ML20147B176
| ML20147B176 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/15/1988 |
| From: | Andognini C, Croley B, Martin D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| GCA-88-074, GCA-88-74, RECM-6878, TAC-56033, NUDOCS 8803020003 | |
| Download: ML20147B176 (17) | |
Text
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LEAD DEPARTMENT:
EFFECTIVE DATE ENVIRONMENTAL PROTECTION Hanager ironmental Protection
___D1 E
___-_3 -a~:R Chairperson-PRC / Date Ch rperson-RC / Date Dir uc Qua ity / Date
-- b AGM-Tech & Ad n Serv / Date 5
r Pwr Prod / Date rr r
QUALITY REVIEW REQUIRED X YES NO PRC REVIEH REQUIRED X YES NO
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HSRC REVIEW REQUIRED X YES NO SCOPE OF REVISION:
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New manual giving policy, functions and responsibilities within the Effluent Control Program at the Rancho Seco Nuclear Generating Station.
HP6878P i
D-0578P j
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.l 8803020003 880215 PDR ADOCK 05000312 P
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TABLE OF CONTENTS SECTION TITLE PAGE Title Page 1
. Table of Contents 2
1.0 Effluent Control Policy Statement 3
2.0 Effluent Control Program Description 5
2.1 Purpose 5
2.2. Effluent Programmatic Functions 5
2.2.1 Code of Federal Regulations 5
2.2.2 Radiological Effluent Technical Specifications 6
2.2.3 ODCH 6
2.2.4 REMP 6
2.2.5 PCP 7
2.2.6 Radioactive Haste Management 7
2.2.7 Implementing Procedures 8
2.2.8 Program Oversight 8
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2.2.9 Effluent Goals / Trend Analysis 8
2.2.10 Reports 9
2.2.11 Nuclear Training 9
3.0 Responsibilities 9
3.1 CEO Nuclear 9
3.2 Hanager-Environmental Protection Department 10 3.3 Hanager-Radiation Protection Department 11 3.4 Hanager-Chemistry Department 12 3.5 Hanager-Operations Department.
12 3.6 Hanager-Haintenance Department 13 3.7 Hanager-Nuclear Engineering Department 13 3.8 Director-Information Hanagement Systems 13 3.9 Hanager-Training Department 13 3.10 Director-Nuclear Quality 14 3.11 All Department Managers 14 3.12 All Facility Personnel 14 4.0 Radiation Protection Oversight Sub-Committee 14
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Effluent Control Program Organizational Interfaces 16 k
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1.0 EFFLUENT CONTROL POLICY STATEMENT 1.1 Federal Regulations concerning effluent control state in part that:
"Persons engaged in activities under licenses issued by the United States Nuclear Regulatory Commission should, in addition to complying with requirements set forth in this part, make every reasonable effort to maintain radiation exposures and release c,f radioactive material in effluents to unrestricted areas as low as is reasonably achievable (ALARA)..." (10 CFR 20.1.c)
"A licensee shall not possess, use, or transfer licensed material so as to release to an unrestricted area radioactive material in concentrations which exceed the limits specified in Appendix B.
t Table II..." (10 CFR 20.106.a)
"Design objectives and limiting conditions for operation conforming to guidelines of this appendix shall be deemed a conclusive showing of compliance with the "as low as reasonably achievable" requirements.." (10 CFR 50, Appendix I)
"No person may receive, process, and dispose of radioactive waste
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containing source, special nuclear, or byproduct material..
unless authorized by a license..." (10 CFR 61.3.a) 1.2 The Sacramento Municipal Utility District (SHUD) recognizes its responsibility to comply with applicable codes and regulations (and to consider other industry criteria) regarding the control of radioactive effluents.
In keeping with the ALARA philosophy, SHUD is ccmmitted to operating and maintaining the Rancho Seco Nuclear Generating Station in a manner that will provide radiation protection for their employees and the general public.
To ensure that every effort is being made to adhere to this commitment, an Effluent Control Program has been instituted.
1.3 The Effluent Control Program is based upon the requirements of applicable Federal Regulations, USNRC Regulatory Guides & NUREGs, as defined by the Updated Safety Analysis Report (USAR) and Technical Specifications.
The program applies to those activities which may result in planned or unplanned releases of radioactive material through gaseous, liquid, or solid paths.
It is the policy of this program to:
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1.3.1 Ensure that effluents, resulting from operation and maintenance activities, have no significant detrimental effects on the environasnt. Resulting radiation doses to members of the general public should be maintained as specified in 10 CFR 50, Appendix I (numerical ALARA guidance), as well as within applicable Nuclear Regulatory Commission (NRC) and Environmental Protection Agency (EPA) regulations.
1.3.2 Ensure that radioactive waste, resulting from operation and maintenance activities, is processed and disposed of in such a manner as to minimize its volume and'its hazard to employees and the general public.
1.4 In keeping with these policies:
1.4.1 Releases of radioactive liquids and gases to the environment, as a result of plant activities, shall be as low as reasonably achievable. Radiation dose resulting from such releases shall also be maintained ALARA.
1.4.2 The facility will be operated to provide reasonable assurance that unplanned releases of radioactive material to the environment do not occur, thereby preventing accidental exposure
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or contamination of personnel.
1.4.3 Comprehensive environmental and assessment programs shall be routinely conducted to determine environmental radioactivity levels and to assess the significance of these levels.
1.4.4 Operations, Maintenance and Chemistry effluent control strategies shall be implemented to reduce radioactive source terms.
Efforts will be made to recycle contaminated water inventories prior to discharge to the environment.
1.4.5 Procedures involving work with effluents; either liquid, gas, or solid, shall ensure that releases are controlled and dose from such releases is maintained ALARA.
1.4.6 Designs which directly impact effluent related systems shall contain provisions for oversight which ensure that changes to such systems will not be detrimental to the Effluent Control Program.
1.4.7 Training of appropriate personni shall be conducted to ensure that they are adequately prepared to support the Effluent Control i
Program, and fulfill their individual responsibilities within the program.
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RADIOLOGICAL EFFLUENT CONTROL MANUAL PAGE 5 0F 16 1.4.8 Data analysis shall be used to determine root causes when abnormal or unplanned conditions, as defined by procedures, exist within the Effluent Control Program.
Root cause determination shall include recommendations for corrective action (s) and tracking of such recommendations to resolution.
1.4.9 Periodic surveillances of the Effluent Control Program shall be conducted by qualified personnel to ensure that program requirements are being adhered to.
1.5 The Effluent Control Program, as described in this document and implemented by Rancho Seco procedures, shall be administered by the Environmental Protection Department, under the approval of the CEO-Nuclear, and shall have the full cooperation of all facility, contractor and visitor personnel.
t 2.0 EFFLUENT CONTROL PROGRAM DESCRIPTION 4
2.1 Purpose i
2.1.1 Effluent control, as it is defined at the Rancho Seco Nuclear Generating Station, refers to all activities whereby radioactive
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materials could be released to the environment.
Effluent 4
controls are established to maintain radiation dose to employees and members of the general public as low as is reasonably achievable (ALARA).
2.1.2 The Radiological Effluent Control Manual is used to describe the various elements of the Effluent Control Program, as well as show the required operational interfaces (see Attachment 1),
2.2 Effluent Control Programmatic Functions t
2.2.1
' Code of Federal Regulations 2.2.1.1 10 CFR 50.36 requires that each license authorizing operation of a facility, such as Rancho Seco, include Technical Specifications.
2.2.1.2 10 CFR 50.36a amplifies the need for Tech Spec requirements in the area of effluents and places specific procedural development and reporting requirements on the license holder.
Specific reference is made to 10 CFR 20.106 and 10 CFR 50, Appendix I; regarding the necessity of maintaining releases of radioactive material to unrestricted areas as low as is reasonably achievable.
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2.2.2 Radiological Effluent Technical Specifications 2.2.2.1 Radiological Effluent Technical Specifications (RETS) are included as part of the previously discussed federal requirements.
The RETS contain definitions, limiting conditions for operation, surveillance requirements and administrative controls over such items as Gaseous Effluents Liquid Effluents, Instrumentation, Solid Radioactive Haste and Radiological Environmental Monitoring.
2.2.2.2 Each department / functional group, providing direct or indirect support of the Effluent Control Program, shall be familiar with the effluent related requirements of the Tech Specs and how these requirements impact their area of responsibility.
2.2.3 Offsite Dose Calculation Manual (ODCM) 2.2.3.1 10 CFR 50, Appendix I states in part that "conformity with the guides on design objectives shall be demonstrated by calculational procedures based upon models and data such that the actual exposure to an individual through appropriate pathways is unlikely to be underestimated..."
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2.2.3.2 The ODCH is a manual containing the description of the
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methodology, algorithms and parameters to be used in the calculation of offsite doses resul_ ting from the release of radioactive material in gaseous and liquid effluents, and in the calculation of gaseous and liquid effluent monitoring instrumentation alarm / trip setpoints.
2.2.3.3 The ODCM is used as a reference for personnel engaged in calculational portions of effluent related operations. As such, personnel involved in these portions of the Effluent Control Program shall be familiar with the ODCH, as well as the ODCM basis (i.e., regulations, Regulatory Guides, NURegs, current research, etc.), and its impact on their area of responsibility.
2.2.4 Radiological Environmental Monitoring Program (REMP) 2.2.4.1 10 CFR 50, Appendix I states that "the licensee shall establish t
an appropriate surveillance and monitoring program to provide data on measurable levels of radiation and radioactive materials i
in the environment to evaluate the relationship between quantities of radioactive materials released in effluents and resultant radiation doses to individuals from principal pathways of exposure..."
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RADIOLOGICAL EFFLUENT CONTROL MANUAL PAGE 7 0F 16 2.2.4.2 The Radiological Environmental Monitoring Program (REMP) details an environmental sampling program which meets the intent of applicable regulations while providing an accurate assessment of the radiological environment in and around the environs of the facility.
The REMP Manual contains a description of the environmental samples to be collected, the sample locations, sampling frequencies and analysis criteria.
Personnel involved in the environmental sampling process shall be familiar with the REHP and its impact on their areas of responsibility.
2.2.5 Process Control Program (PCP) 2.2.5.1 10 CFR 50, Appendix A, Criterion 60 states, in part, that "The nuclear power unit design shall include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid waste produced during normal plant operations..."
2.2.5.2 Tech Specs state, in part, that "The solid radwaste systems shall be used in accordance with a Process Control Program to process solid radioactive wastes to meet shipping and burial requirements..."
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2.2.5.3 The Process Control Program (PCP) contains the equipment operating procedures, process parameters, setpoints, drawings and controls, and laboratory analysis procedures detailing the program of sampling, analysis, and formulation determination by which solidification and/or dewatering of radioactive wastes from liquid systems is assured.
Personnel involved in this solidification process shall be familiar with the PCP and its impact on their areas of responsibility.
2.2.6 Radioactive Haste Management 2.2.6.1 The Nuclear Regulatory Commission has adopted a policy calling on all generators of low level radioactive waste to reduce the volume of waste for disposal.
2.2.6.2 In addition to this policy, the packaging and shipping of radioactive waste is controlled by Department of Transportation (DOT) regulations, NRC regulations and the licensing requirements of receiving sites and individual states crossed during transportation of such waste.
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RADIOLOGICAL EFFLUENT CONTROL MANUAL PAGE 8 0F 16 2.2.6.3 The Radwaste Control Manual contains factors to be considered, and procedures to be followed, when processing radioactive waste.
Personnel involved in the processing of radioactive waste shall be familiar with the Radwaste Control Manual and its impact on their area of responsibility.
Personnel at-the facility should be familiar with the radioactive waste minimization policy, and its impact on their day-to-day work routines.
2.2.7 Implementing Procedures.
2.2.7.1 Each department / functional group, providing direct or indirect support of facility effluent activities, shall review programmatic elements of the Effluent Control Program and
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generate appropriate implementing procedures.
2.2.7.2 These procedures shall be reviewed by the Environmental Protection Department (EPD) to ensure that effluent control considerations are incorporated and that the implementing process conforms to the overall objectives of the facility's effluent control program.
2.2.8 Program Oversight
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2.2.8.1 The Effluent Control Program shall be under the administrative q
control of the Environmental Protection Department, even though inter-departmental operations routinely occur during processing of liquid, gaseous and solid wastes.
The purpose of such administrative control is to establish and maintain consistency 6
within all elements of the Effluent Control Program.
2.2.8.2 Administration of the Effluent Control Program should include f
periodic surveillances of all phases of the Effluent Control Program.
Formal audits and surveillances of the program are conducted by Quality Assurance and Environmental Protection personnel.
l 2.2.9 Effluent Goals / Trend Analysis 2.2.9.1 Effluent Control Program goals shall be established on a facility basis to assist in minimizing all effluents discharged, and their subsequent impact on employees and the general public.
The tracking of progress in achieving these goals will also provide a means of effectively evaluating effluent related activities.
2.2.9.2 Effluent Control Program Goals shall be clearly defined, realistic, measurable and specific to the control of all effluents.
Such goals should be agreed upon by the affected department and the Environmental Protection Department.
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2.2.9.3 Trend analysis shall be performed, in conjunction with Effluent l
Control Program Goals or in support of an unusual effluent related occurrence, to help determine the root cause of a trend and provide this information to the appropriate level of management.
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2.2.9.4 The purpose of this trending is to provide a detailed statistical I
analysis of available information and allow a correlation between data sets which may or may not have been previously recognized'as l
being related.
2.2.10 Reports i
2.2.10.1 Reports that supply-information related to the Effluent Control Program consist of those published to meet regulatory and Tech Spec requirements and thoso published to supply information to facility personnel.
2.2.10.2 In some cases, formats for these reports are dictated by I
regulatory and Tech Spec requirements; in other cases formats are defined by the needs of personnel requesting the information.
Regardless of how the format is dictated, the reports should be easily read and supply the information requested.
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2.2.11 Nuclear Training 2.2.11.1 Training in the Effluent Control Program shall be commensurate with the work performed by an individual, and meet the requirements for familiarity described previously in this program.
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2.2.11.2 As a minimum, facility personnel shall be made aware of the Effluent Control Program, and in particular, the Radioactive Haste Minimization element of the program.
l 2.2.11.3 Support groups, such as Procurement, shall have appropriate training to ensure that Effluent Control concepts are considered as they perform duties related to the nuclear facility (e.g.,
solid waste minimization).
I 3.0 RESPONSIBILITIES 3.1 Chief Executive Officer - Nuclear 3.1.1 Approves the Radiological Effluent Control Manual.
3.1.2 Approves departmental accountabilities, relative to the Effluent Control Program.
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3.1.3 Ensures that all operational aspects of the Effluent Control Program are implemented and maintained in accordance with the Rancho Seco Radiological Effluent Control Manual.
3.1.4 Ensures that resources are made available for the implementation of an effective Effluent Control Program at Rancho Seco.
3.1.5 Approves the Effluent Control Program Goals.
3.1.6 Provides a status of the Effluent Control Program to the Board of Directors on an annual basis.
3.2 Hanager - Environmental Protection Department 3.2.1 5
Develops, implements and administers the Effluent Control Program.
3.2.2 Provides Effluent Control support to all facility departments.
3.2.3 Reviews applicable facility design changes and modifications to assure that Effluent Control Projram concepts and concerns are addressed.
3.2.4 Reviews regulatory concerns, technical papers and revised /new
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issue regulations, from an effluent control standpoint, and makes recommendations for implementation of identified requirements (this review is in conjunction with normally conducted licensing reviews) 3.2.5 Performs reviews of applicable facility procedures, to ensure that effluent control concerns are addressed and that consistency is maintained in the program.
3.2.6 Performs periodic surveillances to assist in the administration of the program.
3.2.7 Coordinates the preparation of facility Effluent Control Goals and submits them for review and approval.
3.2.8 Ensures the periodic reports, published to support the Effluent i
Control Program and to meet regulatory requirements, are published in a timely manner.
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RADIOLOGICAL EFFLUENT CONTROL MANUAL PAGE 110F 16 3.2.9 Maintains the following Effluent Control programmatic manuals:
Radiological Environmental Monitoring Program Manual Offsite Dose Calculation Manual Radiological Effluent Control Manual 3.2.10 Performs an annual analysis of the Effluent Control Program; which includes procedures, equipment operation and maintenance which effects the release of effluents, offsite doses and effluent releases.
The. objectives of the analysis are to:
Determine if the Effluent Control Program is meeting its stated objectives.
Determine which areas need improvement, and specifically determine what these improvements are.
Determine the established cost associated with the implementation of the Effluent Control Program over the preceding calendar year.
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3.2.11 Uses data analysis to determine root causes of abnormal or unplanned conditions, as defined by procedures, and gives recommendations or corrective action to prevent the reoccurance of the condition.
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The below listed fuctions are performed 3
by the Environmental Protection Department but will be transferred to the Chemistry Department after the Efffluent Control i
Program is fully implemented.
3.2.12 Perform pre-release concentrations and dose calculations for both liquid and gaseous releases.
3.2.13 Generates release permits for both liquid and gaseous releases, l
3.3 Manager - Radiation Protection 3.3.1 Maintains a Radiological Control Progam which supports the effluent control concept; for liquids, gases and solids.
3.3.2 Provides interfaces and support to other departments, as they implement actions in support of the Effluent Control Program.
3.3.3 Establishes and implements a Radioactive Haste Control Program which includes waste minimization, waste handling, waste
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solidification and waste shipments.
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The below listed functions are performed by the Radiation Protection Department, but will be transferred to the Chemistry Department when the Effluent Control Program is fully implemented.
3.3.4 Performs sampling of gaseous effluents prior to release, to evaluate the amount of radioactive material to be released and to ensure that established limits will not be exceeded as a result of the release.
3.3.5 Establishes Rad Monitor Alarm setpoints and recommends changes to these setpoints based upon data obtained during the generation of release permits.
3.4 Hanager - Nuclear Chemistry Department 3.4.1 Develops, implements and maintains sampling and analytical techniques that support the effluent control concept, for liquids and gases.
3.4.2 Provides interfaces and support to other departments, as they implement actions in support of the Effluent Control Program.
3.4.3 Performs sampling of liquid effluents prior to release, to ensure f
established limits will not be exceeded as a result of the release.
3.4.4 Performs analysis of effluents, both liquid and gaseous, and provides the results of such analysis to personnel performing dose calculations to support the release.
3.5 Manager - Operations Department 3.5.1 Provides interfaces and support to other departments, as they implement actions in support of the Effluent Control Program.
3.5.2 Performs isolation, valve alignment and circulation (for liquid only) of batch release, prior to sampling.
3.5.3 Performs pre-release evaluations of effluent release information (on Effluent Release Permits) and gives approval for the release.
3.5.4 Approves of applicable changes to effluent monitor setpoints, both liquid and gaseous.
3.5.5 Aligns valves and starts / stops equipment to initiate and terminate the release of effluents, both liquid and gaseous.
3.5.6 Implements and maintains an effluent management program for both primary and secondary systems.
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3.6 Manager - Maintenance Department 3.6.1 Provides interfaces and support to other departments, as they implement actions in support of the Effluent Control Program.
3.6.2 Performs required maintenance and calibration of effluent monitors, both liquid and gaseous, which includes routine surveillences.
3.6.3 Makes changes to effluent monitor setpoints, both liquid and gaseous, when directed to do so by the Operations Department.
3.7 Manager - Nuclear Engineering 3.7.1 5
Provides interfaces and support to other departments, as they implement actions in support of the Effluent Control Program.
3.7.2 Develops, implements and maintains programs and procedures to ensure that applicable design changes to all radiological effluent systems are reviewed for their impact on the Effluent Control Program, prior to their implementation.
3.8 Director - Information Management Systems
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3.8.1 Provides interfaces and support to other departments, as they implement actions in support of the Effluent Control Program.
3.8.2 Provides support for the development, implementation and i
maintenance of computer support systems for the Effluent Control Program.
j 3.8.3 Develops, implements and maintain as programs and procedures to ensue that applicable changes to such support systems are reviewed for their impact on the Effluent Control Program, prior to their implementation.
3.9 Manager - Nuclear Tra ming 3.9.1 Provides interfaces and support to other departments, as they implement actions in support of the Effluent Control Program.
l 3.9.2 Inserts Effluent Control Program concepts and techniques into training programs, both for general employees and specific discipline training. Such training will include concepts for liquid, gaseous and solid effluents.
j 3.9.3 Maintain training program contents, regarding the Effluent i
Control Program, consistent with current regulations and policies.
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3.10 Director - Nuclear Quality 3.10.1 Performs periodic audits and surveillances of the Effluent Control Program, as required by procedures or requested by the l
Hanagement Safety Review Committee (HSRC).
l-3.10.2 Reviews and approves changes to the Effluent Control Program, as applicable, j
3.10.3 Assigns QC Hold Points in selected effluent control procedures.
l 3.11 All Facility Managers l
3.11.1 Ensure that employees, and contractors or. visitors working within their departments, have adequate training and qualifications to L
perform their assigned tasks, in relation to effluent controls.
3.11.2 Ensure that employees, and contractors or visitors working within their departments, are familiar with activities involving-effluent controls / radioactivity, relative to their assigned task, prior to starting work.
l 3.11.3 Ensure that effluent control considerations are factored into lC appropriate departmental activities.
This includes submitting applicable procedures for review to ensure that such l
considerations are included in the procedures contents.
l 3.12 All Facility Personnel 3.12.1 Adopt work practices that minimize the generation of radioactive effluents; either in liquid, gaseous or solid form.
l 3.12.2 Maintain awareness of the working environment, and watch for l
practices that could result in a release of effluents to that environment.
j 3.12.3 Support the Effluent Control Program by submitting applicable suggestions, regarding the control or minimization of effluents, to the Environmental Protection Department for review and evaluation.
4.0 RADIATION PROTECTION OVERSIGHT SUB-COMMITTEE; 0F THE HSRC l
4,1 As part of their oversight functions regarding the Radiation Protection Program, the Radiation Protection Oversight Sub-Committee has the following responsibilities regarding the l
Effluent Control Program.
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4.1.1 Ensure that an-Effluent Control Program, integrating management philosophy and regulatory requirements, has been established.
Accomplishment of this responsibility shall include reviewing proposed changes to the Radiological Effluent Control Manual and making recommendations-regarding approval to the HSRC.
4.1.2 Monitoring that operational procedures, maintenance procedures and detign modifications relative to facility equipment or spaces are reviewed for effluent control considerations and that procedures are provided by which specific effluent control goals will be achieved.
4.1.3 Periodically. reporting the effectiveness of the Effluent Control Program to the Management Safety Review Committee (HSRC).
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Gsuun SACRAMENTO MUNICIPAL UTIUTY DISTRICT C P. O. Box 15830, Sacramento CA 95852 1830,(916) 452-3211 AN ELECTRIC SYSTtM SERVING THE HEART OF CALIFORNIA FEB 191933 GCA 88-074 U. S. Nuclear Regulatory Commission Attn: Frank J. Miraglia, Jr.
Associate Director for Projects 11555 Rockville Pike Rockville, MD 20852 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 RADIOLOGICAL EFFLUENT CONTROL MANUAL
Dear Mr. Miraglia:
Based on discussions between the District and NRC staff, the District hereby submits for your information its "Radioactive Effluent Control Manual" (Enclosed).
The manual describes administrative controls and department responsibilities relating to the District's Effluent Control Program for effective management of radioactive plant effluent.
Please contact me if you have any questions.
Members of your staff with questions requiring additional information or clarification may contact Mr. Richard Mannheimer at (209) 333-2935, extension 4919.
Sincerely, 9
i u
O G.
a rl ' Ando ini Chief Executive Officer, Nuclear Attachment cc:
G. Kalman, NRC, Rockville A. D'Angelo, NRC, Rancho Seco J. B. Martin, NRC, Walnut Creek
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RANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799;(2o9) 333 2935