ML19319D523
| ML19319D523 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/25/1973 |
| From: | US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19319D519 | List: |
| References | |
| NUDOCS 8003170649 | |
| Download: ML19319D523 (5) | |
Text
O CRYSTAL RIVER UNIT NO. 3 DOCKET NO. 50-302 REGULATORY POSITION STATEMENTS Section 2.6 - Site Environmental Radioactivity Monitoring Program The Preoperational and the Operational Environmental Radiological Monitoring programs described in Section 2.6 or Table 2-11 of the FSAR are not adequate. Locations of the sampling sites must be identified and located on a suitable map of the area. A suitable table must be included giving for each sample site: location, media sampled, frequency of sampling, and analysis performed on each sample. Appropriate individual radionuclide analyses must be performed'on all samples with the exception of the weekly air particulate samples and precipitation samples. The weekly air precipitation samples may be analyzed by appropriate gross radioactivity measurement (beta, or beta-gamma); however, should the gross radioactivity measurements exceed the limits for unidentified radionuclide mixture in air or in water, the samples must be analyzed by gamma spectral analysis.
Monthly composites of the air particulate samples must be analyzed by gamma spectral analysis.
Section 4.0 - Reactor Coolant System In response to Request 4.34 in Amendment No. 25 to the FSAR the following statement is made: " Appendix G of the Summer 1972 Addenda,Section III of ASNE Code, was not used as a guide in establishing the operating pressure and temperature limitations of the reactor coolant system." No operating curves were in Amendment No. 25, but the text indicated that the pressure-temperature limitations were less conservative than what Appendix G would have given. Hydrostatic and leak testing limitations were not mentioned.
Pressure-temperature operational limitations during reactor startup and shutdown, and during hydrostatic and leak testing of the reactor coolant system, must be at least as conservative as those determined in conform-ance with Appendix G, " Protection Against Nonductile Failure," of Section III of the ASME Boiler and Pressure Vessel Code, Summer 1972 Addenda.
These limitations must be included in the Technical Specifications.
8003170
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! Section 6.0 - Engineered Safeguards In response to Request 6.1 in Amendment No. 24 to the FSAR, the statement appears that, "A formal inservice inspection program for fluid systems other than those composing the reactor coolant pressure boundary system is not planned..." These inspections must be performed in accordance with the ASME Section XI, 1972 Winter Addenda, " Rules for Inservice Inspection of Nuclear Plant Components," within the limits of accessibility designed into the Crystal River, Unit 3 nuclear power plant. These inspections must be included in the Technical Specifications.
Section 11.0-Radioactive Waste and Radiation Monitoring 1.
Section 11.1 of the FSAR states that the design objective of the radio-active waste treatment systems is to assure that the quantities of radioactive materials released from the plant will not exceed a small fraction of 10 CFR Part 20 limits. Sections 11.2.1.2 and 11.2.2.2 state that the release of liquid and gaseous radioactive wastes to unrestricted areas will be based on 10 CFR Part 20 limits. The design and operation of the radioactive waste treatment systems shall be to reduce the quantities of liquid and gsseous radioactive materials expected to be released from the plant to as low as practicable in accordance with 10 CFR Part 50.
Accordingly, the design objective and release limits for liquid and gaseous radioactive wastes must be i
based on keeping the levels of radioactive materials in effluents to unrestricted areas as low as practicable.
2.
Amendment 26 to the FSAR provided a revised Figure ll-1B that shows the principal flow path for the chemical regenerant liquids as an untreated release to the discharge canal. The collection of these wastes and the criteria that will be used to process these wastes as radioactive must be described. Whenever primary coolant to secondary coolant leakage is detected in the plant, the chemical regenerant
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liquids shall be processed through the miscellaneous waste evaporator and evaporator condensate demineralizer before relesse to unrestricted areas.
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m Section 15.4.2.1 - Reactor Building - Structural Integrity The proposed tendon surveillance program lacks supporting data to justify deviations from Regulatory Guide 1.35, Inservice Surveillance of Ungrouted Tendons in Prestressed Concrete Containment Structures. Unless engineering justifications are provided for deviations, the following specific items and portions of Regulatory Guide 1.35 must be met:
1.
Item C.4 - Surveillance interval of 1, 2 and 3 years after the acceptance test and then on a 5 year interval.
2.
Item C.5.b - The lif t-off test should include a complete unloading cycle going to essentially complete detensioning of the tendon to identify broken or damaged wires on strands for all twenty-one (21) tendons.
3.
Item C.S.c - A minimum of six (6) dome tendons with two (2) in each 60 group, five (5) vertical tendons and ten (10) hoop tendons all being randomly, but representatively distributed will undergo lif t-off testing.
4.
Item C.S.e - The criteria defining the acceptance limits and proce-dures to be followed when the surveyed tendons do not all meet the requirements are te is ve.e part of the tendon surveillance program.
5.
Item C.6 - Previously strest,ed wires or strands are to be removed and tested in accordance with this referenced section.
6.
Item C.7. - The other pertinent components of the tendon system are to be surveyed as indicated within this section.
7.
Item C.S. - The reporting procedures are to be as defined in this section.
I Section 15.4.10 - Environmental Surveillance Program Title should read: " Environmental Radiological Program." The comments above on Section 2.6 apply here, also, including the requirements for defining the sampling locations and showing them on a suitable map of the area.
The program as outlined in Table 15-7 of the FSAR must be modified as follows:
I.
Air (a) Particulate Only 1 off site location within radius of 10 miles of plant" is indicated. The number of sampling locations must be increased to cover areas in all land sectors around the plant, and must include, at least, the locations sampled by the State of Florida in the Crystal River Off-Site Environmental Program, as indicated in the Draft Environmental Statement, Figure 5.4.
At the same locations at which air particulate samples are taken, the air must also be sampled on a continuous basis for radioactive iodine, using KI-impregnated charcoal or equivalent.
Samples must be removed weekly and assayed for radioactive iodine, as I-131.
(c) Precipitation "MPC," the level at which gamma spectral analysis is required must be defined. Samples must also be taken at at least two locations in the direction of prevailing winds, preferably
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at two air sampling stations.
II.
Water (a) Canal and Gulf The discharge canal must be sampled at the head and midway to the gulf end, as well as at the gulf end.
The gamma spectral and Sr-89, 90 analyses must be done quarterly rather than semiannually.
l (e) Bottom Sediments Samples must be taken at the three locations in II (a),
quarterly, when the water samples are taken.
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. III.
Terrestrial (a) Milk "At present, no dairy cows in area of influence." The Final Environmental Statement for Crystal River says that there are cows at a farm 4 miles ENE of the site. The milk of these cows must be sampled. Attachment 1, " Requirements for Radiological Surveillance of Milk" must be followed.
In addition, Technical Specifications must show that applicant will take a census every six months of animals producing milk for human consumption in the vicinity of the Crystal River Plant. Should additional such animals be introduced into the area they ahall be subject to sampling as in " Requirements for Radiological Surveillance of Milk," above.
Month 1v, not Quarterly, composites of mile must be analyzed for gamma spectra and SR-89, 90.
(b) Biota 2) Vegetation Pasture grass must be sampled quarterly at the farm 4 miles ENE where cows are located. Vegetation must be sampled at the two locations near air sampling stations where and at the time the soil samples are to be taken. Crops, including citrus, in the vicinity of the plant must be sampled., Reporting Recairements Environmental Radiological Monitoring should be incorporated inte the Technical Specifications at the proper location.
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