United States Nuclear Regulatory Commission - Protecting People and the Environment

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)

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. 


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