ML20211B552
| ML20211B552 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/09/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20211B524 | List: |
| References | |
| NUDOCS 8702190443 | |
| Download: ML20211B552 (27) | |
Text
UNITED STATES E' '
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NUCLEAR REGULATORY COMMISSION q$
WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGUALTION OF THE REVISED OFFSITE DOSE CALCULATION MANUAL (REV. 7)
AND PROCESS CONTROL PROGRAM (PEV. 0)
FLORIDA POWER CORPORATION CRYSTAL PIVER NUCLEAR GENERATING PLANT, UNIT 3 DOCKET NO. 50-302
1.0 INTRODUCTION
On June 27, 1984, NRC staff issued Amendment No. 69 to Facility Operating License No. DPR-72 for Crystal River Nuclear Generating Plant, Unit 3.
This action provided the Padiological Effluent Technical Specifications (RETS) necessary to implement the requirements of 10 CFR Part 50, Appendix I.
Technical Specifications (TS) 3.7.13 and 3.11 reference the Process Control Program (PCP) and the Offsite Dose Calculation Manual (0DCM). Changes to the PCP and ODCM are addressed in TS 6.14 and 6.15, respectively.
2.0 EVALUATION The Safety Evaluation (SE) enclosed with the June 27, 1984 NRC letter to i
Florida Power Corporation concerning the issuance of Amendment No. 69 to the Facility Operating Licensing included the NRC technical assistance contractor's Technical Evaluation Report (TER) which stated that the Crystal River 00CM (docketed submittal by Florida Power Corporation letter dated April 27, 1983) uses methods consistent with the guidance described in NUREG-0133.
It also noted that the licensee did not submit a PCP for staff review.
8702190443 B70209 PDR ADOCK 05000302 p
. The SE indicated that the staff agrees with the conclusion contained in the TER with the exception that contrary to the TER firding, the licensee is presently operating under a PCP that is available for review by the NRC at any time, and that this is acceptable under NRC guidelines.
Following issuance of the above mentioned SE, the only reported revisions to the Crystal River ODCM and PCP were provided in the Crystal River Semiannual Radioactive Effluent Release Reports for July through December 1984, for 1985, and for January through June 1986 (0DCM, Rev. 2 through Rev. 7) and July through December 1985 (entirely new PCP, Rev. 0). These documents have been reviewed for NRC staff by EG&G Idaho, Inc., under a technical assistance agreement. The contractor's TERs are enclosed as Supplements 1 and 2 to Appendix D from EGG-PHY-7346 and provide technical evaluations of the conformity of the licensee's subnittals with the respective NRC criteria. They are considered a part of this SE.
The staff has reviewed the contractor's TER on the ODCM (Rev. 7) and agrees with the conclusion that the revised OPCM generally uses documented and approved methods that are consistent with the guidelines in NUREG-0133,
" Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants." However, several deficiencies were noted:
1)
The setpoint specification for liquid effluent monitors on page 4 should include the total concentration of 2x10-4 uCi/ml for dissolved or entrained noble gases.
2)
The setpoint expressions for the liquid and gaseous effluent monitors in Sections 1.4-1 through 1.4-7 contain the term 3.3 IBkg which shouldbe3.3IBkg/t,wheretisthetimeofbackgroundcounting.
3)
In Section 1.4-1, the use of the vacuum terms should be clarified in the expression for the Reactor Building Monitor setpoint calculation, and clarification should be provided on whether the units are absolute or gauge pressure.
4)
In Section 1.4-4, the significance of 15 cfm to the vent should be clarified.
5)
The phrase "whichever formula below" should be deleted from Part II in Dose Projection Methodology Section 2.2-1.
6)
The licensee should consider rewriting the dose projection equation in Sections 2.2-1 and 2.2-2.
As written, one day into the quarter results in a dose projection of 31 times the previous quarterly dose.
7)
Clarification should be provided on how the completion of Table 2.3 will be used to demonstrate compliance to the calendar year dose limits or to determine if a special report is required as described in Technical Specification 3.11.3.
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8)
A summation sign should be included in the dose calculation exoression in Section 4.3-2.
9)
Section 4.3-1 containing the air dose calculations should correct the definitions for Dy and D s to state that these terms are doses to air and not doses to an individual.
- 10) Table 4.4-17 contains dose factors for Ag-110m. Clarifications should be provided on what bioaccumulation factor for Ag was used to determine these values.
- 11) The licensee should be aware that the acceptable bioaccumulation factor for phosphorus in freshwater fish has been reduced to 3,000 pCi/kg per pCi/ liter. The previously acceptable value from Regulatory Guide 1.109, Table A-1, is 100,000 pCi/kg per pCi/ liter.
See NUREG/CR-3981, " Bioaccumulation of P-3? in Bluegill and Catfish,"
February 1985.
The licensee should correct these deficiencies in a future revision of the ODCM.
The staff has reviewed the contractor's TER on the new PCP (Rev. 0) and agrees with the conclusion that the document generally is consistent with current NRC criteria and is, therefore, acceptable.
However, several deficiencies were noted:
5 1)
Clarification should be provided on why the Bartlett Nuclear, Inc.,
PCP is referenced in Section 2.0.
If the Bartlett PCP is referenced, the Bartlett topical report number and status 0f NRC approval should be included.
2)
In Section 5.3.1.2, clarification should be provided on whether the sample is obtained from the waste tanks or from the solidification container. A sample obtained from the solidification container would be a better representative of the final waste form.
3)
Solidification Test Frequency Section 5.3.2.2 should be e panded to include the testing of the last batch in the event that ten sequential batches of like waste are not processed.
4)
A sketch should be included in the PCP of the solidification and dewatering systems identifying plant interfaces with other systems and identifying critical components of the systems that monitor process parameters.
5)
Clarification should be provided on whether waste is shipped to burial sites in states other than South Carolina.
The licensee should correct these deficiencies in a future revision to the PCP.
It should be noted that the acceptability of the PCP is based o'n currently available NRC guidance that does not fully incorporate consideration of the requirements of 10 CFR Part 61, which became l
4 effective in 1983. A future revision of the PCP should provide fully detailed inf'ormation on assuring compliance with the requirements of 10 CFR 20.311 regarding classification of waste according to 10 CFR 61.56 and waste characteristics requirements of 10 CFR 61.55. NRC guidance on the above is scheduled for issuaece by early 1988.
3.0 CONCLUSION
Based on the above, the staff concludes that the Crystal River Nuclear Generating Plant, Unit 3 revised ODCM (Rev. 7) and new PCP (Rev. 0) 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 Appen-dix I, governing the release of radioactive materials.
I, Principal Contributor:
Charles Nichols Dated: February 9,1987
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CONTRACTOR'S TECHNICAL EVALUATION REPORT ENCLOSURE 2 4
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APPENDIX D i
EVALUATION OF CHANGES TO-THE ODCM (Crystal River Unit 3) 3 l
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INTRODUCTION
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purpose 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 Crystal River Unit 3.
NRC approval of the original ODCM is contained in an internal NRC letter dated May 19,1983.[13 The ODCM is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with 10 CFR 50, Appendix I requirements.[2]
1 Scope of Revjew.
As specified in NUREG-0472[3] and NUREG-0473,[43 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:
o Alarm and trip setpoints on effluent instrumentation o
Liquid effluent concentrations in unrestricted areas o
Gaseous effluent dose rates at or beyond the site boundary o
Liquid and gaseous effluent dose contributions o
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-Specific Background On behalf of Crystal River Unit 3, the Florida Power Corporation '(FPC)
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submitted revisions to the existing ODCM in Semiannual Radioac,tive Effluent Release reports. The Licensee issued Revisions 2 and 3 in the second six-months report for 1984,[5] Revision 4 in the first six-months report for 1985,[6] and Revisions 5 and 6 in the second six-months report for 1985.[7]
The Licensee's changes to the ODCM were transmitted to an independent review team at the Idaho National Engineering Laboratory (INEL) for review. Since EG&G Idaho did not have an up to date copy of Revisions 0 and 1, the-Licensee mailed a complete ODCM directly to EG&G Idaho. The mailed copy included Revision 7 dated 4-8-86 which should be reported in the first six-months semiannual report for 1986. A review was made of the mailed copy including Revision 7 and the results and conclusions of the
' evaluation are presented in this supplement.
REVIEW CRITERIA Review criteria for 00CM were provided by the NRC in three documents:
NUREG-0472, RETS for PWRs[3]
NUREG-0473, R,ETS for BWRsE43 NUREG-0133, Preparation of RETS for Nuclear Power Plants.[8]
In the 00CM review, the following NRC guidelines were also used:
" General Contents of the Offsite Dose Calculation Manual,"
Revision 1,E93 and Regulatory Guide 1.109.[10] The ODCM format is left to the Licensee and may be simplified by tables and grid printouts.
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EVALUATION The Licensee has followed the methodology of NUREG-0133[8] 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,[113 will not be exceeded by discharges from various liquid or gaseous release points. There are two monitored sources of radioactive liquid effluents to the Nuclear Service Sea Water Discharge line which is in turn released to the condenser cooling discharge canal. The first source is a continuous release of the Secondary Drain tank which contains liquid from the turbine building sump. The second source are batch releases of the evaporator condensate storage tanks and baten releases of the laundry and shower sump tanks.
The continuous release is monitored with radiation monitor RM-L7 and the batch releases are monitored with radiation monitor RM-L2 before release to the Nuclear Service Sea Water Discharge line as shown in Figure 2.3-2 of the ODCM. The Licensee's method for setpoint calculations for the liquid effluent monitors is consistent with the guidelines in the addendum
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to NUREG-0133.
There are two radioactive gaseous effluent release points at Crystal River Unit 3 as shown in Figure 2.3-1 of the ODCM: the reactor building purge exhaust duct, and the auxiliary building and fuel handling area exhaust duct. To ensure the combined release from both vents does not l
exceed the release limit, the alarm setpoints are reduced by an administrative factor. The Licensee's method for setpoint calculations for gaseous effluent monitors is consistent with the guidelines of NUREG-0133 using the dose rate limits of NUREG-0472.
The Licensee's ODCM contains the methods and calculational relationships that are used to compare the radioactivity concentrations in liquid effluents at the point of release to the 10 CFR 20 limits prior to the release.
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The dose rate due to noble gas releases is assured to be within the NUREG-0472 dose rate limits by correctly calculating the setpoints for the noble gas monitors. 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 any organ via the inhalation pathway due to actual releases using the highest calculated annual average X/Q. The bases statement for Dose Rate Technical Specification 3.11.2.1 states the gaseous releases shall restrict the corresponding thyroid dose rate to a child via the inhalation pathway to less than 1500 mrem / year.
Methodology, based on dose projections, to determine required use of the liquid and gaseous radwaste treatment systems is described in the 00CM. Since the liquid and gaseous radwaste treatment systems are in use at all times, the projections will be made only if operations or conditions deviate from normal. However, the Licensee should reconsider the expression for the dose projection in Sections 2.2-1 and 2.2-2.
The 00CM contains simplified flow diagrams illustrating the treatment paths and the components of the radioactive liquid and gaseous waste management systems. A diagram for the solid waste management system is not included with the ODCM since it belongs in the Process Control Program.
Doses to a member of the public due to radionuclides identified in liquid effluents are calculated monthly to show compliance with 10 CFR 50 Appendix I.
The Licensee identifies the fish consumption pathway for the dose calculations assuming the adult as the maximum exposed ir.dividual.
The dose calculation methodology in the ODCM due to liquid effluents satisfies the relationships presented in NUREG-0133.
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Air Doses resulting from the release of noble gases are calculated monthly to show compliance with 10 CFR 50 Appendix I.
The highest calculated annual average relative concentrations for X/Q are used to calculate the maximum air doses. Doses resulting from the release of I-131, tritium, and particulates with half lives greater than eignt days are calculated monthly to show compliance with 10 CFR 50 Appendix I.
The Licensee identifies the inhalation, ingestion, and ground plane pathways for all age groups. The ingestion pathway includes grass-cow-milk, grass-cow-meat, and vegetation. The dose calculation methodology in the 00CM due to radioactive gaseous effluents satisfies the relationships presented in NUREG-0133.
The Licensee's Technical Specification 3.11.3 states that compliance I
.to 40 CFR 190 will be demonstrated in a special report within 30 days if the 10 CFR 50 Appendix I limits are exceeded by a factor of two. The evaluation shall include the contribution from direct radiation.
Section 2.3 of the 00CM refers to Table 2.3-1 of the ODCM.
It is not I
clear how the results of completed Table 2.3-1 will support the Technical f~
Specification.
l Specific parameters of distance and the direction sector from the centerline of a reactor and additional information have been provided for each and every sample location identified in the RETS Environmental j
Monitoring Table 3.12-1.
The data are contained in ODCM Tables 5.1-1, j
5.1-2, and 5.1-3 and in 00CM Figures 5.1, 5.2, and 5.3.
In summary, the Licensee's 00CM as revised uses documented and f
approved methods that are generally consistent with the methodology and guidance in NUREG-0133, and therefore is an acceptable reference.
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CONCLUSION The Licensee's ODCM through Revision 7 has been reviewed. The revised ODCM uses documented and approved methods that are in general consistent with the criteria of NUREG-0133 with the following exceptions:
o The setpoint specification for liquid effluent monitors on page 4 does not include the total concentration of 2x10'4 uCi/ml for dissolved or entrained noble gases.
o The setpoint expr==stoins, for the liquid and gaseous affluent monitors in Sections 1.4-1 through 1.4-7 contain the term 3.3 / Bkg ' which should be 3.3 v Bkg/t' where t is the time of f
background counting.
o In Section 1.4-1, the use of the vacuum terms is not clear in the expression for the Reactor Building Monitor setpoint calculation and are the units absolute or gauge pressure?
o In Section 1.4-4 what is the significance of 15 CFM to the vent?
o The phrase "whichever formula below" should be deleted from Part II in Dose Projection Methodology Section 2.2-1.
o The Licensee should strongly consider rewriting the dose projection equation in Sections 2.2-1 and 2.2-2.
As written, one day into the quarter results in a dose projection of 31 times the previous quarterly dose.
o It is not clear how the completion of Table 2.3-1 will be used to demonstrate compliance to the calendar year dose limits or to determine if a special report is required as described in Technical Specification 3.11.3.
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o Typo: A summation sign is missing in the dose calculation expression in Section 4.3-2.
o Section 4.3-1 containing the air dose calculations sho.uld correct I
the definitions for D and D to state these terms are y
g doses to air and not doses to an individual.
o Table 4.4-17 contains dose factors for Ag-110m. What bleaccumulation factor for Ag was used to determine these values?-
o The Licensee should be aware that the bioaccumulation factors for phosphorus have been reduced significantly from the values of---
Table A-1 in Reg. Guide 1.109.
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REFERENCES 1.
Letter from D. R. Muller-(NRC) to G. C. Lainas (NRC),
Subject:
DSI Safety Evaluation and Environmental Consideration of Crystal River Unit 3 Supporting a License Amendment (RETS, MPA.
Item A-02), May 19, 1983.
2.
Title 10, Code of Federal Regulations, Part 50, Appendix 1, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion, 'As Low As Is Reasonably Achievable,' for 4
Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents".
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3.
U. S. Nuclear Regulatory Ccmmission, " Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors," USNRC NUREG-0472, Revision 3, Draft 7",' September 1982.
i 4.
U. S. Nuclear Regulatory Commission, " Standard Radiological Effluent Technical Specifications for Boiling Water Reactors," USNRC NUREG-0473,
- I Revision 3, Draft 7", September 1982.
5.
Crystal River Unit 3 Semiannual Radioactive Effluent Release Report for Second Six Months of 1984.
6.
Crystal River Unit 3 Semiannual Radioactive Effluent Release Report for j
First Six Months of 1985.
7.
Crystal River Unit 3 Semiannual Radioactive Effluent Release Report for Second Six Months of 1985.
l l
8.
U. S. Nuclear Regulatory Commission, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants, A Guidance Manual for Users of Standard Technical Specifications," USNRC NUREG-0133, October 1978.
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U. S. Nuclear Regulatory Commission, " General Contents of the Offsite Dose Calculation Manual," Revision 1, Branch Technical Position, Radiological Assessment Branch, NRC, February 8, 1979.
- 10. U. S. Nuclear Rebulatory Commission, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I," USNRC Regulatory Guide 1.109, Rev. 1, October 1977.
- 11. Title 10, Code of Federal Reoulations, Part 20, " Standards for-.
Protection Against Radiation."
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INTRODUCTION purpose of Review The purpose of this document is to report the results of a review of the Process Control Program (PCP) as revised by the Florida Power Corporation (FPC), the Licensee of Crystal River Unit 3.
The PCp is a supplementary document for implementing the Radiological Effluent Technical Specifications (RETS) in compliance with Standard Review Plan 11.4E13 and Branch Technical Position ETSB-11-3.[2]
Scope of Review As specified in NUREG-0472[3] and NUREG-0473,[43 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 satisfactorily accomplished. As a minimum, the PCP should provide commitments and information regarding the following topics:[5]
o Processing and packaging of liquid / wet wastes o
Processing and packaging of other wet wastes o
Treatment of oily wastes o
Block diagram sketches of these systems o
Considerations of As Low As Is Reasonably Achievable (ALARA).
6 D2-3
Plant-Soecific Backaround On behalf of Crystal River Unit 3, the Florida Power Corporation (FPC) submitted a revised PCP with the second six-months Semiannual Radioactive Effluent Release Report for 1985[6]. An entire revised PCP (Revision 0) was submitted which supercedes the previous PCP since the FPC changed from a Chem Nuclear Solidification System to a Bartlett Nuclear System.
The Licensee's Semiannual Reports which included the revised PCP were transmitted to an independent review team at the Idaho National Engineering Laboratory (INEL) for review. The PCP review was subsequently conducted by EG&G Idaho (EGG), and the results and conclusions of the PCP evaluation are presented in this document, m
REVIEW CRITERIA NUREG-0472[3] and NUREG-0473[43 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,[73 10 CFR 71,[8] and other Federal and State regulations or requirements governing the offsite disposal of the low-level radioactive waste.
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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 guidelines [5] and do not include criteria to demonstrate compliance to 10 CFR 61.[93 The PCP should include, but is not limited to, the following:
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o A commitment that all liquid / wet wastes shall be solidified prior
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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.
A general description of the laboratory mixing of a sample of o
waste to arrive at process parameters prior to commencing the solidification process.
o A general description of the solidification process including type of solidification agent, process control parameters, parameter boundary canditions, proper waste-form properties, and assurance that the sclidification systems are operated within the established prccess 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 l
detected.
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If the solidification process is exothermic, the process control l
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.
A general description of the dewatering technique and control o
parameters for other wet wastes.
02-5
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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 for 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.
l TECHNICAL EVALUATION The Licensee processes liquid or wet radioactive wastes by solidifica' tion or dewatering to meet the disposal criteria of the low-level radioactive waste burial facilities.
As written the text implies that the solidification and dewatering operations are owned and operated by the Licensee. However, Section 2.0 includes reference to the Bartlett PCP.
It may be that Bartlett Nuclear, Inc. provides contracted services for operation of the compactor'for the packaging of dry active waste or that the solidification / dewatering equipment was purchased from Bartlett and the Licensee's procedures uses excerpts from the Bartlett PCP. The purpose for reference to the Bartlett PCP is not clear. Additionally, the reference should include the Bartlett 4
Topical Report number and state whether the report has NRC approval.
System Description Section 5.1 includes a general description of the j
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solidification process which is designed to solidify radioactive waste including, boric acid waste, evaporator bottoms, ion exchange resin, sludges, oils and various solids for incapsulation and immobilization.
The waste products are solidified using the commonly available Portland I cement modified with the necessary process additives. Corrective Action Section 5.3.4 provides assurance that the solidification system will be operated as designed and Administrative Controls Section 4.0 identifies l
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Administrative Controls to assure that operating procedures will be followed. Acceptance Criteria Section 5.3.3 provides assurance that the
. final waste form will be visually inspected and tested to ensure the i
product is a free-standing monolith with less than 0.5% free-standing liquid by volume.
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Solidification Sections 5.2 and 5.3 outlines the program for sample analysis and solidification testing prior to full scale solidification to ensure that proper solidification of the waste will result.
1 Solidification Testing Section 5.3.1.2 requires a representative sample of waste to to be solidified during full-scale solidification.
However, it is not clear whether the sample is obtained from the waste tanks or from the solidification container. A sample obtained from the solidification container would be a better representative of the final waste form. Solidification Test Frequency Section 5.3.2.2 requires testing of at least one representative test specimen from every tenth batch of each type of waste where batch is defined in Documentation Section 4.3.
The requirement should be expanded to include the testing of
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the last batch in the event ten sequential batches of like waste are not processed. Corrective Action Section 5.3.4 identifies Administrative Controls to assure that corrective action will be taken if any test
, specimen fails to solidify.
i The PCp does not contain a sketch or diagram of the solidification and dewatering systems identifying plant interfaces with other systems and j
identifying critical components of the systems that monitor process parameters, e.g., flow meters, level indicators, torque meters, etc.
However, Operation Procedure 413 gives an overview of the flow paths of liquid wastes from the various tanks to the solidification apparatus and the procedure also gives the valve and pump lineups, and provides an overview of the resin flow path from the spent resin tank to the shipping container and the return path of the excess water.
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e The PCP identifies certain process parameters that provide boundary conditions for the solidification process such as cure time, pH, waste tank circulation requirements, and waste to cement ratios for different waste types. However, the PCP does not identify the range permitted for
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oils, chlorides, boron, and other wastes identified in Section E.2.2.
Regulatory Requirements Section 3.5 lists certain restrictions from the South Carolina Department of Health and Environmental Control. The restrictions include the requirement for the solidification of liquids and permission to use high integrity containers for solidified waste forms and for dewatered resins. However, it is not clear if the Licensee ships waste to burial sites in other states or just South Carolina.
Dewatering Section 6.0 includes an acceptable description of the bead resin dewatering systems which is comprised of two separate processes:
one for the secondary cycle condensate resin and the other for primary or radioactive waste ion exchange resin. The description includes a brief description of the waste transfer operation, a brief description of the system, and a review of the dewatering routine to be followed along with the acceptance testing and corrective action to be taken if the acceptance criteria are not met.
A sketch of the dewatering system is not included along with identification of interfaces to other plant systems and identification of critical components that monitor process parameters.
In summary the PCP contains commitments generally consistent with the guidelines of Reference 5 and is therefore an acceptable reference.
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CONCLUSION The Licensee's Revision 0 -
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. solidification of liquid and..
.ioactive wastes and for the dewatering i
of bead resins submitte-ith the second six months Semiannual RadIioactive i
Effluent Release Report for 1985[6] has been reviewed against current NRC criteria.[5] It is found that the PCP contains commitments generally consistent with the guidelines of Reference 5 and is therefore an acceptable reference with the following possible exceptions:
o It is not clear why the Bartlett Nuclear, Inc. PCP is referenced in Section 2.0.
If the Bartlett PCP must be referenced then the Bartlett topical report number must be included and state whether the report has NRC approval, o
In Section 5.3.1.2 it is not clear whether the sample is obtained from the waste tanks or from the solidification container. A sample obtained from the solidification container would be a
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better representative of the final waste form.
Solidification Test Frequency Section 5.3.2.2 should be expanded o
to include the testing of the last batch in the event ten sequential batches of like waste are not processed.
o The PCP does not contain a sketch of the solidification or dewatering systems identifying plant interfaces with other systems and identifying critical components of the systems that monitor process parameters.
o It is not clear if the Licensee ships waste to burial sites in other states or just South Carolina, i
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REFERENCES 1.
" Solid Waste Management System," Standard Review Plan, Office of Nuclear Reactor Regulation, Section 11.4, Revision 2, July 1981.
2.
Branch Technical Position 11-3, " Design Guidance for Solid Radioactive Waste Management Systems Installed in Light-Water-Cooled Nuclear Power Reactors Plants." attachment to SRP 11.4, Revision 2, July 1981.
3.
NUREG-0472, " Radiological Effluent Technical Specifications for Pressurized Water Reactors," Draft 7",
Revision 3, September 1982.
4.
NUREG-0473, " Radiological Effluent Technical Specifications for Boiling Water Reactors," Draft 7", Revision 3, September 1982.
5.
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.
I 6.
Letter from G. R. Westafer (FPC) to J. N. Grace (NRC),
Subject:
Crystal River Unit 3 Do.cket No. 50-302 Operating License No. OPR-72 Semiannual Radioactive Effluent Release Report, 3F0286-15, February 26, 1986.
7.
Title 10, Code of Federal Regulations, Part 20, " Standards for Protection Against Radiation".
8.
Title 10, Code of Federal Regulations, Part 71, " Packaging and Transportation of Radioactive Material".
9.
Title 10, Code of Federal Regulations, Part 61, " Licensing d
Requirements for Land Disposal of Radioactive Waste.
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