View source for BVY 14-083, Technical Specifications Proposed Change No. 307, Revision to Technical Specification Administrative Controls for Permanently Defueled Condition - Supplement 3

{{Adams
| number = ML14342B003
| issue date = 12/05/2014
| title = Technical Specifications Proposed Change No. 307, Revision to Technical Specification Administrative Controls for Permanently Defueled Condition - Supplement 3
| author name = Wamser C
| author affiliation = Entergy Nuclear Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000271
| license number = DPR-028
| contact person = 
| case reference number = BVY 14-083, TAC MF2991
| document type = Letter type:BVY, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specifications
| page count = 19
| project = TAC:MF2991
| stage = Supplement
}}

=Text=
{{#Wiki_filter:Entergy Nuclear Operations, Inc.
Vermont Yankee 320 Governor Hunt Rd Vernon, VT 05354 SEntergy                                                           Tel 802 257 7711 Christopher J. Wamser Site Vice President BVY 14-083 December 5, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

==SUBJECT:==
Technical Specifications Proposed Change No. 307, Revision to Technical Specification Administrative Controls for Permanently Defueled Condition -
Supplement 3 (TAC No. MF2991)
Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

==REFERENCES:==
: 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Technical Specifications Proposed Change No. 307, Revision to Mitigation Strategy License Condition and Technical Specification Administrative Controls for Permanently Defueled Condition," BVY 13-096, dated October 31, 2013 (ML13316A004)
: 2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Technical Specifications Proposed Change No. 307, Revision to Mitigation Strategy License Condition and Technical Specification Administrative Controls for Permanently Defueled Condition -
Supplement 1 (TAC No. MF2991)," BVY 14-028, dated April 24, 2014 (ML14119A099)
: 3. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Technical Specifications Proposed Change No. 307, Revision to Mitigation Strategy License Condition and Technical Specification Administrative Controls for Permanently Defueled Condition -
Supplement 2 (TAC No. MF2991)," BVY 14-052, dated July 16, 2014 (ML142024A206)

==Dear Sir or Madam:==

By letter dated October 31, 2013 (Reference 1), Entergy Nuclear Operations, Inc. (ENO) proposed an amendment to Renewed Facility Operating License (OL) DPR-28 for Vermont Yankee Nuclear Power Station (VY). This amendment request proposed changes to the staffing, training and programmatic requirements contained in Section 6.0, Administrative Controls, of the VY Technical Specifications (TS) to support the transition of the VY facility to a permanently defueled condition.

BVY 14-083 /page 2of 3 Based on teleconference held with NRC staff on December 4, 2014, ENO has identified additional changes to Section 6.0 of the TS that are needed to reflect the transition of VY from an operating unit to a decommissioning facility. to this letter provides a detailed description and evaluation of the proposed changes. contains a markup of the TS pages that builds on the markups provided in References 1, 2 and 3. Attachment 3 contains the retyped TS pages incorporating the changes proposed in this supplement and those in Reference 1.
The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this supplement.
There are no new regulatory commitments made in this letter.
If you have any questions on this transmittal, please contact Mr. Philip Couture at 802-451-3193.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on December 5, 2014.
Sincerely, CJW/plc Attachments:     1. Description and Evaluation of Proposed Changes
: 2. Markup of Technical Specification Pages
: 3. Retyped Technical Specification Pages cc:     Mr. Daniel H. Dorman Region 1 Administrator U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector

BVY 14-083 / page 3 of 3 cc list continued:
Mr. Christopher Recchia, Commissioner VT Department of Public Service 112 State Street, Drawer 20 Montpelier, VT 05620-2601

BVY 14-083 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Proposed Change 307 - Supplement 3 Description and Evaluation of Proposed Changes

BVY 14-083 / Attachment 1 / Page 1 of 1
: 1.       

==SUMMARY==
DESCRIPTION In Reference 1, Entergy Nuclear Operations, Inc. (ENO) provided notification of the intention to permanently cease power operations of Vermont Yankee Nuclear Power Station (VY) in accordance with 10 CFR 50.82(a)(1)(i) at the end of the current operating cycle.
In Reference 2, ENO submitted proposed changes that would revise and remove certain requirements contained within Section 6.0, Administrative Controls, of the VY Technical Specifications (TS) consistent with the planned transition to a permanently defueled facility.
Additional changes to Section 6.0 of the TS have been identified that are needed to reflect the transition of VY from an operating unit to a decommissioning facility.
: 2.       DETAILED DESCRIPTION AND BASIS FOR THE CHANGES The following table identifies each section that is being changed, the proposed changes, and the basis for the changes:
Proposed Changes to VY Technical Specification Section 6.0, Administrative Controls Affected Sections         Proposed Changes                                   Basis 6.1.A, 6.2.A,           Replace the term          The change from "unit" to "facility" and "unit 6.2.A.2, 6.2.B,         "unit" with "facility"    operation" to "facility staff' is administrative and 6.2.C, 6.2.C.1,         throughout.               reflects that VY will be permanently shutdown and 6.6.D, 6.6.E,                                     defueled and are appropriate for activities 6.7.D.d, 6.7.D.h,       For 6.2.A only -          associated with a decommissioning reactor. Overall 6.7.D.i                 replace "unit             management and staff responsibilities and the operation" with "facility description of the plant are unchanged. These staff'                    changes are consistent with those recently approved for Crystal River Unit 3 (Reference 3) and San Onofre Nuclear Generating Station, Units 2 and 3 (Reference 4).
References
: 1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)
: 2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Technical Specifications Proposed Change No. 307, Revision to Mitigation Strategy License Condition and Technical Specification Administrative Controls for Permanently Defueled Condition," BVY 13-096, dated October 31, 2013 (ML13316A004) (TAC No. MF2991)
: 3. Letter, USNRC to Crystal River Nuclear Plant, "Crystal River Unit 3- Issuance of Amendment to the Facility Operating License Regarding Changes to the Administrative Controls Section of the Technical Specifications (TAC No. MF1 504) (ML14097A145)
: 4. Letter, USNRC to San Onofre Nuclear Generating Station, "San Onofre Nuclear Generating Station, Units 2 and 3 - Issuance of Amendments Regarding Changes to the Administrative Controls Section of the Technical Specifications (TAC Nos. MF2954 and MF2955)
(ML14183B240)

BVY 14-083 Docket 50-271 Attachment 2 Vermont Yankee Nuclear Power Station Proposed Change 307 - Supplement 3 Markup of Technical Specification Pages

VYNPS 6.0   ADMINISTRATIVE CONTROLS 6.1   RESPONSIBILITY A. The plant manager shall be responsible for overall u                 operation and shall delegate in writing the succession to this responsibility during absences.
B. The plant manager or designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety.
C. The shift supervisor shall be responsible for the shift command function.
6.2   ORGANIZATION A. Onsite and Offsite       Organizations                facility staff Organizations shall be. established for unit operation and corporate management.       These organizations shall include the positions for activities affecting safety of the nuclear fuel.
: 1. Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organizational positions.         These relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.        These requirements shall be documented in the Quality Assurance Program Manual.         The plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the Technical Requirements Manual._--fclt
: 2. The plant manager shall be responsible for overall ;4. safe operation and shall have control over those on-site activities necessary for safe storage and maintenance of the nuclear fuel.
: 3. 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 safe management of nuclear fuel.
Amendment No.   ", --&,  4-24,  4-74,  2-14, 2-2-2                                          255

VYNPS 6.2   ORGANIZATION           (Cont'd)
: 4.           The individuals who train the Certified Fuel Handlers, carry out health physics, or perform quality assurance functions may report to the appropriate on-site manager; however, these Facility        individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.
B.                Staff         facility The        ;      staff organization shall include the following:
: 1.           Each duty shift shall be composed of at least one shift supervisor and one Non-certified Operator.              The Non-certified Operator position may be filled by a Certified Fuel Handler.
: 2. At least one person qualified to stand watch in the control room (Non-certified Operator or Certified Fuel Handler) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.
: 3. All fuel handling operations shall be directly supervised by a Certified Fuel Handler.
: 4.           Shift crew composition shall meet the requirements stipulated herein.      Shift crew composition may be less than the minimum requirement of Specification 6.2.B.1 for a period of time not to exceed 2 hours 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 and all of the following conditions are met:
: a. no fuel movements are in progress;        and
: b. no movement of loads over fuel are in         progress; and
: c. no unmanned shift positions during shift turnover shall be permitted while the shift crew is less than the minimum.
: 5.           An individual qualified in radiation protection procedures shall be present on-site during the movement of fuel and during the movement of loads over fuel.
: 6.           Deleted
: 7.           The shift supervisor shall be a Certified Fuel Handler.
: 8.           Deleted Amendment No.    &3,*,-         *-4, 9-4,   -0, 40, 4-34-, 4-68, 4-74-, ,,  -44 ,                 256 2-5-3

VYNPS 6.2   ORGANIZATION        (Cont'       Facility C.              Staff Qualifications nii4-t.                                        a
: 1.        Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Quality Assurance Program Manual (QAPM).
: 2.        An NRC approved training and retraining program for Certified Fuel Handlers shall be maintained.
I 6.3   Deleted 6.4   PROCEDURES Written procedures shall be established,                implemented,  and maintained covering the following activities:
A. Normal startup, operation and shutdown of systems and components needed for the safe storage of nuclear fuel.
B. Fuel handling operations.
C. Actions to be taken to correct specific and foreseen potential malfunctions of systems or components needed for the safe storage of nuclear fuel.
D. Emergency conditions involving potential or actual release of radioactivity.
E. Preventive and corrective maintenance operations which could have an effect on the safety of the nuclear fuel.
F. Surveillance and testing requirements.
G. Fire protection program implementation.
H. Process Control Program in-plant implementation.
I. Off-Site Dose Calculation Manual implementation.
6.5   HIGH RADIATION AREA As provided in paragraph 20.1601(c) of 10 CFR 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraphs 20.1601(a) and 20.1601(b) of 10 CFR 20:
A. High Radiation Areas with dose rates greater than 0.1 rem/hour at 30 centimeters, but not exceeding 1.0 rem/hour at 30 centimeters from the radiation source or from any surface penetrated by the radiation:
Amendment No. 3-6,  4-,   4-3, -83, 4-5 4, 4-6-,---7-, 2-104, 2--4, 2  5-3           257

VYNPS Report /
D. Radioactie Effluent Release The Rad active Effluent Release Rep rt covering the operation of the 4       shall be submitted by May p5 of each year and in accordance with 10 CFR 50.36a.              Th report shall include a summary of the quantities of radioactive               quid and gaseous effluents and solid waste released from the                     The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM) and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section Iv.E.1.
a     a       A    cfanci                       ityi E. Annual Radiological Environmtal Operating Report The Annual Radiological >vironmental Operating Report covering the operation of the n             during the previous calendar year shall be submitted by May 15 of each year.                 The report shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period.          The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM),        and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.
The Annual Radiological Environmental Operating Report shall include summarized and tabulated results of all radiological environmental samples taken during the report period pursuant to the table and figures in the ODCM.              In the event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results.      The missing data shall be submitted as soon as possible in a supplementary report.
6.7   PROGRAMS AND MANUALS The following programs shall be established,                 implemented and maintained:
A. Deleted Amendment No.  &-    , 4-1-4, 4-2-6, 444, 4-5-,  4-47, 4-64,    4-7-16                 263

VYNPS D. Radioactive Effluent Controls Program This program conforming to 10 CFR 50.36a provides for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable.         The program shall be contained in the ODCM, shall be implemented by operating procedures, and shall include remedial actions to be taken whenever the program limits are exceeded.            The program shall include the following elements:
: a.       Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM;
: b.       Limitations on the concentrations       of radioactive material released in liquid effluents from       the site to unrestricted areas, conforming to 10 times the       concentration values in Appendix B, Table 2, Column 2, to       10 CFR 20.1001 - 20.2402;
: c.      Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents pursuant to 10 CFR 20.1302 and with the methodology and parameters in the ODCM;
: d.       Limitations on the annual and quarterly doses or dos commitment to a member of the public from radioact e materials in liquid effluents released from the ".a        to unrestricted areas, conforming to 10 CFR 50, Appendix I;
: e.       Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days;
: f.      Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would exceed 2 percent of the guidelines for the annual dose or dose commitment, conforming to 10 CFR 50,      Appendix I;
: g.      Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at or beyond the site boundary shall be limited to the following:
: 1. For noble gases:    less than or equal to a dose rate of 500 mrems/yr to the total body and less than or equal to a dose rate of 3000 mrems/yr to the skin, and
: 2. For iodine-131, iodine-133, tritium, and for all radionuclides in particulate form with half lives greater than 8 days:   less than or equal to a dose rate of 1500 mrems/yr to any organ; Amendment No. 4-7-4,    2-24, 2-2-2                                                   266

VYNPS
: h.      Limitations on the annual and quarterly air doses resulti&#xfd; from noble gases released in gaseous effluents from the unit to areas at or beyond the site boundary, conforming to 10 CFR 50, Appendix I;
: i. Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, tritium, and all         facility radionuclides in particulate form with half lives grea    to than 8 days in gaseous effluents released from the       to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and
: j.      Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.
E. TECHNICAL SPECIFICATIONS (TS)      BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications,
: a.      Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
: b.      Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:
: 1. A change in  the TS incorporated in  the license, or
: 2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
: c.      The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.
: d.      Proposed changes that meet the criteria of Specification 6.7.E.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).
Amendment No. 4-74, 2--26                                                       267

BVY 14-083 Docket 50-271 Attachment 3 Vermont Yankee Nuclear Power Station Proposed Change 307 - Supplement 3 Retyped Technical Specification Pages

VYNPS 6.0   ADMINISTRATIVE CONTROLS 6.1   RESPONSIBILITY A. The plant manager shall be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during absences.
B. The plant manager or designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect nuclear safety.
C. The shift supervisor shall be responsible for the shift command function.
6.2   ORGANIZATION A. Onsite and Offsite Organizations Organizations shall be established for facility staff and corporate management.         These organizations shall include the positions for I             ac-t-i-vi-ti-es a-f-fect-ing safety of the nuclear fuel.
: 1.      Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through intermediate levels to and including all operating organizational positions.        These relationships shall be documented and updated, as appropriate, in the form of organizational charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.       These requirements shall be documented in the Quality Assurance Program Manual.        The plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the Technical Requirements Manual.
: 2.      The plant manager shall be responsible for overall facility safe operation and shall have control over those on-site activities necessary for safe storage and maintenance of the nuclear fuel.
: 3.      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 safe management-of nuclear-fuel.
Amendment No.   "-,   7&-, 4-2-1, 4-7,  244, 2-2-2                                      255

VYNPS 6.2   ORGANIZATION     (Cont'd)
: 4. The individuals who train the Certified Fuel Handlers, carry out health physics, or perform quality assurance functions may report to the appropriate on-site manager; however, these individuals shall have sufficient organizational freedom to ensure their ability        to perform their assigned functions.
B. Facility Staff The facility      staff   organization   shall include the following:
: 1. Each duty shift        shall be composed of at least one shift supervisor and one Non-certified Operator.              The Non-certified Operator position may be filled           by a Certified Fuel Handler.
: 2. At least one person qualified to stand watch in the control room (Non-certified Operator or Certified Fuel Handler) shall be present in the control room when nuclear fuel is stored in the spent fuel pool.
: 3. All fuel handling operations shall be directly supervised by a Certified Fuel Handler.
: 4. Shift crew composition shall meet the requirements stipulated herein.        Shift crew composition may be less than the minimum requirement of Specification 6.2.B.1 for a period of time not to exceed 2 hours 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
                     'd(iredffdr1fs and ll of the following conditions are met:
: a. no fuel movements are in        progress;  and
: b. no movement of loads over fuel are in          progress;  and
: c. no unmanned shift       positions during shift     turnover shall be permitted while the shift        crew is less than the minimum.
: 5. An individual qualified in radiation protection procedures shall be present on-site during the movement of fuel and during the movement of loads over fuel.
: 6. Deleted
: 7. The shift supervisor shall be a Certified Fuel Handler.
: 8. Deleted Amendment No.   &3 ,     ,   4-, .9,4& - 44,     4-64, 44--, 1-9,  244, 253             256

VYNPS 6.2   ORGANIZATION    (Cont'd)
C. Facility Staff Qualifications
: 1. Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1978 for comparable positions with exceptions specified in the Quality Assurance Program Manual (QAPM).
: 2. An NRC approved training and retraining program for Certified Fuel Handlers shall be maintained.
6.3   Deleted 6.4   PROCEDURES Written procedures shall be established, implemented,                 and maintained covering the following activities:
A. Normal startup, operation and shutdown of systems and components needed for the safe storage of nuclear fuel.
B.      Fuel handling operations.
C. Actions to be taken to correct specific and foreseen potential malfunctions of systems or components needed for the safe storage of nuclear fuel.
D. Emergency conditions involving potential or actual release of radioactivity.
E. Preventive and corrective maintenance operations which could have an effect on the safety of the nuclear fuel.
F. Surveillance and testing requirements.
G.      Fire protection program implementation.
H.      Process Control Program in-plant implementation.
I. Off-Site Dose Calculation Manual implementation.
6.5   HIGH RADIATION AREA As provided in paragraph 20.1601(c) of 10 CFR 20, the following controls shall be applied to high radiation areas in place of the controls required by paragraphs 20.1601(a) and 20.1601(b) of 10 CFR 20:
A. High Radiation Areas with dose rates greater than 0.1 rem/hour at 30 centimeters, but not exceeding 1.0 rem/hour at 30 centimeters from the radiation source or from any surface penetrated by the radiation:
Amendment No.    -, 4-3, 4-3, 4-3, 4-54-, 4-6,   1   , 2 -i-, 4, , 2 2-4-, --  3          257

VYNPS D. Radioactive Effluent Release Report The Radioactive Effluent Release Report covering the operation of the facility shall be submitted by May 15 of each year and in accordance with 10 CFR 50.36a.       The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility.          The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM) and Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.
E. Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the operation of the facility during the previous calendar year shall be submitted by May 15 of each year.          The report shall include summaries, interpretations, and an analysis of trends of the results of the radiological environmental surveillance activities for the report period.       The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM),     and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.
The Annual Radiological Environmental Operating Report shall include summarized and tabulated results of all radiological environmental samples taken during the report period pursuant to the table and figures in the ODCM.       In the event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report.
6.7   PROGRAMS AND MANUALS The following programs shall be established, implemented and maintained:
A. Deleted Amendment No.    -&#xfd; 4r  44-4, 4-4, 444.,            14*-,&, 4                    263

VYNPS D. Radioactive Effluent Controls Program This program conforming to 10 CER 50.36a provides for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as. reasonably achievable.      The program shall be contained in the ODCM, shall be implemented by operating procedures, and shall include remedial actions to be taken whenever the program limits are exceeded.       The program shall include the following elements:
: a. Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM;
: b. Limitations on the concentrations   of radioactive material released in liquid effluents from   the site to unrestricted areas, conforming to 10 times the   concentration values in Appendix B, Table 2, Column 2, to   10 CFR 20.1001 - 20.2402;
: c. Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents pursuant to 10 CFR 20.1302 and with the methodology and parameters in the ODCM;
: d. Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released from the facility to unrestricted areas, conforming to 10 CFR 50, Appendix I;
: e. Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days;
: f. Limitations on the functional capability and use of the liquid and gaseous effluent treatment systems to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would exceed 2 percent of the guidelines for the annual dose or dose commitment, conforming to 10 CFR 50,    Appendix I;
: g. Limitations on the dose rate resulting from radioactive material released in gaseous effluents from the site to areas at or beyond the site boundary shall be limited to the following:
: 1. For noble gases: less than or equal to a dose rate of 500 mrems/yr to the total body and less than or equal to a dose rate of 3000 mrems/yr to the skin, and
: 2. For iodine-131, iodine-133, tritium, and for all radionuclides in particulate form with half lives greater than 8 days:   less than or equal to a dose rate of 1500 mrems/yr to any organ; Amendment No. 4-74, 2_     2-32                                                  266

.11 VYNPS
: h. Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from the facility to areas at or beyond the site boundary, conforming to 10 CFR 50, Appendix I;
: i. Limitations on the annual and quarterly doses to a member of the public from iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half lives greater than 8 days in gaseous effluents released from the facility to areas beyond the site boundary, conforming to 10 CFR 50, Appendix I; and
: j. Limitations on the annual dose or dose commitment to any member of the public, beyond the site boundary, due to releases of radioactivity and to radiation from uranium fuel cycle sources, conforming to 40 CFR 190.
E. TECHNICAL SPECIFICATIONS    (TS)  BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications.
: a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
: b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:
: 1. A change in  the TS incorporated in  the license, or
: 2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
: c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.
: d. Proposed changes that meet the criteria of Specification 6.7.E.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).
Amendment No. 44-1, 2-2-26                                                      267}}