ML20210Q229

Proposed Revised Tech Specs Re TS Change Request 59

ML20210Q229
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	08/21/1997
From:	GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20210Q225	List: ML20210Q221 ML20210Q229 ML20210Q232
References
NUDOCS 9708280244
Download: ML20210Q229 (21)

Text

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l l Attachment 5 t

Proposed Revised Technical Specifications 19 Pages 1

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I 9708290244 97 1 i PDR ADOCK 0 146 F PDR .

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1.0 DEFINITIONS 1.0.1 CONTAINhiENT VESS]lk.

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 SEC.UEED.-

The term CV SECURED applies to the cor.trols necessary to make an initial CONTAINhtENT VESSEL (CV) entry. It does not refer to any security measures. CV SECURED means that the CV has been scaled for personnel entiy.

1.0.3 DilCQbihilSSIONING ACTIVIT]ES_-

The term DECOhihilSSIONING 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, structures and components, and fmal status survey.

1.0.4 DECOhihilSSIONING SUPPORT BUILDING (DSBL- _

The DECOhihilSSIONING SUPPORT BUILDING (DSB)is the facility constructed southeast of the CONTAINhtENT 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 ofGPU Inc.

1.0.7 hiEASURAHLE. RELEASE _.

A hiEASURAllLE RELEASE is dermed as those potential radioactive releases which meet or exceed the Lower Limit of Detection (LLD) for liquid and gaseous radioactive emuents as specified in the ODChi.

1.0.8 h1EMDER(S)_QE111E PUBilC:

hiEhiBER(S) 0F Tile PUllLIC shall include all persons who are not occupationally associated with the Saxton Nuclear Experimental Corporation 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.

1.0.9 DEESTf_ DOSE CALCULATION hi ANUAL_(QQCM)_:

The OFFSITE DOSE CALCULATION htANUAL (ODChi) contains the methodology and parameters used in the calculation ofoffsite doses resulting from radioactive gaseous and liquid emuent, in the calculation of gaseous and liquid emuent monitoring alarm / trip setpoints, and in the conduct of the Radiological Environmental hionitoring Program (REh1P). The ODCM also contains (1) the Radiological Emuent Controls, (2) the REhiP, (3) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Emuent Release Reports.

3.0.10 DPERABLE - OPERABILITY -

A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified ibnction(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 capable of performing their related support function (s).

1.0.11 PROCESS CONTROL PROGR.Ahi (PCf)_-

The PROCESS CONTROL PROGRAhi (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 soud wastes will be accomplished in such a way as 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.

4 1.0.12 PRODUCTION ACTIVITIES-PRODUCTION ACTIVITIES include all of the physical activities needed to conduct the decommissioning of the SNEC facility site. Included are such activities as the removal of systems, structures and components, demolition of stmetures and associated components, removal of contaminants to alluw free release, excavation, trenching and removal ofunderground facilities.

These activities are a sub set of DECOMMISSIONING ACTIVITIES.

1.0.13 RADIOACTIVE WASTE MANAGEMENT ACTIVITIES -

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

1.0.14 - SECURIiQ.:

The tenn 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 phyi,1callock. 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 __ y in0PERABLE, temporary openings in the CV shell or EXCLUSION AREA fence could be physica;ly 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 effluents is the line formed by a 200 meter radius from the center of the containment building.

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

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1.0.17 SilRSTANTIVE C))ANGE(Sh SUBST ANTIVE CllANGE(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 UNRESTRICIED AREA-An UNRESTRICTED AREA shall be any area at or beyond the SITE 13OUNDARY access to which is act controlled by the licensee for purposes of protection ofindividuals from exposure to radiation and radioactive materials, or l any area within the SITE 110UNDARY used for residential quarters or for l indur. trial, commercial, institutional, and/or recreational purposes.

As used here the term is used as it applies to radioactive etliuents. The definitions as they apply to 10CFR Parts 20 and 100 still apply.

1.1 S]IE 1.1.1 Loration The Saxton Nuclear Experimental Corporation (SNEC) facility is on a 1.148 acre tract deeded from the Pe' asylvania Electric Company to the SNEC It is located within the property of the Pennsylvania Electric Company near the Borough of 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 2 EXCLUSION AREA BQutidaty 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 IZCLUSION AREA Controls 1.1.3.1 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 4-

system. Intrusion alarms wi!! be activaied whenever the site is not manned.

OPERABLILITY shall be vetified in accordance with section 3.5.3.1.b.

2.0 : PRINCIPAL ACTIVITIES Activities permitted at the SNEC L.ility shall include the routine and emergency inspections, maintenance assocv'ated with the possession of the SNEC facility, characterization activities and activities delineated in section 1.0.3, DECOMMISSIONING ACT4VITIES, of these Technical Specificatiom.

2;l Limiting Conditions for Performing DECOMMISSIONING ACTIVITIES 2.1.1 During activities with'm 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 operating in a manner such that the release pathway is via the monitored ventilation system exhaust, 2.1.2 _ The ventilation exhaust monitoring instrumentation and the CV/DSB '

ventilation system will be operated simultaneously. The ventilation system will be SECURED if the exhaust monitoring instmmentation is inoperable.

-2.1.3 Verificaticn by analysis that release criteria have been satisfied is required -

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

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. 3.1. Organization and Responsibilities '

w _ 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.L1 The hesident 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 Nuclear Safety and Technical Services (NSTS)

' Division assures that all division and corporate activities are performed in

accordance with corporate policies, applicable laws, 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 ACTIVITIES, and for assuring that the requirements of License No. DPR-4 and these TSs are implemented.

3.1.4 The SNEC Facility Site Supenisor prosides 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 safety activities through implementation of l the Radiation Protection Plan. All radiological controls personnel shall

! have stop work authority in matters relating to or impacting radiation safety.

l 3.1.6 The Group Radiological Controls Supenisor (GRCS) directly supenises i

radiation afety activities.

3.1.7 Other GPU NUCLEAR personnel provide SNEC facility management with technical support, project management capabilities and manpower.

3.2 Eacility Staffmg Reauirements:

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).

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.

4 3.4 Italing GPU NUCLEAR Mll maintain training programs as necessary for those personnel performing decommissioning work functions at the SNEC facility.

3.4.1 Thejob 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 Program Director SNEC Facility or his designee.

3.5 Review. Insnection and AuJjl l

3.5.1 Technical Review 3.5.1.1 The Vice President of each division within GPU NUCLEAR supportmg the SNEC facility decommissioning project shall be responsible for ensuring the preparation, review, and approval of documents required by the actisities 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 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 chariges to the TS shall be reviewed by a knowledgeable individual or group other than the individual (s) or group who .

prepared the change.  !

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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

Plan and QA progam, shall 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 / group other than the individual / group which ,

designed the modification 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 preparation and forwarding of repons covering evaluation and recommendations to prevent recurrence, shall be reviewed by a knowledgeable individual / group other than the individual / group which performed the investigation.

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

1 3.5.1.8 Individuals responsible for reviews performed in accoidance 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 j- necessary, such reviews shall be performed by the appropriate i 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 un4 eviewed 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 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 ensuring the independent safety review of the subjects described in section 3.5.2.3 within his assigned area of review responsibility.

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I3.5.2 21 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.

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 areasi nuclear unit operations electrical, mechanical and nuclear engineering chemistry and radiochemistry

- metallurgy;

. instrumentation and control ,

radiological safety-administrative controls and quality assurance practices -

other appropriate fields such as radioactive waste management. i 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 ftmetionally assigned divisions:

~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).

w-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 performance of a change, test or experiment shall be -

completed prior to the initiation of the activity, i3.53.5.2: 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 their submittal to the NRC.

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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 reportable events which require reporting to the NRC in writing. Such reviews are performed after the fact. Review of events covered under this subsection shall include results of any investigations to prevent or reduce the probability of recurrence of the event.

3.5.2.5.5 Written summaries of audit reports identified in section '

3.5.4.

3.5.2.5.6 Any other matter invoNing 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 than one cpecialty area Credit toward experience will be given for f 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 procedures. The inspection activities shallinclude:

a Verification that EXCLUSION AREA access points are SECURED at the completion of each authodzed entry.

b. Verification of the OPERABLILITY of the EXCLUSION AREA intrusion alarms shall be performed quarterly.

c. The station ventilation system effluent particulate monitor channel checks, source checks, channel test and channel calibration shall be performed at a frequency specified in the ODCM.

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d. The ventilation system HEPA Filter will be tested to verify efficiencies in accordance with the requirements of the ODCM.

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 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 recommendation of the Vice President NSTS. Three members shall constitute a quorum.

3.5.5.2 It shall be responsible to provide independent overview and 4 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, DECOMMISSIONING ACTIVITIES, special nuclear and radioactive material activities, facility changes, radiological conditions, audit reports and NRC Inspection reports and corrective actions for deficiencies identified.

'3.5.5.3 Meetings 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.

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 wr tten, reviewed and approved procedures of a type y topriate to the circumstances.

3.6.1.2 Written procedures 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 l

program implementation), facility inspections and audits.

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

I 3.6.1.2.4 Activities which could result in a MEASURABLE 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 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 envircnment, 3.6, l .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.

3.6.1.3.3 Facility inspections and access controls shall meet specific requirements of the sections 3.5.3 and 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 applicable administrative procedure requirements prior to their initial use.

3.6.2 Programs

4 The following programs shall be established, implemented, and maintained dunng DECOMMISSIONING ACTIVITIES:

j 3.6.2.1 Radioactive Emuent Controls Program A program shall be provided conforming with 10 CFR, Section 50.36a for the control of radioactive emuents and for maintaining 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:

l 3.6.2.1,1

' Limitations on the OPERABLILITY of radioactive emuent monitoring instmmentation, 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 liquid 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 quarterly doses or dose commitment to a MEMBER (S) OF THE PUBLIC from radioactive materials in liquid emuents released to UNRESTRICTED AREAS conforming to Appendix 1 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 OPERABLILITY and use of the radioactive emuent treatment systems to ensure that the appropriate ponions 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 emuents 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 MEhiBER(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 conform'mg to Appendix 1 to 10 CFR, l Part 50; I

l 3.6.2.1.9 Limitations on the annual dose or dose commitment to any hiEMBER(S) OF THE PUBLIC due to releases of radioanivity and to radiation from uranium fuel cycle sources conforming to 40 CFR, Part 190.

3.6.2.2 Radiological Environmental Monitoring Program j

3.6.2.2.1 A program shall be provided to monitor the radiation and nadionuclides in the ensirons of the plant. The program shall proside:

3.6.2.2.1 a. Representative measurements of radioactisity in the highest potential exposure pathways, and

b. Verification of the accuracy of the Emuent Monitoring I Program and modeling of environmental 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 following:

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

b. A Land Use Census to ensure that changes in the use of 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;

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 perfomied as part of the Quality Assurance Program for environmental monitoring. ,

3.6.2.3 PROCESS CONTROL PROGRAM (PCP)

The PCP shall contain the current formulas, sampling, analyses, tests, and determinations to be made to ensure that the processing and the packaging of solidified radioactive wastes will be accomplished to ensure compliance with 10 CFR, Part 20; 10 CFR, Part 61; and 10 CFR, Part 71; burial ground requirements and other requirements governing the disposal of solid radioactive wastes.

3.6.2.3.1 Changes to the PCP:

l 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 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.

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 Ar,surance Plan. Revisions to this plan will be submitted to the NRC: prior to the implementation of changes which involve a reduction in commitments previously accepted by the NRC and after implementation of changes having no reduction in commitment.

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3.6.3 Manuals 3.6.3.1 oft-Eite Dose Calculation Manual (ODCM) 3.6.3.1.1 Conter t

, a. The ODCM shall contain the methodology and parameters t

used in the calculation of off-site doses resulting from rad'oactive gaseous and liquid efiluents, in the calculation of radioactive gaseous and liquid emuent monitoring alarm and t p setpoints, and in the conduct of the Radiological Environmental Monitoring Program; and

b. The ODCM shall also contain the Radioactive Efiluent 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

} should be included in the Annual Radiological Environmental Monitoring Report required by Specification 3.8.2.

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 together with the appropriate analyses or evaluation justifying the change (s), and

2. A determination that the change will maintain the level of the radioactive effluent 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 effluent, dose, or setpoint calculations.

b. Shall become effective after 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 Efiluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the areas of the page that was changed, and shall indicate the date (e.g., moath/ year) the change was implemented.

1 3.7 Fire Protection 3.7.1 Procedures will be established and implemented for fire prevention and responding to fires.

3.7.?. 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 l frequency.

L 3.8 Renoning In addition to those reports required by applicable NRC regulations (ie, violation oflicense or technical specification condition) GPU NUCLEAR shall submit the

, following:

I 3.8.1 A report of any occurrence of a possible unsafe condition relating to the facility 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 telegraph, the Administrator of Region I, or designee, and the NRC Operations Center, and shall submit 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 shallinclude:

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 supenisory positions designated in section 3.1 as being responsible for decommissioning the facility, l

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3.8.2.2 A summary of decommissioning, design, and maintenance changes made to the deactivated facility; 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 measures.

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:

i 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 of entries 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 release or discharge; 3.9.6 Records of reviews performed for changes made to procedures or equipment pursuant to 10 CFR 50.59; 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 Emironmental Monitoring Program that would permit evaluation of the accuracy of the analysis at a later date; and 3.9.10 Records of reviews performed and changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.

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3.9.11 -- - Inspections of the decommissioned facility including the results of surveys of radioactivity levels and as found and as-leR conditions of the facility.

J 3.9.12 : Characterization study results.

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Attachment 6 Updated Safety Analysis Report, Revision 1 Title Page, Table of Contents Pages_1 - 7 and 1 a thru 1 z And Figures l- I thm 1 -~ lnstructions:

Replace the Title page and Table of Contents pages with the revised pages attachedc

' Remove page 1 -' 7 and insert the remainder of the revised USAR in its place (in front of -

. existing page 1 - 8.

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