GO2-25-011, License Amendment Request for Change to Tehnical Specification TSTF-65-A, Revision 1, Use of Generic Titles for Utility Positions
| ML25058A497 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/27/2025 |
| From: | David Brown Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-25-011 | |
| Download: ML25058A497 (1) | |
Text
David P. Brown Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509.377.8385 l F. 509.377.4150 dpbrown@energy-northwest.com GO2-25-011 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST FOR CHANGE TO TECHNICAL SPECIFICATION TSTF-65-A, REVISION 1, USE OF GENERIC TITLES FOR UTILITY POSITIONS
Dear Sir or Madam:
Pursuant to 10 CFR 50.90, Energy Northwest hereby is submitting a request for an amendment to revise the Columbia Generating Station (Columbia) Technical Specifications (TS).
The proposed amendment adopts NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-65-A, Revision 1. The proposed change will allow the use of generic personnel titles instead of plant-specific titles. Additionally, an enhancement is proposed to replace the term "plant-specific titles" with "generic titles" in TS Section 5.0 Administrative Controls and to use appropriately de-capitalized titles for positions, ensuring consistency with the Columbia TS listed sections. None of the proposed changes result in changes to technical requirements.
The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards considerations. The bases for these determinations are included in of this submittal. The proposed TS markup pages are included as and clean pages of the proposed TS changes are included as Enclosure 3 of this submittal.
This letter and its enclosures contain no regulatory commitments.
Approval of the proposed amendment is requested within one year of the date of the submittal. Once approved, the amendment shall be implemented within 60 days.
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February 27, 2025 ENERGY NORTHWEST
GO2-25-011 Page 2 of 2 If there are any questions or if additional information is needed, please contact Mr. R. M. Garcia, Licensing Supervisor, at 509-377-8463.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this ______ day of ___________, 2025.
Respectfully, David P. Brown Site Vice President
Enclosures:
- 1. Evaluation of Proposed Technical Specification Change
- 2. Proposed Columbia Technical Specification Changes (Mark-Up)
- 3. Proposed Columbia Technical Specification Changes (Re-Typed) cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector CD Sonoda - BPA EFSEC@efsec.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH
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GO2-25-011 Page 1 of 6 Evaluation of Proposed Technical Specification Change 1.0
SUMMARY
DESCRIPTION This evaluation supports a License Amendment Request (LAR) to the Columbia Generating Station (Columbia) Technical Specifications (TS). The proposed changes are administrative and editorial and will not result in any changes to operating requirements. This amendment adopts NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-65-A, Revision 1, and proposes several administrative and editorial changes to the TS. These include the insertion of generic personnel titles in place of plant-specific titles by replacing "plant-specific titles" with "generic titles" and the use of appropriate de-capitalized titles for positions in section 5.0 of the TS. Neither the administrative nor editorial changes will result in changes to technical or operating requirements.
The specific sections of the TS affected by the change are listed below:
Section 5.1 Responsibility Section 5.2 Organization Section 5.3 Unit Staff Qualifications Section 5.5 Programs and Manuals.
Implementation of this LAR will result in no physical modification to the plant. This proposed change has no adverse effect on the plant or plant safety.
2.0 DETAILED DESCRIPTION 2.1 Current Technical Specifications Requirements Energy Northwest proposes changes to the TS to adopt NRC-approved TSTF-65-A, Revision 1 by replacing the plant-specific personnel titles with generic personnel titles as provided by DSSOLFDEOH$16,VWDQGDUG and using appropriate de-capitalized titles for positions. These organizational title changes are incorporated into this LAR and do not eliminate any of the qualifications, responsibilities, or requirement for these positions.
Energy Northwest is addressing the reasoning and descriptions for the proposed changes below.
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GO2-25-011 Page 2 of 6 2.2 Reason and Description for the Proposed Changes The use of generic titles in the TS Section 5.0 in lieu of plant-specific titles was approved by the NRC by TSTF-65-A. The proposed title changes do not have any safety implications as the responsibilities and requirements of the position are unchanged. As a result, this proposed title change is administrative in nature.
The use of de-capitalized titles for positions aligns with a more standardized and consistent approach as recommended by TSTF-65-A, Revision 1. This change ensures uniformity across documents and helps in avoiding inconsistencies that might arise from varying capitalizations. Additionally, it reflects modern editorial practices that prefer a simpler style for titles and positions, enhancing readability and clarity. It also ensures that the technical specifications are more accessible and easier to maintain.
3.0 TECHNICAL EVALUATION
The proposed changes to Columbias TS are administrative and editorial. These proposed changes do not impact plant safety systems or impact any design basis accident. In addition, these changes do not involve any changes to plant equipment or any changes to the methods of plant operation or plant maintenance. The changes will not result in changes to the assigned responsibility, the organization reporting relationships, or impact the updated Final Safety Analysis Report (FSAR) accident analysis.
3.1 Impact on Submittals under Review by NRC The NRC is presently reviewing Energy Northwests LARs.
x LAR to Revise Columbia Emergency Plan submitted under 0/$.
x LAR to Adopt TSTF-592, Revise ADS Instrumentation Requirements submitted
under 0/$ is revising TS 3.3.5.1 Emergency Core Cooling System (ECCS)Instrumentation to reflect the plant design and the safety signification of
inoperableADS monitoring channels.
The LARs presently under NRC review do not impact TS Section 5.
3.2 Correction to Affected Sections This change only affects job titles and does not change reporting structure.
The corrections in title names are detailed below.
- 1. TS page 5.1-1
- a. 5.1.1 Plant General Manager updated to plant manager.
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GO2-25-011 Page 3 of 6
- 2. TS page 5.2-1
- a. 5.2.1 (a) Modified discussion to conform with use of generic title
- b. 5.2.1 (b) Plant General Manager updated to plant manager
- c. 5.2.1 (c) The Chief Executive Officer updated to A specified corporate officer
- d. 5.2.2 (a) Equipment Operators replaced with non licensed operators
- 3. TS page 5.2-2
- a. 5.2.2 (e) Operations Director or Assistant Operations Manager updated to operations director or assistant operations manager
- 4. TS page 5.3-1
- a. 5.3.1 (a) Operations Director updated to operations director
- b. 5.3.1 (b) Radiation Protection Manager updated to radiation protection manager
- 5. TS page 5.5-1
- a. 5.5.1 (c)(2) Plant General Manager updated to plant manager
4.0 REGULATORY EVALUATION
The Columbia FSAR Chapter 13 provides detailed information about Columbias organization structure including responsibilities, qualifications, reporting lines, training, and procedures in compliance with the applicable regulatory requirements and guidance.
The proposed TS amendment is administrative and editorial and:
x Does not result in any change in the qualifications of any component.
x Does not result in the reclassification of any components status in the areas of shared, safety-related, independent, redundant, and physically or electrically separated.
x Does not result in any change in Columbias organization structure including responsibilities, qualifications, reporting lines, training, and procedures.
4.1 Applicable Regulatory Requirements The proposed changes to the Columbia TS are either administrative or editorial and do not affect any regulatory requirements or guidance. These changes adopt NRC approved TSTF-65-A, Revision 1 and do not affect how plant equipment is operated or maintained and there are no changes to the physical plant or analytical methods.
Therefore, there are no impacts on the FSAR accident analysis.
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GO2-25-011 Page 4 of 6 5.0 PRECEDENT Southern Nuclear Company (SNC) submitted a similar request for an amendment to the Technical Specifications (TS) for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2, and Vogtle Electric Generating Plant (VEGP), Units 1 and 2, adopting NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-65-A, Revision 1 (ML16291A030). The changes implemented by these nuclear plants are analogous to those proposed in this amendment request.
However, minor differences based on the structure of Columbia Generating Station do not impact the technical evaluation.
6.0 NO SIGNIFICANT HAZARDS CONSIDERATION Energy Northwest has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below.
- 1)
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The impacts of these administrative changes do not affect how plant equipment is operated or maintained. The proposed changes do not impact the intent or substance of the TS. There are no changes to the physical plant or analytical methods.
The proposed amendment involves administrative and editorial changes only. The proposed amendment does not impact any accident initiators, analyzed events, or assumed mitigation of accident or transient events. The proposed changes do not involve the addition or removal of any equipment or any design changes to the facility. The proposed changes do not affect any plant operations, design functions, or analyses that verify the capability of structures, systems, and components (SSC) to perform a design function. The proposed changes do not change any of the accidents previously evaluated in the updated FSAR. The proposed changes do not affect SSCs, operating procedures, or administrative controls that have the function of preventing or mitigating any of these accidents.
Therefore, there is no significant increase in the probability or consequences of an accident previously evaluated.
- 2)
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?
Response: No.
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GO2-25-011 Page 5 of 6 The proposed amendment only involves administrative and editorial changes. No actual plant equipment or accident analyses will be affected by the proposed changes. The proposed changes will not change the design function or operation of any SSCs. The proposed changes will not result in any new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases. The proposed amendment does not impact any accident initiators, analyzed events, or assumed mitigation of accident or transient events.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3)
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed amendment only involves administrative and editorial changes. The proposed changes do not involve any physical changes to the plant or alter the way plant systems are operated, maintained, modified, tested, or inspected. The proposed changes do not alter the way safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not affected by these changes. The proposed changes will not result in plant operation in a configuration outside the design basis. The proposed changes do not adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition.
Therefore, the proposed change does not involve a significant reduction in the margin of safety.
Based on the above, Energy Northwest concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
7.0 CONCLUSION
S Based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the applicable regulations as identified herein, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
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GO2-25-011 Page 6 of 6
8.0 ENVIRONMENTAL CONSIDERATION
Energy Northwest has determined that the proposed amendment would not change requirements with respect to installation or use of a facility component located within Columbia's restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. Energy Northwest has evaluated the proposed change and has determined that the change does not involve, (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
9.0 REFERENCES
- 1. TSTF-65-A, Rev. 1, Technical Specification Task Force Improved Standard Technical Specifications Change Traveler.
- 2. TSTF-65 Adoption by Vogtle, Hatch, and Farley dated January 2017(ML16291A030).
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GO2-25-011 Proposed Columbia Technical Specification Changes (Mark-Up)
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Responsibility 5.1 Columbia Generating Station 5.1-1 Amendment 149,169 225 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 5.1.2 The Plant General Manager plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.
The Plant General Manager plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, and modification to systems or equipment that affect nuclear safety.
The Shift Manager (SM) shall be responsible for the control room command function. During any absence of the SM from the control room while the unit is in MODE 1, 2, or 3, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function.
During any absence of the SM from the control room while the unit is in MODE 4 or 5, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.
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Organization 5.2 Columbia Generating Station 5.2-1 Amendment 149,169 225 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.
D
Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirementsofthose personnel fulfilling the responsibilities of the positions delineated inthese Technical Specifications shall be documented in the FSAR.
E
The Plant General Manager plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
F
The Chief Executive Officer A specified corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
G
The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.
5.2.2 Unit Staff The unit staff organization shall include the following:
a.
At least two Equipment Operators non licensed operators shall be assigned when the unit is in MODES 1, 2, or 3; and at least one Equipment Operator non licensed operator shall be assigned when the unit is in MODE 4 or 5.
b.
Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
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Organization 5.2 Columbia Generation Station 5.2-2 Amendment 182,213 225 273 5.2 Organization 5.2.2 Unit Staff (continued) c.
An individual qualified to implement radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
d.
Deleted.
e.
The Operations Director or Assistant Operations Manager operations director or assistant operations manager shall hold an SRO license.
f.
An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.
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Unit Staff Qualifications 5.3 Columbia Generation Station 5.3-1 Amendment 169,182 225 273 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS N18.1-1971, for comparable positions described in the FSAR, except for:
a.
The Operations Director operations director, who shall meet the requirements of ANSI/ANS N18.1-1971 with the exception that in lieu of meeting the stated ANSI/ANS requirement to hold a Senior Reactor Operator (SRO) license at the time of appointment to the position, the Operations Director operations director shall:
1.
Hold an SRO license at the time of appointment; 2.
Have held an SRO license; or 3.
Have been certified for equivalent SRO knowledge; and b.
The Radiation Protection Manager radiation protection manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1-R, May 1977.
5.3.2 For the purpose of 10 CFR 55.4, a licensed SRO and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).
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Programs and Manuals 5.5 Columbia Generating Station 5.5-1 Amendment 270 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.
5.5.1 Offsite Dose Calculation Manual (ODCM) a.
The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and b.
The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release reports required by Specification 5.6.1 and Specification 5.6.2.
c.
Licensee initiated changes to the ODCM:
1.
Shall be documented and records of reviews performed shall be retained. This documentation shall contain:
(a)
Sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s),
and (b)
A determination that the change(s) maintain the levels of radioactive effluent control required pursuant to 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations; 2.
Shall become effective after review and acceptance by the Plant Operations Committee and the approval of the Plant Manager plant manager; and 3.
Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of, or concurrent with, the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.
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GO2-25-011 Proposed Columbia Technical Specification Changes (Re-Typed)
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Responsibility 5.1 Columbia Generating Station 5.1-1 Amendment 149,169, 225 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The plant manager shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his absence.
The plant manager or his designee shall approve, prior to implementation, each proposed test, experiment, and modification to systems or equipment that affect nuclear safety.
5.1.2 The Shift Manager (SM) shall be responsible for the control room command function. During any absence of the SM from the control room while the unit is in MODE 1, 2, or 3, an individual with an active Senior Reactor Operator (SRO) license shall be designated to assume the control room command function.
During any absence of the SM from the control room while the unit is in MODE 4 or 5, an individual with an active SRO license or Reactor Operator license shall be designated to assume the control room command function.
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Organization 5.2 Columbia Generating Station 5.2-1 Amendment 149,169 225 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the nuclear power plant.
D
Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and all operating organization positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements ofthose personnel fulfilling the responsibilities of the positions delineated inthese Technical Specifications shall be documented in the FSAR.
E
The plant manager shall be responsible for overall safe operation of the plant and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
F
A specified corporate officer shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
G
The individuals who train the operating staff, carry out health physics, or perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures.
5.2.2 Unit Staff The unit staff organization shall include the following:
a.
At least two non-licensed operators shall be assigned when the unit is in MODES 1, 2, or 3; and at least one non-licensed operator shall be assigned when the unit is in MODE 4 or 5.
b.
Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 5.2.2.a and 5.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
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Organization 5.2 Columbia Generation Station 5.2-2 Amendment 182,213 225 273 5.2 Organization 5.2.2 Unit Staff (continued) c.
An individual qualified to implement radiation protection procedures shall be on site when fuel is in the reactor. The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
d.
Deleted.
e.
The operations director or assistant operations manager shall hold an SRO license.
f.
An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.
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Unit Staff Qualifications 5.3 Columbia Generation Station 5.3-1 Amendment 169,182 225 273 5.0 ADMINISTRATIVE CONTROLS 5.3 Unit Staff Qualifications 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS N18.1-1971, for comparable positions described in the FSAR, except for:
a.
The operations director, who shall meet the requirements of ANSI/ANS N18.1-1971 with the exception that in lieu of meeting the stated ANSI/ANS requirement to hold a Senior Reactor Operator (SRO) license at the time of appointment to the position, the operation director shall:
1.
Hold an SRO license at the time of appointment; 2.
Have held an SRO license; or 3.
Have been certified for equivalent SRO knowledge; and b.
The radiation protection manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1-R, May 1977.
5.3.2 For the purpose of 10 CFR 55.4, a licensed SRO and a licensed Reactor Operator (RO) are those individuals who, in addition to meeting the requirements of Specification 5.3.1, perform the functions described in 10 CFR 50.54(m).
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Programs and Manuals 5.5 Columbia Generating Station 5.5-1 Amendment 270 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals The following programs shall be established, implemented, and maintained.
5.5.1 Offsite Dose Calculation Manual (ODCM) a.
The ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program; and b.
The ODCM shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating and Radioactive Effluent Release reports required by Specification 5.6.1 and Specification 5.6.2.
c.
Licensee initiated changes to the ODCM:
1.
Shall be documented and records of reviews performed shall be retained. This documentation shall contain:
(a)
Sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s),
and (b)
A determination that the change(s) maintain the levels of radioactive effluent control required pursuant to 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and do not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations; 2.
Shall become effective after review and acceptance by the Plant Operations Committee and the approval of the plant manager; and 3.
Shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of, or concurrent with, the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed, and shall indicate the date (i.e., month and year) the change was implemented.
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