ML20140C144

Proposed Revised TS Pages Re Decommissioning

ML20140C144
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	05/30/1997
From:	GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20140C132	List: ML20140C127 ML20140C144
References
NUDOCS 9706090130
Download: ML20140C144 (19)

Text

1.0 DEFINITIONS 1.0.1 CONTAINMENT VESSEL -

Term used to describe the vertical steel cylinder which houses the Saxton Nuclear Experimental Corporation Facility Nuclear Steam Supply System (NSSS) and related components, also known as the CV.

1.0.2 CV SECURED -

l The term CV SECURED applies to the controls necessaiy to make an initial CONTAINMENT VESSEL (CV) entry. It does not refer to any security measures. CV SECURED means that the CV has been sealed from personnel entry.

1.0.3 DECOMMISSIONING ACTIVITIES -

The term DECOMMISSIONING ACTIVITIES describes all of those activities needed to decommission the SNEC Facility and return the site to unrestricted use.

Examples of these activities include; PRODUCTION ACTIVITIES needed to conduct decommissioning such as physical dismantlement; radioactive waste preparation, treatment, packaging and shipment; radiation protection activities, construction and installation of support systems, stmetures and components, and final status survey.

1.0.4 DECOMMISSIONING SUPPORT BUILDING (DSB)-

The DECOMMISSIONING SUPPORT BUILDING (DSB)is the facility constructed south east of the containment vessel (CV) and attached to the CV.

Used to facilitate the decommissioning process and allow the preparation and packaging of radioactive material for shipment.

1.0.5 EXCLUSION AREA -

The term EXCLUSION AREA refers to the area shown on Figure 1 of the Technical Specifications and defines the area controlled for the purpose of security and access restrictions.

1.0.6 GPU NUCLEAR -

GPU NUCLEAR is the co-licensee with the Saxton Nuclear Experimental Corporation (SNEC) for the Saxton Nuclear Experimental Corporation facility and is responsible for the decommissioning of the SNEC facility. GPU NUCLEAR is a wholly owned subsidiary of GPU Inc.

9706090130 970530 PDR ADOCK 05000146 P PDR 1

1.0.7 MEASURABLE RELEASE -

1 A MEASURABLE RELEASE is defined as that radioactive release which meets or exceeds the Lower Limit of Detection (LLD) for liquid and gaseous radioactive effluents as specified in the ODCM.

( l.0.8 MEMBER (S) OF THE PUBLIC -

l MEMBER (S) OF THE PUBLIC shall include all persons who are not occupationally associated with the Saxton Nuclear Experimental Corporation l facility. This category does not include employees of the GPU Inc., contractors or vendors. Also excluded from this category are persons who enter the Facility site to service equipment or to make deliveries. ,

1 1.0.9 _OFFSITE DOSE CALCULATION MANUAL (ODCM)-

The OFFSITE DOSE CALCULATION MANUAL (ODCM) contains the i methodology and parameters used in the calculation of offsite doses resulting from l radioactive gaseous and liquid effluent, in the calculation of gaseous and liquid effluent monitoring alarm / trip setpoints, and in the conduct of the Radiological Environmental Monitoring Program (REMP). The ODCM also contains (1) the Radiological Efiluent Controls, (2) the REMP, and (3) descriptions of the i

information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Efiluent Release Reports.

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! 1.0.10 OPERABLE - OPERABILITY -

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 instrumentation, 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 i capable ofperforming their related support function (s). l 1.0.11 PROCESS CONTROL PROGRAM (PCP) -

l The PROCESS CONTROL PROGRAM (PCP) contains the current formulas, l sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished in such a way as to assure compliance with 10 CFR Parts 20,61, and 71, State regulations, burial i ground requirements, and other requirements governing the disposal of solid j radioactive waste.

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l f 1.0.12 PRODUCTION ACTIVITIES -

l l PRODUCTION ACTIVITIES are the physical activities needed to conduct the l decommissioning of the SNEC facility site. Included are such activities as the l removal of syctems, structures and components, demolition of structures and associated components; removal of contaminants to allow free release, excavation, trenching and removal of underground facilities.

These activities are a sub-set ofDECOMMISSIONING ACTIVITIES.

1.0.13 RADIOACTIVE WASTE MANAGEMENT ACTIVITIES -

The term RADIOACTIVE WASTE MANAGEMENT ACTIVITIES is defmed as those activities which involve the handling of radioactive waste materials.

1.0.14 SECURED-The term SECURED is used in place of the term " locked" in order to describe those controls required to be placed on the EXCLUSION AREA to prevent unauthorized access. SECURED means that reasonable methods will be employed to prevent unauthorized access inside the EXCLUSION AREA. Such methods shall be at least equivalent to locking with a physical lock. Examples of such means are: windows on the DECOMMISSIONING SUPPORT BUILDING (DSB) could be covered with a security grating, a door or hatch on the CONTAINMENT VESSEL (CV) could be welded shut or rendered inoperable, temporary openings in the CV shell or EXCLUSION AREA fence could be  ;

physically guarded until otherwise suitably secured, or restraining devices such as i I

inaccessible or tamper resistant bolts could be installed on gates or doors.

1.0.15 SITE BOUND ARY -

The SITE BOUNDARY is the boundary line forming the base for the limits on the release of radioactive gaseous emuents. At the SNEC facility, the SITE BOUNDARY for radioactive gaseous emuents is the line formed at a 200 meter radius from the center of the Containment Building.

1.0.16 SNEC-The term SNEC is an acronym for the Saxton Nuclear Experimental Corporation.

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. SUBSTANTIVE CHANGE (S)-

SUBSTANTIVE CHANGE (S) are those which affect the activities associated with a document or the document's meaning or intent. Examples of non-substantive changes are: (1) correcting spelling; (2) adding (but not deleting) sign-off spaces; (3) blocking in notes, cautions, etc.; (4) changes in' corporate and .

personnel titles which do not reassign responsibilities and which are not referenced ,

in the Technical Specifications; and (5) changes in nomenclature or editorial .

changes which clearly do not change function, meaning or intent.  ;

1.0.18 UNRESTRICTED AREA- .

An UNRESTRICTED AREA shall be any area at or beyond the SITE j BOUNDARY access to which is not controlled by the licensee for purposes of protection ofindividuals from exposure to radiation and radioactive materials, or any area within the SITE BOUNDARY used for residential quarters or for industrial, commercial, institutional, and/or recreational purposes.  ;

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1.1.1 Location j The Saxton Nuclear Experimental Corporation (SNEC) facility is on a 1.148 acre ,

j tract deeded from the Pennsylvania Electric Company to the SNEC. It is located -!

within the property of the Pennsylvania Electric Company near the Borough of l Saxton, Pennsylvania, in Liberty Township, Bedford County, Pennsylvania. The ,

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Pennsylvania Electric Company property consists of approximately 150 acres  !

along the Raystown Branch of the Juniata River. ,

1.1.2 Exclusion Area Boundary i

The exclusion area consists of that portion of the SNEC facility property enclosed  !

within a fence and building boundaries as posted. See Figure 1. i 1.1.3 Exclusion Area Controls l.1.3.1 Except for authorized entry, access points to the exclusion area will be secured.

1.1.3.2 The Containment Vessel (CV) and the Decommissioning Support Building

- (DSB) shall be equipped with an intrusion alarm system. Intrusion alarms will be activated whenever the site is not manned. Operability shall be verified in accordance with section 3.5.3.1.b.

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2.0 PRINCIPAL ACTIVITIES Activities permitted at the SNEC facility shall include the routine and emergency inspections, maintenance associated with the possession of the SNEC facility,  ;

characterization activities and activities dehneated in Section 1.0.3, I Decommissioning Activities, of these Technical Specifications.

2.1 Limiting Conditions for Performing Decommissioning Activities l

2.1.1 During activities within the CV/DSB that have the potential to cause a measurable release to the environment of airborne radioactivity, the CV/DSB ventilation system will be operated in a manner such that the release pathway is via the monitored ventilation system exhaust.

2.1.2 The ventilation exhaust monitoring instmmentation and the CV/DSB ventilation system will be operated simultaneously. The ventilation system .

will be secured if the exhaust monitoring instrumentation is inoperable.

2.1.3 Verification by analysis that release criteria have been satisfied is required l prior to making any batch release ofliquid waste process effluent. Efiluent release calculations will be made in accordance with the Offsite Dose Calculation Manual.

3.0 ADMINISTRATIVE CONTROLS 3.1 Organization and Re_g,ansibilities GPU Nuclear has the responsibility for safely performing decommissioning activities. Lines of authority, responsibility and communication are procedurally defined and established. The relationships shall be identified and updated, as appropriate, in organizational charts, departmental functional responsibility and relationship descriptions, job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in the SNEC Facility PSDAR.

3.1.1 The President GPU Nuclear is responsible for and provides a full-time dedicated staff for the purpose of conducting all activities safely and effectively.

3.1.2 The Vice President Nuclear Safety and Technical Services (NSTS) i Division assures that all division and corporate activities are performed in i accordance with corporate policies, applicable laws, regulations, licenses l and Technical Specifications (TSs).

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l 3.1.3 The Program Director SNEC Facility is responsible for administration of all l SNEC facility functions, for direction of all decommissioning activities, and for assuring that the requirements of License No. DPR-4 and these TSs are implemented 3.1.4 The SNEC Facility Site Supervisor provides on-site management and l continuing oversight of production activities.

l 3.1.5 The Radiation Safety Officer (RSO) is responsible for the conduct and 1 i oversight of all SNEC radiation safety activities through implementation of l the Radiation Protection Plan. All radiological controls personnel shall i have stop work authority in matters relating to or impacting radiation i safety. l 3.1.6 The Group Radiological Controls Supervisor (GRCS) directly supervises radiation safety activities.

L 3.1.7 Other GPU Nuclear personnel provide SNEC facility management with technical support, project management capabilities and manpower. 1 3.2 Facility Stafling Brguirements:

3.2.1 At least two individuals, one of which must be knowledgeable in radiation monitoring and the radiological hazards associated with the facility, shall perform radiological surveys necessary to suppon planned activities within the Containment Vessel if the Containment has been secured for a period greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3.2.2 The RSO or a GRCS shall be present on site whenever radioactive waste management activities ir in progress.

3.3 Facility StafrOualifications 3.3.1 Each Radiological Controls Technician /GRCS shall meet or exceed the qualifications of ANSI N18.1-1971, paragraph 4.5.2 and 4.3.2 respectively or shall be formally qualified through an NRC approved radiological controls training program.

3.3.2 All personnel performing decommissioning or associated activities shall be briefed on the SNEC site specific conditions and applicable requirements of the SNEC PSDAR for the task assigned.

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3.4 Training I l

GPU Nuclear shall maintain training programs as necessary for those personnel performing decommissioning work functions at the SNEC facility.

3.4.1 The job specific training or knowledge necessary to accomplish a specific l l task or project goal shall be dictated by the dismantlement or l i

decommissioning work scope. i l

i l 3.4.2 In lieu of training, performance of specialized tasks, techniques and equipment operation shall be permitted, provided competency is demonstrated to the Program Director SNEC Facility or his designee.

3.5 Review. Inspection and Audit 3.5.1 Technical Review 3.5.1.1 The Vice President of each division within GPU Nuclear supporting the SNEC facility decommissioning project shall be responsible for ensuring the preparation, review, and approval of documents required by the activities described in sections 3.5.1.2 through 3.5.1.7 within his functional area. Implementing approvals shall be performed at the cognizant manager lesel or above.

3.5.1.2 Each procedure required by section 3.6.1 and substantive changes thereto shall be prepared by a designated individual or group knowledgeable in the area of the affected procedure. Each procedure and substantive change thereto, shall be given a technical review by an individual or group other than the preparer, but who may be from the same organization as the individual who prepared the procedure or change.

3.5.1.3 Proposed changes to the TS shall be reviewed by a knowledgeable individual or group other than the individual (s) or group who prepared the change.

3.5.1.4 Proposed tests and experiments shall be reviewed by a knowledgeable individual or group other than the preparer but who may be from the same division as the individual who prepared the tests and experiments.

! 3.5.1.5 Proposed modifications to facility structures systems and

( components as described in the SNEC Facility PSDAR determined to be within the scope of the SNEC Facility Decommissioning QA 7

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Plan and QA program, shall be designed by an individuaU l

organization knowledgeable in the areas affected by the proposed modification. Each such modification shall be technically reviewed by an individual other than the individual which designed the l modification but may be from the same group as the individual who l designed the modification.

3.5.1.6 Investigation of all violations of the TS including the preparation I and forwarding of reports covering evaluation and recommendations to prevent recurrence, shall be reviewed by a knowledgeable individuaUgroup other than the individuaUgroup which performed the investigation.

3.5.1.7 All reportable events shall be reviewed by an individuaUgroup other than the individuaUgroup which prepared the report.

3.5.1.8 Individuals responsible for reviews performed in accordance with sections 3.5.1.2 through 3.5.1.7 shall include a determination of whether or not additional cross disciplinary review is necessary. If necessary, such reviews she.Il be performed by the appropriate personnel. Individuals responsible for reviews considered under sections 3.5.1.2 through 3.5.1.6 shall render determinations in writing with regard to whether or not 3.5.1.2 through 3.5.1.6 constitute an unreviewed safety question.

3.5.1.9 Responsible Technical Reviewers shall meet or exceed the qualifications of ANSI /ANS 3.1 of 1978 Section 4.6, or 4.4 for applicable disciplin::s, or have seven years of appropriate experience in the field of specialty. Credit toward experience will be given for advanced degrees on a one-to-one basis up to a maximum of two years. Responsible Technical Reviewers shall be designated in writing.

3.5.1.10 Records of the review activities performed in accordance with 3.5.1.2 through 3.5.1.7 shall be maintained in accordance with section 3.9.

3.5.2 Independent Safety Review 3.5.2.1 The Vice President of each division within GPU Nuclear supporting the SNEC facility decommissioning project shall be responsible for l

ensuring the independent safety review of the subjects described in l section 3.5.2.3 within his assigned area ofreview responsibility.

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l 3.5.2.2 Independent safety review shall be completed by an individual or group not having direct responsibility for the performance of activities under review, but who may be from the same functionally cognizant organization as the individual or group performing the original work.

j 3.5.2.3 GPU Nuclear shall collectively have or have access to the

! experience and competence required to independently review l subjects in the following areas:

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nuclear unit operations electrical, mechanical and nuclear engineering l

chemistry and radiochemistry metallurgy instrumentation and control radiological safety administrative controls and quality assurance practices other appropriate fields such as radioactive waste management.

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

3.5.2.5 The following subjects shall be independently reviewed by Independent Safety Reviewers in the functionally assigned l divisions:

3.5.2.5.1 Written safety evaluations of changes in the facility and changes of procedures described in the Safety Analysis l Report, and of tests or experiments not described in the Safety Analysis Report, which are completed without prior l

NRC approval under the provisions of 10 CFR 50.59(a)(1). 1 This review is to verify that such changes, tests or experiments did not involve a change to the TS or an unreviewed safety question as defined in 10 CFR 50.59(a)(2). Written safety evaluations associated with the direct puformance of a change, test or experiment shall be completed prior to the initiation of the activity.

3.5.2.5.2 Proposed changes in procedures, in the facility or tests or experiments, any of which involves a change in the TS or in

! an unreviewed safety question as defined in 10 CFR

! 50.59(c). Matters of this kind shall be reviewed prior to l their submittal to the NRC.

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i 3.5.2.5.3 Proposed changes to TS or license amendments shall be reviewed prior to submittal to the NRC for approval.

1 3.5.2.5.4 Violations, deviations and reportable events which require j reporting to the NRC in writing. Such reviews are performed after the fact. Review of events covered under l this subsection shall include results of any investigations to l prevent or reduce the probability of recurrence of the event.  !

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3.5.2.5.5 Written summaries of audit reports identified in section 3.5.4. l 3.5.2.5.6 Any other matter involving the facility which a reviewer ,

deems appropriate for consideration or which is referred to '

the independent reviewers.

3.5.2.6 The Independent Safety Reviewers shall either have a Bachelors Degree in Engineering or the Physical Sciences and five years professional level experience in the area being reviewed or have nine years of appropriate experience in the field of specialty. An ,

individual performing reviews may possess competence in more

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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.

3.5.2.7 Records of reviews encompassed in section 3.5.2.5 shall be maintained in accordance with section 3.9.

3.5.3 Inspection 3.5.3.1 Facility inspections shall be performed in accordance with approved l procedures. The inspection activities shall include:

a Verification that exclusion area access points are secured at the completion of each authorized entry,

b. Verification of the operability of the exclusion area intrusion alarms shall be performed quarterly.

c. The station ventilation system efUuent particulate monitor channel checks, source checks, channel test l and channel calibration shall be perfo.: ^d at a frequency specified in the ODCM.

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d. The ventilation system HEPA Filter will be tested to i verify efliciencies in accordance with the

. requirements of the ODCM.

3.5.4. Audits l The audit function is independent of the SNEC facility management.

Audits shall be performed by qualified individuals, as a minimum, for those activities designated within the scope of the SNEC facility's Quality Assurance Program. Audits are generally conducted bienn'ially, however, frequency is based on the level of activity at the SNEC facility. Audits may .

also be performed at the request of the GPU Nuclear President. Audits are i

performed in accordance with the GPU Nuclear audit program procedures.

The audit procedures identify areas which may be included in the audit scope. Audit reports shall be forwarded to the GPU Nuclear President within 60 days of completion of the audit.

3.5.5 Radiation Safety Committee-3.5.5.1 The Radiation Safety Committee shall report to the Vice President Nuclear Safety and Technical Services Division (NSTS). The Committee will consist of at least four members. Membership will be on the recomn'endation of the Vice President NSTS. Three  ;

members shall constitute a quorum.

3.5.5.2 It shall be responsible to provide independent overview and assessment of all matters with radiological safety implications relative to activities at the SNEC facility. The Committee will  ;

review proposed License and Technical Specification changes, I decommissioning activities, special nuclear and radioactive material activities, facility changes, radiological conditions, audit reports and  !

NRC Inspection reports and corrective actions for deficiencies j identified.

3.5.5.3 Meetings are scheduled quarterly and shall be held at least three times per year.

3.5.5.4 Written minutes of all meetings shall be prepared and distributed to the Vice President NSTS within 30 days of the meeting date.

l 3.6 Procedures. Programs and Manuals l

3.6.1 Procedures

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l 3.6.1.1 Activities which are designated as within the scope of the SNEC facility's Quality Assurance Program shall be prescribed by written, reviewed and approved procedures of a type appropriate to the circumstances.

3.6.1.2 Written procedures shall be established, implemented and maintained for the activities listed below:

l 3.6.1.2.1 Characterization, decommissioning and maintenance activities determined to be within the scope of the QA l

program.

i l 3.6.1.2.2 Access control, emergency actions (including fire protection program implementation), facility inspections and audits.

3.6.1.2.3 Radiological exposure control, survey activities and radwaste shipping and handling.

3.6.1.2.4 Activities which could result in a measurable radioactive release to the environment. I 3.6.1.3 These procedures shall require that the following actions be taken:

3.6.1.3.1 All decommissioning activities and maintenance work under )

Health Physics control shall be consistent with 10 CFR, Part 20 requirements.to minimize the radiation exposure of personnel and to prevent the release of radioactivity in excess of allowable limits to the environment.

3.6.1.3.2 All radit ' ion surveys, tests, counting work, radiation exposure control measures and all other work performed in radiologically controlled areas shall conform with the requirements of the Radiation Protection Plan.

i 3.6.1.3.3 Facility inspections and access controls shall meet specific requirements of the sections 3.5.3 and 1.1.3, respectively, of these TS.

3.6.1.4 These procedures and any subsequent revisions shall be prepared, reviewed and approved in accordance with the requirements of the l applicable administrative procedure requirements prior to their l initial use.

3.6.2 Programs 12

l The following programs shall be established, implemented, and maintained  ;

.during decommissioning activities: '

3.6.2.1 Radioactive Emuent Controls Program l

l A program shall be provided conforming with 10 CFR, Section l 50.36a for the control of radioactive emuents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

3.6.2.1 1 Limitations on the operability of radioactive emuent l monitoring instrumentation, including surveillance tests and .

setpoint detemiination in accordance with the methodology l in the ODCM; i

3.6.2.1.2 Limitations on the concentrations of radioactive material i released in liquid emuents to unrestricted areas confonning I to 10 times the concentrations specified in 10 CFR 20, Parts 20.1001 - 20.2402, Appendix B, Table 2, Column 2; l l

3.6.2.1.3 Monitoring, sampling, and analysis of radioactive emuents in accordance with 10 CFR, Part 20.1301 and with the rnethodology and parameters in the ODCM; 3.6.2.1.4 Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid emuents released to unrestricted areas i cu.1 forming to Appendix I to 10 CFR, Part 50; 3.6.2.1.5 Determination of cumulative and projected dose contributions from radioactive emuents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days;

! 3.6.2.1.6 Limitations on the operability and use of the radioactive emuent treatment systems to ensure that the appropriate

! portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period i

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would exceed 2% of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR, Part 50; 3.6.2.1.7 Limitations on the dose rate resulting from radioactive ,

t material released in gaseous effluents to areas at or beyond .

the site boundary to less than or equal to 1500 mrem /yr to any. organ; 3.6.2.1.8 ,

Limitations on the annual and quarterly doses to a member

~of the public from tritium, and all radionuclides in particulate form with half-lives greater than eight days in gaseous effluents released to areas beyond the site boundary l conforming to Appendix I to 10 CFR, Part 50;

! 3.6.2.1.9 Limitations on the annual dose or dose commitment to any

. member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR, Part 190.

3.6.2.2 Radiological Environmental Monitoring Program l

3.6.2.2.1 A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide:-

3.6.2.2.1 a. Representative measurements of radioactivity in the highest  :

potential exposure pathways, and  !

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b. Verification of the accuracy of the Efiluent Monitoring .l '

Program and modeling of environmental exposure pathways.

3.6.2.2.2 The program shall (1) be contained in the ODCM; (2) conform to i the guidance of Appendix I to 10 CFR, Part 50; and (3) include the -

following:

a. Monitoring, sampling, analysis, and reporting of radiation l' and radionuclides in the environment in accordance with the methodology and parameters in the ODCM,

b. A Land Use Census to ensure that changes in the use of I areas at and beyond the site boundary are identified and that

[ modifications to the monitoring program are made if

[ required by the results of this census, and;  ;

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c. Participation in an Interlaboratory Comparison Program to ensure that independent checks on the precision and

l. accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the Quality Assurance Program for environmental monitoring. ,

l- 3.6.2.3 Process Control Program (PCP) l l The PCP shall contain the current formulas, sampling, analyses, tests, and L determinations to be made to ensure that the processing and the packaging l of solidified radioactive wastes will be accomplished to ensure compliance - '

l with 10 CFR, Part 20; 10 CFR, Part 61; and 10 CFR, Part 71; burial

ground requirements and other requirements governing the disposal of l solid radioactive wastes.

3.6.2.3.1 Changes to the PCP:

j a. Shall be documented and records of reviews performed shall

. be retained as required. This documentation shall contain:

l 1. Suflicient information to support the change l together with the appropriate analyses or evaluation justifying the change (-s), and

2. A determination that the change will maintain the overall conformance of the solidified waste product to existing requirements of federal, state, or other applicable regulations.

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b. Shall become effective after review and approval by the Program Director, SNEC Facility.

3.6.2.4 Quality Assurance Program Quality assurance program requirements shall be established in a written SNEC Decommissioning Quality Assurance Plan. Revisions to this plan i will be submitted to the NRC prior to the implementation of changes which i

involve a reduction in commitments previously accepted by the NRC and after implementation of changes having no reduction in commitment.

3.6.3 Manuals i

3.6.3.1 Off-Site Dose Calculation Manual (ODCM) i 15 e +- e -- -

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, l 3.6.3.1.1 Content:

a. The ODCM shall contain the methodology and parameters used in the calculation of off-site doses resulting from radioactive gaseous and liquid emuents, in the calculation of radioactive gaseous and liquid emuent monitoring alarm and trip setpoints, and in the conduct of the Radiological Environmental Monitoring Program; and I

b. The ODCM shall also contain the Radioactive Emuent  :

Controls Program and the Radiological Environmental Monitoring Program required by Specifications 3.6.2.1 and 3.6.2.2 respectively, and descriptions of the information that i should be included in the Annual Radiological l Environmental Monitoring Report required by Specification  !

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3.6.3.1.2 Changes to the ODCM:

a. Shall be documented and records of reviews performed shall be retained as required by Specification 3.9.10. This documentation shall contain:

1. Suflicient information to support the change I together with the appropriate analyses or evaluation I justifying the change (s), and

2. A determination that the change will maintain the level of the radioactive emuent control required by 10 CFR, Part 20.1301; 40 CFR, Part 190; 10 CFR, Section 50.36a; and Appendix I to 10 CFR, Part 50 and not adversely impact the accuracy or reliability of emuent, dose, or setpoint calculations.

b. Shall become effective afler review and approval of the Program Director, SNEC Facility.

c. Shall be submitted to the Commission in the form of a complete, legible copy of the entire ODCM as part of or concurrent with the Annual Radioactive Emuent Release Report for the period of the report in which any change to j the ODCM was made. Each change shall be identified by

( markings in the margin of the affected pages, clearly l indicating the areas of the page that was changed, and shall 16

indicate the date (e.g., month / year) the change was implemented.

3.7 Fire Protection 3.7.1 Procedures will be established and implemented for fire prevention and responding to fires.

3.7.2 Portable fire extinguishing equipment shall be available to support decommissioning activities in progress.

3.7.3 Personnel standing fire watch will be trained and requalified on an annual 4 frequency.

I 3.8 Reporting i

j In addition to those reports required by applicable NRC regulations (ie, violation

oflicense or technical specification condition) GPU Nuclear shall submit the j following

i 3.8.1 A report of any occurrence of a possible unsafe condition relating to the i facility or to the public For each occurrence, SNEC shall promptly, within j 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery, notify by telephone or facsimile, the Administrator i of Region I, or designee, and the NRC Operations Center, and shall submit i a written follow-up report to the Document Control Desk and the Administrator of Region I within 30 days, which describes the circumstances and the corrective action taken. These reports shall include:

3.8.1.1 Any unplanned or uncontrolled release of radioactive material beyond the site boundary.

3.8.2 An annual report shall be submitted to the Document Control Desk and the Administrator of Region I, within 6 months after the end of the calendar year, of the status of the deactivated facility including:

3.8.2.1 Information relating to changes in those management and supervisory positions designated in section 3.1 as being responsible for decommissioning the facility; 3.8.2.2 A summary of decommissioning, design, and maintenance changes made to the deactivated facility; 17

1 3.8.2.3 Results of surveys and monitoring performed in accordance with Specifications 3.6.2.1 and 3.6.2.2; 3.8.2.4 A review of the performance of access control and surveillance l

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3.9 Records In addition to the records required by applicable NRC regulations, including Subpart L of 10 CFR, Part 20,20.2101 through 20.2110 inclusive, GPU Nuclear shall retain records of the following for the duration of the license:

3.9.1 Records of all reportable events submitted to the Commission; 3.9.2 Records of principal decommissioning activities; 3.9.3 Records of training and qualification of members of the facility staff; 3.9.4 Records oAntries into the Containment Vessel involving radiation work permits and the reason for the entry; 3.9.5 Radioactivity releases or discharges into the air or water beyond the effective control of SNEC as measured at or prior to the point of such i 1

release or discharge; 1

3.9.6 Records of reviews performed for changes made to procedures or equipment pursuant to 10 CFR 50.59; I 3.9.7 Records of Quality Assurance activities required by of the SNEC Facility Decommissioning Quality Assurance Plan which are classified as permanent records by applicable regulations, codes and standards;  !

3.9.8 Records of reviews or audits required by Specification 3.5.4; 3.9.9 Records of analyses required by the Radiological Environmental Monitoring Program that would permit evaluation of the accuracy of the analysis at a later date; and 3.9.10 Records ofreviews performed and changes made to the Offsite Dose Calculation Manual and the Process Control Program 3.9.11 Inspections of the decommissioned facility including the results of surveys of radioactivity levels and as-found and as-left conditions of the facility.

l 3.9.12 Characterization study results.

l 18

FIGURE 1 SAXTON NUCLEAR EXPERIMENTAL CORP. FACILITY LAYOUT FENCE ^

uTes .

GATE w

o 2 W d .

a Z

W-w REACTOR CONTAI NMENT DECuM" ""

support B ILDING VESSEL STE M E" l FENCE u v MTE% I

/r= 1

. ;:. :.: v_ y _,q:;

y  !

l s

3x

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= *~%

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scu? 19 ,@ @ 9 y mi ,

yg. :: 37c3_ i o a to towns x "

• FENCE -

FENCE i

N\\N EXCLUSON AREA - NO1E: The "EXCLUSON ARE,.," identifled by the hatched l \\\\ oreo is typical and le not meant to represent any specific crea dimension or shape, it will conelst, os a minimum, of the Reactor Containment Yessel and may extend to the SNEC outer security fence.

19 l