ML20069F960

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Amends 25 & 11 to Licenses NPF-87 & NPF-89,respectively, Changing TS by Revising Radiological Effluent Reporting Times
ML20069F960
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/01/1994
From: Black S
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20069F962 List:
References
NUDOCS 9406090169
Download: ML20069F960 (15)


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UNITED STATES 5 iY -

NUCLEAR REGULA. TORY COMMISSION L

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1 TEXAS UTILITIES ELECTRIC COMPANY COMANCHE PEAK STEAM ELECTRIC STATION. UNIT 1 DOCKET NO. 50-445 64ENDMENT TO FACILITY OPERATING LICENSE Amendment No. 25 l

License No. NPF-87' l.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Texas Utilities Electric Company (1U Electric, the licensee) dated February 14, 1994, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance:

(1) that the activities authorized by this amendmen.t can be conducted without endangering.the health-and safety of the public, and (ii) that such activities will be' conducted in compliance with the Commission's regulations; l

D.

The issuance of this license amendment will not be ' inimical to the common defense and security or to the health and safety of the' public; and E.

The-issuance of this amendment is in accordance with 10 CFR Part 51-of the. Commission's regulations and all applicable requirements have been satisfied. -

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2.

Accordingly, the license is amended by changes to.the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2.C.(2) of Facility Operating License No. NPF-87 is hereby amended to read as-follows:-

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Technical Specifications and Environmental Protection Plan I

The. Technical Specifications contained in Appendix A, as revised through Amendment No. 25, 'and the Environmental Protection-Plan-

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contained in Appendix B, both of which are attached hereto, are i

hereby incorporated in the license. The licensee shall operate the.

facility in accordance with the Technical Specifications and the Environmental Protection Plan.

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The~ license amendment is effective as of its date of issuance, = to be implemented within 30 days of issuance.

J FOR THE NUCLEAR REGULATORY COMMISSION 3

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uza ne C. B k, Director j ct Directo te IV-2

.l Div ion of_ Reactor Projects III/IV Office of Nuclear Reactor Regulation j

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Attachment:

Changes to the Technical l

Specifications l

'i Date of Issuance:

Dune 1, 1994 I

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l TEXAS UTILITIES ELECTRIC-COMPANY j

COMANCHE PEAK STEAM ELECTRIC STATION. UNIT 2 DOCKET NO. 50-446 AMENDMENT TO FACILITY OPERATING LICENSE Amendment'No. 11 1

License No. NPF-89 i

3.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Texas Utilities Electric Company

'l (TV-Electric, the licensee) dated' February 14, 1994, complies with.

i the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set

.j forth in 10 CFR Chapter I; 4

B.

The facility will operate in conformity with the application, as l

amended, the_ provisions of the Act, and the rules and regulations of 1

the Commission; j

C.

There is reasonable assurance:

(i) that the activities authorized' by this amendment can be conducted without endangering the health and safety of'the public, and (ii) that such activities will be conducted in compliance with the Commission's_ regulations D.

The issuance of this license amendment will not be' inimical.to'the-common defense and security or to the health and safety of-the l

public; and q

E.

The issuance of this amendment is.in accordance with 10'CFR Part 51 of the Commission's regulations and all_ applicable requirements have j

been satisfied.

l 2.

' Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C.(2) of Facility Operating License No._NPF-89 is.hereby-

.j amended to read as follows:

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(2) Technical Specifications and Environmental Proteciton Plan The Technical Specifications contained. in Appendix A, as ~ revised' 1

through Amendment No.11, and the Environmental Protection Plan i

contained in Appendix B, are hereby incorporated into this license.

ETU Electric shall operate the facility in accordance with.the j

Technical Specifications and the Environmental Protection Plan.

3.

This-license amendment is effective as of its date of issuance, to be implemented within 30 days of~ issuance.

i FOR THE NUCLEAR REGULATORY COMMISSION:

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l Suza ne C.

Qc., Director goj ct DirectW ate IV-2 Diel ion of Reactor Projects III/IV Office of Nuclear Reactor Regulation j

Attachment:

Changes to the Technical 4

Specifications j

. i Date of Issuance:

June 1, 1994 i

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e ATTACHMENT TO LICENSE AMENDMENT NOS 25 AND 11 FACILITY OPERATING LICENSE N05. NPF-87 AND NPF-82 DOCKET NOS. 50-445 AND 50-446 Replace the following pages of the Appendix A Technical Specifications with the attached pages.

The revised pages are identified by Amendment number and contain marginal lines indicating the areas of change.

The corresponding overleaf pages are also provided to maintain document completeness.

REMOVE INSERT xvi xvi 1-4 1-4 3/4 11-1 3/4 11-1 3/4 11-3 3/4 11-3 6-19 6-19 6-25 6-25 a

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INDEX ADMINISTRATIVE CONTROLS PEtE SECTION 6-1 6.1 RESPONSIBILITY................................................

6-1 6.2 ORGANIZATION..................................................

6.2.1 ONSITE AND OFFSITE ORGANIZATION.............................

6-1 1 6.2.2 UNIT STAFF..................................................

TABLE 6.2-1 MINIMUM SHIFT CREW COMPOSITION TWO UNITS WITH A COMMON CONTROL R00M.................................

6-3 6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG) 6-4 Function....................................................

6-4 Composition.................................................

i 6-4 l

Responsibilities............................................

6-4 Records.....................................................

6-4 6.2.4 SHIFT TECHNICAL ADVIS0R.....................................

6-4 l

6.3 UNIT STAFF 0VALIFICATIONS....................................

6-5 6.4 TRAINING.....................................................

6-5 6.5 REVIEW AND AUDIT.............................................

6.5.1 STATION OPERATIONS REVIEW COMMITTEE (50RC) 6-5 Function....................................................

6-5 Composition.................................................

6-5 Al t e rn a t e s..................................................

6-6 l

Meeting Frequency...........................................

6-6 Quorum......................................................

l 6-6 Responsibilities............................................

6-8 Records.....................................................

6.5.2 OPERATIONS REVIEW COMMITTEE (ORC) 6-8 Function....................................................

6-8 Composition.................................................

6-9 Alternates..................................................

6-9 C o n s ul t a n t s.................................................

6-9 Meeting Frequency...........................................

6-9 Quorum......................................................

6-9 Review......................................................

6-10 Audits......................................................

6-11 Records.....................................................

Unit 1 - Amendment No. 14 COMANCHE PEAK - UNITS 1 AND 2 xv

INDEX ADMINISTRATIVE CONTROLS PAGE SECTION 6.5.3 TECHNICAL REVIEW AND CONTR0LS...............................

6-11 6.6 REPORTABLE EVENT ACT10N.......................................

6-13 6.7 SAFETY LIMIT V10LAT10N........................................

6-13 6.8 PROCEDURES AND PR0 GRAMS.......................................

6-13 i

6.9 REPORTING RE0VIREMENTS........................................

6-17 1

6.9.1 ROUTINE REP 0RTS.............................................

6-17 6-17 Startup Report..............................................

6-18 Annual Reports..............................................

l Annual Radiological Environmental Operating Report..........

6-19 Annual Radioactive Effluent Rel ease Report..................

6-19 l

6-19 Monthly Operating Reports...................................

.f 6-20 Core Operating Limits Report................................

i 6.9.2 SPECIAL REP 0RTS.............................................

6-22 6.10 RECORD RETENTION.............................................

6-22 l

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

6-23 l

l 6.12 HIGH RADIATION AREA..........................................

6-23 6.13 PROCESS CONTROL PROGRAM (PCP)................................

6-25 6.14 0FFSITE DOSE CALCULATION MANUAL (0DCM).......................

6-25 COMANCHE PEAK - UNITS 1 AND 2 xvi Unit 1 - Amendment No. 25 Unit 2 - Amendment No.11

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DEFINITIONS DOSE EQUIVALENT I-131 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (m'icrocurie/

1.12 gram) which alone would produce the same thyroid dose as.the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135 actually present.

The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844, " Calculation of Distance Factors for. Power and Test Reactor Sites" or Table E-7 of NRC Regulatory Guide 1.109, Revision 1, l.

October 1977.

E - AVERAGE DISINTEGRATION ENERGY 1.13 E shall be the average (weighted in proportion to the concentration of each radionuclide in the sample) of the sum of the average beta and gamma energies per disintegration (MeV/d) for the radionuclides with a halflife-greater than ten (10) minutes in the sample.

ENGINEERED SAFETY FEATURES RESPONSE TIME The ENGINEERED SAFETY FEATURES (ESF)' RESPONSE TIME shall be that time-i 1.14 interval from when the monitored parameter exceeds its ESF Actuation Setpoint l

i at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump Times shall include i

discharge pressures reach their required values, etc.).

diesel generator starting and sequence loading delays where applicable.

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FREQUENCY NOTATION 1.15 The FREQUENCY NOTATION specified for.the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

IDENTIFIED LEAKAGE 1.16 IDENTIFIED LEAKAGE shall be:

l Leakage ~(except CONTROLLED LEAKAGE) into closed systems, such as pump a.

seal or valve packing leaks that are captured and conducted t;, a sump.

or collecting tank, or b.

Leakage into the containment atmosphere from sources that are both-specifically located and known either not to interfere with the operation of Leakage Detection Systems or not to be PRESSURE BOUNDARY LEAKAGE, or Reactor Coolant System leakage through a 'silam generator to the c.

Secondary Coolant System.

MASTER RELAY TEST

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l.17 A MASTER RELAY TEST shall be the energization of each master relay and

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verification of OPERABILITY of each relay. The MASTER RELAY TEST shall include a continuity check of each associated slave relay.

COMANCHE PEAK - UNITS 1 AND 2 1-3

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DEFINITIONS MEMBER (S) 0F THE PUBLIC i

l.18 MEMBER (S) 0F THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the licensee, its contractors, or vendors.

Also excluded from this category are persons who enter the site to service equipment or to'make deliveries.

This category does include persons who use portions of the. site.

l for recreational, occupational, or other purposes not associated with. the plant.

OFFSITE DOSE CALCULATION MANUAL 1.19 The OFFSITE DOSE CALCULATION MANUAL (0DCM) shall contain the methodology and parameters used in the calculation of offsite doses resulting from

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J radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring Alarm / Trip Setpoints, and in the conduct of the i

Environmental Radiological Monitoring Program.

The ODCM shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental.

Monitoring Programs required by Section 6.8.3 and (2) descriptions of the information that should be included in the Annual Radiological Environmental' Operating and Annual Radioactive Effluent Release Reports required by l

Specifications 6.9.1.3.and 6.9.1.4.

OJ_ERABLE - OPERABILITY 1.20 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s),

and when all necessary attendant in'strumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for.the system, subsystem, train, component, or device to perform its.-

function (s) are also capable of performing their related support function (s).

' OPERATIONAL MODE - MODE i

l. 2_1 'An OPERATIONAL MODE (i e.., MODE) shall correspond to any one inclusive.

combination of core reactivity condition, power level, and. average reactor.

coolant temperature specified in Table 1.2.'

PHYSICS TESTS' j

i 1.22 PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics' of the reactor core and related instrumentation:

(1)= described in Chapter 14.0 of the FSAR, (2) authorized under the provisions of;10 CFR 50.59, or (3) otherwise approved by the Commission.

PRESSURE B0UNDARY LEAKAGE 1.23 PRESSURE BOUNDARY LEAKAGE shall be leakage (except steam generator-tubeJ

-i leakage) through.a nonisolable fault in a Reactor Coolant System component body, pipe wall, or vessel wall.

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COMANCHE PEAK - UNITS 1 AND 2 1 Unit 1 - Amendment No. 25 -

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Unit 2 - Amendment No.11

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RADI0 ACTIVE EFFLUENTS 3/4.11.1 L10VID EFFLUENTS L10VID HOLDUP TANKS

  • LIMITING CONDITION FOR OPERATION 3.11.1 The quantity of radioactive material contained in each unprotected outdoor tank shall be limited to less than or equal to 10 Curies, excluding tritium and dissolved or entrained noble gases.

APPLICABILITY:

At all times.

ACTION:

l With the quantity of radioactive material in any unprotected outdoor a.

tank exceeding the above limit, immediately suspend all additions of j

radioactive material to the tank, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the tank l

contents to within the limit, and describe the events leading to this condition in the next Annual Radioactive Effluent Release l

Report, pursuant to Specification 6.9.1.4.

b.

The provisions of Specifications 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.11.1 The quantity of radioactive material contained in each of the unprotected outdoor tanks shall be determined to be within the above limit by l

analyzing a representative sample of the tank's contents at least once per 7 days when radioactive materials are being added to the tank.

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-* Tanks included in this specification are those unprotected outdoor tanks that are not surrounded by liners, dikes, or walls capable of holding the tank I

contents and that do not have tank overflows and surrounding area drains

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connected to the Liquid Radwaste Treatment System.

J COMANCHE PEAK - UNITS 1 AND 2 3/4 11-1 Unit 1 - Amendment No. 25 Unit 2 - Amendment No.11 1

RADI0 ACTIVE EFFLUENTS 3/4.11.2 GASEOUS EFFLUENTS EXPLOSIVE GAS MIXTURE LIMITING CONDITION FOR OPERATION 3.11.2.1 The concentration of oxygen in the WASTE GAS HOLDUP SYSTEM shall be limited to less than or equal to 3% by volume whenever the hydrogen concentration exceeds 4% by volume.

APPLICABILITY: At all times.

ACTION:

(Units 1 and 2)

With the concentration of oxygen in the WASTE GAS HOLDUP SYSTEM a.

greater than 3% by volume but less than or equal to 4% by volume,_

reduce the oxygen concentration to the above limits within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

b.

With the concentration of oxygen in the WASTE GAS HOLDUP SYSTEM r

greater than 4% by volume and the hydrogen concentration greater than 4% by volume,.immediately suspend all additions of waste gases to the system and reduce the concentration of oxygen to less than or i

equal to 4% by volume, then take ACTION a., above.

The provisions of Specifications 3.0.3 are not applicable.

c.

l SURVEILLANCE REOUIREMENTS r

4.11.2.1 The concentrations of hydrogen and oxygen in the WASTE GAS HOLDUP SYSTEM shall be determined to be within the above limits by continuously monitoring the waste gases in the WASTE GAS HOLDUP SYSTEM with the hydrogen and oxygen monitors required OPERABLE by Table 3.3-7 of Specification 3.3.3.4, or by the associated ACTION statements.

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COMANCHE PEAK - UNITS 1 AND 2 3/4 11-2 Unit 1 - Amendment No. 14

RADI0 ACTIVE EFFLUENTS GAS STORAGE TANKS LIMITING CONDITION FOR OPERATION 3.11.2.2 The quantity of radioactivity contained in each gas storage tank shall be limited to less than or equal to 200,000 Curies of noble gases (considered as Xe-133 equivalent).

APPLICABILITY: At all times.

ACTION:

(Units 1 and 2)

With the quantity of radioactive material in any gas storage tank a.

exceeding the above limit, immediately suspend all additions of radioactive material to the tank, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the tank contents to within the limit, and describe the events leading to this condition in the next Annual Radioactive Effluent Release l

Report, pursuant to Specification 6.9.1.4.

b.

The provisions of Specifications 3.0.3 are not applicable.

SURVEILLANCE RE0VIREMENTS 4.11.2.2 The quantity of radioactive material contained in each gas storage tank shall be determined to be within the above limit at least once per 92 days when radioactive materials are being added to the tank.

f COMANCHE PEAK - UNITS 1 AND 2 3/4 11-3 Unit 1 - Amendment No. 44,25 Unit 2 - Amendment No.11

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-ADMINISTRATIVE CONTROLS ANNUAL REPORTS (Continued) b.

The results of specific activity analyses in.which the primary coolant exceeded the limits of' Specification 3.4.7.

The following information shall be included:

(1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded (in graphic and tabular format); (2) Results 'of the last isotopic l

analysis for radioiodine performed prior to exceeding the limit, i

results of analysis while limit was exceeded and results of one-analysis after the radioiodine activity was reduced'to less than-limit.

Each result should include date and time of. sampling and the

'l radioiodine concentrations; (3) Clean-up flow history starting l

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; i

(4) Graph of the I-131 concentration (gCi/gm) and one other j

radioidine isotope concentration (#Ci/gm) as a function of time for the duration of the specific activity above the steady-state level; l

and (5) The time duration when the specific activity of the primary coolant exceeded the radiciodine limit.

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT

-l the operation of the unit during the previous calendar year shall be submitted before May 1 of each year. The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological.

Environmental Monitoring Program for the reporting. period. The material provided shall be consistent with the objectives outlined in (1) the ODCM, and (2) Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR 50.

ANNUAL RADI0 ACTIVE EFFLUENT RELEASE REPORT ** -

-l 6.9.1.4 -The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous year shall-be submitted prior to May 1 of each ye a r..

The report shall include a summary of the quantities.of. radioactive liquid and gaseous-effluents and solid waste released from the unit.. The material provided shall be (1) consistent with the objectives outlined in'the ODCM and PCP and (2) in conformance with 10 CFR 50.36a.and'Section IV.B.1_of Appendix I to 10 CFR 50.

1 MONTHLY OPERATING REPORTS

6.9.1.5 Routine reports of operating statistics and shutdown. experience,.

including ' documentation of all challenges to the.PORVs or safety valves,-

  • A single submittal may be made ~ for a multiple unit station.
    • A single submittal may be made for a multi-unit station.

The' submittal

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should combine those sections that are common to all units at the station; however, for units with-separate radwaste systems, the. submittal shall specify.the releases of radioactive material.from each unit.

COMANCHE' PEAK 1-UNITS 1 AND 2 6-19 Unit 1 - Amendment No. 25 Unit 2

. Amendment No.11 h

ADMINISTRATIVE CONTROLS MONTHLY OPERATING REPORTS (Continued) shall be submitted on a monthly basis to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator of the Regional Office of the NRC, no later than the 15th of each month following the calendar month covered by the report.

CORE OPERATING LIMITS REPORT 6.9.1.6a Core operating limits shall be established and documented in the CORE OPERATING LIMITS REPORT (COLR) before each reload cycle or any remaining part of a reload cycle for the following:

1). Moderator temperature coefficient BOL and EOL limits and 300 ppm sur-veillance limit for Specification 3/4.1.1.3, 2). Shutdown Rod Insertion Limit for' Specification 3/4.1.3.5, 3). Control Rod Insertion Limits for Specification 3/4.1.3.6, 4). AXIAL FLUX DIFFERENCE Limits and target band for Specification 3/4.2.1.,

RTP for Specifica-5). Heat Flux Hot Channel Factor, K(Z), W(Z), and Fg tion 3/4.2.2, 6). Nuclear Enthalpy Rise Hot Channel Factor Limit and the Power Factor Multiplier for Specification 3/4.2.3.

6.9.1.6b The following analytical methods used to determine the core operating limits are for Units 1 and 2, unless otherwise stated, and shall be those previously approved by the NRC in:

1). WCAP-9272-P-A, " WESTINGHOUSE RELOAD SAFETY EVALUATION METHODOLOGY,"

July 1985 (M Proprietary).

(Methodology for Specifications 3.1.1.3 -

Moderator Temperature Coefficient, 3.1.3.5 - Shutdown Bank Ir' -tion Limit, 3.1.3.6 - Control Bank Insertion Limits, 3.2.1 - Axial c lux i

Difference, 3.2.2 - Heat Flux Hot Channel Factor, and 3.2.3 - Nuclear Enthalpy Rise Hot Channel Factor.)

2). WCAP-B385, " POWER DISTRIBUTION CONTROL AND LOAD FOLLOWING PROCEDURES -

TOPICAL REPORT," September 1974 (M Proprietary).

(Methodology for Specification 3.2.1 - Axial Flux Difference [ Constant Axial Offset l

Control].)

l T. M. Anderson to K. Kniel (Chief of Core Performance Branch, NRC l

3).

January 31, 1980--

Attachment:

Operation and Safety Analysis Aspects

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of an Improved Load Follow Package.

(Methodology for Specification 3.2.1 - Axial Flux Difference [ Constant Axial Offset Control).)

4). NUREG-0800, Standard Review Plan, U.S. Nuclear Regulatory Commission, Section 4.3, Nuclear Design, July 1981.

Branch Technical Position CPB 4,3-1, Westinghouse Constant Axial Offset Control (CAOC), Rev. 2, July 1981. (Methodology for Specification-3.2.1 - Axial Flux Difference [ Constant Axial Offset Control).)

COMANCHE PEAK - UNITS 1 AND 2 6-20 Unit 1 - Amendment No. 6, 14 i

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ADMINISTRATIVE CONTROLS o

6.13 PROCESS CONTROL PROGRAM (PCP) l Changes to the PCP:

a.

Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.30.

This documentation shall contain:

1)

Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change (s) and 2)

A determination that the change will maintain the overall conformance of the solidified waste product to existing 4

requirements of Federal, State, or other applicable regulations.

b.

Shall become effective after review and acceptance by the SORC and the approval of the Vice President, Nuclear Operations.

i 6.14 0FFSITt' DOSE CALCULATION MANUAL (0DCM)

Changes to the ODCM:

I a.

Shall be documented and records of reviews performed shall be retained as required by Specification 6.10.30.

This documentation i

shall contain:

l 1)

Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change (s) and j

2)

A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.106, 40 CFR 190, 10 CFR 50.36a, and Appendix I to 10 CFR 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

b.

Shall become effective after review and acceptance by the 50RC and the approval of the Vice President, Nuclear Operations.

c.

Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the l

report in which any change to the ODCM was made.

Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (e.g., month / year) the change was implemented.

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COMANCHE PEAK - UNITS 1 AND 2 6-25 Unit 1 - Amendment No. 25 Unit 2 - Amendment No. ii