Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555
January 31, 1989
TO ALL POWER REACTOR LICENSEES AND APPLICANTS
SUBJECT: IMPLEMENTATION OF PROGRAMMATIC CONTROLS FOR RADIOLOGICAL EFFLUENT
TECHNICAL SPECIFICATIONS IN THE ADMINISTRATIVE CONTROLS SECTION OF
THE TECHNICAL SPECIFICATIONS AND THE RELOCATION OF PROCEDURAL DETAILS
OF RETS TO THE OFFSITE DOSE CALCULATION MANUAL OR TO THE PROCESS
CONTROL PROGRAM (GENERIC LETTER 89-01)
The NRC staff has examined the contents of the Radiological Effluent Technical
Specifications (RETS) in relation 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 effluents and radiological environmental monitoring
can be relocated to the Offsite Dose Calculation Manual (ODCM). Likewise, the
procedural details of the current TS on solid radioactive wastes can be
relocated to the Process Control Program (PCP). These actions simplify the
RETS, meet the regulatory requirements for radioactive effluents and
radiological environmental monitoring, and are provided as a line-item
improvement of the TS, consistent with the goals of the Policy Statement.
New programmatic controls for radioactive effluents and radiological
environmental monitoring are incorporated in the TS to conform to the
regulatory requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a, and
Appendix I to 10 CFR Part 50. Existing programmatic requirements for the PCP
are being retained in the TS. The procedural details included in licensees'
present TS on radioactive effluents, solid radioactive wastes, environmental
monitoring, and associated reporting requirements will be relocated to the
ODCM or PCP as appropriate. Licensees will handle future changes to these
procedural details in the ODCM and the PCP under the administrative controls
for changes to the ODCM or PCP. Finally, the definitions of the ODCM and PCP
are updated to reflect these changes.
Enclosure 1 provides guidance for the preparation of a license amendment
request to implement these alternatives for RETS. Enclosure 2 provides a
listing of existing RETS and a description of how each is addressed.
Enclosure 3 provides model TS for programmatic controls for RETS and its
associated reporting requirements. Finally, Enclosure 4 provides model
specifications for retaining existing requirements for explosive gas
monitoring instrumentation requirements that apply on a plant-specific basis.
Licensees are encouraged to propose changes to TS that are consistent with the
guidance provided in the enclosures. Conforming amendment requests will be
expeditiously reviewed by
8901300114
.Generic Letter 89-01 2 January 31, 1989
the NRC Project Manager for the facility. Proposed amendments that deviate
fromthis guidance will require a longer, more detailed review. Please contact
the appropriate Project Manager if you have questions on this matter.
Sincerely,
Steven A. Varga
Acting Associate Director for Projects
Office of Nuclear Reactor Regulation
Enclosures: 1 through 4 as stated
.Generic Letter 89 -01 ENCLOSURE 1
GUIDANCE FOR THE IMPLEMENTATION OF PROGRAMMATIC CONTROLS FOR RETS
IN THE ADMINISTRATIVE CONTROLS SECTION OF TECHNICAL SPECIFICATIONS
AND THE RELOCATION OF PROCEDURAL DETAILS OF CURRENT RETS TO THE
OFFSITE DOSE CALCULATION MANUAL OR PROCESS CONTROL PROGRAM
INTRODUCTION
This enclosure provides guidance for the preparation of a license amendment
request to implement programmatic controls in Technical Specifications (TS)
for radioactive effluents and for radiological environmental monitoring
conforming to the applicable regulatory requirements. This will allow the
relocation of existing procedural details of the current Radiological Effluent
Technical Specifications (RETS) to the Offsite Dose Calculation Manual (ODCM).
Procedural details for solid radioactive wastes will be relocated to the
Process Control Program (PCP). A proposed amendment will (1) incorporate
programmatic controls in the Administrative Controls section of the TS that
satisfy the requirements of 10 CFR 20.106, 40 CFR Part 190, 10 CFR 50.36a.
and Appendix I to 10 CFR Part50, (2) relocate the existing procedural details
in current specifications involving radioactive effluent monitoring
instrumentation, the control of liquid and gaseous effluents, equipment
requirements for liquid and gaseous effluents, radiological environmental
monitoring, and radiological reporting details from the TS to the ODCM, (3)
relocate the definition of solidification and existing procedural details in
the current specification on solid radioactive wastes to the PCP, (4) simplify
the associated reporting requirements, (5) simplify the administrative
controls for changes to the ODCM and PCP, (6) add record retention
requirements for changes to the ODCM and PCP, and (7) update the definitions
of the ODCM and PCP consistent with these changes.
The NRC staff's intent in recommending these changes to the TS and the
relocation of procedural details of the current RETS to the ODCM and PCP is to
fulfill the goal of the Commission Policy Statement for Technical
Specification Improvements. It is not the staff's intent to reduce the level
of radiological effluent control. Rather, this amendment will provide
programmatic controls for RETS consistent with regulatory requirements and
allow relocation of the procedural details of current RETS to the ODCM or PCP.
Therefore, future changes to these procedural details will be controlled by
the controls for changes to the ODCM or PCP included in the Administrative
Controls section of the TS. These procedural details are not required to be
included in TS by 10 CFR 50.36a.
DISCUSSION
Enclosure 2 to Generic Letter 89-01 provides a summary listing of
specifications that are included under the heading of RETS in the Standard
Technical Specifications (STS) and their disposition. Most of these
specifications will be addressed by programmatic controls in the
Administrative Controls section of the TS. Some specifications under the
heading of RETS are not covered by the new programmatic controls and will be
retained as requirements in the existing plant TS. Examples include
requirements for explosive gas monitoring instrumentation, limitations on the
quantity of radioactivity in liquid or gaseous holdup or storage tanks or in
the condenser exhaust for BWRs, or limitations on explosive gas mixtures in
off gas treatment systems and storage tanks.
.Generic Letter 89-01 - 2 - Enclosure 1
Licensees with nonstandard TS should follow the guidance provided in Enclosure
2 for the disposition of similar requirements in the format of their TS.
Because solid radioactive wastes are addressed under existing programmatic
controls for the Process Control Program, which is a separate program from the
new programmatic controls for liquid and gaseous radioactive effluents, the
requirements for solid radioactive wastes and associated solid waste reporting
requirements in current TS are included as procedural details that will be
relocated to the PCP as part of this line-item improvement of TS. Also, the
staff has concluded that records of licensee reviews performed for changes
made to the ODCM and PCP should be documented and retained for the duration of
the unit operating license. This approach is in lieu of the
current,requirements that the reasons for changes to the ODCM and PCP be
addressed in the Semiannual Effluent Release Report.
The following items are to be included in a license amendment request to
implement these changes. First, the model specifications in Enclosure 3 to
Generic Letter 89-01 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
to10 CFR Part 50. The definitions of the ODCM and PCP should be updated to
reflect these changes. The programmatic and reporting requirements are
general in nature and do not contain plant-specific details. Therefore, these
changes to the Administrative Controls section of the TS are to replace
corresponding requirements in plant TS that address these items. They should
be 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. If the current TS include requirements for explosive gas
monitoring instrumentation as part of the gaseous effluent monitoring
instrumentation requirements, these requirements should be retained.
Enclosure 4 to Generic Letter 89-01 provides model specifications for
retaining such requirements.
Second, 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 ODCM or PCP as appropriate
and in a manner that ensures that these details are incorporated in plant
operating procedures. The NRC staff does not intend to repeat technical
reviews of the relocated procedural details because their consistency with the
applicable regulatory requirements is a matter of record from past NRC reviews
of RETS. 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.
Finally, licensees should confirm in the amendment request that changes for
relocating the procedural details of current RETS to either the ODCM or PEP
have been prepared in accordance with the proposed changes to the
Administrative Controls section of the TS so that 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. The NRC staff will not concur in or approve the
revised ODCM.
.Generic Letter 89-01 - 3 - Enclosure 1
Licensees should refer to "Generic Letter 89-01" in the Subject line of
license amendment requests implementing the guidance of this Generic Letter.
This will facilitate the staff's tracking of licensees' responses to this
Generic Letter.
SUMMARY
The license amendment request for the line-item improvements of the TS
relative to the RETS will entail (1) the incorporation of programmatic
controls for radioactive effluents and radiological environmental monitoring
in the Administrative Controls section of the TS, (2) incorporation of the
procedural details of the current RETS in the ODCM or PCP as appropriate, (3)
confirmation that the guidance of this Generic Letter has been followed.
.Generic Letter 89-01 Enclosure 2
DISPOSITION OF SPECIFICATIONS AND ADMINISTRATIVE CONTROLS
INCLUDED UNDER THE HEADING OF RETS IN THE STANDARD TECHNICAL SPECIFICATIONS
SPECIFICATION TITLE DISPOSITION OF EXISTING SPECIFICATION
1.17 OFFSITE DOSE CALCULATION Definition is updated to reflect the
MANUAL change in scope of the ODCM.
1.22 PROCESS CONTROL PROGRAM Definition is relocated to the PCP.
1.32 SOLIDIFICATION Definition is relocated to the PCP.
3/4.3.3.10 RADIOACTIVE LIQUID Programmatic controls are included in
EFFLUENT MONITORING 6.8.4 g. Item 1). Existing specifi-
INSTRUMENTATION cation procedural details are
relocated to the ODCM.
3/4.3.3.11 RADIOACTIVE GASEOUS Programmatic controls are included in
EFFLUENT MONITORING 6.8.4 g. Item 1). Existing specifi-
INSTRUMENTATION cation procedural details are
relocated to the ODCM. Existing
requirements for explosive gas
monitoring instrumentation should be
retained. Model specifications for
these requirements are provided in
Enclosure 4.
3/4.11.1.1 LIQUID EFFLUENTS: Programmatic controls are included in
CONCENTRATION 6.8.4 g. Item 2) and 3). Existing
specification procedural details are
relocated to the ODCM.
3/4.11.1.2 LIQUID EFFLUENTS: DOSE Programmatic controls are included in
6.8.4 g. Item 4) and 5). Existing
specification procedural details are
relocated to the ODCM.
3/4.11.1.3 LIQUID EFFLUENTS : LIQUID Programmatic controls are included in
RADWASTE TREATMENT Item 6). Existing specification pro-
SYSTEM cedural details are relocated to the
ODCM.
3/4.11.1.4 LIQUID HOLDUP TANKS Existing specification requirements
to be retained.
.Generic Letter 89-01 - 2 - Enclosure 2
DISPOSITION OF SPECIFICATIONS AND ADMINISTRATION CONTROLS
INCLUDED UNDER THE HEADING OF RETS IN THE STANDARD TECHNICAL SPECIFICATIONS
(Cont.)
SPECIFICATION TITLE DISPOSITION OF EXISTING SPECIFICATION
3/4.11.2.1 GASEOUS EFFLUENTS: Programmatic controls are included in
DOSE RATE 6.8.4 g. Item 3) and 7). Existing
specification procedural details are
relocated to the ODCM.
3/4.11.2.2 GASEOUS EFFLUENTS: Programmatic controls are included in
DOSE-NOBLE GASES 6.8.4 g. Item 5) and 8). Existing
specification procedural details are
relocated to the ODCM.
3/4.11.2.3 GASEOUS EFFLUENTS: Programmatic controls are included in
DOSE--IODINE 131, 6.8.4 g. Item 5) and 9). Existing
TRITIUM, AND RADIOACTIVE specification procedural details are
MATERIAL IN PARTICULATE relocated to the ODCM.
FORM
3/4.11.2.4 GASEOUS EFFLUENTS: Programmatic controls are included in
GASEOUS RADWASTE 6.8.4 g. Item 6). Existing specifi-
TREATMENT or VENTILATION cation procedural details are
EXHAUST TREATMENT SYSTEM relocated to the ODCM.
3/4.11.2.5 EXPLOSIVE GAS MIXTURE Existing specification requirements
should be retained.
3/4.11.2.6 GAS STORAGE TANKS Existing specification requirements
should be retained.
3/4.11.2.7 MAIN CONDENSER (BWR) Existing specification requirements
should be retained.
3/4.11.2.8 PURGING AND VENTING Programmatic controls are included in
(BWR Mark II contain- 6.8.4 g. Item 10). Existing specifi-
ments) cation procedural details are
relocated to the ODCM.
3/4.11.3 SOLID RADIOACTIVE WASTES Existing specifications procedural
details are relocated to the PCP.
3/4.11.4 RADIOACTIVE EFFLUENTS: Programmatic controls are included in
TOTAL DOSE 6.8.4 g. Item 11). Existing specifi-
cation procedural details are
relocated to the ODCM.
.Generic Letter 89-01 - 3 - Enclosure 2
DISPOSITION OF SPECIFICATIONS AND ADMINISTRATIVE CONTROLS
INCLUDED UNDER THE HEADING OF RETS IN THE STANDARD TECHNICAL SPECIFICATIONS
(Cont.)
SPECIFICATION TITLE DISPOSITION OF EXISTING SPECIFICATION
3/4.12.1 RADIOLOGICAL ENVIRON- Programmatic controls are included in
MENTAL MONITORING: 6.8.4 h. Item 1). Existing specifi-
MONITORING PROGRAM cation procedural details are
relocated to the ODCM.
3/4.12.2 RADIOLOGICAL ENVIRON- Programmatic controls are included in
MENTAL MONITORING: 6.8.4 h. Item 2). Existing specifi-
LAND USE CENSUS cation procedural details are
relocated to the ODCM.
3/4.12.3 RADIOLOGICAL ENVIRON- Programmatic controls are included in
MENTAL MONITORING: 6.8.4 h. Item 3). Existing specifi-
INTERLABORATORY cation procedural details are
COMPARISON PROGRAM relocated to the ODCM.
5.1.3 DESIGN FEATURES: SITE - Existing specification requirements
MAP DEFINING UNRESTRICTED should be retained.
AREAS AND SITE BOUNDARY
FOR RADIOACTIVE GASEOUS
AND LIQUID EFFLUENTS
6.9.1.3 REPORTING REQUIREMENTS: Specification simplified and existing
ANNUAL RADIOLOGICAL reporting details are relocated to
ENVIRONMENTAL OPERATING the ODCM.
REPORT
6.9.1.4 REPORTING REQUIREMENTS: Specification simplified and existing
SEMI-ANNUAL RADIOACTIVE reporting details are relocated to
EFFLUENTS RELEASE REPORT the ODCM or PCP as appropriate.
6.13 PROCESS CONTROL PROGRAM Specification requirements are
simplified.
6.14 OFFSITE DOSE CALCULATION Specification requirements are
MANUAL simplified.
6.15 MAJOR CHANGES TO LIQUID, Existing procedural details are
GASEOUS, AND SOLID relocated to the ODCM or PCP as
RADWASTE TREATMENT appropriate.
SYSTEMS
.Generic Letter 89-01 Enclosure 3
TECHNICAL SPECIFICATIONS TO BE REVISED
1.17 DEFINITIONS: OFFSITE DOSE CALCULATION MANUAL
1.22 DEFINITIONS: PROCESS CONTROL PROGRAM
6.8.4 g. PROCEDURES AND PROGRAMS: RADIOACTIVE EFFLUENT CONTROLS
6.8.4 h. PROCEDURES AND PROGRAMS: RADIOLOGICAL ENVIRONMENTAL MONITORING
6.9.1.3 REPORTING REQUIREMENTS: ANNUAL RADIOLOGICAL ENVIRONMENTAL
OPERATING REPORT
6.9.1.4 REPORTING REQUIREMENTS: SEMIANNUAL RADIOACTIVE EFFLUENT
RELEASE REPORT
6.10 RECORD RETENTION
6.13 PROCESS CONTROL PROGRAM (PCP)
6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)
MODEL TECHNICAL SPECIFICATION REVISIONS
(To supplement or replace existing specifications)
1.0 DEFINITIONS
OFFSITE DOSE CALCULATION MANUAL
1.17 The OFFSITE DOSE CALCULATION MANUAL (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/Trip Setpoints, and in the conduct of the
Environmental Radiological Monitoring Program. The ODCM shall also contain
(1) the Radioactive Effluent Controls and Radiological Environmental
Monitoring Programs required by Section 6.8.4 and (2) descriptions of the
information that should be included in the Annual Radiological Environmental
Operating and Semi-annual Radioactive Effluent Release Reports required by
Specifications 6.9.1.3 and 6.9.1.4.
1.22 The PROCESS CONTROL PROGRAM (PCP) shall contain the current formulas,
sampling, analyses, test, and determinations to be made to ensure that
processing and packaging of solid radioactive wastes based on demonstrated
processing of actual or simulated wet solid wastes will be accomplished in
such a way as to assure compliance with 10 CFR Parts 20, 61, and 71, State
regulations, burial ground requirements, and other requirements governing the
disposal of solid radioactive waste.
.Generic Letter 89-01 - 2 - Enclosure 3
6.0 ADMINISTRATIVE CONTROLS
6.8 PROCEDURES AND PROGRAMS
6.8.4 The following programs shall be established, implemented, and
maintained:
g. Radioactive Effluent Controls Program
A program shall be provided conforming with 10 CFR 50.36a 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 (1) shall be contained in the ODCM, (2)
shall be implemented by operating procedures, and (3) shall include
remedial actions to be taken whenever the program limits are
exceeded. The program shall include the following elements:
1) Limitations on the operability of radioactive liquid and gaseous
monitoring instrumentation including surveillance tests and
setpoint determination in accordance with the methodology in the
ODCM,
2) Limitations on the concentrations of radioactive material
released in liquid effluents to UNRESTRICTED AREAS conforming to
10 CFR Part 20, Appendix B, Table II, Column 2,
3) Monitoring, sampling, and analysis of radioactive liquid and
gaseous effluents in accordance with 10 CFR 20.106 and with the
methodology and parameters in the ODCM,
4) Limitations on the annual and quarterly doses or dose commitment
to a MEMBER OF THE PUBLIC from radioactive materials in liquid
effluents released from each unit to UNRESTRICTED AREAS
conforming to Appendix I to 10 CFR Part 50,
5) 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,
6) Limitations on the operability and use of the liquid and gaseous
effluent treatment systems to ensure that the appropriate
portions of these systems are used to reduce releases of
radioactivity when the projected doses in a 31-day period would
exceed 2 percent of the guidelines for the annual dose or dose
commitment conforming to Appendix I to 10 CFR Part 5,
7) Limitations on the dose rate resulting from radioactive material
released in gaseous effluents to areas beyond the SITE BOUNDARY
conforming to the doses associated with 10 CFR Part 20, Appendix
B, Table II, Column 1,
.Generic Letter 89-01 - 3 - Enclosure 3
ADMINISTRATIVE CONTROLS
6.8.4 g. Radioactive Effluent Controls Program (Cont.)
8) Limitations on the annual and quarterly air doses resulting from
noble gases released in gaseous effluents from each unit to
areas beyond the SITE BOUNDARY conforming to Appendix I to 10
CFR Part 50,
9) 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 each unit to areas
beyond the SITE BOUNDARY conforming to Appendix I to 10 CFR Part
50,
10) Limitations on venting and purging of the Mark II containment
through the Standby Gas Treatment System to maintain releases as
low as reasonably achievable (BWRs w/Mark II containments), and
11) Limitations on the annual dose or dose commitment to any MEMBER
OF THE PUBLIC due to releases of radioactivity and to radiation
from uranium fuel cycle sources conforming to 40 CFR Part 190.
h. Radiological Environmental Monitoring Program
A program shall be provided to monitor the radiation and
radionuclides in the environs of the plant. The program shall
provide (1) representative measurements of radioactivity in the
highest potential exposure pathways, and (2) verification of the
accuracy of the effluent monitoring program and modeling of
environmental exposure pathways. The program shall (1) be contained
in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part
50, and (3) include the following:
1) Monitoring, sampling, analysis, and reporting of radiation and
radionuclides in the environment in accordance with the
methodology and parameters in the ODCM,
2) A Land Use Census to ensure that changes in the use of areas at
and beyond the SITE BOUNDARY are identified and that
modifications to the monitoring program are made if required by
the results of this census, and
3) Participation in a Interlaboratory Comparison Program to ensure
that independent checks on the precision and accuracy of the
measurements of radioactive materials in environmental sample
matrices are performed as part of the quality assurance pro-
gram for environmental monitoring.
.Generic Letter 89-01 - 4 - Enclosure 3
ADMINISTRATIVE CONTROLS
6.9 REPORTING REQUIREMENTS
ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT*
6.9.1.3 The Annual Radiological Environmental Operating Report covering the
operation of the unit during the previous calendar year shall be submitted
before May 1 of each year. The report shall include summaries, interpreta-
tions, and analysis of trends of the results of the Radiological Environmental
Monitoring Program for the reporting period. The material provided shall be
consistent with the objectives outlined in (1) the ODCM and (2) Sections
IV.B.2,IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.
SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT**
6.9.1.4 The Semiannual Radioactive Effluent Release Report covering the
operation of the unit during the previous 6 months of operation shall be
submitted within 60 days after January 1 and July 1 of each year. The report
shall include a summary of the quantities of radioactive liquid and gaseous
effluents and solid waste released from the unit. The material provided shall
be (1) consistent with the objectives outlined in the ODCM and PCP and (2) in
conformance with 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part
50.
6.10 RECORD RETENTION
6.10.3 The following records shall be retained for the duration of the unit
Operating License:
o. Records of reviews performed for changes made to the OFFSITE DOSE
CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.
6.13 PROCESS CONTROL PROGRAM (PCP)
Changes to the PCP:
a. Shall be documented and records of reviews performed shall be
retained as required by Specification 6.10.3o. This documentation
shall contain:
1) Sufficient information to support the change together with the
appropriate analyses or evaluations justifying the change(s) and
*A single submittal may be made for a multi-unit station.
**A single submittal may be made for a multi-unit station. The submittal
should combine those sections that are common to all units at the station;
however, for units with separate radwaste systems, the submittal shall specify
the releases of radioactive material from each unit.
.Generic Letter 89-01 - 5 - Enclosure 3
ADMINISTRATIVE CONTROLS
6.13 PROCESS CONTROL PROGRAM (PCP) (Cont.)
2) A determination that the change will maintain the overall
conformance of the solidified waste product to existing
requirements of Federal, State, or other applicable regulations.
b. Shall become effective after review and acceptance by the [URG] and
the approval of the Plant Manager.
6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)
Changes to the ODCM:
a. Shall be documented and records of reviews performed shall be
retained as required by Specification 6.10.3o. This documentation
shall contain:
1) Sufficient information to support the change together with the
appropriate analyses or evaluations justifying the change(s) and
2) A determination that the change will maintain the level of
radioactive effluent control required by 10 CFR 20.106, 40 CFR
Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and
not adversely impact the accuracy or reliability of effluent,
dose, or setpoint calculations.
b. Shall become effective after review and acceptance by the [URG] and
the approval of the Plant Manager.
c. Shall be submitted to the Commission in the form of a complete,
legible copy of the entire ODCM as a part of or concurrent with the
Semiannual Radioactive Effluent Release Report for the period of the
report in which any change to the ODCM was made. Each change shall
be identified by markings in the margin of the affected pages,
clearly indicating the area of the page that was changed, and shall
indicate the date (e.g., month/year) the change was implemented.
