ML19320B119
| ML19320B119 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/01/1980 |
| From: | Goodwin C PORTLAND GENERAL ELECTRIC CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| IEB-80-10, NUDOCS 8007090329 | |
| Download: ML19320B119 (5) | |
Text
____ _ ____________
bc: M usts. William 2/Lindb1cd, Bro:hl, Durham, Heider, Yundt, y
Lentsch, Zimmarman, Christensen, Gaidos, Sullivan, L. Damon (Bechtel), L. Cunningham (W), L. Weislogel (PP&L),
j D. Axtell (EWEB), R. Nyland (BPA), ii. Axelrad, C. Trammell, M. halmros, LIS, Reading File, TNP: GOV REL F:NRC, esen em
--== PodiaMdN1oDIMI1c"bny y'
LG h
Cves Gcc:<. / : ss s:rt '/:ce : es cent i
July 1, 1980 Trojan, Nuclear Plant Docket 50-344 License NPF-1 Mr. R.,H.
Engelken, Director U. S. Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Blvd.
Walnut Creek, CA 94596
Dear Sir:
IE Bulletin 80-10 " Contamination of Nonradicactive Systems and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to the Environment" was issued on May 6, 1980. Attached is Portland General Electric's evaluation requested by IE Bulletin 80-10.
Sincerely, i
j)
, v')
C. Goodwin, Jr.
Assistant Vice President Thermal Plant Operation and Maintenance CG/TDW/MQH/4eg7A13 Attachment c:
Mr. Lynn Frank, Director State of Oregon g
Department of Energy
,)
U g' g b
/
J. W. Lentsch 80070903
.n,~==,~=
= _ -
o o
Trojan Nuclear Plant Response to IE Bulletin 80-10 INTRODUCTION NRC IE Bulletin 80-10 required a review of facility design and operation to identify systems that are considered as nonradioactive but that could possibly become radioactively contaminated through interf aces with radio-active systems due to leakage, abnormal system operations or valving errors. This review was completed prior to June 20, 1980 and the results are detailed below.
RESPONSE TO ITEMS Item 1 Review your facility design and operation to identify systems that are considered as nonradioactive (or described as non-radioactive in the FSAR) but could possibly become radioactive through interfaces with radioactive systems, i.e.,
a radioac-tive system that could become contaminated due to leakage, valving errors, or other operating conditions in radioactive systems.
In particular, special consideration should be given to the following systems: Auxiliary Boiler System; Demineral-ized Water System; Isolation Condenser System; PWR Seccndary Water Cleanup System; Instrument Air System; and the Sanitary Waste System.
Response
The review was diviced into two segments: Primary Plant Interfaces and Secondary Plant Interfaces.
1.
Primary Plant Interfaces Primary Plant Interfaces between radioactive and nonradioactive systems were examined for potential of cross-contamination due to valving errors. All inter-faces are provided with check valves or pressure-reducing valves. Experience has shown that these valves provide an adequate barrier to prevent cross-contamination.
j Primary Plant In* rfaces were also examined for points l
where leakage be seen components could resu'.t in l
cross-contamination. The potential exists for contami-l nation of the Process Steam System and the Startup Boiler System should leaks develop in the boric acid evaporator or radwaste evaporator heat exchangers.
This could result in an unmonitored release due to boiler bottor blow and steam dump (dummy load);
however, because steam systems are maintained at a i
r higher pressure, cross-contamination would be unlikely.
Nevertheless, boiler blowdown from these systems will be sampled weekly for radioactivity when in operation.
2.
Secondary Plant Interfaces The secondary Plant systems are normally not radio-actively contaminated. However, during periods of steam generator tube leakage, minor contamination is present. Assuming that the secondary plant is contami-nated, the following systems have a potential to be cross-contaminated due to mechanical failure or operator error:
Oily Water Separator (OWS) - The OWS receives a.
potentially radioactive water from the Turbine Building sump and the Condensate Demineralizer Building Sumps. A temporary system and sump pump has been installed in the OWS to pump the effluent to the Discharge and Dilution Structure. This system is sampled for contamination daily when the secondary system is contaminated (steam generator blowdown activity exceeding 10-5 pCi/cc). Modifications are under way to make
+
this system permanent and it will incorporate a permanent radiation monitor on the OWS discharge line.
b.
Plant Sewer System - This system could receive potentially radioactive water from the secondary sampling sink during periods of primary-to-secondary leakage. The sample sink drain line is routed to the dirty radwaste system when the secondary Plant contamination is detected.
Sewer system effluent and sludge is sampled weekly when the secondary system is contaminated.
c.
Plant Stator Water Cooling System - The poten-tial for cross-contamination of the Plant Stator Water Cooling System exists from the Condensate Makeup System. The Plant Stator Water Cooling System is operated as a closed system. When system maintenance or inspection is required, the system is drained to the Turbine Building sump whose effluent is monitored for radioactivity under 2.a, above.
l Additionally, this system will be sampled semi-annual 1.y when the Plant secondary system is contamineted.
! i
a a
d.
Turbine Building Be. ting Cooling Water System -
The potenti.1 for cross-contamination of the Turbine Building Bearing Cooling Water System exists via the sanole cooler rack, if a cooler coil leak occurs. The Turbine Building Bearing Cooling Water System is operated as a closed system. When system maintenance or inspection is required, the system is drained to the Turbine Building sump whose effluent is monitored for radioactivity under 2.a, above. The Bearing Cooling Water System will be sampled semi-annually when the Plant secondary system is contaminated.
Plant Secondary System contamination is closely monitored and routine sampling of the above-listed systems will detect cross-contamination prior to any significant unmonitored and/or uncontrolled release.
Item 2 Establish a routine sampling / analysis or monitoring program for these systems in order to promptly identify any contaminating events which could lead to unmonitored, uncontrolled liquid or gaseous releases to the environment, including releases to onsite leaching fields or retention ponds.
Response
4 The routine sampling / analysis or monitoring program described above will promptly identify cross-contamination for each identified system above.
Item 3 If these nonradioactive systems are or become contaminated, further use of these systems shall be restricted until the cause of contamination is identified and corrected and the system has been decontaminated. Decontamination should be performed as soon as possible. However, if it is considered necessary to continue operation of the system as contaminated, an immediate Safety Evaluation of operation of the system as a radioactive system must be performed in accordance with -the l
requirements of 10 CFR 50.59.
The 10 CFR 50.59 Safety Evalua-tion must consider the level of contamination (i.e., concen-tration and total Curie inventory) and any potential releases
'(either routine or accident) of radioactivity to the environ-I ment.
The relationship of such releases to the radioactive effluent limits of 10 CFR 20 and the facility's Technical Specification and to the environmental radiation dose limits of 40 CFR 190 must also be evaluated. The record of the Safety Evaluation must set forth the bases and criteria on which the determination was made..,.
a.
s a
Response
At the time of this evaluation, detectable activity was not found in any of the systems identified under Item 1, above.
If activity is detected in one of these systems, an investigation will be conducted as to the source of the activity.
It is not expected that any of the systems identified above could result in substantial activity release. Continued system operation, if contaminated, shall be based on a favorable evaluation per 10 CFR 50.59.
Item 4 If it is determined in the 10 CFR 50.59 Safety Evaluation that operation of the system as a radioactive system is acceptable (i.e., does not involve an unreviewed safety question or a change to the Technical Specifications) provisions must be made to comply with the requirements of 10 CFR 20.201, General Lesign Criterion 64 to 10 CFR 50, Appendix ! to 10 CFR 50 and the facility's Technical Specifications.
In specific, any potential release points must be monitored and all releases must be controlled and maintained to (as low as is reasonably achievable) levels as addressed in Appendix I to 10 CFR 50 and within the corresponsding environmental dose limits of 40 CFR 90.
However, if in the 10 CFR 50.59 determination it is determined that operation of'the system as a radioactive system does constitute an unreviewed safety questien or does require a change to the Technical Specifications, the syste=s shall not be operated as contaminated without prior Commission approval.
Response
If unrestricted system operation is determined to be acceptable per 10 CFR 50.59, compliance to requirements of 10 CFR 20.201, General Design Criteria 64 to 10 CFR 50, Appendix I to 10 CFR 50 and the Trojan Technical Specifica: ions will be demonstrated.
If system operation is determined to be unacceptable per 10 CFR 50.59, operation of that system will be restricted until the cause of contamination has been corrected and the system decontaminated or until NRC approval for continued system operation received.
l l
l f
MQH/4mg7A14 -
-