NRC-91-0131, Application for Amend to License NPF-43,changing Tech Specs to Relocate Radiological Effluent Tech Specs to ODCM or Process Control Program,Per Generic Ltr 89-01

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Application for Amend to License NPF-43,changing Tech Specs to Relocate Radiological Effluent Tech Specs to ODCM or Process Control Program,Per Generic Ltr 89-01
ML20086G124
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 11/26/1991
From: Orser W
DETROIT EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086G127 List:
References
CON-NRC-91-0131, CON-NRC-91-131 GL-89-01, GL-89-1, NUDOCS 9112040207
Download: ML20086G124 (19)
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A November 26, 1991 NP.C-91-0131 U. S. Dur. lear Regulat ,,ry eminrion Atto: Document Cont'.o1 Desk Washingt e, , D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-34 t NRC hicense No. NPF-43
2) U1C Generic Letter 89-01 " Implementation of Progra c atic Controls for Radiological Effluent Teebnical Speciiications in the Adminintiative Controls: Section of the Technical Specifications and the Relocation of Procedutal Details of RETS to the Of fsite Dose Calculation knual or to the Proceris Control Program", datiel January 31, 1989 g 3) NUREG-1302, "Of f aite Dose Calculation Manual Guidance: Standard Radiological Cont mis f or Boiling

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Water Reactors Generic Letter 89 -01, Supplement No. 1",, datui April 1991

Subject:

Proposed Technical Specification Change (License '

Amend.nent) - Relocation of Radiological Ef fluent Technical Specificatio'. (Implementation of GENERIC 1.E1TER 89-01 Guidance)

Pursuant to 10CbMO.90. Detroit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes to the Technical Specifications (TS) .

In accordance with the guidance povided in Referenceo 2 and 3 this proposed amendment will (1) incorporate programmatic controls in the administrative controls section of the TS that satisfy the requirement a of -10CFR 20.106, 40 CFR Part 190.10CFR 50.36a and Appendix I to 10CFR Part 50; (2) transter the procedural details involving radioactive ef fluent monitoring instrumentation. liquid and gaseous of fluent controls, liquid and gaseous of fluent equ!pment requirements, radiological environmental monitoring, and radiological reporting details located in the current TS to ths Of'-ite Dr oe Calculation Manual (UDCM); (3) trancier the solid rdic 'ive wastes 9112040:w7 911126 D PDR P

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!:RC-91-0131 O reze 2 procedural details and the definition of solidification located in the current TS to the Process Control Program (PCP): (4) simplify the associated reporting requirements: t$) singlify the administrative controls for changes to the ODCM and PCP (6) add record retention requirements for changes to the (DCM and PCP: and (7) revise the definitions of the ODCM and PCP consistent with these changes.

The Radiological Ef fluent Technical Specifications ;RETS) procedural details that will be transferred to the ODCM have been changed to Radiologicel Effluent Controls and the 1.imiting Conditions for Operation have been converted to Controls as described in Reference 3.

- Several TS pages amended by this submittal are also changed by proposed TS amendments which are currently under review by the NRC. I Thev proposals and the ef fect6. of this submittal on the common pages are listed in Enclosure 4 of this, submittal .

During the preparation of this s.ubmittal two typographical errors were found in the existing TS. These errors are described in Enclosure 1 of this submit tal.~ They have been corrected as shown in Enclosure 3 of this submittal.

O oetrat Edisen has evateated the ,reresed TS aeainst the criteria ef

' 10CFR50.92 and has determined that no significant hazards consideration la involved. The proposed TS amendment has been reviewed by the Fermi 2 Onsite Review Organization (OSRO) and the Nuclear Safety Review Group (NSIG). Both OSR0 and NSIC concur with the enclosed determinations. In accordance with 10CFR50.91. Detroit Edison has provided a copy of thin letter to the State of Michigan.

Detroit Edison requests that this amendment be of fective 60 days citer

. NRC issuance to allow suf ficient time for ir.plementation of these changes.

Detroit Edison also squests that this amendment be approved no later than November 1. 1992 ; allow for implementation betore the January

1. 1993 10CFR20. reviait implementation date. Otherwise, some of the TS being relocated by th proposal will need to be revised for the
10/'FR20 change prior to rei aation. That ef fort would entail an inef ficient use of NRC and Do nit Edison resources as well as create the potential for confudon due 5 overlapping changes.

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USHRC Novembe r 26, 1991 NRC-91-0131

. 0; re3 If you have any questions, please contact Mr. David H. Brown at (313) 566-42'.3.  !

Sincetely, b

.losures Enclosure 1 - Evaluation of Proposed Change Enclosure 2 - Cross Reference Document of Dispositioned 'l Technical Specifications l Enclosure 3 - Proposed Technical Specifications Mark-Up

  • Enclosure 4 - Conmon TS Pages ,

Enclosure 5 - Technical Specification Chinge Pages Enclosure 6 - Draf t (DCM  !

cc - C. E. Ca rpent er, Jr.

A. B. Davis 3 R. W. DeFayette S. Stacek Supervisor, Electric Operatore, Michigan Public Service Ccamission - J. R. Padgett

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UENitC November 26, 1991 l

NPC-91-0131 t Page 4 l

1. WILLIAM S. ORSER, do hereby af f dtm that the foregolng statmento are based on f acts and circumstances which are true and accurate to the best of my knwledge and belief, l

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i. ILLI AM S. ORSER l Senior Vico President O

On this ckd' __dayof2ftYhty'hig, 1991, before me personally appeared William S. Orser being first duly sworn and says that be executed the foregoing as his f ree act and deed.

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_/ C<t{ h , -l/Krtfc Dotary Public PO#'t!E A ARMETTA P40 tory Pubile, Monrco County M' l

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O ENC 1,05URE 1 EVALUATION 1

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Enclosure 1 to NRC-91-0131 Page 1 0 INTit0 DUCTION The NitC steff has examined the contents of the Radiological Effluent Technical Specifications (RETS) in relat. ion to the Commission's Interim Policy Statement on Technical Specification Improvements. The staff has determined that programmatic controls can be implemented in the Administrative Controls section of the Technical Specifications (TS) to satisfy existing regulatory requirements for RETS. At the same time, the procedural details of the current, TS on radioactive oftluents and radiological environmental monitoring can be relocated to the Offsite Dose Calculation Manual (ODCH). Likewise, the procedural details of the current T5 on solid radioactive wastes can be relocated to the Process Control Program (PCP). The NRC issued Generic Letter 89-01 (Reference 2) and NUREG 1302 - Generic Letter 89-01, Supplement 1 (Reference 3) to provide guidance for preparation of this license amendment.

This proposed amendment request is consistent with the guidance provided in References 2 and 3 with one exception. Detroit, Edison is requesting a 60 day implementation period after approval of this amendment request to allow sufficient time to implement the amendment. Changes to the ODCM and PCP that, result from this TS amendment, will be incorporated during the 60 day implementation period in accordance with the proposed changes to the TS Administrative Controls in this submittal as opposed to the "immediato implementation upon amendment issuance" recommended by Reference 2. This issue is discussed in the evaluation belou.

EVALUATION-In order to document conir'ionce with the guidance provided in References 2 and 3, the spectric guidance is stated and followed by Detroit, Edison's response.

GENEHIC LFTTER 89-01:

The model specifications in Enclosure 3 to cenceic Letter 89-01 (Reference 2) should be incorporated into the TS to satisfy the requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50 36a, and Appendix I to 10 CFR Part 50. The definitions of the ODCH and PCP should be updated to reflect these changes. The programmatic and report.ing requirements are general in nature and do not, cantain-plant-specific details. Therefore, these changes to the Administrative Controls sect,lon of the TS are to replace corresponding requirements in plant TS that address these items. They should be O

.- . - - - _ . - _ _ _ - - - - - - - ~ . -- . _ _ - - . _ _ _ - _

Enclosure i to fHIC-91-0131 Page 2 O proposed for incorporation into the plant's TS without change in substance to replace existing requirements. If necessary, only changes in format should be proposed.

Dl;. Tit 0lT EDISON RIG 10NSE:

The model TS listed in Enclosure 3 or Generic Letter 89-01 have been incorporated into the proposed amendment with no changes in substance. Please review Cross Reference Document for Dispositioned Technical Specifications, Enclosure 2, for the disposition of each TS revised by this amendment. One additional change has been made to the aefinition section of TS. The definition for " Ventilation Cxhaust Treatment Systen" has been removed from TS and incorporated into the ODCH. The only reference to " Ventilation Exhaust Treatment System" is in TS 3/4.11.2.5, which is being delet.ed from TS and incorporated in the ODCH by this proposed amendment. Therefore, the definillon is not required in TS.

GENEltlC LETTER 89-01:

The requirements for explosive gas monitoring instrumentation should be retained if these requirements are part of the current gaseous effluent monitoring instrument.ation TS. Enclosure 4 to Generlo Letter 89-01 provides aodel specifications for retaining such requirements.

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DETitOIT EDISON ItESPONSE:

Proposed TS 3/4.3 7 12 has been revised using the guidance proviued in Enclosure 4 of Generic Letter 89-01. " Alarm / trip" has been cuanged to

" alarm" because there is no trip function associated with the explosive monitoring instrumentation. A descript,lon of the alarm is contained in UFSAR subsection 7.7.1.5 3 5.

GENEitIC LETTEH 89-01:

The procedural details covered in the licensee's current RETS, consisting of the limiting conditions for operation, their applicability, remedial actions, surveillance requirements, and the Bases section of the TS for these requirements, are to be relocated to the ODCH or PCP as appropriate and in a manner that ensures that. these details are incorporated in plant operating procedures.

DETHOIY EDISON RESPONSE:

The RETS procedural details and associated bases in the current. TSs are transfered to draft copies of the ODCH or PCP as indicated in Enclosure 2. TS that are refere..ced by RETS procedural details have

l Encir'sure 1 to j NRC-91-0131 <

Page 3 I O been included in the draft ODCH and PCP. Procedure changes shall be completed prior to implementation of this anendment.

GENERIC LINTER 89-01:

If licensees make other than editorial changes in the procedural details being transferred to the ODCM, each change should be identified by markings in the margin and the requirements of new Specification 6.14a.(1) and (2) followed.

DETit0IT E0lSON llES10NSE:

All changes to the details being transferred from the TS to the ODCM are editorial. These changes include numbering changes, identifying HETS as Radiological Effluent Controls, and identifying Limiting Conditions for Operation as Controls. These last two items follow the guidance in NUREG-1302 and are discussed below.

GENERIC LETTER 89-01:

Licensees should confirm in the amendment request that changes for relocating the procedural details of current RETS to either the ODCM or PCP have been prepared in accordance with the proposed changes to the Administrative Controls section of the TS so t. hat they may be implemented immediately upon issuance of the proposed amendment. A complete and legible copy of the revised ODCM should be forwarded with the amendment request for NRC use as a reference.

DETil0IT EDISON llESPONSE:

As stated above, DECO is request.ing a 60 day implementation period after issuance to allow sufficient time to implement these changes. A 60 day implementation period is acceptable because the RETS programmatic and procedural details will remain in TS throughout the implementatation period. The level of radiological control is not reduced during the implementation period because the programmatic and procedural det. alls are being transfered to other documents rather than being changed.

Procedural details of the current, RETS have been relocated in draft copies of the ODCM and PCP. The changes to the ODCM and PCP draft, copies that result from this license amendment have been reviewed as part, of the OSR0 and NSRG review of this TS amendment submittal. A complete and legible draft copy of the revised ODCH is contained in Enclosure 6.

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Enclosure 1 to NRC-91-0131 Page 4 O The need for changes to the current ODCH and PCP may arise between submittal and approval of this proposed anendment. These interim changes will be made in accordance with the existing TS. Upon approval of this amendment, the draft ODCH and PCP RETS procedural details will be incorporated into their respective programs during the 60 day implementation period in accordance with the proposed changes to the Administrative Controls section of the TS.

NUitEG 1302:

NU!!EG-1302 (Bercrence 3) provides guidance on identirying RETS as Radiological Effluent Controls and Limiting Conditions for Operation as Controls in the ODCH.

DETitOIT EDISON RESPONSE:

In accordance with the guidance in NUREG-1302, the RETS are identified as Radiological Effluent Controls and the Limiting Conditions for Operation are identified as Controls in the draft copy of the ODCH.

TECl!NICAL SPECIFICATION TYPOGRAPillCAL Erit 0ltS:

Two typographical errors were found during the preparation of this submittal that involve changes made to the TS by Amendment 30. As requested, the text title for section 6.2.1 should have read "Offsit

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and Onsite Review Organizations". The title currently reads in the singular: "Offsite and Onsite Review Organization". Additionally, this section title was never changed in the index. Both errors have been corrected as shown in Proposed Technical Specifications Mark-Up, Enclosure 3 JUSTIFICATION:

The proposed changes are justified based on the following:

1) The changes are administrative in nature and thus do not involve a physical modification to the plant and do not change any safety system or setpoint.
2) The administrative concept of relocating the RETS programmatic controls to the Administrative Controls section of the TS and'the procedural details to either the ODCH or PCP does not affect the i safety analysis present in the Fermi 2 Updated Final Safety Analysis Report (UFSAR).

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Enclosure 1 to NBC-91-0131 Page S

3) This amendment does not reduce the level of radiological control because the RETS programmatic controls and procedural details have been retained. Programmatic controls remain in the TS and procedural details have been transferred to the ODCM or PCP. The procedural details are not required to be included in TS per 10CFP50 36a. Modirications to the current TS, ODCM and PCP are consistent with the guidance provided in References 2 and 3
4) The proposed changes introduce no new mode of plant operation because RETS programmatic controls and procedural details have been retained. Programmatic controls remain in the TS and procedural details have been transferred to the ODCM or PCP. The ODCH and PCP are controlled and reviewed by the Onsite Review Organization (OSRO) and are available to the NRC for review.

SIGNIFICANT llAZAICS CONSIDEllATION; In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination. Detroli. Edison has established that operation in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the possibility of a new or different kind of accident from any accident

(} previously evaluated, or (3) involve a significant reduction in a margin of safety.

1) The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because the changes do not involve a physical modifination to the plant, a change to any safety system, or a change to any setpoint. The administrative concept of relocating RETS programmatic controls to the Administrative Centrols tection of the TS and the procedural details to the ODCM or PCP does not affect the safety analysis present in the Fermi 2 UFSAR. TS requirements ensure ODCH and the PCP changes are reviewed by OSRO. The requirement that all ODCM and PCP change reviews be retained for the duration of the plant operating 11eanse ensures that changes to the ODCH or PCP are available for inspection by the NRC.

This amendment does not reduce the level of radiological control because the RETS programmatic controls and procedural details have been retained. Programmatic controls remain in the TS and procedural details have been transferred to the ODCM or PCP. The l- procedural details are not required to be included in the TS per 1 o 1

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- -- _ =- ,_ - .. . .. - -. -- .- ._ . - . - - . .

Enclosure 1 to NHC-91-0131 Page 6 10CFR50 36a, Hodifications to the current TS, ODCH and PCP are consistent with the guidance provided in Hef'erences 2 and 3

2) The proposed changes do not, create the possibility of a new or different kind of accident from any accident previously evaluated because the changes are arhinistrative in nature and do no affect, the accident analysis, the c,peration, or the function of any safety-rnlated equipment. The proposed changes introduce no new mode of plant operation because the RETS programmat,1c controls remain in the TS and the procedural details are located in ODCM and PCP. The ODCH and PCP are reviewed by tne OSHO and the TS record retention requirements ensure that changes in the ODCH and PCP are available to the NRC for inspection.
3) The proposed changes do not involve a significant reduction in the margin of safety because the level of radfulogical control has not been reduced. The RETS programmat.ic controls remain in the TS and the procedurcl details are located in the ODCH and PCP. The proposed changes are purely administrative in nature.

They do not affect the accident analysis or t.he function and operation of any safety-related equipment. The proposed changes do not introduce a new mode of plant operation.

Based on the above, Detroit, Edison has determined that the proposed amendment does not involve a significant hazards consideration.

ENVIRONMINTAL IMPACT:

Detroit Edison has reviewed the proposed TS amendment, against the criteria of 10CFR51.22 for environmental considerations. The proposed amendment: (1) does not involve a significant, hazards consideration, (2) does not significantly change the types or significantly increase the amounts of effluents that may be released offsite, and (3) does not significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit, Edison has concluded that the proposed TS amendment does meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an environmental impact stat,ement.

CONCLUSION:

Based on the evaluation above: (1) there is reasonable assurance that, the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activit,les will be conducted in compliance with the Commission's regulat,lons and proposed amendments will not, be inimical ',o the common defense and security or to the health and safety of the public.

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O ENGASURE 2 CROSS REFERENCR DJCUMENT QF, I

D_ISPOSITIONED TEQlNICAL SPECIFICATIONS O)

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Enclosure 2 to trRC-91-0131  ;

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CRGSS REFERENCE DOCUMENT OF DISPOSITIONED TECHNICAL SPECIFICRTIONS j r

CURFETT TS/

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< FROPOSED TS TITLE DISPOSITICM i

DEFINITION 1.24/ Offsite Dose Calculation Pfanual This DEFINITION has been revised to be the samme

] CEFINITION 1.28 as the applicable model CEFINITION specified in i Enclosure 3 of Generic Letter 89-01 with the i r

i exception that the *Drvironmental Radiclogical  !

Monitoring Program

  • is called the " Radiological

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Environmental Monitoring Program

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I title of the prograre in the Administrative TS, f The revised CEFINITION addresses the increased I scope of the CDCM. The CDCM scope has been I

increased to incJude the procedural details for i radioactive effluents and radiological

  • environmental monitoring included 1.~. the current i 4

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DEFINITION 1.30/ Process Control Program This DEFINITION has be=en revised to be the set *e '

l DEFINITION 1.30 as the applicable model DEFINITION specified in  !

T J SURE 3 of Generic Letter 89-01. The *

! . revised CEFINITION eddresses the increased scope  !

l of the PCP. The PCP Scope has been increased to f include the procedural details for solid i i radioactive waste included in the current TS.

) i i DEFINITION 1.39/ Solidification This definition has been relocated to the PJ. ,

DELu w Section 4.

DEFINITION 1.46/ Ventilation Exhaust Treatment System This definition has been relocated to the ODCM.

DELETED Part 1. S Mtion 2. l I

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, Page 2 1'

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) . 3: . CURRENT TS/

l; PROPOSED TS . TITLE DISPOSITICN

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3/4.3.7.5/ Accident Monitoring' Instrumentation The reference for Standby Cas Treatment l

i 3/4.3.7.5 System low rar*ge noble gas monitors in Table

! 3.3.7.5-1 has been Changed from " Table 3.3.7.12-1 item 3.a* to *CF73ITE DOSE CAIEUI.ATION MANt;AL*. These annitors are deleted

, from Table 3.3.7.12-1 and relocated to the CDCM f Part 1. Section 3 as part of this submittal.

{. 3/4.3.7.11/ Radioactive Liquid Effluent- The r u e - atic controls have been relocated j DE'm Monitoring Instrumentation to proposed TS 6.8.5.e Item 1. The existing TS procedural details have been relocated to CDCM Part 1. Section 3.

j 3/4.3.7.12/ Radioactive Caseous Effluent The programmatic controls have been relocated 3/4.3.7.12 . Monitoring Instrumentation to proposed TS 6.8.5.e Item 1. In accordance with Ceneric Letter 89-01 the existing TS 1

5 requirements for explosive gas monitoring " *

,l , been retained. This TS has been sedifici. vt 4 accordance with the guidance provided in j Enclosure 4 of Generic Letter 89 01 with the exception that *alers/ trip

  • has baen changed to
  • alarm *. There is no trip function associated with the explosive monitoring instrumentatim.

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g The exist' -TS procedural details except those l related to explosive gas monitoring. have baen 1

relocated to CDOT Part 1. Section 3.

8 3/4.11.1.11 Liquid Effluents: Concentration The programatic controls have baan relocated DELETED to proposed TS 6.8.5.e Items 2 and 3. The existing TS procedural details have been relocated to CDCM Part t. Section 3.

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3/4.11.1.2/ ' Radioactive Effluents: .Dese The pr%&--atic controls have been relocated to DELETED proposed TS 6.8.5.e Items 4 and 5. The existing [

TS procedural details have been relocated to

ODJT Part 1. Section 3. [

i 3/4.11.1.3/ Radioactive Effluents: , Liquid .The pr %. tic controls have been relocated to DELETED Weste Treatment proposed TS 6.8.5.e item 6. The existing TS t procedural details have been relocated to CDCM . f l

} Part 1. Section 3. I j 4 3/4.11.1.4/ Radioactive Effluentsi Liquid This TS has been retained in acce dance with NO CHANGE Holdup Tanks Generic Letter 89 01.

i 3/4.11.2.1/ Caseous Effluents: Dose Rate The pi% etic controle have been relocated to i t

DELETED proposed TS 6.8.5.e Items 3 and 7. The existing  ;

TS procedural details have been relocated to

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i CDCM Part 1. Section 3.

l 3/4.11.2.2/ Caseous Effluents: Dose . The piw _ctic centrols beve been relocated to I j  ;

i DELETED Noble Cases preposed TS 6.8.5.e Items 5 and 8. The existing TS procedural details have been relocated to -

j- CDCM Part 1. Section 3.

f 3/4.11.2.3/ Radioactive Effluents: Dose . The programatic controls have been reloc*g to l DELETED Iodine-131. Iodine-133. proposed TS 6.8.5.e. Item 5 and 9. The =xisting Tritium, and Radionuclides TS procedural details have been relocated to g

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in Particulate Form ODCM Part 1. Section 3. [

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3/4.11.2.4/ Radioactive Effluents: Off-Gas The pivvi___; tic controls have been relocated to l f DELETED Treatment System proposed TS 6.8.5.e Item 6. The existing TS i k

procedural details have been relocated to ODCM [

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- I . a x a . a o e r a a a a o a a T . R E R C R C P o R R R RM R L o .

t 2 1 / S . / / / /

3 S T 5 6 7 7 8 e 1 T E / / / /

r 0 D . 2 2 G 2 2 2 3 4 1 2 u - T. E . N D D D D Ol S . 1 w 1 A 1 1 1 E w 1 E 2 E 2 E s 1 4  ? 1 o9 E C . 1 1 1 H 1 1 1 T 1 a 1 T 1 T 1 T e 2 C E E E T CP .. 4. L t.

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i

L Enclosure 2 to "NRC-91-G131 Page 5 I

, ' CURRENT TS/.

'PRCPOSED TL. TITLE DISPOSITICN

{ . . . . . . . . . . . _ - --- - -_

_- ., j 3/4.12.3/ Radiological Environmental Monitoring: The pi , - atic controls have been relocated to

l. Dt". M Interlaboratory Comparison Program proposed TS 6.8.5.f Item 3. The existing TS j procedural details have been relocated to G M Part 1. Section 3.
s. j 5.1.3/ Site Boundaries This TS has been retained in accordance with

, NO CHANGE Generic Letter 89-01.

t j

[

! 6.8.5/ Procedures and Progrees: Radioactive This TS has been revised to be the same as the i f 6.8.5 (added Item el Effluent controls Program appliemble model TS specified in Paciosure 3 of Ceneric Letter 89-01 with exception that the

{_

I reactor building ventilation system is included j in item e.10 to acccmodate Mark I containment

8. limitations on venting and purging. The

.' proposed TS has been revised to include the pre w. tic controls of the TS that have been relocated in the CDCM.

4 6.8.5/ Radiological Envirennental Monitoring This TS has been revised to be the same as the

j. 6.3.5 (added Item f) Program applicable model TS specified in Enclosure 3 of t Generic Letter 89-01. The proposed TS has been revised to include the pro vi tic controls of the existing TS that have been ruocated in the j

l s

i [

I 6.9.1.7/ Reporting Requirements: Annual This TS has been revised to be th* same as the [

j~ 6.9.1.7 . Radiological Environmental Operating applicable sedel TS specified in Enclosure 3 i Report of Generic Letter 89-01. The existing reporting g requirements have been included in OCCM Part 1.

f Section 5.

.l f t i 5

b i  !

5 i

1- ,

j' I t

.- - - - . . . . _ . _ r

O i

O O Enclosura 2 to

!!PC-91 0131 Page.6 CL7. RENT 3/ U1S"0SITION PROPCSED TS TITLE . - -

Reporting Requirtwents Semiannual This TS has been revised to be the same as the 6.0.1.8/

Radiosctise Effluent Release Report applicable codel TS specified in E wlosure 3 of 6.9.145 Generic Letter 69-01. The existing reporting reqsirements have been included in CDCPt Part 1.

Section 5 and PCF, Sections 1 and 6.

Record Retention This TS has been revised to be the saw as the 6.10.3/

applicable M el TS in Enclosure 3 of Generic 6.10.3 tadded Item n)

Latter 89-01.

Procest Control Program (PCP) This TS has been revised to be the saw as the 6.13.2/

applicable M el TS specified in Enclosure 3 cf 6.13.2 Generic tetter 89-01.

Cffsite Dese Calculation Manual This TS has been revisad to be the same as the 6.14.2/

spplicable TS specified in Enclosure 3 of 6.14.2 (CDCM)

Generic letter 89-01.

Ptajor Chang *s To Radioactive Liquid.

The existing TS procedural details have t*en 6.15/

Caseous, and Solid Radweste Systems relocated to CDCM Part 1. Section 5 and PCP.

CELETED Section 6.

The existing Technical Specification Bases section of the relocated TS have been ir .porated into the applicable CDCM cr PCF.  !

See attached revised draft CDCM.

. .

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