......................................

6-9 6.5.4.8 Records....................................................

6-10 6.6 REPORTABLE EVENTS ACTI0N.........................................

6-10 6.8 PROCEDURES........................................................

6-10 8808240245 880815 PDR ADOCK 050(X)320 P

pny THREE MILE ISLAND - UNIT 2 1x

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INDEX ADMINISTRATIVE CONTROLS SECTIQN PAGE 6.9 REPORTING-REQUIREMENTS 6.9.1 ROUTINE REPORTS AND REPORTABLE OCCURRENCES.................

6-11 6.9.1.4 Annual Reports.............................................

6-11 6.9.2 SPECIAL REPORTS............................................

6-12 6.10 RECORD RETENTION................................................

6-13 5

6.11 RADIATION PROTECTION PR0 GRAM....................................

6-14 6.12 HIGH RADIATION AREA.............................................

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THREE MILE ISLAND. UNIT 2 X

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1.0 DFFINITTONS CHANNEL FUNCTIONAL TEST 1.10 A CHANNEL FUNCTIONAL TEST shall be:

a.

Analog channels - the injection of a simulated signal into the channel as close to the primary sensor as practicable to,erify OPERABILITY including alarm and/or trip functions.

b.

Blstable channels - the injection of a simulated signal into the channel sensor to verify OPERABILITY including alarm and/or trip fur.ctions.

STAGGERED TEST BASIS 1.11 A STAGGERED TEST BASIS shall corsist of:

a.

A test schedule for n systems, subsystems, trains or designatcd components obtained by dividing the spe-ified test interval into n equal subintervals, b.

The testing of one system, subsystem, train or designated components at the beginning of each subinterval.

FEf00ENCY NOTATION 1.12 The FREQUENCY NOTATION specified for the performance of surveillance requirements shall correspond to the intervals defined in Table 1.2.

FIRE SUPFRESSION HATER SYSTEM 1.13 A FIRE SUPPRESSION HATER SYSTEM sha'l consist of:

a dater source; gravity tank Or pumps; and distribution pipi.ig and associated sectionalizing control or isolation valves.

Such valves shall include yard hydrant curb valves, and the first valve upstream of the water flow alarm device on each sprinkler, hose standpipe or spray system riser.

REVIEH SIGNIFICANT 1.14 During Modes 1 and 2, REVIEH SIGNIFICANT items shcIl consist of items

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that are Important to Safety, or proposed changes to Technical Specifications, License, Special Orders or Agreements, Recovery Operations Plan, Organization Plan, or involve an Unreviewed Safety Question or a Significant Environmental Impact. Also, those procedures which require NRC approval pursuant to Specification 3.9.13.

In addition, those activities not covered by an NRC approved system description, SER or TER and which exceed PEIS values.

THREE MILE ISLAND - UNIT 2 1-4

ADMfNISTRATfVE CONTROLS l

6.3 UNIT STAF8 QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N 18.1 of 1971 for comparable positions unless otherwise noted in the Technical Specifications.

6.3.2 The Radiological Controls 01 rector TMI-2 or his deputy shall meet or 4

exceed the qualifications of Regulatory Guide 1.8, September 1975.

Each Radiological Controls Technician in responsible positions / Foreman shall meet or exceed the qualifications of ANSI 18.1-1971, paragraph 4.5.2/4.3.2, or be 1

formally quallfled through an NRC approved THI-2 Radiation Controls training program.

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

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

1 6.4 TRAINING 6.4.1 A retraining and replacement training program for the unit staff shall be maintained under the direction of the Plant Training Manager and shall meet or exceed the requirements and recommandations of Regulatory Guide 1.8 of 1977 and Appendix "A" of 10 CFR Part 55 except that Radiological Controls training may be under the direction of Vice President-Radiological and Environmental Controls.

6.4.2 A training program for the Fire Brigade shall be maintained under the direction of the Plant Training Manager 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 Office of TMI-2 Division Director and Support Division Vice-Presidents withir GPU Nuclear Corporution as indicated in Organization Plan Figure 1.1, snall be esponsible for ensuring the preparation, review, and approval of documents required by the activities within their functional area of responsibility for TMI-2.

Implementing approvals shall be performed at the cognizant section manager / director level or above.

In.npendent safety review and audit shall be conducted in accordance with this Technical Specification.

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i THREE MILE ISLAND - UNIT 2 6-3

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ADMfNf9TRATfVE CONTROLS ACTIVITIES 6.5.1.1 Each procedure required by Technical Specification 6.8 and other procedures including those for test and experiments and changes thereto shall be prepared by a designated individual (s)/ group knowledgeable in the area affected by the procedure.

Each such procedure, and changes thereto, shall be given a technical review 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 Deleted 6.5.1.3 Proposed modifications to unit structt'res, systems and components shall be designed by an individual / organization knowledgeable in the areas affected by the proposed modificatio,.

Each such modification shall be technicall" reviewed by an individual / group other than the individual / group which des, ad the modification but may be from the same group as the individual w' > designed the modification.

1 6.5.1.4

... posed tests and experiments shall be reviewed by a knowledgeable individual (s)/ group other than the preparer but who may be from the same

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division as the individual who prepared the tests and experiments.

6.5.1.5 The Security Plan and implementing procedures shall be reviewed by a knowledgeable individual (s)/ group other than the individual (s)/ group which prepared them.

6.5.1.6 The Emergency Plan and implementing procedures shall be reviewed by a knowledgeable individual (s)/ group other than the individual (s)/ group which prepared them, d

6,5.1.7 The Recovery Operations Plan and implementing procedures and changes thereto shall be reviewed by a knowledgeable individual (s)/ group other than the individual (s)/ group which prepared them.

i 6.5.1.8 Individuals responsible for reviews performed in accordance with 6.5.1.1 through 6.5.1.7 shall include a determination of whether or not additional cross-disciplinary review is necessary.

If deemed necessary, such review shall be performed by the appropriate personnel.

6.5.1.9 Support Division procedures will be reviewed and approved in accordance with their Division level procedures.

If the procedure / change i

i impacts the operational status of unit systems of equipment, it must be i

concurred with by the THI-2 Division. Unreviewed Safety Question, Technical 2

Specification change (including Recovery Operations Plan change), or i

Significant Environmental Impact requires line THI-2 Division and independent i

safety review prior to implementation.

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THREE MILE ISLAND - UNIT 2 6-4 1

ADMiNiSTRAVIVE CONTROLS RECORDS 6.5.1.10 Written records of activities performed under Specifications 6.5.1.1 through 6.5.1.8 shall be maintained in accordance with 6.10.

QUALIFICATIONS 6.5.1.11 Responsible Technical Reviewers shall meet or exceed the qualifications of ANSI /ANS-3.1 - 1978 Section 4.4 for Reactor Engineering, Instrumentation and Control, Chemistry and Radiochemistry, Radiation Protection and Quality Assurance Reviewers or have seven (7) years of appropriate experience in the area of their speciality. All other RTRs shall meet Section 4.6, i.e., shall either, 1) have a Bachelor's Degree in Engineering or the physical sciences and three years of professional level experience in the area being reviewed or, 2) have seven years of appropriate experience in the field of their 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 to two years.

j,.5.2 INDEPENDENT SAFETY REVIEW FUNCTION 6.5.2.1 The Office of THI-2 Division Director and Support Division Vice Presidents within GPU Nuclear Corporation as indicated in Organization Plan Figure 1.1 shall be responsible for ensuring the Independent Safety Review of the subjects described in 6.5.2.5 within his assigned area of safety review responsibility.

Divisions other than the TMI-2 Division will perform the Independent Safety Review of their own procedures affecting TMI-2 in accordance with approved procedures except as specified in Section 6.5.1.9.

When the Pteparer determines a procedure is not Review Significant, the signature of the RTR indicates concurrence with this determination.

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.

During Modes 1 and 2, for l

those THI-2 Division documents determined to be Review Significant, the Independent Safety Review shall be performed by or under the cognizance of SRG.

6.5.2.3 GPU Nuclear Corporation shall collectivel," have or have access to the experience and competence required to ind aendently review subjects in the i

following crea:

a.

Nuclear Unit operations b.

Nuclear engineering c.

Chemistry and radiochemistry d.

Metallurgy e.

Instrumentation and control THREE MILE ISLAND - UNIT 2 6-5 l

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l ADMfNISTRAlfVE CONTROLS f.

Radiological safety q.

Mechanical engineering h.

Electrical engineering 1.

Administrative controls and quality assurance practices j.

Emergency plans and related organization, procedures and equipment k.

Other appropriate fields such as radioactive waste operation associated

.i with the unique characteristics of THI-2.

i 6.5.2.4 Consultants may be utilized to provided expert advice.

RESPONSIBILITIES 6.5.2.5 The following subjects shall be independently reviewed by the SRG l

during Modes 1 and 2 and by the Independent Safety Reviewers during Mode 3:

a.

Written safety evaluations of changes in the facility as described in the Safety Analysis Report, Technical Evaluation Reports, or docketed System Descriptions, changes in procedures as described in the Safety Analysis Report, Technical Evaluation Reports, or docketed System Descriptions, and tests or experiments not described in the Safety Analysis Report, Technical Evaluation Reports, or docketed System Descriptions, which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(1).

This review of items determined not to be Review Significant when performed by SRG is a supplemental review to verify that such changes, tests or experiments did not involve a change in the Technical Specifications or an Unreviewed Safety Question, b.

Proposed changes in procedures, proposed changes to the facility, or proposed tests or experiments, any of which involves a change in the Technical Specifications or an Unreviewed Safety Question shall be independently reviewec prior to implementation. Changes to Review Significant procedures which revision is not deemed to be Review Significant shall not be required te i: reviewed by SRG prior to implementation.

c.

Proposed changes to Techrical Specifications or license amendments prior to submittal to the NRC for approval, d.

Violations, deviations, and reportable events which require either one or four hour immediate notification to the NPC.

Such reviews are performed after the fact.

Review of events covcred under this subsection shall include results of any investigations made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event, e.

Deleted.

f, Special reviews, investigations or analyses and reports thereon as requested by the Office of the Director THI-2 or other manager reporting directly to the Office of the Director TMI-2.

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g.

Written summaries of audit renorts in the area specified in Section 6.5.3.

THREE MILE ISLAND - UNIT 2 6-6

AMf NISTRATIVE CONTROLS h.

Recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components, that could affect nuclear safety or radioactive waste safety, 1.

Any other matters involving safe operation of the nuclear power plant which the SRG or independent safety reviewers deem appropriate for consideration, or which are referred to the SRG or independent safety reviewers.

6.5.2.6 During Modes 1 and 2, for those subjects which are REVIEW SIGNIFICANT the Indapendent Safety Review will be performed by an individual (s) meeting the qualifications of Section 6.5.4.7.

RECORDS 6.5.2.7 Reports of reviews encompassed in Section 6.5.2.5 shall be maintained in accordance with 6.10.

QUALIFICATIONS FOR INDEPENDENT SAFETY REVIEHERS (Mode 3 Only) 6.5.2.8 The independent safety reviewer (s) shall either have a Bachelor's Gegree in Engineering or the Physical Sciences and five years of professional

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1evel experience in the area being reviewed or have nine years of appropriate experience in the /leid of his or her speciality. An individual performing reviews may possess competence in more than one specialty area. Credit toward experience will be given for advanced degrees on a or,e-for-one basis up to a maximum of two years.

6.5.3 AUDITS 6.5.3.1 Audits of unit activities shal' be performed in accordance with the TMI-2 Recovery QA Plan. These audits shall enccmpass:

a.

The conformance of unit operations Jo provisions contained within the Technical Specifications and applicable license conditions.

The audit frequency shall be at least once per 12 moriths.

b.

The performance, training and qualifications of the entire urd t staff.

The audit frequency shall be least once per 12 months.

c.

The verification rf the ncnconformances and corrective cet"ons program as related to actions taken to correct deficiencies occurring in unit equipment, 'tructures, systems or methods of operation that affect nuclear safety.

The audit frequency shall be et least onr.e per 6 months.

d.

The performance of activities required by the Recovery Quality Assurance J

Plan to meet the criteria of Appendix "B",

10 Of94 50.

The rudit frequency shall be at least once per 24 months.

e.

The Emergency Plan and implementing procedures.

T0e audit frericency shall be at least once per 12 months.

f.

The Security Plan and implementing procidureb The audit frequency shall be at least once per 12 months.

1 THREE MILE ISLAND - UNIT 2 6-7

ADHINISTRATIVE CONTROLS g.

The Radiation Protection Plan and implementing procedures.

The audit frequency shall be at least once per 12 months.

h.

The Fire Protection Program and implementing procedures.

The audit frequer.cy shall be at least once per 24 months, 1.

An independent fire protection and loss prevention program inspection and technical audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

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

During Modes 1 and 2, any other area of unit operation considered l

appropriate by the SRG, the Manager, SRG's immediate supervisor, other managers reporting directly to the Office of the Director THI-2, the Office of the Director THI-2, or the Office of the President - GPUNC.

Any other areas required to be audited by QA will be identified to the appropriate QA Management level.

RECORDS 6.5.3.2 Audit reports encompassed by Section 6.5.3.1 shall be forwarded for action to the management positions responsible for the areas audited and SRG, during Modes I and 2, within 60 days after completion of the audit.

During Modes 1 and 2, SRG will review specified audits performed by QA and make corrective action recommendations as appropriate.

6.5.4 SAFETY REVIEW GROUP (SRG)

FUNCTION 6.5.4.1 The SRG shall be a full-time group of engineers, independent of the Site Operations of Engineering staff, and located onsite within the THI-2 division. (See Organization Plan Figure 1.2.)

APPLICABILITY 6.5.4.1.1 Modes 1 and 2 ORGANIZATION 6.5.4.2 The THI-2 SRG shall consist:

6.5.4.2.1 Manager, SRG and a minimum staff of 5 engineers (Mode 1).

6.5.4.2.2 Manager, SRG and a minimum staff of 3 engineers (Mode 2).

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event of an unanticipated vacancy in the SRG staff, the number of staff i

members can be two (2) for a period not to exceed one (1) month pending selection of a quallfted candiate to fill the vacancy.

THREE MILE ISLAND - UNIT 2 6-8

ADMlNTSTRATIVE CONTROLS i

The SRG shall report within the THI-2 Division independent of the unit operations and engineering functions, but no lower in the organization than one level below the Office of the Director, THI-2.

RESPONSIBILITY 6.5.4.3 The Manager, SRG is advisory to the Office of the Director THI-2.

However, he has the authority and responsibility to bring to the attention of the Office of the President GPUNC any issues he believes are not being addressed with adequate consideration of nuclear or radiological safety.

6.5.4.4 The review functions of the SRG shall include:

a.

The independent safety review activities stated in Section 6.5.2.5.

b.

Assessment of unit operations and performance and unit safety programs from a nuclear safety perspective, c.

Any other matter involving safe nuclear operations at the nuclear power plant that the Manager, SRG, the Manager, SRG's immediate supervisor, or other managers reporting directly to the Office of the Director THI-2 deem appropriate for consideration.

6.5.4.5 For those reviews requiring expertise outside that possessei by SRG, SRG is authorized to require reviews by other company groups as deemed appropriate by the Manager, SRG.

SRG may also utilize consultant expertise as it deems appropriate.

AUTHORITY 6.5.4.6 The SRG shall have access to the unit and unit records as necessary to perform its evaluations and assessments.

Based on its reviews, the SRG shall provide recommendations to the management positions responsible for the areas reviewed.

The SRG shall have authority to require independent reviews by other organizations as necessary to complete its functional responsibilities.

The Manager, SRG is advisory to the Office of the Director TMI-2. However, he has the authority and responsibility to bring to the attantion of the Office of the President any issues he believes are not being addressed with adequate consideration of nuclear or radiological safety.

QUALIFICATIONS 6.5.4.7 The SRG engineers shall have either:

1) a Bachelor's Degree in Engineering or the Physical Sciences and five (5) years of professional level experience in the DJclear power fl?ld including technical supporting functions, or, 2) nine (9) years of uppropriate experience. Credit toward experience will be given for advance degrees on a one-to-one basis up to a maximum of two years.

Th3 Manager, SRG shall meet or exceed the requirements of Section 4.7 of ANSI /ANS 3.1-1978.

l THREE MILE ISLAND - UNIT 2 6-9 i

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ADMfNISTRATfVE CONTROLS RECORDS 6.5.4.8 Although day to day results of evaluations by the SRG are communicated directly to the responsible department by the SRG, special reports are prepared only for items deemed appropriate by SRG as concurred with the Manager, SRG's immediate supervisor.

These special reports of evaluations and assessments by SRG shall be prepared, approved, and then transmitted to the Office of the Director, TMI-2 and the management position responsible for the area reviewed through the Manager, SRG's immediate supervisor.

These reports shall be maintained for the life of the operating license.

6.6 REPORTABLE EVENTS ACTION 6.6.1 The following actions shall he taken for REPORTABLE EVENTS:

a.

The Commission shall be notified and/or a report submitted pursuant to the requirements of Section 50.73 of 10 CFR Part 50, and b.

During Modes 1 and 2, each REPORTABLE EVENT shall be investigated and reviewed by the SRG, including the preparation and forwarding or reports covering evaluation and recommendations to prevent recurrence. A report shall be submitted to the Manager, SRG's immediate supervisor and the Office of the Director, THI-2. During Mode 3, each REPORTABLE EVENT shall undergo an independent safety review which shall be performed after the fact.

6.7 SECTION DELETED 6.8 PROCEDURES 6.8.1 Written procedures shall be established, implementcJ and maintained covering the activities referenced below:

a.

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

b.

Recovery Operations Plan implementation.

4 c.

Surveillance and test activities of safety-related equipment and radioactive waste management equipment.

d.

Security Plan implementation.

e.

Emergency Plan implementation, f.

Radiation Protection Plan implementation, i

g.

Limiting the amount of overtime worked by plant staff members performing safety-related functions in accordance with the NRC policy statement on working hours as transmitted by the Generic Letter 82-12.

6.8.2.1 Each procedure and any change to any procedure prepared pursuant to 6.8.1, shall be prepared, reviewed and approved in accordance with 6.5 and will ce reviewed periodically as required by ANSI 18.7 - 1976.

1Property "ANSI code" (as page type) with input value "ANSI 18.7 - 1976.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. THREE MILE ISLANO - UNIT 2 6-10

ADMINISTRATIVE CONTROLS 6.8.2.2 Deleted.

6.8.3.1 Temporary changes to procedures of 6.8.1 may be made provided that; a.

The intent of the original procedure control is not altered, and b.

1) For those procedures which affect the operational status of unit systems or equipment, the change is approved by two members of the unit management staff, at least one of whom holds a Senior Reactor Operator's License.

If one of the two above signatures is not by a supervisory person within the Department having cognizance of the procedure being changed, the signature of that supervisory person within the department will also be required, or 2)

For those procedures which do not affect the operational status of unit tystems or equipment, the change is approved by two members of the responsible organization.

If one of the two above signatures is not by a section manager / director within the Department having cognizance of the procedure being changed, the signature of that section manager / director within the department will also be required, and c.

The change is documented, Independent Safety Review completed, and the required reviews and approvals are obtained within 14 days, and d.

Those changes to procedures required by Specification 3.9.13 are submitted to the NRC for review within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following approval oy the management level specified for implementation by Section 6.5.1.9.

6.9 REPORTING REQUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 6.9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50.4 unless otherwise noted.

ANNUAL REPORTSll 6.9.1.4 Annual reports covering the activities of the Unit as described below during the previvus calendar year shall be submitted prior to March I of each year.

6.9.1.5 Reports required on an annual basis shall include:

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1 A single submittal may be made for a multiple unit station.

The submittal should combine those sections that are common to all units at the station.

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THREE MILE ISLAND - UNIT 2 6-11 l

ADMfNISTRATIVE CONTROLS a.

A tabulation of the number of station, utility and other personnel (including contractors) receiving exposures greater than 100 mrem /yr gnd their associated manrem exposure according to work and job functions,61 e.g., reactor operations and surveillance, in-service 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 whole body dose received from external sources shall be assigned to specific major work functions, b.

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

1.

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

2.

The total number of movements of aircraft larger than 200,000 pcunds, based on a current percentage estimate provided by the airport manager or his designee.

RADIATION SAFETY PROGRAM REPORT 6.9.1.6 Deleted.

REPORTABLE OCCURRENCES 6.9.1.7 Deleted.

PROMPT NOTIFICATION WITH WRITTEN FOLLOWUP 6.9.1.8 Deleted f

THIRTY DAY HRITTEN REPORTS 6.9.1.9 Deleted.

REPORTING REQUIREMENTS FOR INCIDENT WHICH OCCURRED ON MARCH 28. 1979 6.9.1.10 Section deleted. All reporting requirements completed.

SPECIAL REPORTS 6.9.2 Special reports shall be submitted in accordance with 10 CFR 50.4 i

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within the time period specified for each report, 2 This tabulation supplements the requirements of K20.407 of 10 CFR Part 20.

THREE MILE ISLAND - UNIT 2 6-12 4

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

i a.

Records of sealed source and fission detector leak tests and results.

b.

Records of annual pnysical inventory of all sealed source material of t

record, c.

Records of changes made to the procedures required by Specifications 6.8.1.d and e.

6.10.2 The following records shall be retained as long as the Licensee has an NRC license to operate or possess the Three Mile Island Facility.

a.

Records and logs of unit operation covering time interval et each power level.

b.

Records and logs of principal maintenance activities, inspection, repair.

i and replacement of principal items of equipment related to nuclear safety and radioactive waste systems.

c.

ALL REPORTABLE EVENTS submitted to the Commission, d.

Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

e.

Records of changes made to the procedures required by Specifications

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6.8.1.a. b, c, and f.

f.

Radiation Safety Program Reports and Quarterly Recovery Progress Reports on the March 28, 1979, incident, j

g.

Records of radioactive shipments.

h.

Records and logs of radioactive waste systems operations.

4 1.

Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Safety Analysis Report, TER, 4

50, or Safety Evaluation previously submitted to NRC.

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

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k.

Records of transient or operational cycles for those unit components

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designed for a limited number of transients or cycles.

1.

Records of reactor tests and experiments.

4 Records of training and qualification for current members of the unit m.

I staff.

1 THREE MILE ISLAND - UNIT 2 6-13 l

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i-o ADMINISTRATIVE' CONTROLS n.

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

c.

Records of Quality Assurance activities required by the Operating Quality Assurance Plan.

r.

Records of the incident which occurred on March 28, 1979.

s.

Records of unit radiation and contamination _ surveys.

t.

Records of radiation exposure for all Individuals entering radiation control-a eas.

u.

Records of gaseous and liquid radioactive material released to the environs.

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 In lieu of the "control device" or "alarm signal" required by Paragraph 20.203(c)(2) of 10 CFR 20. each high radiation area shall be controlled as i

specified in the Radiation Protection Plan.

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i THREE MILE ISLAND - UNIT 2 5-14

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