ML20093D015
| ML20093D015 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/31/1983 |
| From: | Duce S, Mandler J, Serrano W EG&G, INC., ENERGY ENGINEERING GROUP |
| To: | NRC |
| Shared Package | |
| ML20093D011 | List: |
| References | |
| CON-FIN-A-6459 EGG-PHYS-6171, TAC-08985, TAC-8985, NUDOCS 8407160070 | |
| Download: ML20093D015 (34) | |
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EGG-PHYS-6171 May 1983 RADI0 LOGICAL EFFLUENT TECHMICAL SPECIFICATI0nS (RETS) IMPLEMENTATION - CRYSTAL RIVER UNIT NO. 3 NUCLEAR GENERATING PLANT William Serrano Stephen W. Duce John W. Mandler Ferrol B. Simpson Douglas W. Akers Thomas E. Young Idaho National Engineering Laboratory Operated by the U.S. Department of Energy
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l e407160070 840627 PDR ADOCK 05000302 P
PDR Prepared for the U.S. NUCLEAR REGULATORY COMMISSION ESEGid ho Under DOE Contract No. DE-AC07-76IO01570
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EGG-PHYS-6171 RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS) IMPLEMENTATION-CRYSTALRIVERUNITNO.3 NUCLEAR GENERATING PLANT William Serrano Stephen W. Duce John W. Mandler Ferrol B. Simpson Douglas W. Akers 1
Thomas E. Young i
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, Published May 1983 EGAG Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. NUCLEAR REGULATORY COMMISSION under DOE Contract No. DE-AC07-76ID01570 FIN NO. A6459 D.
FOREWORD This Technical Evaluation Report was prepared by EG&G. Idaho, Inc. under a contract with the U. S. Nuclear Regulatory Comission (Office of Nuclear Reactor Regulation, Division of Systems Integration) for technical assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRC.
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23ST7ACT A review of the Radiological Effluent Technical Specifications (RETS) of the Crystal River Unit No. 3 Nuclear Generating Plant was performed.
The principal review guidelines used were NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Pcwer Plants,"
and Draft 7' of NUREG-0472, Revision 3, " Radiological Effluent Technical Specifications for PWR's." Draft submittals were discussed with the Licensee until all items requiring changes to the Technical Specifications were resolved. The Licensee then submitted final proposed RETS to the NRC which j
were evaluated and found to be in compliance with the requirements of the NRC review guidelines with the exception of one item in the environmental monitoring program. The proposed Offsite Dose Calculation Manual was reviewed.
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i COMTENTS I
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Forward 1
I Abstract............................
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1.
INTRODUCTION.......................... 1 1.1 Purpose of the Technical Evaluation............
1 1
1.2 Generic Issue Background 1
1.3 Plant-Specific Background................. 3 2.
REVIEW CRITERIA
........................ 5 3.
TECHNICAL EVALUATION...................... 7 3.1 General Description of Radiological Effluent System.... 7 3.2 Radiological Effluent Technical Specifications 13 3.3 Offsite Dose Calculation Manual.............
22 i
3.4 Process Control Program.................
24 4.
CONCLUSIONS 25 5.
REFERENCES..........................
27 i
APPENDIX 4
A Evaluation of Proposed Radiological Effluent Technical Specifications (RETS)
...............30 I
FIGURES 1.
Liquid and Gaseous Discharge Points,.............. 9 2.
Liquid Radwaste System....................
10 j
3.
Miscellaneous Liquid Process System
.............11 4.
Gaseous Radwaste/ Effluent Treatment System 12 TABLES i :
Number Title Page 1
Correspondence of Provisions of NUREG-0472, The Licensee's Current Technical Specifications and The Licensee's Proposal for Crystal River Unit No. 3............
26 i
A-1 Comparison of Model Technical Specification's (NUREG-0472) and Proposed Technical Specifications for Crystal River Unit i
No. 3 Nuclear Generating Plant................
32-42 111
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1.1 Purpose of tne Technical Evaluation 4
i The purpose of this Technical Evaluation Report (TER) is to review and evaluate the proposed changes in the Technical Specifications of the Crystal 1
River Unit No. 3 Nuclear Generating Plant with regard to Radiological Effluent Technical Specifications (RETS), the proposed Offsite Dose Calculation Manual (0DCM), and the Process Control Program (PCP).
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The evaluation used criteria proposed by the Nuclear Regulatory Commission (NRC) staff in the model Technical Specifications for pressurized water reactors l
I (PWR's),NUREG-0472,El3 and subsequent revisions. This effort is directed I
toward the NRC objective of implementing RETS which comply with the regulatory requirements, primarily those of 10 CFR Part 50, Appendix I.E23 Other regula-tions pertinent to the control of effluent releases ara also included within
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the scope of compliance.
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1.2 Generic Issue Background l
Since 1970, 10 CFR Part 50, Section 50.36a,[3] " Technical Specifications on Effluents from Nuclear Power Reactors," has required licensees to provide
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Technical Specifications which ensure that radioactive releases will be kept l
as low as,is reasonably achievable (ALARA).
In 1975 numerical guidance for the ALARA requirement was issued in 10 CFR Part 50, Appendix I.
The licensees of all operating reactors were requiredE43 to submit, no later than June 4, 1976, their proposed ALARA Technical Specifications and information for evaluation in accordance with 10 CFR Part 50, Appendix 1.
However, in February 1976 the NRC staff recomended that proposals to l
modify Technical Specifications be deferred until the NRC completed the model l
RETS. The initial NRC position on the model RETS was established in May 1978 when the NRC's Regulatory Requirements Review Comittee approved the first model RETS (NUREG-0472 for PWR's and NUREG-0473 for boiling water reactors
[BWR's]).
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The model RETS deal with radioactive waste management systems and environmental monitoring. Although the model RETS address the 10 CFR Part 50,. Appendix I requirements, subsequent revisions include provis;ans I
for addressing issues not covered in Appendix I.
These provisions are l
stipulated in the following regulations:
10 CFR Part 20,[5] " Standards for Protection Against Radiation,"
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l Sections 20.105(c), 20.106(g), and 20.405(c) which require that l
nuclear power plants and other licensees comply with 40 CFR Part 190,[6] " Environmental Radiation Protection Standards for Nuclear Power Operations," and submit reports to the NRC when the 40 CFR Part 190 limits have been or may be exceeded.
10 CFR Part 50, Appendix A,E73 " General Design Criteria for Nuclear i
e Power Plants," which contains Criterion 60--Control of releases of radioactive materials to the environment; Criterion 63--Monitoring fuel and waste storage; and Criteriatr64-Monitoring radioactive releases.
I 10 CFR Part 50, Appendix B,[8] which establishes the quality e
assurance required for nuclear power plants.
Copies of the model RETS were sent to licensees in July 1978 with a request to submit proposed site-specific RETS on a staggered schedule over a
,j six-month period. Licensees responded with requests for clarifications and l
extensions.
l i1 The Atomic Industrial Forum (AIF) formed a task force to connent on the model RETS. NRC staff members first met with the AIF task force on June 17 j
1978. The model RETS were subsequently revised (Revision 1) to reflect comments from the AIF and others. A principal change was the transfer of much of the material concerning dose calculations from the' model RETS to a separate document, the 00CM.
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Revision 1 of the model RETS was sent to licensees on November 15 and 16, 1978 with guidance (NUREG-0133)E93 for preparation of the RETS and the
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ODCM and a new schedule for responses, again staggered over a six-ecnth period.
Four regional seminars on the RETS were conducted by the NRC staff during November and December 1978. Subsequently, a preliminary copy of Revision 2 of the model RETS and additional guidance on the 00CM and a PCP were issued in February 1979 to each utilit{ at individual meetings. NUREG-0472, E13 and NUREG-0473, Revision 2[10J were published in July 1979 and Revision 2 updated in January 1980 and February 1980. In response to the NRC's request, operating reactor Itcensees subsequently submitted initial proposals on plant i
i RETS and the 00CM. Review leading to ultimate implementation of these docu-ments was initiated by the NRC in September 1981 using subcontracted independent teams as reviewers.
I As the RETS reviews progressed, feedback from the licensees led the NRC to modify some of the provisions in the February 1,1980 version of Revision 2 to clarify specific concerns of the licenseesDd thus expedite the reviews.
l Starting in April 1982, the NRC distributed revised versions of RETS in draft form to the licensees during the site visits. The new guidance on these changes was presented in an AIF meeting on May 19, 1982.[113 Some interim j
changes regarding the Radiological Environmental Monitoring Section were issued in August 1982.[12] With the incorporation of these changes, the NRC issued a draft Revision 3 of NUREG-0472[13] in September 1982 to serve as new guidance for the review teams.
1.3 Plant-Specific Background
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In conformance with the 1975 directiveE43 Flcrida Power Corporation (FPC), the Licensee of the Crystal River Unit No. 3 Nuclear Generating Plant, 4
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had the NUS Corporation submit information for an " Appendix I Analysis for Crystal River Nuclear Unit," dated May 28,1976.E143 This information was evaluated by the Nuclear Regulatory Commission Division of Site Safety and Environmental Analysis and found to meet the requirements of Appendix I.[15]
I The Licensee did not propose new RETS at this time.
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The RETS were addressed in the next submittal by the Licensee [16] to the l
NRC dated February 13, 1979. The submittal followed the format of NUREG-0472 3
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for PWR's.
EGaG Idaho Inc. (EGSG), selected as an independent task review team, initiated a review and evaluation of this submittal.
The submittal was compared with the ::;odel RETS and assessed for complaince with the require-ments of 10 CFR Part 50, Appendix I, and 10 CFR Part 50, Appendix A.
Review connents and questions dated November 23, 1981El73 were mailed to the NRC and the Licensee prior to arranging a site visit with the Licensee.
The Licensee chose to prepare another submittal based on the questions included in the review and postponed the site visit. The Licensee's revised RETS (Revision 1) were received July 15,1982 by EG8G. This submittal was reviewed for compliance with Revision 3 of the model RETS. Review comments and ques-tions on the Revision 1 submittal (September 14,1982[18]). were mailed to the NRC and the Licensee prior to a site visit at the Crystal River Unit No. 3 Generating Plant.
The site visit was arranged for the purpose of resolving questions identified in the review of the Revision 1 submittal.
During the site visit (October 27-28, 198 0, the Licensee presented a revised RETS (Revision 2) which, together with technical discussions, resolved most of the shortcomings of the Crystal River RETS (e.g., missing information and other deviations from the requirements) identified in the review of the Revision 1 submittal.
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l On November 11, 1982 another RETS submittal (Revision 3) was received which reflected the agreements made at the October 27-28, 1982 meeting. This j
document was compared with Revision 3 of NUREG-0472[13] to ensure that all j
items met the intent of the model RETS requirements proposed by the NRC.A j
telephone conference call was held on December 13, 1982EI83 between NUS and EG&G personnel (NUS is preparing the FPC submittal). This telecon clarified the few unresolved items identified in the review of the Revision 3 submitt A telecon was then held between NRC and EG8G personnel on December 13,1982[20]
for concurrence on deviations identified in the submittal.
It was agreed that the Licensee's Revision 3 submittal was acceptable. Based on the acceptance j
of these reviews the FPC submitted final proposed RETS to the NRC.
A copy of FPC's final proposed Technical Specifications [213 was received by the EG4G review team on January 28, 1983. The Licensee's final proposed 4
I RETS submittal was re. W ed against NUREG-0472E133 and it was concluded that i
one open item remained in the environmental monitoring program. All other
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items regarded as deviations from the intent of the NUREG-0472 requirements were resolved, allowing the EG&G review team to complete a TER for submittal to the NRC.
The Licensee's proposed ODCM[22] was received by the EG8G review team I
on May 3, 1983. The 00CM submitted was reviewed against NUREG-0133 and Regulatory Guide 1.109 and it.was concluded that the 0DCM contains methods
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consistent with the criteria of NUREG-0133. Discrepancies in the ODCM are identified in the cover letter for this document.
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The Licensee has not submitted a PCP.' The Licensee has coraitted to having a PCP in the Technical Specifications. Therefore, a TCP will be i
submitted to the NRC for review and approval.
2.0 REVIEW CRITERIA Review criteria for the RETS were provided by the NRC in three documents:
1.
NUREG-0472 RETS for PWR's 2.
NUREG-0473, RETS for BWR's 3.
NUREG-0133, Preparation of RETS for Nuclear Power Plants.
t ll Twelve essential crittiria are given for the RETS and 00CM:
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1.
All significant releases of radioactivity shall be controlled and monitored.
4 2.
Offsite r;oncentrations of radioactivity shall not exceed the j
10 CFR Part 20,. Appendix 5 Table II Ilmits.[23]
3.
Offsite radiation doses shall be ALARA.
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4.
Equipment shall be maintained and used to keep offsite doses ALARA.
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Radwaste tank inventories shall be limited so that failures would not cause offsite doses exceeding 10 CFR Part 20 limits.
6.
Hydrogen and/or Oxygen concentrations in the waste gas system shall be controlled to prevent explosive mixtures.
t 7.
Wastes shall be processed to shipping and burial ground criteria j
under a documented program, subject to quality assurance verification.
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8.
An environmental monitoring program, including a land use census, shall be implemented.
I 9.
The radwaste management program shall be subject to regular audits and reviews.
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- 10. Procedures for control of liquid W gaseous effluents shall be maintained and followed.
- 11. Periodic and special reports on environmental monitoring and on releases shall be submitted.
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- 12. Offsite dose calculations shall be performed using documented and l;
approved methods consistent.with NRC methodology.
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In addition to NUREG-0472 and NUREG-0473, and their subsequent revisions, i
the NRC staff issued guidelines,[24,253 clarifications,[26,27] and branch positions [28,29,303 establishing a policy that requires the licensees of operating reactors to meet the intent, if not the letter, of the model RETS requirements. The NRC branch positions issued since the RETS implementation review began have clarified the model RETS for operating reactors.
Review criteria for the 00CM is based on the following NRC guidelines:
Branch Technical Position " General Content of the Offsite Dose Calculation
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Manual"E313;NUREG-0133E9 ; and Regulatory Guide 1.109[32]
The fonr.at 1
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for the ODCM is left to the Licensee and may be simplified by tables and grid printouts.
Review critaria for the Process Control Program is based on guidance provided by the NRC staff 33),
3.0 TECHNICAL EVALUATION
3.1 General Description of Radiological Effluent System This section briefly describes the liquid and gaseous radwaste effluent treatment systems, release paths, and control systems installed at Crystal River Unit No. 3 Nuclear Generating Plant, a PWR.
l 3.1.1 Radioactive Liquid Effluents Miscellaneous wastes.from (a) radioactjge laboratory drains, (b) building and equipment drains and sumps, (c) regeneration solution for deborating demineralizers, (d) demineralizer backwash, and (e) radioactive laundry and-shower drains are processed through the miscellaneous liquid process system.
The miscellaneous processing system consists of the miscellaneous waste storage tank, cation demineralizer, miscellaneous waste evaporator, evaporator condensate demineralizer, and evaporator condensate storage tanks. The evaporator condensate demineralizers and storage tanks are common to both the primary coolant process system and the miscellaneous liquid process system. -
The contents of the evaporator condensate tanks may be transferred to the f
reac+.or coolant bleed tanks for feed to the primary system or to the nuclear sernce seawater system for release to the discharge canal.
The secondary drain tank receives liquid from the turbine building drains and sump, any leakage from the component cooling water (CCW) and l
service water (SW) systems and the steam generator blowdown. These liquids are not treated prior to collection in the secondary drain tank as the liquid radioactivity concentration is normally very low.
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I Cooling water is withdrawn from and returned to the Gulf of Mexico. The CCW and SW systems are both closed lecp systems, i.e., have no direct discharge pathway.
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The secon'dary drain tank discharges to the nuclear service seawater system. This discharge path is monitored by RM-L7, which will terminate the discharge upon reaching the alarm / trip setpoint. The auxiliary building radwaste line receives liquid wastes from the (a) laundry and shower tanks (A and B), and (b) radwaste evaporator condensate storage tanks (A and B). The discharge is monitored by RM-L?, which will terminate the discharge upon reaching the alarm / trip setpoint, and goes to the nuclear service seawater discharge system. The intake and discharge canals constructed for the plant are considered to be navigable waters and the State of Florida requires public access to navigable waters. The '.adioactive liquid effluents are released to the discharge canal as shown in Figure 1.
Figure 1 identifies the site boundary for liquid effluents as being in the discharge canal; however, it is not clear if it is a site boundary or an unnrstricted area within the site boundary. A schematic diagram of the liquid radwaste and the miscellaneous liquid process systems are shown in Figures 2 and 3, respectively.
3.1.2 Radioactive Gaseous Effluents q
The waste gas vent header system is essentially split into two sections:
i one section within the reactor building and one section within the auxiliary j
building. Condensing water vapor and liquids entering the section of the j
vent header system within containment drain to the reactor coolant drain 3
tank, while those entering the vent header system within the auxiliary I
building drain to the miscellaneous waste storage tank. The vent line from 1
the reactor coolant drain tank discharges to the miscellaneous waste storage j-tank. The gases from the miscellaneous waste storage tank and the three reactor coolant bleed tanks are joined and discharged to the suction of the waste gas compressors via an intermediate waste gas surge tank. The com-pressed gas portion of the waste gas system starts at the waste gas compres-sors and includes the three waste gas decay tanks (WGDT's)..
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Liquid Radwaste System Steam Generator
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Drain L7 Turbine Building Tank Sump
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600 gpm Nuclear Service Sea Mater Laundry and Discharge Shower Tanks A&B V
10,000 gpm Auxiliary Building RM (minimum)
Liquid Radwaste 12_
Effluent Line T
100 gpm Radwaste Evaporator Condensate Storage Tanks A & B
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Hiscellantous Liquid Process S.vstem i
- Radioactive Labora tory Drains
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Sumps Miscellancous Equipment Haste Storage Cation Miscellaneous Evaporator
-Sa Waste condensa te Drains and
- Tank Demin Sumps Evaporator Demin Regeneration
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Liquid Tanks Demineralizer Bottoms To Wet Backwash Solidification System
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Evaporator Evapora tor T
Condensate Condensate Storage Storage Tank A Tank B I
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)>C F{ i f \\r U Resctor Coolant Bleed Tanks 1 l t l 4
i 1 Figure 4 Gaseous Radwaste/ Effluent Treatment System RM RM Al 1 P i --t A 1 i Plenum ,1 --+ 6 P ~ Containment 4/4/t Auxiliary and Fuel Handling Building ? ? t I i r} C C C C l A A A A P l P P P sk .s ik n 4l', Waste _ /k From (_ A } RM
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g All j- [ cas ras. F ( g ) Collection r Tank _ Decay Header l Compressor ( C }- Tanks
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Gaseous discharge frcm the WGDT's go to the auxiliary and fuel handling building ventilation. This discharge ventilation air is processed through a ventilation exhaust treatment system (which is a train of prefilters, HEPA filters, and charcoal adsorbers) prior to release out the plant vent. The containment atmosphere is processed through a ventilation exhaust treatment system (also a train of prefilters. HEPA filters, and charcoal adsorbers) prior to release out the containment vent. Gaseous discharge from the WGOT's is monitored by RM-All which will terminate the discharge upon reaching the alarm / trip setpoint. The facility vent is a single cylinder which is divided by a septum creating two separate discharge pathways (f.e., plant vent and 4 containment vent). The plant vent is continuously monitored by RM-A2, which will also terminate the discharge of a WGDT upon reaching the alarm / trip setpoint of the noble gas monitor. The containment vent is continuously monitored by RM-Al when ventilation air is being discharged. This monitor will terminate the discharge when the alarm / trip setpoint is reached.Figure 1 shows the gaseous discharge point. Figure 4 shcws a schematic of the gaseo radwaste/ effluent treatment system./ 3.2 _ Radiological Effluent Technical Specifications, The following sub-sections describe the primary objectives of each section of the model RETS and a summary of the commitments of the Licensee's RETS. A cross reference between the numbering in the model RETS and the Licensee's RETS is contained in Table 1. The chronological sequence of the RETS review was described in the Plant-Specific Background, Section 1.3 of this report. i 3.2.1 Effluent Instrumentation The objective of the model RETS with regard to effluent instrumentation is to ensure that all significant liquid and gaseous radioactive effluents are monitored. The model RETS specify that al; effluent monitors be operable with periodic surveillance and that alarm / trip setpoints be detemined in order to ensure that offsite radioactive effluent concentrations do not exceed maximum permissible concentrations (MPC's) listed in 10 CFR Part 20. 13
1 J The Licensee has provided radiation monitors for potential liquid or gaseous effluent lines. In addition, automatic isolation is provided for major effluent lines such as the liquid radwaste, the WGDT effluent, and the containment purge. There are two radioactive liquid effluent release points at Crystal River Unit No. 3: the auxiliary building liquid radwaste effluent line and the secondary drain tank liquid effluent line. Both of these systems are monitored with adequate instrument surveillance being performed. The CCW and the SW systems are both closed loop systems. Potential leakage from these systems would be discharged through the secondary drain tank system. All gaseous effluent releases at Crystal River Unit No. 3 are discharged through either the auxiliary building and fuel hn..J11ng area vent or the reactor building purge exhaust vent. Both of these systems are monitored with adequate instrument surveillance beingTerformed. Both will isolate the release pathway on alarm of the noble gas monitor. In addition, a noble gas monitor on the WDGT discharge line will isolate this release on alarm. This instrument also has adequate surveillance requirements. The Licensee has stated that the concentration of radioactive material will be monitored "at all times," or "during releases" for batch releases. The setpoints at each release point are established to prevent exceeding the release concentrations for liquid releases or corresponding dose rates for gaseous releases of 10 CFR Part 20 in unrestricted areas. The setpoints for I the liquid and gaseous effluent instrumentation will be determined according to the Offsite Dose Calculation Manual (00CM). l The Licensee's RETS submittal on liquid and gaseous effluent monitoring j instrumentation has satisfi d the provisions and meets the intent of NUREG-0472. e 3.2.2 Concentration and Dose Rates of Effluents 3.2.2.1 Liquid Effluent Concentration l l The Licensee's RETS include a coninitment to maintain the concentration of l 14
l I radioactive liquid effluents released from the site to the unrestricted areas to within 10 CFR Part 20 limits, and if the concentration of liquid effluents j to the unrestricted area exceeds these limits, it will be restored without delay to a value equal to or less than the MPC values specified in 10 CFR Part 20. Both batch and continuous releases are sampled and analyzed peri-odically in accordance with a sampling and analysis program. Therefore, the Licensee's RETS submittal on liquid effluent concentrations meets the intent of NUREG-0472. 3.2.2.2 Gaseous Effluent Dose Rate The Licensee's RETS include a connitment to maintain the offsite gaseous dose rate from the site to areas at and beyond the site boundary to within 10 CFR Part 20 limits, and if the concentration of gaseous effluents exceeds these limits or the equivalent dose rate values, it will be restored without delay to a value equal to or less than thesilimits. The radioactive gaseous waste sampling and analysis program provides adequate sampling and analysis of the discharges. Therefore, the Licensee's RETS submittal on gaseous effluent dose rates meets the intent of NUREG-0472. 3.2.3 Offsite Doses from Effluents The objectives of the model RETS with regard to offsite dos'es from l effluents are to ensure that offsite doses are kept ALARA, are in compliance with dose specifications of NUREG-0472 and are in accordance with 10 CFR Part 50, Appendix I and 40 CFR Part 190. The Licensee's RETS include commitments (a) to meet the quarterly and yearly dose criteria for liquid effluents and to use the 00CM methodology for i determining the cumulative dose to individuals, (b) to. maintain the air doses I I for noble gases in unrestricted areas to those specified in 10 CFR Part 50, t 15
Appendix I, Section II.B., (c) to maintain the dose level to an individual frem release of Icdine-131, tritium, and particulates with half-lives greater than eight days to meet the design objectives of 10 CFR Part 50, Appendix I, Section II.C, and (d) to limit the annual dose to the maximally exposed member of the public due to releases of radioactivity and radiation from uranium fuel cycle sources to within the requireme~nts of 40 CFR Part 190. Therefore, the Licensee's RETS submittal on offsite doses from radio-active effluents meets the intent of NUREG-0472. 3.2.4 Effluent Treatment The objectives of the model RETS with regard to effluent treatment are to ensure that the radioactive waste treatment systems are used to keep releases ALARA and to satisfy the provisions for Technical Specifications governing the maintenance and use of radwaste treatment equipment. ~ The Licensee's RETS include a commitment to use the liquid and gaseous radwaste treatment systems when the projected monthly doses exceed 25 percent of the annual dose design objectives and to use the ventilation exhaust treatment system if the projected monthly dose exceeds the limits prescribed in the model RETS. The projections are to be made at lease once per 31 days, The Licensee's RETS include a commitment to prepare a special report if radwaste treatment is required before release and the radwaste treatment equipment is inoperable. 1 Therefore, the Licensee's RETS submittal on effluent treatment meets the f intent of NUREG-0472. ~~ - 3.2.5 Tank Inventory Limits The objective of the model RETS with regard to a curie limit on liquid-containing tanks is to ensure that in the event of a tank rupture, the concentra-tions in the nearest potable water supply and cne nearest surface water supply in an unrestricted area would not exceed the limits of 10 CFR Part 20, Appendix B, 1 16
Table II. The objective of the model RETS with regard to a curie limit on gas-containing tanks is to ensure that in the event of an uncontrolled release of the tank's contents the resulting total body exposure to an individual at the nearest exclusion area boundary will not exceed 0.5 rem. The Licensee's RETS does not include a specification on curie limits for outside tanks containing liquids. The Crystal River site is adjacent to the Gulf of Mexico and any water flows are to the Gulf; consequently, any leakage would not effect drinking or surface water supplies. Thus, a technical speci-fication is not required. The Licensee's RETS state that each WGDT is limited to less than or equal ts 39,000 curies (Xe-133 equiva~ient) which is less than the value corresponding to 0.5 rem at the exclusion area boundary. Surveillance on the WGDT's will be performed once per 24 hours during degassing periods and weekly at other times. ~ This surveillance is acceptable since the tank is sampled at the frequency required by the model RETS during degassing which is the time that has the greatest potential for exceeding the dose limit. Therefore, the Licensee's RETS submittal on tank inventory limits meets the intent of NUREG-0472. 3.2.6 Explosive Gas Mixtures The objective cf the model RETS with regard to explosive gas mixtures is i to prevent hydrogen explosions in the waste gas system. The Licensee's RETS include a comitment to maintain a safe concentration of oxygen in the WGDT's when the hydrogen concentration is equal to or greater E343 show that if H is less than or than four percent. Flamability curves 2 equal to four percent, oxygen can be at any concentration and a flamable i mixture will not result. Both hydrogen and oxygen are monitored and the system is being modified to sample exclusively from the in-service WGDT. 17
Although the Licensee does not have the number of channels specified in the model RETS, the number of channels and the modification to sample only the in-service WGDT were accepted on an interim basis at the site meeting [25], 3.2.7 Solid Radwaste System The objective of the model RETS with regard to the solid radwaste system is to ensure that radwaste will be properly processed and packaged before it is shipped from the plant to the burial site to satisfy the requirements of 10 CFR Part 20, Section 20.301 and 10 CFR Part 71.[35] The Licensee has committed to use the methods prescribed in a Process Control Program (PCP) to ensure that the requirements of 10 CFR Part 20 and 10 CFR Part 71 are met prior to shipment of radwaste from the site. The plant will use the Chem Nuclear Services waste solidification system which is currently being evaluated Q the NRC. Therefore, the Licensee's RETS submittal on solid radioactive waste meets the intent of NUREG-0472. 3.2.8 Radiological Environmental Monitoring Program c The objectives of the model RETS with regard to radiological environ-j mental monitoring are to ensure that (a) an adequate full-area coverage environmental monitoring program exists, (b) there is an appropriate i land use census, and (c) an acceptable interlaboratory comparison program exists. The monitoring program implements Section IV.B.2 of Appendix I l to 10 CFRPart 50, the land use census satisfies the requirements of 1 Section IV.B.3 of Appendix I to 10 CFR Part 50, and the requirement for jj participation in an approved interlaboratory comparison program is provided to ensure that independent checks are performed as part of the !] quality assurance program for environmental monitoring to demonstrate l that valid results are'obtained for Section IV.B.2 of Appendix I to 10 [ CFR Part 50. i l 18 i
The environmental monitoring program obtains milk samples frcm a control location as there are no other milk samples available within the radii specified in the model RETS. If milk samples become available, they will be identified in the land use census and included in the environmental monitoring program. Since milk sampling is not performed, emphasis should be placed on vegetation sampling in the two highest D/Q I sectors. There are no foods grown on land that is irrigated by water in which liquid plant wastes have been discharged. The Licensee performs a ganna spectral I-131 analysis an green leafy vegetable samples taken semi-innually during harvest. The collection frequency should be increased to monthly when available and the sample should be any broad leaf vegetation at two different offsite locations of highest predicted annual average ground level D/Q. The Licensee's RETS on a radiological environmental monitoring program have followed the model RETS and the BP8nch Technical Position on the subject issued November 1979,[29] as applicable to the site, and have provided an adequate number of sample locations for pathways identified except for the broad leafy vegetation. The Licensee's method of sample analysis and maintenance of the monitoring program satisfies the require-ments of Appendix I, 10 CFR Part 50. The Licensee's RETS contain a land use census specificaHon which requires the appropriate annual information for a pWR'. The RETS also state that the Licensee will participate in an NRC approved interlaboratory comparison program. Thus, the Licensee's RETS submittal for a radiological environmental program meets the intent of NUREG-04'/2 except for one item.- 3.2.9 Audits and Reviews The objective of the model RETS with regard to audits and reviews is to ensure that audits and reviews of the radwaste and environmental monitoring . programs are properly conducted. ~ i 19 j
e-The Licensee's administrative structure identifies the Plant Review Committee (PRC) and the Nuclear General Review Connittee (NGRC) as the two groups comparable to the Unit Review Group (URG) and the Company Nuclear Review and Audit Group (CNRAG), respectively. The PRC is responsible for reviewing every unplanned release of radioactive material and any changes to the ODCM and PCP, as required by the model RETS. The NGRC is responsible for reviewing the radiological environmental program and results thereof, the ODCM and implementing procedures, the PCP and ' implementing procedures, and the performance of activities required by the quality assurance (QA) program. These reviews are performed at the frequency required by the model RETS. These reviews were determined to be acceptable substitutes for the audit requirements described in the model RETS. The PRC and NGRC encompass the total reponsibility for reviews and audits specified in NUREG-0472. 3.2.10 Procedures and Records The objective of the n.odel RETS with regard to procedures is to ensure that written procedures be established, implemented and maintained for the f PCP, the ODCM and the QA program for effluent and environmental monitoring. j The objective of the model RETS with regard to records is to ensure that the ,l' documented records pertaining to the radiological environmental monitoring ,i program are retained. The Licensee's RETS include a connitment to establish, implement, and maintain written procedures for the PCP, ODCM, and QA programs. The Licensee's lJ RETS state that the records of the radiological environmental monitoring 't program will be retained for the duration of the facility operating license. { Therefore, the Licensee's RETS submittal on procedures and records meets the intent of NUREG-0472. 20 i , -. - -.. - ~
I 3.2.11 Reports The objective of the model RETS with regard to reporting requirements is to ensure that appropriate annual and semi-annual periodic reports and special reports are submitted to the NRC. The Licensee's RETS include commitments to submit the following reports: 1. Annual Radiological Environmental Operating Report This report includes summaries, interpretations and analysis of trends of the results of the radiological environmental surveillance program. The report also includes the results of the land use census and results of the participation in the interlaboratory comparison program. The report will be submitted prior to March 1 of each year. ~ 2. Semiannual Radioactive Effluent Release Report This report contains a summary of the quantities of radioactive liquid and gaseous effluents and is submitted within 60 days after January 1 and July 1 of each year. The report also includes a summary of solid waste shipped offsite, an assessment of offsite doses, doses to individuals due to their activities inside the site boundary, doses to the hypothetical worst case individual (including direct radiation), the prescribed meterological data, and a list,of unplanned releases. A listing of new locations required by the land use census as well as any changes to ODCM, PCP and the radioactive waste treatment system is included. i l l 3. Special Reports The Licensee's RETS include a connitment to file a special report within 30 days under the following conditions: Exceeding the liquid effluent dose limits according to e Specification 3.11.1.2. l i Exceeding the gaseous effluent dose limits according to e Specifications 3.11.2.2 and 3.11.2.3 1 1 21
3 Ercred4 ; 'be t:tal dese limits ac::7 ding to 2pecificatica 3.11.3. Exceecing tne reporting levels for tne radioactivity measured in environmental sampling program Specification 3.12.1.1. e When radioactive liquid or gaseous effluents require treatment before discharge and the waste treatment equipment is inoperable as specified in 3.7.13.2 and 3.17.13.3. Therefore, the Licensee's RETS submittal on reports meets the intent of NUREG-0472. 3.2.12 Other Administrative Controls An objective of the model RETS in the administrative controls section is to ensure that any changes to the PCP and 00CM and major changes to the radio-active waste treatment systems are reported to the NRC. Such changes shall be reviewed and accepted by the URG before, implementation. i The Licensee's RETS state that the aforementioned changes will be reported to the NRC after review and acceptance by the PRC. Therefore, the Licensee's RETS submittal for these administrative 'j controls meets the intent of NUREG-0472. 3.3 0FFSITE DOSE CALCULATION MANUAL ! -j.: ,] As specified in NUREG-0472, the ODCM is to be developed by the Licensee i to document the methodology and approaches used to calculate offsite doses and maintain the operability of the effluent system. As a minimum, the 00CM '4 should pilvide equations and methodology for the following topics: e alarm and trip setpoints for effluent instrumentation e liquid effluent concentration in unrestricted areas gaseous effluent dose rate or concentrations at or beyond the e l site boundary U 22
liquid and gaseous effluent dose contributions e total dose compliance, including direct shine e liquid and gasacus affluent dose projections. a 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 00CM. 3.3.1 Evaluation The Licensee's ODCM satisfies the equation in the addendum of NUREG-0133 to determine the alarm and trip setpoints for the liquid effluent monitors. This assures that the alarm and trip actions will occur prior to exceeding the 10 CFR Part 20, Appendix B, Table II values at the discharge point to the unrestricted area. The alarm and trip setpoints for the gaseous effluent monitors are calculated to assure that alarm and trip actions will occur prior to exceeding the limits set in 10 CFR Part 20 for annual dose rate to unrestricted areas. The Licensee uses equations similar to those contained in NUREG-0133 with the dose rate values identified in NUREG-0472. The Licenste's ODCM contains the methods and calculational relation-ships that are used to compare the radioactivity concentrations at the l point of release to the 10 CFR Part 20 limits prior to the release and i after the release. ) The Licensee's ODCM states that noble gas discharges are assured to ' ' within the NUREG-0472 dose rate limits by correctly determining the setpoints for the noble gas monitors. Therefore, additional sampling and analysis are not required. The dose rate due to the release of I-131, tritium, and particulates with half-lives greater than eight days is assured to be within the NUREG-0472 limit of 1500 mrem per year to a child via the 23
i M 3ia:Ma ;nhway by c.:ic:.init:g the d::a r;;a cua to :tia actual release using the highest calculated annual average dispersion parameter X/0 used for estimating dose to an individual. The Licensee's ODCM demonstrates compliance with 10 CFR Part 50, Appendix I by calculating the monthly dose commitments for liquid and gaseous effluents at least once per 31 days. The calculated cumulative values are compared to the quarterly and annual limits to demonstrate compliance. The doses due to liquid releases are calculated using the adult ingestion pathway since drinking water is not affected by plant discharges. The doses due to gaseous releases are calculated using the inhala' tion, ingestion, and ground plane pathways. The Licensee's ODCM contains the method used to project the monthly doses due to anth.ipated liquid and gaseous releases. The dose projection is made at least once every 31 days. If the projected values exceed 25 percent of the annual dose prorated monthly the radwaste tr,gatment system must be operated. The Licensee's ODCM contains a description and map of the sample loca-tions for the environmental monitoring program. In addition, the ODCM contains block diagram descriptions of the flow paths and treatment systems for the liquid and gaseous releases. -4 The Licensee's ODCM for Crystal River Unit No. 3 is in compliance with the NRC requirements and uses methods consistent with the methodology and guidance prescribed in NUREG-0133. 4ip 3.4 PROCESS CONTROL PROGRAM l NUREG-0472 specifies that the Licensee develop a PCP to ensure that the jf processing and packaging of solid radioactive wastes will be accomplished I in compliance with 10 CFR Part 20,10 CFR Part 71, and other federal and state regulations or requirements governing the offsite disposal of the low-level radioactive waste. l l 24 1
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 Licentec. S c criteria u:ad for the PCP are to address only today's requirements. The uncertainty about PCP requirements results from the recent promulgation of 10 CFR Part 61, " Licensing Requirements for Land Disposal of Radioactive Waste." The NRC staff's technical positions are presently being developed by the Division of Waste Management [33], 3.4.1 Eval uat io,n, The Licensee did not submit a PCP for review. A PCP will be submitted to the NRC for review and approval.
4.0 CONCLUSION
S The Licensee's proposed RETS and ODCM were reviewed and evaluated and the following conclusions were reached: ~ The Licensee's proposed RETS for the Crystal River Unit No. 3 e Nuclear Generating Plant, submitted January 17,1983, meets the intent of the NRC staff's " Standard Radiological Effluent Technical Specifications," NUREG-0472 except for the item in the radiological environmental monitoring program. ~ The Licensee's 00CM, submitted.May 1983 uses documented and approved e methods that are applicable to Crystal River Unit No. 3 and are consistent with the criteria of NUREG-0133. Discrepancies are identified in the cover letter for this report. The Licensee did not submit a PCP for review. A PCP will be e ) submitted to the NRC for review and approval. i A correspondence batween (a) NUREG-0472, (b) the Licensee's current RETS, and (c) the Licensee's proposed RETS is shown in Table 1. A more detailed explanation of how each Specification in the Licensee's RETS meets the intent of NUREG-0472 is contained in Appendix A. i 25
TABLE 1. CORRESPONDENCE OF PROVISIONS OF NUREG-0472, THE LICENSEE'S CURRENT TECHNICAL SPECIFICATIONS AND THE LICENSEE'S PROPOSAL FOR Car 5iAL KivdM UNIT NO. 3 Current Technical Licensee NURE - Specification Proposal RETS Requirement 0472 Appendix B (Section) (Section) Effluent 3.3.3.10 2.4.1 3.3.3.8 Instrumentation 3.3.3.11 2.4.2 3.3.3.9 Concentrations 3.11.1.1 2.4.1 3.11.1.1 3.11.2.1 2.4.2 3.11.2.1 Offsite Ooses 3.11.1.2 2.4 3.11.1.2 3.11.2.2 2.4 3.11.2.2 3.11.2.3 3.11.2.3 3.11.4 3.11.3 Effluent Treatment 3.11.1.3 3.7.13.2 3.11.2.4 3.7.13.3 Tank' Inventory 3.11.1.4 Limits 3.11.2.6 2.4.2 3.7.13.1 m Explosive Gas 3.11.2.5 3.7.13.5 Mixtures Solid Radwaste 3.11.3 2.4.3 3.7.13.4 Environmental 3.12.1 3.2 3.12.1.1 } Monitoring Land Use Census 3.12.2 3.12.1.2 I j Interlaboratory 1 Comparisons 3.12.3 3.12.1.3 l' Audits and Reviews 6.5.1 5.3 6.5.1 l. 6.5.2 6.5.2 1 : Procedures and Records 6.8,6.10 5.5 6.8.1 Reports 6.9 5.6.1 6.9.1.5.c 5.6.1 6.9.1.5.d Other Administrative 6.13,6.14,6.15 6.14,6.15,6.16 Controls 1 Section number sequence is according to NUREG-0472, Rev. 3, Draft 7'. 2 Being Revised or Deleted 26 e
5. REFERENCES I 1. United St:te: Mucle:r acgulatory Ccm.ission, Standard Radiological Cf 9uent Tcchn?cf cecifications roc ;:casor,m eter -ac:ces, huREG-0472, Revision 2, July 1979. 2. United States Office of The Federal Register, 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." 3. United States Office of the Federal Register, Title 10, Code of Federal Regulations, Part 50, Section 50.36a, " Technical Specifications on Effluents from Nuclear Power Reactors." 4. United States Office of the Federal Register, Title 10, Code of Federal 4 Regulations, Part 50, Appendix I, Section V.B., " Effective Dates." 5. United States Office of the Federal Register, Title 10, Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation." 6. United States Office of the Federal Register, Title 40, Code of Federal Regulations, Part 190, " Environmental Radiation Protection Stanoaros for Nuclear Power Operations." 7. United States Office of the Federal Register, Title 10, Code of Federal Regulations, Part 50, Appendix A, " General Design Critera for Nuclear Power Plants." 8. United States Office of the Federal Register, Title 10, Code of Federal -} Regulations, Part 50, Appendix B, " Quality Assurance Criteria for Nuclear - } Power Plants and Fuel Reprocessing Plants." i. .l 9. United States Nuclear Regulatory Comission, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, NUREG-0133, October 1978.
- 10. United States Nuclear Regulatory Comission, Standard Radiological Effluent Technical Specifications for Boiling Water Reactors, NUREG-0473, Revision 2, July 1979.
11. C. A. Willis and F. J. Congel, " Summary of Draft Contractor Guidance of RETS," AIF Environmental Subcommittee Meeting. Washington, D.C., I l May 19, 1982. i 27
12. F. J. Congel, memo to RAB Staff (NRC), Interim Changes in the Model RETS, August 9,1982. 13. United States Nuclear Regulatory Commission, Standard Radiological Effluent Technical Soecifications for Pressurized Water Reactors, NUREG-0472, Revision 3, Oraft 7', September 1982. l i 14. NUS Corporation, letter of transmittal, Appendix I Analysis for Crystal River Nuclear Unit, NUS-1721 (Revision 1), May 28,1976. 15. R. Vollmer, letter of transmittal, Supplement No. 2 to the Safety Evaluation Report for Crystal River Unit No. 3 With Respect to Appendix I to 10 CFR Part 50, August 30, 1976. 16. R. M. Bright, letter of transmittal, Technical Specification Change Request No. 36, February 13, 1979. 17. F. B. Simpson, letter of transmittal, Transmittal of Questions for Crystal River RETS Review, SIM-28-81, November 23, 1981. ~ 18. W. Serrano, letter of transmittal, Transmittal of Questions for Crystal River RETS Review, Serr-ll-82, September 14, 1982. 19. E. W. Ford (NUS) and S. W. Duce (EG&G), telephone conference, December 13, 1982. 20. C. A. Willis (NRC), S. W. Duce (EG8G), and W. Serrano (EG8G), telephone + l conference, December 13, 1982. j 21. G. R. Westafer, letter of transmittal, Technical Specification Change j Request No. 36, January 17, 1983. 22. G. R. Westafer, letter of transmittal, Offsite Dose Calculation Manual, May 1983. t 23. United States Office of The Federal Register, Title 10, Code of Federal Regulations, Part 20, Appendix B, " Concentrations in Air and Water r Above Natural Background." ~ 24. C. A. Willis, letter to F. B. Simpson (summarizing changes to RETS requirements following meeting with Atomic Industrial Forum), November 20, 1981. 28 1'
e 25. W. E. Kregar (NRC), memo to R. J. Mattson (NRC), Plans for Dealing witn s 4, +r---4-- u ~ ~4 c u : ,, e p - 6 4.f e en :::y ~ Specifications (RETS), December 14, 1981. C. A. Willis and F. J. Congel, " Status of NRC Radiological Effluent 26. Technical Specification Activities," Atomic Industrial Forum Conference on HEPA and Nuclear Regulations, October 4-7, 1981. C. A. Willis, memo to P. C. Wagner, Plans for Implementing Radiological 27. Effluent Technical Soecifications for Operating Reactors, Novemoer 4, 1981. W. P. Gamill (NRC), memo to P. C. Wagner (NRC), Current Position on 28. Radiological Effluent Technical Specifications (RETS) including Exolosive Gas Controls, October 7, 1981. United States Nuclear Regulatory Comission, Radiological Assessment 29. Branch Technical Position, An Acceptable Radiological Environmental Monitoring Program, November 1979. United States Nuclear Regulatory Comission, Methods for Demonstrating 30. LWR Comoliance with the EPA Uranium FuelTycle Standard (40 CFR Part 190), NUREG-0543, Feoruary 1980. United States Nuclear Regulatory Comission, Branch Technical Position, 31. General Contents of the Offsite Dose Calculation Manual, Revision 1, February 8, 1979. Regulatory Guide 1.109, " Calculation of Annual Doses to Man from Routine 32. Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, " Revision 1, U. S. Nuclear Regulatory Comission, Washington, D. C. 20555, October 1977. .t 33. C. A. Willis, letter of transmittal, Guidance on the Review of the jl Process Control Programs (PCP), January 3, 1983. 34. C. A. Willis (NRC) and J. S. Boegli (NRC), memo to W. P. Gamill (NRC), t Tech Spec on Control of Explosive Gas Mixtures in the Waste Gas System at TMI-1, July 22, 1981.
- 35. United States Office of the Federal Register, Title 10, Code of Federal Regulations, Part 71, " Packaging of Radioactive Material For Transport and Transportation of Radioactive Material Under Certain Conditions."
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