ML17207A880
| ML17207A880 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/04/1980 |
| From: | Bangart R Office of Nuclear Reactor Regulation |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8003120955 | |
| Download: ML17207A880 (10) | |
Text
Docket No. 50-335 MEMORANDUM FOR:
R.
W. Reid, Chief
.Operating Reactors Branch No. 4, DOR FROM:
R. L. Bangart, Acting Chief Effluent Treatment Systems
- Branch, DSE
SUBJECT:
REVIEW OF PROPOSED RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS FOR ST.
LUCIE, UNIT NO.
1 By a letter dated March 15, 1979, Florida Power and:.Light Company proposed to amend the existing Technical. Specifications of St. Lucie, Unit No. 1, for the radiological effluent and'nvironmental monitoring systems, to.implement the provisions of Appendix I to 10 CFR Part 50 and the provisions approved by the Regulatory Requirements Review Coranittee.
Our review of the proposed Radio-logical Effluent Technical Specifications was based on the model Radiological Effluent Technical Specifications. for Pressurized Water Reactors, NUREG-0472, Revision 2, July 1979.
Our comments and marked-up copy of the model radiological effluent lrechnical Specifications are attached as Enclosures 1 and 2, respectively.
The licensee should be requested to incorporate these comments into his submittal.
The proposed amendment did not include the required Technical Specifications on solid radioactive waste, liquid sampling, system operability, effluent dose limitations, explosive gas mixtures, curie content in outdoor. liquid holdup
- tanks, and administrative controls.
The enclosed comments and marked=up speci-fications do not include input from the Radiological Assessment Branch (RAB) nor do they include comments by RAB on the Offsite
.Dose Calculation Manual (ODCM),
since it was not submitted by the licensee.
Since the enclosed comments will likely represent the majority of the comments that will be generated, we recom-mend that these comments and the marked-up, copy of the model radiological effluent-Technical Specifications be forwarded to Florida Power and Light. Company for their resolution.
As noted earlier, the licensee has not s'ubmitted an&ODCM for review.
Nor did he submit a Process Control Program (PCP) for solidification of radioactive wastes for St. Lucie, Unit No. 1, since he did not submit the required Technical Speci-fications for solid radioactive waste.
Whether the licensee uses a contractor for waste solidification/dewatering or performs his own waste processing, a
PCP should be submit'ted.
We recommend that the ODCM and PCP be submitted for our review; and that a response to the enclosed comments be made within thirty (30) days of receipt of these comments.
To clarify our comments on the pro osed OFFICE $
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amendment, a conference call or meeting with the 'licensee may be necessary within this thirty (30) day period.
Original Signed By; Riohard Lo. Bangarb,/
Richard L. Bangart, Acting Chief Effluent Treatment Systems Branch Division of Site Safety and Environmental Analysis
Enclosures:
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ETSB Comments 2.
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'iCLi>SURE 1 COMMEi~l~ Of'. ST.
LUCIE UNIT NO. 1, RETS 1.
We have reviewed the subject radiological effluent Technical Specifications as submitted by the licensee, and have marked up our standard RETS based on the licensee's submittal to reflect a document which is acceptable to us.
This will in some cases change the licensee's wording and tables to make them conform to the contents of NUREG-0472, Rev. 2, which has been agreed upon by NRC headquarters personnel, I@E inspectors, and the AIF.
Specific changes made may require subsequent discussion.
2.
Definitions 1.10, 1.11, 1.19, and 1.30 should be modified as
- shown, and definitions 1.31 thru 1.37 should be added to be consistent with NUREG-0472.
3.
Table 1.2 frequency notation should conform to NUREG-0472.
4.
Use of plant procedures to establish alarm and trip action setpoints, and II referencing them in these specifications is not acceptable.
An OFFSITE DOSE CALCULATION.MANUAL (ODCM) should be prepared, submitted to us for review, and referenced in these specifications as 'noted.
5.
~he APPLICABILITY OF Specifications 3.3.3.8 and 3.3.3.9 should be "At All Times" except as specifically noted in the marked-up specification.
6.
Specifications 4.3.3.8 and 4.3.3.9 should include'SOURCE CHECK requirements as noted.
7.
In Specification 3.3.3.8, indicate the following monitoring or sampling capabi1 ities:
a.
turbine building drains effluent line b.
ser vice water effluent. line 8.
In Specification 3.3.3.8, indicate the following flow rate measurement capabil ities:
a.
liquid radwaste effluent line b.
discharge canal c.
steam generator blowdown effluent line 9.
In Specification 3.3.3.8, indicate level monitoring capability for any out-side tanks containing potentially radioactive fluids.
10.
A cycling gas analyzer is provided to monitor H2/02 concentrations in the i:a" ie gas holdup system.
It is our position that continuous monitoring is required.
How do you intend to meet the requirements of Surveillance Requirement 4.11.2.5'!
11.
In Specification 3.3.3.9, include specification for the waste gas holdup system effluent flow rate measuring device.
12.
In Specification 3.3.3.9, indicate iodine and particulate
- sampling, and flow rate monitoring capability for the air ejector vent.
13.
The, containment purge system effluent source should have the capability for alarm and automatic termination of release on high activity.
Specifica-tion 3.3.3.9 should reflect this requirement.
14.
In Specifications 3.3.3.8 and 3.3.3.9 (Tables 3.3-11 and 3.3-12) use ACTIONS as indicated in mark-up.
15.
In Table 4.11-1, liquid sampling should also include analysis of P-32/Fe-55.
16.
In Table 4.11-1 the sampling frequency for continuous releases should be con-tinuous rather than 4 per month.
,,17.
Specification 3.11.1.2 should have annual dose limitations in addition to the quarterly limitations.
18.
Specification 3.11.1.3 should have an operability r equireme i'.,
and projected dose limits for operability, per NUREG-0472.
19.
In Specification 4.11.1.3.2, provide a time interval for demonstrating operability.
20.
Provide a specification for maximum curie content in outdoor liquid holdup tanks.
21.
The radioactive gaseous waste sampling and analysis program should conform to attached mark-up of Table 4.11-2.
22.
Specifications 3.11.2.2 and 3.11.2.3 should have annual dose limitations in addition to quarterly limitations.
23.
In Specification 3.11.2.4, include a specification for the VENTILATION EXHAUST TREATMENT SYSTEM (with corresponding projected dose limit), and use the projected dose limits specified in NUREG-0472 for the GASEOUS RAOPJASTE TREATMENT SYSTEM.
24.
In Specification 4.11.2.4.2, provide a time interval for demonstrating operability.
"5.
Provide a specification for an explosive gas mixture in the waste gas hold-up system per NUREG-0472.
26.
Provide a specification for the solid radwaste system per NUREG-0472, and provide a
PROCESS CONTROL -PROGRAM (PCP) for our review.
27.
Note that BASES given in the mark-up supplement the specifications and are not specifications in themselves.
Since this mark-up reflects the speci-fications as they are acceptable to us, the BASES should correspond to those in the mark-up.
28.
In Section 5.0, "DESIGN FEATURES", include reference to the site boundary figures for liquid and""gaseous effluents.
29.
In Specification 6.5.1.6, include FRG responsiblities as noted in mark-up.
30.
In Specification 6.5.2.8, include AUDITS as noted in mark-up.
31.
In Specification 6.8.1, include procedure implementation as noted in mark-up.
32.
In Specification 6.9.1.9, include text as noted in mark-up.
33.
In Specification 6.9.1.10, include reference to ODCM.
34.
In Specification 6.9.1.12, include items j and k as noted in mark-up.
3"i, In Specificatio 6.9.1.13, includ.
item f shown in mark-up.
36.
In Specification 6.10.2, include records of analyses required by the radio-logical environmental monitoring program.
37.
Add Specifications 6.13 through 6.15 as noted in mark-up.
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