ML17219A319

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Safety Evaluation Re Rev 6 to Offsite Dose Calculation Manual & Rev 4 to Process Control Program.Revs Acceptable Refs for Use W/Tech Specs in Compliance w/10CFR20 & 50,Apps a & I,Respectively.Several Deficiencies Noted
ML17219A319
Person / Time
Site: Saint Lucie  
Issue date: 01/12/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17219A317 List:
References
NUDOCS 8701210408
Download: ML17219A319 (23)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION LRD P

OFFSITE DOSE C

C L TI N

M L

REV SION 6 1.0

2.0 INTRODUCTION

On August 18, 1983, the staff issued Amendment No.

59 to Facility Operating License No.

DPR-67 for the St. Lucie Plant Unit No. l.

On April 6, 1983, the Commission issued Facility Operating License No.

NFP-16 for the St. Lucie Plant Unit No.

2 which incorporated Technical Specifications (TS) through Amendment No.

5 in the license.

Each of the above actions provided the Radiological Effluent Technical Specifications (RETS) necessary to implement the requirements of 10 CFR Part 50, Appendix I.

For each unit, TS 3. 11 references the Offsite Dose Calculation Manual (ODCM) and the Process Control Program (PCP).

Changes to the PCP and ODCM are addressed in Unit 1 TS 6. 17 and 6.18, respectively, and in Unit 2 TS 6.13 and 6.14, respectively.

EVALUATION By letter dated July.28, '1983, the staff approved the Florida Power and Light Company submittal (letter L-83-185 dated March 23, 1983) of an ODCMI (Revision 2) for St. Lucie Unit 1.

The St. Lucie Units 1 and 2

PCP was submitted by licensee letter L-83-229 dated April 13, 1983.

The staff's Safety Evaluation (SE) enclosed with the August 18, 1983 NRC letter concerning the issuance of Amendment No.

59 to the Facility Operating License for St. Lucie Plant Unit No.

1 included the NRC technical assistance contractor's Technical Evaluation Report (TER) which stated that the licensee's ODCM and PCP proposals were reviewed and approved by the staff in their initial issuance of the St. Lucie Unit ho.

2 license.

The SE indicated that the staff agreed with the evaluation contained in the TER.

Following issuance of the staff SE, the only reported revisions to the St. Lucie Units 1 and 2

ODCM and PCP were provided in the St. Lucie Plant Units 1 and 2 Semi-Annual Radioactive Effluent Release Reports for 1983, January through June

1985, and January through June 1986 (ODCMI Revision 3 through Revision 6) and 1984 (PCP Revision 2 through Revision 4).

These revised documents (except for ODCM Revision 6) have been reviewed for the staff by EGKG Idaho, Inc. under a technical assistance agreement.

The contractor's TERs are enclosed as Supplements 1 and 2 to Appendix D

from EGG-PHY-7209, and provide technical evaluations of the conformance of the licensee's submittals with the respective NRC criteria.

They are considered a part of this SE.

8701210408 870li2 PDR ADOCK 05000335 P

'DR l' The staff has reviewed the contractor's TER on the ODCM (Revision 5) and agrees with the conclusion that the revised ODCM generally uses documented and approved methods consistent with the guidelines of NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants,"

however, several deficiencies were noted:

1.

The equation in Step 1.2.2.2 should reference Step 1.2.1.3 instead of Step 1.2.1.1.

2.

The equation in Steps 2.2.3.5 and 2.2.3.7 should include g instead of 3.

The dose rate due to iodines, tritium, and particulates is calculated for the thyroid of an infant from the grass-cow-milk pathway.

The calculation should be made for the thyroid of a child from the inhalation pathway for consistencv with Draft 7" to Revision 3 of NUREG-0472.

4.

The grass-milk pathway in the table of Step 2.6.5.1 should reference Step 2.6.3.6 instead of Step 2.6.3.7.

5.

Step 3.0.1 should state that compliance to 40 CFR 190 be demonstrated if twice the quarterly or twice the annual limits are exceeded.

6.

Simplified diagrams of the liquid, gaseous, and solid waste systems should be included in the ODCM.

7.

The licensee changed Ag-110m to Ag-110 throughout the tables in the ODCM.

The nuclide of concern is Ag-110m and should be restated as Ag-110m.

The licensee should correct these deficiencies in a future revision of the ODCM.

The staff has reviewed the ODCM (Revision 6) and notes that the above determinations from the contractor's review of the ODCM"(Rev'ision 5)'lso apply to the latest version of the ODCM-(Revision 6).

The staff has reviewed the contractor's TER on the PCP and agrees with the conclusion that the PCP (Revision 4) generally is consistent with current NRC criteria and is, therefore, acceptable.

However, several deficiencies were noted:

2.

Sections 3.2.2, 4.2 and 8.2 of Administrative Procedure Number 0520025 could be deleted since these sections are concerned with processes other than the dewatering of resin beads.

The methodology of assuring no free liquids by the visual inspection method referenced in Section 4.3 of Adminstrative Procedure Number 0520025 should be described.

Clarification should be provided on how a person can visually inspect for free liquid during the transfer of the resin beads or in the final disposal container after it is loaded.

3.

Clarification should be provided on whether Chem Nuclear is contracted to perform the dewatering process or Chem Nuclear equipment was purchased and is operated by the licensee.

4.

Chem Nuclear documents referenced in Sections 3.2 and 6.0 of Administrative Procedure Number 0520025 should be in agreement with the. documents referenced in Section 6.0 of Operating Procedure Number 0520023.

5.

The PCP should state that the containers listed in Section 8.1 of Administrative Procedure Number 050025 have been certified by the State of South Carolina for use at the Barnwell, South

Carolina, land disposal facility.

6.

A description or sketch of the plant's dewatering system and the vendor's interface requirements should be included in the PCP.

The licensee should correct the deficiencies in a future revision of the PCP.

It should be noted that the acceptability of the revised PCP is based on currently available NRC guidance that does not fully incorporate consideration of the requirements of 10 CFR Part 61 which became effective in 1983.

A future revision of the PCP should provide fully detailed information on assuring compliance with the requirements of 10 CFR 20.311 regarding classification of waste according to.10 CFR 61;55 and waste characteristics requirements of 10 CFR 61.56.

NRC guidance in the above areas is scheduled for development and issuance by earlv 1988.

3.0 CONCLUSION

S Based on the above, the staff concludes that the St. Lucie Units 1 and 2

ODCN (Revision 6) and PCP (Revision 4) are acceptable references for use with the plant TS for assuring compliance with the requirements of 10 CFR Part 20 and Part 50, Appendix A and Appendix I, governino the release of radioactive materials.

Principal Contributor:

C. Nichols

Attachment:

TER

CONTRACTOR'S TECHNICAL EVALUATION REPORT Enclosure 2

SUPPLEMENT 1

to APPENDIX D EVALUATION OF CHANGES TO THE ODCM

(Blank Page) 01-2

INTRODUCTION Pur ose of Review The purpose of this document is to review and evaluate the changes to the Offsite Dose Calculation Manual (ODCM) made by the Licensee of the St. Lucie Plant Units 1 and 2 since March 28, 1983 when the ODCM was issued by the Licensee as Revision 2.~1~

Revision 2 of the ODCM was subsequently approved by the NRC.~2~

The ODCM is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix I requirements.~

~

Sco e of Review As specified in NUREG-0472~4~

and NUREG-0473,~5~ the ODCM is to be developed by the Licensee to document the methodology and approaches used to calculate offsite doses and maintain the operability of the radioactive effluent systems.

As a minimum, the ODCM should provide equations and methodology for the following topics:

Alarm and trip setpoints on effluent instrumentation Liquid effluent concentrations in unrestricted areas Gaseous effluent dose rates at or beyond the site boundary Liquid and gaseous effluent dose contributions Liquid and gaseous effluent dose projections.

In addition, the ODCM should contain flow diagrams, consistent with the systems being used at the station, defining the treatment paths and the components of the radioactive liquid, gaseous, and solid waste management systems.

A description and the location of samples in support of the environmental monitoring program are also needed in the ODCM.

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Plant-S ecific Back round On behalf of St. Lucie Plant Units 1 and 2, the Florida Power and Light Company (FPL) submitted changes to the existing ODCM~ j in the Semiannual Radioactive Effluent Release Reports issued by the Licensee.

The Licensee issued Revision 3 of the 'ODCM in the first six months of 1983,~6~

Revision 4 in the second six months of 1983,L7j and Revision 5 in the first six months of 1985.~8j The Licensee's semiannual reports and the changes to the ODCM were transmitted to an independent review team at the Idaho National Engineering Laboratory (INEL) for review.

The ODCM review was subsequently conducted by EGSG Idaho, and the results and conclusions of the evaluation are presented in this supplement.

REVIEW CRITERIA Review criteria for ODCM were provided by the NRC in three documents:

NUREG-0472, RETS for P WRs i4j NUREG-0473, RETS for BHRs~5j NUREG-0133, Preparation of RETS for Nuclear Power Plants.~9j In the ODCM review, the following NRC guidelines a'e used:

"General Contents of the Offsite Dose'alcul'ation"Manual,"

Revisi'on',~

~ and NUREG-0133.~

~

Regulatory Guide 1.109~1 j also provides technical

.guidance =for the review.

The ODCM format is left to the Licensee and may be simplified by tables and grid printouts.

EVALUATION The Licensee has followed the methodology of NUREG-0133~ j to determine the alarm and trip setpoints for the liquid and gaseous effluent

.monitors, which ensures that the maximum permissible concentrations (MPCs),

as specified in 10 CFR 20,~12j will not be exceeded by discharges from various liquid or gaseous release points.

All plant piping is routed to the discharge canal.

The liquid radwaste is diluted with the circulating water before entering the Atlantic Ocean at a point approximately 1200 feet offshore.

To allow for multiple sources of gaseous releases from different or common release points, the allowable operating setpoints will be controlled administratively by allocating a

percentage of the total allowable release to each of the release sources.

The Licensee's method for setpoint calculations is consistent with the guidelines of NUREG-0133.

Compliance to the MPCs of 10 CFR 20 for radioactive liquid releases is assured by demonstrating that the sum of the concentration ratios for each nuclide is less than or equal to one.

The concentration ratios are determined using assay re'suits from a liquid sample.

Compliance to the MPCs of 10 CFR 20 for noble gas releases is assured by the setpoints calculated for the noble gas monitors.

Compliance to the dose rates from radioiodines, tritium, and particulates with half lives greater than eight days is assured through the dose rate calculation described in the ODCM.

The ODCM identifies the grass - cow/goat - milk pathway as the most limiting pathway with the infant's thyroid being the critical organ.

This is consistent with an earlier version of NUREG-0472.

However, Draft 7" of Revision 3 to NUREG-0472 identifies inhalation as the most limiting pathway with the child's thyroid as the critical organ.

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Doses to members of the public due to radionuclides identified in liquid effluents will be calculated monthly to show compliance with 10 CFR 50 Appendix I.

The Licensee identifies the fish and shellfish consumption pathways for the dose calculations assuming the adult as the maximum exposed individual.

The dose calculation methodology in the ODCN due to radioactive liquid effluents satisfies the relationships presented in NUREG-0133.

Doses resulting from the release of noble gases, and radioiodines, tritium, and particulates with half lives greater than eight days are calculated monthly to show compliance with 10 CFR 50 Appendix I.

The dose calculation methodology in the ODCM due to radioactive gaseous effluents satisfies the relationships presented in NUREG-0133.

Methodology, based on dose projections, to determine required use of the liquid and gaseous radwaste treatment systems is described in the ODCM.

The projections are based on the dose calculations due to radioactive effluents which satisfies the relationships in NUREG-0133.

The Licensee's RETS identify a limit of 285,000 curies of noble gas considered as Xe-133 in' waste gas decay tank.

Surveillance to determine the curie inventory will be determined at least once.per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the reactor coolant activity exceeds 100/E.

The bases for the surveillance frequency is described in the ODCM.

The ODCM does not contain simplified flow diagrams illustrating the treatment paths and the'omp'onents of the-'radioa'ctive"-li'quid;-gaseous and solid waste management systems.

Methodology for demonstrating compliance to 40 CFR 190 is described in the ODCN.

The Licensee's RETS and the ODCN state the time period is over 12 consecutive months instead of over a calender year which is permitted by Draft 7" to Revision 3 of NUREG-0472.

The ODCM states that compliance to 40 CFR 190 will be demonstrated only if the doses exceed twice the quarterly dose limits of the Technical Specifications.

However, the Technical Specifications state that compliance will be demonstrated if the doses exceed either twice the quarterly or twice the annual dose limits.

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Specific parameters of distance and the direction sector from the plant and additional information have been provided for each and every sample location identified in the St. Lucie RETS Environmental Monitoring Table 3.12-1.

The data are contained in a table and a map in Appendix E

of the ODCM.

In summary, the Licensee's ODCM as revised used documented and approved methods that are generally consistent with the methodology and guidance in NUREG-0133, and therefore is an acceptable reference.

Dl-7

CONCLUSIONS The Licensee's revisions (Rev.

3 through

5) to the Offsite Dose Calculation Manual (ODCM Rev.
2) as submitted in the Licensee's Semiannual Radioactive Effluent Release Reports~

~

~ j use documented and approved methods and are consistent with the criteria of NUREG-0133, except for the following discrepancies:

o The equation in Step 1.2.2.2 should reference Step 1.2.1.3 instead of Step 1.2.1.1.

o The equation 'in Steps 2.2.3.5 and 2.2.3.7 should include g

instead of g.

o The dose rate due to iodines, tritium, and particulates is calculated for the thyroid of an infant from the grass-cow-milk pathway.

The calculation should be made for the thyroid of a child from the inhalation pathway for consistency with Draft 7" to Revision 3 of NUREG-0472.

o The grass-milk pathway in the table of Step 2.6.5.1 should reference Step 2.6.3.6 instead of Step 2.6.3.7.

,, o Step 3.0.,1 should state that compliance to 40 CFR 190 be

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.,)ATE eqp~-0 demonstrated if twice the quarterly or twice the annual limits are exceeded.

o The ODCM does not contain simplified diagrams of the liquid,

gaseous, and solid waste systems.

o The Licensee changed Ag-110m to Ag-110 throughout the tables in the ODCM.

The nuclide of concern is Ag-110m and should be restated as Ag-110m.

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REFERENCES 1.

Letter from R.

E. Uhrig (FPL) to D. G. Eisenhut (NRC),

Subject:

Offsite Dose Calculation Manual ODCM, L-83-185, March 28, 1983.

2.

Letter from G.

W. Knighton (NRC) to R.

E. Uhrig (FPL),

Subject:

Offsite Dose Calculation Manual ODCM

, July 28, 1983.

3.

Title 10, Code of Federal Regulations, Part 50, Appendix I, "Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion, "As Low As Is Reasonably Achievable," for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents".

4.

"Radiological Effluent Technical Specifications for Pressurized Water Reactors,"

Rev. 3, Draft 7", intended for contractor guidance in reviewing RETS proposals for operating reactors, NUREG-0472, September 1982.

"" 5.

"Radiological Effluent Technical Specifications for Boiling Water Reactors,"

Rev.

3, Draft 7", intended for contractor guidance in reviewing RETS proposals for operating reactors, NUREG-0473, September 1982.

6.

Letter from R.

E. Uhrig (FPL) to J.

P. O'Reilly (NRC),

Subject:

St.Lucie Unit 1 Semi-Annual Radioactive Effluent 'Release

Report, L-83-462, August 26, 1983.

7.

Letter from J.

W. Williams, Jr.

(FPL) to J.

P. O'Reilly (NRC),

Subject:

St. Lucie Units 1 and 2 Semi-Annual Radioactive Effluent Release

Report, L-84-52, March 1, 1984.

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8.

Letter from J.

W. Williams, Jr.

(FPL) to J.

N. Grace (NRC),

Subject:

St. Lucie Units 1 and 2 Semi-Annual Radioactive Effluent Release

Report, L-85"339, August 30, 1985.

9.

"Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A guidance Manual for Users of Standard Technical Specifications,"

NUREG-0133, October 1978.

10.

"General Contents of the Offsite Dose Calculation Manual," Revision 1

Branch Technical Position, Radiological Assessment

Branch, NRC, February 8, 1979.
11. "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I," Regulatory Guide 1.109, Rev.

1, October 1977.

12. Title 10, Code of Federal Regulations, Part 20, "Standards for Protection Against Radiation".

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CONTRACTOR'S TECHNICAL EVALUATION REPORT SUPPLEMENT 2 to APPENDIX D EVALUATION OF CHANGES TO THE PCP

(Blank Page)

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INTRODUCTION Pur ose of Review The purpose of this document is to report the results of a review of the Process Control Program (PCP),

updated through June 30,

1985, as revised by the Licensee of the St. Lucie Plant Units 1 and 2 since April 13, 1983 when the PCP was issued by the Licensee as Revision 1,~1j which was subs'equently approved by the NRC.~2j The PCP is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with Standard Review Plan 11.4~ j and Branch Technical Position ETSB-11-3.~4j Sco e of Review As specified in NUREG-0472~5j and NUREG-0473,~6~

the PCP is to be developed by the Licensee to document the current formulas,

sampling, analyses,
tests, and determinations to be made to ensure that the processing and packaging of solid radwastes are accomplished.

As a minimum, the PCP should provide commitments and information regarding the following topics:~7~

Processing and packaging of liquid/wet wastes Processing and packaging of other wet wastes Treatment of oily wastes Block diagram sketches of these systems Considerations of As Low As Is Reasonably Achievable (ALARA).

02-3

Plant-S ecific Back round On behalf. of St. Lucie Plant Unit 1 and 2, the Florida Power

& Light Company (FPL) submitted changes to the existing PCP~1j in the Semiannual Radioactive Effluent Release Reports issued by the Licensee.

The Licensee issued Revisions 2 and 3 of the PCP in the first six months of 1984.~8~

Revision 4 was reported in the second six-month period of 1984.~91 Each revision supersedes the previous revision.

The Licensee's Semiannual Reports and the changes to the PCP were transmitted to an independent review team at the Idaho National Engineering Laboratory (INEL) for review.

The review was subsequently conducted by EGSG Idaho (EGG),

and the results and conclusions of the PCP evaluation are presented in this document.

REVIEM CRITERIA NUREG-0472~

~ and NUREG-0473~

~ specify that the Licensee develop a

PCP to ensure that the processing and packaging of solid radioactive wastes will be accomplished in compliance with 10 CFR 20,~

,-= 10 CFR 71,~11~

and other Fe'deral and State regulations or requirements governing the offsite disposal of the low-level radioactive waste.

The PCP is not intended to contain a set of detailed procedures; rather, it is the source of basic criteria for the detailed procedures to be developed by the Licensee.

The criteria used to evaluate the PCP are derived from current NRC guidelinesI7j and do not include criteria to demonstrate compliance to 10 CFR 61.~12j The PCP should include, but is not limited to, the following:

o A commitment that all liquid/wet wastes shall be solidified prior to shipment offsite.

o A commitment that containers, shipping casks, and methods of packaging for liquid/wet wastes meet applicable Federal regulations, e.g.,

10 CFR 71.

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o A commitment that radioactive wastes will be shipped to a

licensed burial site in accordance with applicable Commission",

Department of Transportation, and State regulations, including the burial site regulation requirements.

o A general description of the laboratory mixing of a sample of waste to arrive at process parameters prior to commencing the solidification process.

I A general description of the solidification process including type of solidification agent, process control parameters, parameter boundary conditions, proper waste-form properties, and assurance that the solidification systems are oper ated within the established process parameters.

o A general description of sampling of at least one representative sample from every tenth batch to ensure solidification, and the action to be taken if the sample fails to verify solidification.

o The provisions to verify the absence of free liquid.

o The provisions to reprocess containers in which free liquids are detected.

o If the solidification process is exothermic, the process control parameters that must be met prior to capping the container.

o Appropriate statements for other wet wastes which could include filter sludge, spent powdered resins, spent bead resins, and spent cartridge filter elements.

o A general description of the dewatering technique and control parameters for other wet wastes.

D2-5

o Provisions should be included to reprocess the other wet wastes through the dewatering system if excess free water is observed.

o A general description f'r treatment of oily wastes which are to be transported offsite'for burial should be included.

o Sketches of the solid radwaste treatment systems.

o A statement that ALARA considerations were addressed in all phases of the solidification process.

TECHNICAL EVALUATION The Process Control Program is actually a set of procedures subset to the controlling Administrative Procedure.

Revision 4 to Administrative Procedure No. 050025 supersedes the previous revisions.

The PCP for the

't. Lucie plant is only applicable to the dewatering of spent bead

" resins.

The resins are dewatered in accordance with Chem Nuclear criteria

and are to be packaged and shipped in specified high-integrity containers.

PbEI The PCP is specific to the dewatering of bead resins and is not being

"'evaluated for other processes.

If in the future solidification, encapsulation, or entombment becomes necessary, then the PCP must be modified to address the processing and packaging requirements for these

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g ',Ml processes.

Consequently, it may be prudent to delete Sections 3.2.2, 4.2, and 8.2 of Admiqistrative Procedure No. 0520025 or state in the PCP that these processes have not been reviewed or approved.

Section 8.0 of Operating Procedure No. 0520023 provides sufficient description of the dewatering process that ensures the absence of free liquid in the dewatered waste form.

Section 4.3 of Administrative Procedure No. 0520025 permits a method of visual inspection to ensure acceptable volumes of free liquid.

However, the methodology is not described.

D2-6

Administrative provisions are included to suspend shipment of.

inadequately dewatered bead resins and to correct the Process Control Program in the event the dewatering process is inadequate.

It is not clear whether the Licensee contracts Chem Nuclear to perform the dewatering process or Chem Nuclear equipment has been purchased and is being operated by the Licensee.

Additionally, Chem Nuclear documents are referenced and it is not clear if the documents were included with the original NRC approval.

The Chem Nuclear document numbers referenced in Administrative Procedure No. 0520025 are not in agreement with the document numbers referenced in Operating Procedure No. 0520023.

Sections 3.2 and 6.0 of Administrative Procedure No. 0520025 reference Chem Nuclear Project No. 11118 whereas Section 6.0 of Operating Procedure No. 0520023 references Chem Nuclear Project No.

11038.

Section 4.4.1 of Operating Procedur'e No. 0520023 Rev.

0 states that the bead resins may be disposed of in high-integrity containers pursuant to the Barnwell Site Criteria.

Therefore, Section 4.2 of Operating Procedure No. 0520023 and Section 8.1 of Administrative Procedure No. 0520025 should state that the containers have been certified by the State of South Carolina for use at the Barnwell, South Carolina land disposal facility.

A description or sketch of the plant's dewatering system and the interface requirements for the contracted vendor's equipment is not included with the PCP.

In summary the PCP contains commitments generally consistent with the guidelines of Reference 7 and the PCP is therefore an acceptable reference.

D2-7

CONCLUSION The Licensee's Revision 4 to the Process Control Program for the dewatering of bead resins submitted with letter dated March 4, 1985~ j has been reviewed against current NRC criteria.~7j It is found that the PCP contains commitments generally consistent with the guidelines of Reference 7 and is therefore an acceptable reference with the following possible exceptions:

o Sections 3.2.2, 4.2, and 8.2 of Administrative Procedure Number 0520025 could be deleted since these sections are concerned with processes other than the dewatering of bead resins.

o The methodology of assuring no free liquids by the visual inspection method referenced in Section 4.3 of Administrative Procedure Number 0520025 must be described.

It is not clear how a person can visually inspect for free liquid during the transfer of the bead resins or in the final disposal container after it is loaded.

o It is not clear if'he Licensee contracts Chem Nuclear to'perform the dewatering process or if Chem Nuclear equipment was purchased and is operated by the Licensee.

.o...

Chem Nucl,ear.-.documents J;eferenced

.in.,Sections,3.2,,and,.6,.0.of.

Administrative Procedure Number 0520025 are not in agreement with the documents referenced in Section 6.0 of Operating Procedure Number 0520023.

o The PCP should state that the containers listed in Section 8.1 of Administrative Procedure Number 050025 have been certified by the State of South Carolina for use at the Barnwell,,South Carolina land disposal facility.

o A description or sketch of the plant's dewatering system and the vendor's interface requirements should be included in the PCP.

D2-8

REFERENCES 1.

Letter from R.

E. Uhrig (FPL) to D. G. Eisenhut (NRC),

Subject:

St. Lucie Unit No.

1 and 2 Plant Process Control Program, L-83-229, April 13, 1983.

2.

Letter from D.

R. Muller (NRC) to G.

C. Lainas (NRC),

Subject:

DSI SAFTEY EVALUATION AND ENVIRONMENTAL CONSIDERATION OF ST.

LUCIE UNIT 1 SUPPORTING A LICENSE AMENDMENT (RETS, NPA ITEN A-02), Nay 2, 1983.

3.

"Solid Waste Management System,"

Standard Review Plan, Office of Nuclear Reactor Regulation, Section 11.4, Revision 2, July 1981.

4.

Branch Technical Position 11-3, "Design Guidance for Solid Radioactive Waste Management Systems Installed in Light-Mater-Cooled Nuclear Power Reactors Plants,"

attachment to SRP 11.4, Revision 2, July 1981.

5.

NUREG-0472, "Radiological Effluent Technical Specifications for Pressurized Water Reactors," Draft 7", Revision 3; September 1982.

6.

NUREG-0473, "Radiological Effluent Technical Specifications for Boiling Mater Reactors," Draft 7", Revision 3, September 1982.

7.

Letter from C. A. Willis (NRC) to F.

B. Simpson (EGG),

Subject:

"Guidance for Review of the Process Control Program,," Criteria for Process Control Program, January 7, 1983.

8.

Letter from J.

M. Williams, Jr.

(FPL) to J.

P. O'Reilly (NRC),

Subject:

St. Lucie Units 1 and 2 Docket Nos. 50-335, 50-389 Semi-Annual

Reports, L-84-227, August 30, 1984.

9.

Letter from J.

M. Williams, Jr.

(FPL) to J.

N. Grace (NRC),

Subject:

St. Lucie Units 1 and 2 Docket Nos. 50-335, 50-389 Semi-Annual Radioactive Effluent Release

Report, March 4, 1985.

D2-9

10. Title 10, Code of Federal Regulations, Part 20, "Standards for Protection Against Radiation".

ll. Title 10, Code of Federal Regulations, Part 71, "Packaging and Transportation of Radioactive Material".

12. Title 10, Code of Federal Regulations, Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste".

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