ML19320D095
| ML19320D095 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/25/1980 |
| From: | Richard Bright FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 3-0-3-A-4, IEB-80-10, NUDOCS 8007180540 | |
| Download: ML19320D095 (4) | |
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3,,.. i Power C O R PO R A i sO N June 25, 1980 File: 3-0 a-4 Mr. J. P. O'Reilly Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Suite 3100 101 Marietta Street Atlanta, GA 30303 Suj ec t : Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Bulletin 80-10 CONTAMINATION OF NONRADI0 ACTIVE SYSTEM AND RESULTING POTENTIAL FOR ONMONITORED, UNCONTROLLED RELEASE OF RADI0ACTI VITY TO ENVIRONMENT
Dear Mr. O'Reilly:
Enclosed is our response to IE Bulletin 80-10.
Please contact this office if you require any additional discussion con-cerning our response.
Very truly yours, FLORIDA POWER CORPORATION k
Ronald M. Brig t Acting Manager Nuclear Support Services Attachments IE80-10(DN-71)
- e. L a i..u. c,, y Geperal Office 3201 ininy-founn street souin. P O Box 14042. st Petersburg Florida 33733 e 813-866-5151 8007180540 Q
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FPC RESPONSE TO IE BULLETIN 80-10 ITEM 1 i
Rev!ew your facility design and operation to identify systems that are considered as nonradioactive (or described as nonradioactive in the FSAR), but could possibly become radioactive through interfaces with radioactive systems, i.e., a nonradioactive system that could b.
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contaminated due to leakage, valving errors, or other operating cons tions in radioactive systems.
In particular, special considerations should be given to the following systems:
auxiliary boiler system, de-mineralized water system, isolation condenser system, PWR secondary wat-er cleanup system, instrument air system, and the sanitary waste system.
RESPONSE
We have reviewed the design and operation of the following systems:
(i)
Demineralized Water System (ii)
Condenser Off Gas System (iii)
Turbine Building Sump Discharge System (iv)
Turbine Building Drain System (v)
Sanitary Waste System vi)
PWR Secondary Cleanup System Vii)
Station and Instrument Air Systems During the design phase of the facility, the above systems were categorized to be nonradioactive.
However, as a result of leakage with the secondary system during the operation of the facility, all of the above systems except demineralized water and station and instrument air systems, have become radioactive.
ITEM 2 Establish a routine sampling / analysis or monitoring program for these systems in order to promptly identify any contaminating events which could leak to unmonitored, uncontrolled liquid or gaseous release to the environment, including releases to on-site leaching fields or retention ponds.
RESPONSE
To prevent unmonitored, uncontrolled liquid and gaseous re-leases to the environment, the following programs have been established at CR-3 for those systems which have become radio-active or contaminated.
(i)
Demineralized water system has not become ra-dioactive or contaminated.
However, water from IE80-10(DN-71)
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this system is periodically sampled to deter-mine radioactivity, if any.
(ii)
Condensate off-gases are now vented through the Auxiliary Building Ventilation System.
This change allowed the gases to flow through a set of HEPA and charcoal filters. This also allow-
-ed for accountability of the noble gases re-leased to the environment.
(iii)
The Turbine Building Sump Discharge System has been piped to the Nuclear Services Seawater System.
This flow is monitored by a liquid ra-diation monitor. The Turbine Building Sump re-ceives all leakage that could be generated on the secondary side of the plant.
l (iv)
The designed flow path from the Turbine Build-ing drains to the nonradioactive settling ponds are being administrative 1y controlled.
The ap-plicable valves have been placed on the plant locked valve list.
(v)
The floor area at the sewage lift station has been diked to prevent any inadvertent Turbine Building leakage with the sewage system.
(vi)
The Secondary Cleanup System has become radio-active due to leakage.
Therefore, it has been i
decided that the condensate demineralizers would not be regenerated due to the limited radwaste capabilities.
In lieu of regenera-tion, the resins are sluiced and subsequently sent to waste burial.
(vii)
The Station and Instrument Air Systems have not become radioactive or contaminated.
- However, air from these systems is periodically sampled prior to each breathing use.
ITEM 3 If these nonradioactive systems are or become contaminated, further use l
of the system shall be restricted until the cause of the contamination is identified and corrected and the system has been decontaminated.
De-I contamination should be performed as soon as possible.
However, if it is considered necessary to continue operation of the system as contamin-i ated, an innediate safety evaluation of the operation of the system as a i
radioactive' system must be performed in accordance with the requirements of 10 CFR 50.59.
The 10 CFR 50.59 safety evaluation must consider the level - of contamination (i.e., concentration and total Curie inventory) and potential releases (either routine or accident) of radioactivity to i
IE80-10(Responses)DN71 t
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the environment.
The relationship of such releases to the radioactive effluent limits of 10 CFR 20 and the facilitiy'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 basis and criteria on which the determination was made.
RESPONSE
A safety evaluation for each affected system had been per-formed when it was considered necessary to continue operation of the system as a radioactive or contaminated system.
- And, either the systems have been modified or appropriate changes have been made in the procedures so that 10 CFR 20 and/or 40 CFR 190 limits would not be exceeded due to operation of these systems.
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 in-volve an unreviewed safety question or a change to the Technical Speci-fications), provisions must be nude to comply with the requirements of 10 CFR 20.201, General Design Criterion 64 to 10 CFR 50, Appendix I to 10 CFR 50 and the facility's Technical Specifications.
In specific, any potential release points must be monitored and all releases must be con-trolled and maintained to "As low As is Reasonably Achievable" levels as addressed in Appendix I to 10 CFR 50 and within the corresponding envi-ronmental dose limits of 40 CFR 190.
However, if, in the 10 CFR 50.59 determination, it is determined that operation of the system as a radio-dCtive system does Constitute an unrevieWed safety question or does re-quire a change to the Technical Specifications, the system shall not be operated as contaminated without prior Commission approval.
RESPONSE
It has been determined in the safety evaluation that operation of the systems as radioactive systems 's acceptable and pro-visions have been made to monitor and con;rol all releases.
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