ML19339A502
| ML19339A502 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/14/1980 |
| From: | Richard Bright FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| IEB-80-10, NUDOCS 8011040147 | |
| Download: ML19339A502 (6) | |
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October 14, 1980 File: 3-0-3-a-4 Mr. J. P. O'Reilly Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Suite 3100 101 Marietta Street Atidnta, GA 30303
Subject:
Crystal River t3 Docket No 0 an9 Operating License No. DPR-72 IE Bulletin 80-10 CONTAMINATION OF NONRADI0 ACTIVE SYSTEM AND RESULTING POTENTIAL FOR UNM0NITORED, UNCONTROLLED RELEASE OF RADI0 ACTIVITY TO ENVIRONMENT
Dear Mr. O'Reilly:
4 Enclosed is our revised 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
!Ronald M. Bright -
Acting Manager Nuclear Support Services Attachments IE80-10(DN-71) 8011040 147 General Office 3201 Tnirty-fourtn street soutn. P O Box 14042. st Petersburg. Florida
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REVISED FPC RESPONSE TO IE BULLETIN 80-10 ITEM 1 Review your facility design and operation to identify systems that ' are con-sidered as nonradioactive (or described as nonradioactive in the FSR), but could possibly become radioactive through interface with radioactive systems, i.e., a nonradioactive system that could become contaminated due to leakage, valve errors, or other o,",erating conditions in radioactive systems.
In particular, special considerations shoulo be given to the fol-lowing systems; auxiliary boiler system, demineralized water system, isola-tion condenser system, PWR secondary water cleanup system, instrument air system, and the sanitary waste system.
RESP 0 HSE We have reviewed the design and operation of the following systems and found no cross-ties (i.e. valves) exist with contaminated systems:
(a) Cycle Startup (b) Extraction Steam (c) Feedwater (d) Emergency Feedwater (e) Feedwater Heater Drains (f) Feedwater Heater Reliefs Vents & Drains (g) Miscellaneous Turbine Room Steam Drains (h) Condensate Air Removal & Priming (1) Seal & Spray Water (j) Condensate Demineralizers (k) Cycle Makeup Water Treatment (1) Chemical Feed Secondary Cycle (m) Secondary Cycle Sampling (n) Turbine Gland Steam & Drains (o) Chemical Cleaning Steam Generators (p) Secondary Services Closed Cycle Cooling (q) Nuclear Services & Decay Heat Sea Water We have reviewed the design and operation of the following systems end found that cross-ties exist with ccntaminated systems.
These systems are separated from the contaminated systems by check valves and isolation valves or by isolation valves only.
(a) Condensate Demineralizers Regeneration (b) Nitrogen & Hydrogen (c) Main & Reheat Steam (d) Auxiliary Steam (e) Nuclear Services Closed Cycle Cooling (f) Condensate & Demineralizer Water Supply-Nuclear Plant t
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During the design phase of the facility "e above systems were categorized to be ncnradioactive.
However, as a re: alt of leakage in the Once Through Steam Generators during operation of the plant, all secondary cycle systems have become contaminated or are treated as potentially core:.aminated.
As a result of leakage from the Core Flood System into the Nitragen System, the Nitrogen System is now treated.as a contaminated system.
Secondary Services Closed Cycle Cooling Water, Nuclear Services & Decay Heat Sea Water, Nuclear Services Closed Cycle Cooling Water, Condensate &
Demineralizer Water Supply-Nuclear Plant, and Instrument Air Systems are not considered to be contaminated at this time.
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 environ-ment, including releases to on-site leaching fields or retention ponds.
RESPONSE
To prevent unmonitored, uncontrolled liquid and gaseous releases to the envirorcent, the following programs have been established at CR-3:
(a) The following sampling frequencies are followed in order to iden-tify any contaminating event:
(1) Daily:
- Tritium on secondary demineralizer effluent to monitor for any increase in primary to secondary leak rate.
- Record count rate on RML-3 monitor on Nuclear Services Closed Cycle Cooling Water System to detect any increase in activity.
- Record count rate on RML-5 and RML-6 monitors on Decay Heat Closed Cycle Cooling Water System, Loops "A" and "B",
to detect any increase in activity.
1 (2) Twice per Week:
- Perform gamma scan analysis on mixed bed resin column from both Main Steam Loops.
1 (3) Three Times per Week:
- Perfonn gross beta analysis on both hotwells.
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s (4) Weekly:
- Perform gross beta analysis on both Main Steam Loops.
- Perform gross beta analysis on demineralized water due to contamination of the Nitrogen System.
(5) Monthly:
- Perform gross beta analysis on: Secondary Services Closed Cycle Cooling Water System, Condensate Storage Tank, Sec-ondary Sample Room Demineralized Water, Domestic Water Storage Tank, Nuclear Services Closed Cycle Cooling Water Sy stem, Decay Heat Closed Cycle Cooling Water, nuclear Services Area Sump, Industrial Cooler Closed Cycle Cooling Water, Industrial Cooler Tower Sump, and Auxiliary Build-ing Demineralized Water Storage Tank.
(6) Quarterly:
- Perform gross beta analysis on Fire Water Storage Tank.
(7) Semi-Annually:
- Perform Dose Equivalent Iodine analysis on both hotwells.
- Perform gross beta and tritium analysis on the Borated Water Storage Tank.
- Perform gross nta analysis on the NaOH Storage Tanks.
(8)
In addition, af*.er any trip or any time the reactor _is critical at less than 15% power, the shell side of the steam generators are monitored for gross beta every four hours.
(b) Condensate off-gases are now vented through the Auxiliary Build-ing Ventilation System.
This change allowed the gases to flow through a set of HEPA and charcoal filters.
This also allowed for accountability of the noble gases released to the environ-ment.
(c) The Turbine Building Sump Discharge System has been piped to the Nuclear Services Seawater system.
This flow is munitored by a liquid radution monitor. The Turbine Building Sump receives all leakage that could be generated on the secondary side of the plant.
(d) The designed flow path from the Turbine Building drains to the nonradioactive settling ponds are being administratively con-trolled.
The applicable valves have been placed on the plant locked valve list.
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e (e) The floor area at the sewage lift station has been diked to pre-vent any inadvertent Turbine Building leakage with the sewage system.
(f) The Secondary Cleanup System has become radioactive due to leak-age.
Therefore, it has been decided that the condensate demin-eralizers would not be regenerated due to the limited rad waste capabilities.
In lieu of regeneration, the resins are sluiced and subsequently sent to waste burial.
(g) The Station and Instrument Air Systems have not become radio-active or contaminated. However, air from these systems is peri-odically sampled prior to each breathing use.
ITEM 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. Decontam-ination should be performed as soon as possible, However, if it is con-sidered 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 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 poten-tial releases (either routine or accident) of radioactivity to the environ-ment. The relationship of such releases to the radioactive effluent limits of 10 CFR 20 and the facility's Technical Specification and to the environ-mental 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 10 CFR 50.59 safety evaluation for each affected system had been perform-ed 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 involve an unreviewed safety question or a change to the Technical Specification),
provisions must be made to comply with the requirements of 10 CFR 20.201, General Design Criterion 64 to 10 CFR 50, Appendi x 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 controlled, and maintained to "As Low As is Reasonably Achievable" levels as addressed in Appendix I IE80-10(DN101-2) i
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to 10 CFR -50 and within the corresponding environmental dose limits of 40 CFR 190..However, if, in the 10 CFR 50.59 determination, it is deter-mined that ~ operation of the system as a radioactive system.does constitute an unreviewed safety questions or does require a change to the Technical Specification, the system shall not be operated as a contaminated without Commission approval.
RESPONSE
It has been determined in the safety evaluation that operation of the systems as radioactive systems is acceptable and provisions have been made to monitor and control all releases.
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