ML19330B861
| ML19330B861 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 06/26/1980 |
| From: | Crane P PACIFIC GAS & ELECTRIC CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| IEB-80-10, NUDOCS 8008070089 | |
| Download: ML19330B861 (3) | |
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PACIFIC GAS AND ELECTR,IC C O M PANY bb'Mb l
77 BEALE STREET,31ST FLOOR SAN FR ANCISCO, C ALIFO RNI A 94106 (415) 781 4211 M A LCOL M H. p U R B US H
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Mr. R. H. Engelken, Director
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Office of Inspection and Enforcement
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Docket No. 50-133
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Dear Mr. Engelken:
This is in response to your letter dated May 6, 1980, which enclosed IE Bulletin No. 80-10 concerning the possible contamination of non-radio-active systems.
The act. ion statements of the Bulletin and our responses are given in Attachment A.
r truly yours 5
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Attachment
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Director Office of Inspection and Enforcement Division of Reactor Operations Inspection
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U. S. Nuclear Regulatory Commission 1
Washington, D. C. 20555 8008070069 803.C.
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PACIFIC CAS AND ELECTRIC COMPANY HUMBOLDT BAY POWER PLANT UNIT NO. 3 Docket No. 50-133 License No. DPR-7 ATTACHMENT A RESPONSE TO IE BULLETIN NO. 80-10 DATED MAY 6, 1980 The subject Bulletin lists four actions to be taken by licensees with an operating license. These action statements are listed below with our response.
"1.
Review 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 withradioactives/ stems,i.e.,anonradioactivesystemthatcould 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, demineralized water system, isolation condenser system, PWR secondary water clean-up system, instrument air system, and the sanitary waste system."
This review was performed and the following nonradioactive systems were identified as being capable of becoming contaminated through interfaces with radioactive systems:
auxiliary boiler systems (i.e. Units 1 and 2), demineralized water system, isolation condenser system, instrument air system, sanitary waste system, domestic water system, closed cooling water system, salt (circulating) water system, and the turbine lube oil system.
"2.
Establish a routine sampling / analysis or monitoring program for these syst'ms in order to promptly identify any contaminating e
events which could lead to unmonitored, uncontrolled liquid or gaseous releases to the environment, including releases to on-site leaching fields or retention ponds."
All but two of the systems identified above are monitored by a routine program to promptly identify any contaminating events.
The two unmonitored systems are the instrument air and auxiliary boiler systems. Monitoring programs for these two systems are presently being developed and will be established by June 20, 1980.
"3.
If these nonradioactive systems are or become contaminated, further use of the system shall be restricted until the cause of the contamination is identified and corrected and the system has been decontaminated.
Decontamination should be performed as soon as possib*e. However, if it is considered necessary to continue operation of the system as contaminated, an immediate safety evaluation of the operation of the system as a radioactive system must be performed in accordance with the requirements of 10CFR50.59. The 10CFR50.59 safety evaluation must consider the level of contamination (i.e., concentration and G
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s total curie inventory) and any potential releases (either routine or accident) of radioactivity to the environment. The relationship of such releases to the radioactive effluent limits of 10CFR20 and the facility's Technical Specification and to the environmental radiation dose limits of 40CFR190 must also be evaluated. The record of the safety evaluation must set forth the basis and criteria on which the determination was made."
"4.
If it is determined in the 10CFR50.59 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 10CFR20.201, General Design Criterion 64 to 10CFR50, Appendix I to 10CFR50 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 Reasonabl'j Achievable" levels as addressed in Appendix I to 10CFR50 and within the corresponding environmental dose limits of 40CFR190. However, if in the 10CFR50.59 determination it is determined that operation of the system as a radioactive system does constitute an unreviewed safety question or does require a change to the Technical Specifications, the system shall nyt be operated as contaminated without prior Commission approval."
A radiation control proced'ure has been prepared which incorporates the requirements of the above two action statements. This procedure will be reviewed and adopted as plant policy by June 20, 1980.
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