ML20202B247
| ML20202B247 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 02/03/1998 |
| From: | GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20202B237 | List: |
| References | |
| NUDOCS 9802110152 | |
| Download: ML20202B247 (25) | |
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I 6L20-98 30036 1" ' Attaciunent 5 sg 3 s
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Attac'hment 5 Proposed Revised Technical Specifications .
20 Pages -
Changes from the previous August 21,1997 submittal are identified by margin bars, s.
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1.0 DEFINITIONS 1.01 i
00RMINMENT VESSL '
Tum used to d scribe the vertical steel cylinder which houses tim Saxton Nuclear
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Experimental Corpcrat!on Facility Nuclear Steam Supply System (NSSS) and , <>
related componerts, aft.o' known as the CV; r, s
1 4 1.0.2 CV SECURED - '
g The term CV SECURED applies to the controls I;ecisso;y t' o make an ichtal CONTAINMENT VESSEL (CV) entry, it dues not rer to any security measurn CV SECURED means that the CV has been scaled for persormel entry.
1.0.3 DECOMMISSIONING ACTIVITlilS -
The ,erm DECOMMISSIONING ACTIVITIES describes all of those activitics '
needed to decommission the SNEC Facility and return the site to unrestricted dse.
Examples of these activities include; PRODUCTION AC flVITIES needed to conduct decommissioning such as physical di:mantlement; radioactivc waste preparation, treatment, packagira and shipment; radiation protection nctivit!.a.
construction and installation of support systems, structures and components, and fmal status survey. '
t 1.0.4 DECOMhilSSIONING SUPPORT FACILITY (DSF) and DECOMMISSIONING SUPPORT BUILDING (DSB) .
The DECOMMISSIONING SUPPORT FACILITY (DSF)is the fdeilityL constructed southeast cf the contahment vessel (CV) and attached ta the CV.
The DSF consists of three stmetures, the DECOMMISSIONINO SUPPORT BUILDING (DSB), the Material 11andling Bay and the Personnel Access Facility.
The DSB is used to facilitate the decommissioning process and allow the preparation and packaging of radioactive material for shipping.
1.0.5 - EXCLUSION AREA-The term EXCLUSION AREA refers to the area shown on Figure i of the Technical Specifications and dermes the area controlled for the purpose of security and access restrictions. The EXCLUSION AREA will be posted.
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.b 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 respoasible for the decommissioning of the SNEC facility. GPU NUCLEAR is a wholly owned subsidiary of GPU Inc.
1.0.7 hiEASURADI,E REl, EASE:
A hiEASURABLE RELEASE is defined as those potential radioactive releases which meet or exceed the Lower Limit of Detection (LLD) for liquid and gan aus radioactive emuents as specified in the ODChi.
1.0.8 bilMBER(S).DF TIIE PUB 1JCf hiEhiBER(S) OF TIIE PUBLIC shall include all persons who are not occupationally associated with the Saxton Nuclear FNperimental Corporation facility. This category does not include employees of GPU Inc., contra tors or vendors. Also excluded fiom this categmy are persons who enter the Facility site
- to service equipment or to make deliveries.
1.0.9 DHS116 SQSE cal.CULATIONA1ANUAL (ODChi) -
The OFFSITE DOSE CALCULATION hiANUAL (ODCht) containt the methodology and parameters used in the calculation of offsite doses resulting from -
"dioective gaseous and liquid emuent, in tite calculation of gaseous and liquid emuent monitoring alarm / trip setpoints, and m the conduct of the Radiological Enviromnental hionitoring Program (REMP). The ODChi also contains (1) the s Radiological Emuent Controls, (2) tie REhiP, (3) descriptions of the information that r,hould be included 't the Annu.sl Radiological Emironmental Opeiating and Annual Radioactive EfLent Release Reports.
n 1.0.10 OfEBADLE - OPERABillLL A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function (s) and t
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 P.s function (s) are also capable of performing their related support function (s).
e l.0.11 ISiQGSSE.QNTROL PROGRAhi(PCP) -
The PROCESS CONTROL PROGRAM (PCP) shall contain the current formulas, 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 a* to assure compliance with 10 CFR Parts 20,61, and 71, State regulations, burial ground requirements, and other requirements governing the disposal of solid radioactive waste.
1.0.12 PRODUCTION ACTIVITIEL-PRODUCTION ACTIVITIES include all of the physical activities needed to conduct the decommissioning of the SNEC facility site. Included are such retivities as the removal of systems, stmeture and components, demolition of structures ed associated components, removal of contaminants to allow free release, excavation, trenching and removal of underground facilities.
These activities are a sub set of DECOhihilSSIONING ACTIVITIES.
1.0.13 RADIOACTIVE WASTE h1ANAGEhiENT ACTIVITIES -
The term RADIOACTIVE WASTE h1ANAGEhiENT ACTIVITIES is dermed as those activities which involve the handling of radioactive waste materials.
1.0.14 SffMRED_-
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 such 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 DECOhihilSSIONING SUPPORT FACillTY (DSF) could be covered with a security grating, a door or hatch on the CONTAINhiENT 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, restraining devices such as inaccessible or tamper resistant bolts could be installed on gates or doors.
1.0.15 SITE BOUNDARY -
The SITE BOUNDARY used as the basis for the limits on the release of gaseous ellluents is the line formed by a 200 meter radius from the center of the containment vessel,
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4 1.0.16 SNEC-The term SNEC is an acrorSm for the Saxton Nuclear Experimemal Corporation.
1.0.17 SUBSTANTIVE Cil ANGE(S)-
SUBS *."ANTIVE CilANGE(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 : '-leting) sign -
off spaces; (3) blocking in notes, cautions, etc.; (4) cnanges in cose
,A t and personnel titles which do not reassign responsibilities and which are not referenced in the Technic;l Specifications; and (5) changes in nomenclature or editorias changes which clearly do not change function, meaning or intent.
1.0.18 UNRESTRICTED AREA-An UNRESTRICTED AREA shall tu any area at or beyond the SITE IlOUNDARY access to which is wt controlled by the licensee for purposes of protection ofindividuals from er.posure 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.
As used here the term is used as it applies to radioactive efiluents. The definitions as they apply to 10CFF carts 20 and 100 still apply.
1.1 SITE l.l.1 Jtpation l
The Saxton Nt. Jear Experimental Corporation (SNEC) facility is on a 1.148 acre 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
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Saxton, Pennsylvania, in Liberty Township, Bedford County, Pennsylvania. The Pennsylvania Electric Company property consists of approximately 150 acres along the Raystown Branch of the Juniata River, 1.1.2 EXCLUSION AR_llA Boundary The EXCLUSION AREA consists of that portion of the SNEC facility property enclosed within a fence and building boundaries as posted. See Figure 1.
1.1.3 EXCLUSION AREA Controh 1.1.3.1 Except for authorized entry, access points to the EXCLUSION AREA will be SECUl4ED.
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1.1.3.2 The CONTAINh1ENT VESSEL (CV) at d the DECOhthilSSIONING SUPPORT FACILITY (DSF) r. hall be eq iipped 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. !
1.l.3.3 Access points to the CONTAINh1ENT VESSEL (CV) and the DECOhthilSSIONING SUPPORT FACILITY (DSF) will be SECURED following an authorized entry, prior to activating the intmsion alarms.
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 delineated in section 1.0.3, DECOhthilSSIONING ACTIVITIES, of these Technical Specifications.
2.1 limiliDg Conditions for Performing DECOhihilSSIONING ACTIVITIES 2.1.1 During activities within the CV/DSB that have the potential to cause a h1EASURABLE RELEASE to the environment of airborne radioactivity, the CV/DSB ventilation system will be operating in a manner such that the release pathway is via the monitored ventilation system exhaust.
2.1.2 When the CV/DSB ventilation exhaust is in operation, the exhaust monitoring instrumentation will be operated simultaneously. The sentilation system will be shutdown if the exhaust monitoring instmmentation is inoperable.
2.1.3 Verification by analysis that release criteria have been satisfied is required prior to making any batch release ofliquid waste process emuent. Ellluem release calculations will be made in accordance with the NFSITE DOSE CALCULATION hiANUAL.
3.0 ADh11NISTRATIVE CONTROLS 3.1 Organization and Responsibilities GPU NUCLEAR has the responsibility for safely performing DECOhthilSSIONING 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
6 personnel positions, or in equivalent forms of documentation. These requirennents shall be documented in the SNEC Facility USAR.
l 3.1.1 The President GPU NUCLEAR is responsible for and provides full time dedicated staff for the purpose of conducting all activities safely and effectively.
3.1.2 . The Vice President Engineering Division assures that all division and l.
corporate activitier, are performed in accordance with corporate policies, applicable la%, regulations, licenses and Technical Specifications (TSs).
3.1.3 The Program Director SNEC Facility is responsible for administration of all SNEC facility functions, for direction of all DECOMMISSIONING l ACTIVITIES, and for assuring that the requirements of License No. DPR-l 4 and these TSs are implemented.
3.1.4 The SNEC Facility Site Supervisor provides on site management and continuing oversight of PRODUCTION ACTIVITIES.
3.1.5 The Radiation Safety Officer (RSO)is responsible for the conduct and oversight of all SNEC radiation safet activities through implementation of the Radiation Protection Plan. All radiological contrcis personnel shall have stop work authority in matters relating to or impacting radiation safety.
3.1.6 The Group Radiological Controls Supervisor (GRCS) directly supervises radiation safety activities.
3.1.7 Other GPU NUCLEAR personnel provid: SNEC facility management with technical support, project management capabilities and manpower.
3.2 Facility Stafling Requirements:
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 support the initial entry into the CV for the day.
3.2.2 The RSO or a GRCS shall be present on site whenever CV entry, PRODUCTION ACTIVITIES, maintenance, characterization and/or RADIOACTIVE WASTE MANAGEMENT ACTIVITIES are being performed in Radiologically Controlled Areas (RCA's).
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6 3.3 Encihtv Sta[Qualificalions "
3.3.1 Each Radio'ogical 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 tLrough an NRC approved radiological controls training program.
3.3.2 All personnel performing decommissioning or associated activities shall be 1 briefed on the SNEC site specific conditions and applicable requirements of the task assigned.
3.4 Indning GpU NUCLEAR shall maintain training programs as necessary for those personnel ;
performing decommissioning work fimetions at the SNEC facility.
l 3.4.1 The job specific training or knowledge necessary to accomplish a specific task or project goal shall be dictated by the dismantlement or decommissioning work scope.
3.4.2 in lieu of training, performance of specialized tasks, techniques and equipment operation shall be permitted, provided competency is demonstrated to the Progiam Director SNEC Facility or his designee.
3.5 Review,insgection and Auslil 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 level or above.
3.5.1.2 Each procedure required by section 3.6.1 and SUD9TANTIVE CilANGES 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.
4 3.51.3 Propose $ 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
- nsy be from the same division as the individual who prepared the tests and experiments.
3.5.1.5 Proposed modifications to facility stmetures systems and j
components. as described in the SNEC Facility USAR determined to l 1 be within the scope of the SNEC Fa.cility Decommissioning QA )'
Plan and QA program, shaU be designed by an individual /
organization knowledgeable in the areas affected by the proposed modification. Each such modification shall be technically reviewed by an individual /groep other than the individual / group which designed the modificmion but may be from the same group as the individual who designed the modification. '
3.5.1.6 Investigation of all violations of the TS including the prer.aration j and forwarding of reports cove ing evaluation and recommendations to pievent recurance, shall be resiewed by a knowledgeable individual / group other than the individual / group which pet formed the investigation.
3.5.1.7 All repo 1able events shall b; reviewed by an individual / group other than the indisidual/ group which prepared the report.
3.5.1.8 Individuals re.cponsible for resiews performed in accordance with sections 3.5.1.2 through 3.5.1.7 shallinclude a determination of whether or not additional cross disciplinary review is necessary. If necessary, such reviews shall 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 disciplines, or have seven years of appropriate experience in the field or 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. --
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3.5.1.10 Records of the review act;vities performed in accordance with 3.5.4.2 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 decomr .issioning project shall be responsib'e for ensuring the independent safety review of the subjects described in section 3.5.2.3 within his assigned area of review responsibility.
3.5.2.2 Independent safety review sh:.ll 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 indaidual or group performing the original work.
3.5.2.3 GPU NUCLEAR shall collectively have or have access to the experience and competence required to independently review subjects in the following areas:
nuclear unit operations electrical, mechanical and nuclear engineering ehemistry and radiochemistry metallurgy instmmentation and control radiological safety administrative controls and quality assurance practices other appropriate fields such as radioactive waste management.
3.5.2A Consultants may be utilized as determined by the cognizant Vice President to provide expert advice.
3.5.2.5 The following c ojects shall be independently reviewed by Independent Safety Reviewers in the functionally assigned disisions:
3.5.2.5.1 Written safety evaluations of changes in the facility and changes of procedures described in the Safety Analysis Report, and of tests or experiments not described in the Safety Analysis Report, which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(1).
This review is to verify that such changes, tests or 9
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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 perfonnance of a change, test or experiment shall be completed prior to the initiation of the actisity.
3.5.2.5.2 Proposed changes in procedures, in the facility or terts or expesiments, 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 piior to I their submittal to the NRC.
3.5.2.5.3 Proposed changes to TS or license amendments shall be reviewed prior to submittal to the NRC for approval.
3.5.2.5.4 Violations, deviations and reponable events which require reporting to the NRC in writing. Such reviews are performed afler the fact. Review of events covered under this subsection shall include results of any investigations to prevent or reduce the piobability of recurrence of the event.
3.5.2.5.5 Written summaries of audit repons identified in section 3.5.4.
3.5.2.5.6 Any other matter invohing 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 i professional level experience in the arch being reviewed or have nine years of appropriate experience in the field of specialty. An indisidual perfonning reviews may possess competence in more than one specialty area. Credit toward experience will be given for advarced degrees on a one-for-one basis up to a maximum of two years.
3.5.2.7 Records of resiews 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 procedures. The inspection activities shallinclude:
a Verification that EXCLUSION AREA access points aie SECURED at the completion of each authorized entry.
- b. Verification of the OPERABILITY of the l EXCLUSION AREA intrusion alarms shall be performed quarterly.
- c. The station ventilation system efiluent paniculate monitor channel checks, source checks, channel test and channel calibration shall be performed at a trequer,y specified in the ODCh1.
- d. The ventilation system l{ EPA Filter will be tested to verify efliciencies in accordance with the requirements of the ODChi.
3.5.4 Audits 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 biennially, 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 performed in accordance with the GPU NUCLEAR audit program
! procedures. The audit procedures identify areas which may be included in I 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 l
l 3.5.5.1 The Radiation Safety Committee shall report to the Vice President l Engineering. The Committ.;e will consist of at least four members.
hiembership will be on the recommendation of the Vice President l (
Engineering. Three members shall coastitute a quomm. l 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, DECOhihilSSIONING ACTIVITIES, special nuclear and
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radioactive material activities, facility changes, radiological
-conditions, audit reports and NRC Inspection reports and corrective actions for deficiencies identified.
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3.5.5.3 , Meetings shall be held at least three times per year.
3.5.5.4 Wiltten minutes of all meetings shall be prepared and distributed to the Vice President Engineering within 30 days of the meeting date. l 3.6 Procedures. Programs and Manuals 3.6.1 Procedures 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 apprnved procedures of a type appropriate to the circumstances.
i 3.6.1.2 Written prc:edures shall be established, implemented and maintained for the actisities listed below:
3.6.1.2.1 Characterization, decommissioning and maintenance activities determined to be within the scope of the QA program.
3.6.1.2.2 Access control, emergency actions (including fire protection program implementation), f acility inspections and audits.
t 3.6.1.2.3 Radiological exposure control, sun ey activities and radwaste shipping and handling.
3.6.1.2.4 Activities which could result in a MEASU'RABLE RELEASE to'the environment.
- 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 11ealth Physics control shall be consistent with 10 CFR Part 20 requirements to minimize the radiation
- exposure of personnel and to prevent the release of radioactisity in excess of allowable limits to the ensironment.
3.6.1,3.2 All radiation 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.
6 3.6.1.3.3 Faci *ity inspections and access controls shall meet specific requirements of the sections 3.5.3 and 1.1.3, respectively, of l 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 applicable administrative procedure equirements prior to their initial use.
3.6.2 Programs The following programs shall be established, implemented, and maintained -
during DECOMMISSIONING ACTIVITIES:
3.6.2.1 Radioactive Emuent Controls Program A program shall be provided conforming with 10 CFR, Section 50.36(a) for the control of radioactive emnents and for mainmining the doses to MEMBER (S) OF THE PUBLIC from radioactive emuents 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 determination in accordance with the methodology in the ODCM; 3.6.2.1.2 Limitations on the concentrations of radioactive material released in hquid emuents to UNRESTRICTED AREAS conforming to 10 times the concentrations specified in 10 CFR 20, Parts 20.1001 - 20.2402, Appendix B Table 2, Column 2; 3.6.2.1.3 Monitoring, sampling, and analysis of radioactive emuents in accordance with 10 CFR, Part 20.1302 and with the methodology and parameters in the ODCM; 3.6.2.1.4 Limitations on the annual and quanctly doses or dose commitment to a MEMBER (S) OF THE PUBLIC from radioactive materials in liquid emuents released to l
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4 4 UNRESTRICTED AREAS conforming to Appendix I to 10 !
CFR, Part 50;
.h 3,6.2.1.5 Determination of cumulative and projected dose contributions from rsdioactive efiluents for the current calendar quaner and current calendar year in accordance with the methodology and parameters in the ODChi at least every 31 days; 3.6.2.1.6 Limitations on the OPERABILITY and use of the l radioactive efiluent 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 would exceed 2% of the guidelines for the annual dose or dose commitment conforming to Appendix 1 to 10 CFR, Part 50; 3.6.2.1.7 Limitations on the dose rate resulting from radioactive material released in gaseous efiluents 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 hiEhfBER(S) OF THE PUBLIC from tritium, and all radionuclides in particulate form with half lives greater than >
eight days in gaseous efiluents released to areas beyond the SITE BOUNDARY conforming to Appendix f to 10 CFR, Part 50; 3.6.2.1.9 Limitations on the annual dose or dose commitment to any hfEhiBER(S) 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 hionitoring Program 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 d
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- b. Verification of the accuracy of the Efiluent Monitoring Program and modeling cf etivironmental exposure pathways.
3.6.2.2.2 The program shall (1) be contained in the ODCM; (2) conform to the guidance of Appendix 1 to 10 CFR, Part 50; and (3) include the follov$ing:
- a. hionitoring, sampling, analysis, and reporting of radiation 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 areas at and t eyond the SITE BOUNDARY are identif I and that modifications to the monitoring program are made if required by the results of this census, and,
- c. Participation in an interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the Quality Assurance Program for emironmental monitoring.
3.6.2.3 PROCESS CONTROL PROGRAM (PCP)
The PCP shall contain the current formulas, campling, analyses, tests, and determinations to be made to ensure that the processing and the packaging of solid radioactive wastes will be accomplished to ensure complience with l 10 CFR, Part 20; 10 CFR, Part 61; and 10 CFR, Part 71; burial ground requirements and other requirements governing tne disposal of solid radioactive wastes.
3.6.2.3.1 Changes to te PCP:
a, Shall be documented and records of reviews performed shall be retained as required. This documentation shall contain:
- 1. Suflicient information to support the change together with the appropiiate analyses or evaluation justifying the change (s), and
- 2. A detcrmination thet 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. Slaall 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 establ.:shed in c wiitten SNEC Decommissionir.g Quality Assurance Plan. Revisions to this plaa will be submitted to the NRC prior to the implementation of changes whicii Involve a reduction in commitments previously accepted by the NRC and after implementation of changes having no reduction in commitment.
3.6.3 hianuais l 3.6.3.1 OFFSITE DOSE CALCULA fl0N hiA'NUAL (ODChi) l l
3 A3.1.1 Content:
- a. The ODChi 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
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radioactive gaseous and liquid emuent monitoring alarm and trip setpoints, and in the conduct of the Radiological Environmental hionitoring Program; and
- b. The ODCM shall also contain the Radioactive Emuent Controls Program and the Radiological Environmental hionitoring Program required by Specifications 3.6.2.1 and 3.6.2.2 respectively, and descriptions of the information that should be included in the Annual Radiological Environmental hionitoring Repon required by Specification 3.8.2.
3.6.3.1.2 Changes to the ODCht:
- a. Shall be documented and records of reviews performed shall be retained as required by Specification 3.9.10. This documentation shall contain:
- 1. Sumcient information to support the change together with the appropriate analyses or evaluation justifying the change (s), and
- 2. A deteiminatk a that the change will maintain the level of the radioactive emuent control required by m _
10 CFR, Part 20.1301; 40 CFR, Part 190; 10 CFR, Section 50.36(a); and Appendix 1 to 10 CFR, Part 50 and not adversely impact the accuracy or reliability of emuent, dose, or setpoint calculations.
- b. Shall become effective aller 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 pan of or concurient with the Annual Radioactive Emuent Release Report for the period of the repon in wWh any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the areas of the page that was changed, and shall indicate the date (e.g., month / year) the change was implemented.
3.7 Eirs 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 frequency.
3.8 Reporting in addition to those reports required by applicable NltC regulations (i.e., violation oflicense or technical specification condition) GPU NUCLEAR shall submit the following:
3,8,1 A report of any occurrence of a possible unsafe condition r :lsting to the faci!ity or to the public. For each occurrence, SNEC shall promptly, within 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 Non Power Reactors and Decommissioning Project Directorate Director, or designee, and the NRC Operations Center, and shall submit a written follow-up report to the Document Control Desk and the Non Power Reactors and Decommissioning Project Directorate Director within 30 days, which describes the circumstances and the corrective action taken These reports shallinclude:
3.8.1.1 Any unplanned or uncontrolled release of radioactive material beyord the SITE DOUNDARY.
3.8.2 An annual report shall be submitted to the Document Control Desk and the Non Power Reactors and Decommissioning Project Directorate Director, within 6 months afler 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; I 3.8.2.3 Results of surveys and monitoring performed in accordance wit!:
Specifications 3.6.2.1 and 3.6.2.2; 3.8.2.4 A review of the performance of access control and surveillance measures.
3.9 Ilecords in addition to the records required by applicable NRC reguhtions, 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 reporteble 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 of entries into the CONTAINMENT VESSEL invohing radiation work permits and the reason for the entry; 3.9.5 Radioactivity releases or dische.rges into the air or water beyond the effcetive control of SNEC as measured at or prior to the point of such release or discharge; 3.9.6 Records of reviews performed for changes made to procedares or equipment pursuant to 10 CFR 50.59;
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3.9.7 Records of Quality Assurance activities required by section 18 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; 3.9.10 Records of reviews performed and changes made to the OFFSITE DOSE t CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.
3.9.11 Inspections ot'the decommissioned facility including the results of surveys of radioactivity levels and as found and as-lef) conditions of the facility and l
3.9.12 Characterization study results.
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Attachment 6 Attachment o l Revised SNEC Facility Updated Safety Analysis Report Title Page, page 5 - 2 and Figure 1 - 8 Instructions:
Replace the Title page, page 5 - 2 and Figure 1 - 8 with the revised pages attached.
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. UPDATED SAFETY ANALYSIS REPORT FOR DECOMMISSIONING THE SNEC FACILITY REVISION 2 February,1998
SA.\ TON NUCLEAR EXPERIMENTAL FACILITY UPDATED SAFETY ANALYSIS REPORT 5.0 Conduct of Decommissioning 5.1 Organization 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 equivalent forms of documentation. The SNEC organization is depicted on Figures 2.31 and 2.3-2 of;he SNEC Facility PSDAR.
- a. The President GPU Nuclear is responsible for and provides full time dedicated staff for the purpose of conducting all decommissioning associated activities safely and effectively.
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- b. The Vice President Engineering Division assures that all division and corporate activities are performed in accordance with corporate policies, applicable laws, regulations, licenses end Technical Specifications (TSs).
- c. The Program Director SNFC Facility is responsible for admir,: tratior, of all SNEC facility functions, for direction of all decommissioning activities, and for assuring thtt the requirements of License No. DPR-4 and these TSs are implemented.
- d. The SNEC Facility Site Supervisor provides on-site management and continuing oversight of production activities.
- c. The Radiation Safety Officer (RSO)is responsible for the conduct and oversight of all SNEC radiation safety activities through implementation of the Radiation Protection Plan. All radiological controls personnel have stop work authority in matters relating to or impacting radiation safety.
- f. The Group Radiological Controls Supervisor (GRCS) directly supervises iadiation safety activities.
- g. Other GPU Nuclear Vice Presidents (Financial and Planning Services, Engineering, and Three Mile Island) provide SNEC facility management with technical support, project management capabilities and manpower, S2
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j Figure 1-8 Cod File: S1A-SKC-1009