ML19339A788
| ML19339A788 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/06/1980 |
| From: | Hancock J FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19339A786 | List: |
| References | |
| CS-80-232, NUDOCS 8011050227 | |
| Download: ML19339A788 (2) | |
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rdt 04 POST OFFICE BOX 219 - CRYSTAL RIVER, FLORfDA 32629 - TEL EPHONE: (904) 705-3802 3 3-a-2 CORPOR ATION CS-80-232 Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection & Enforcement Licensee No. DPR-72 U. S. Nuclear Regulatory Commission Ref:
RII: TFS 101 Marietta S t., Suite 3100 50-302/80-24 Atlanta, GA 30303
Dear Mr. O'Reilly:
We offer the following response to the apparent item of Noncomplian e in the referenced inspection report.
Environmental Technical Specification 3.1.5 states in part:
" Representative samples shall be obtained and analyzed once per month from test wells 1, 4, and 5, the discharge canal directly to the north of the ponds, at the ponds themselves." (See Fig. 3.1-1)
Figure 3.1-1 illustrates the locations of test wells 1, 4, and 5.
10 CFR Part 50.59 (a)(1) states:
"The holder of a license authorizing opration of a production or utilization facility may (1) make changes in the facility as described in the safety analysis report, (ii) make changes in the procedures as described in the safety analysis report, and (iii) conduct tests or experiments not described in the safety analy-sis report without prior Commission approval, unless the proposed change, test or experiment involves a change in the Technical Specifica-tions incorporated in the license or an unreviewed safety qtestion."
Contrary to the above, as of February 22, 1980, samples have not been obtained and analyzed from test well 4, and on March 13, 1980, a change to Environmental Technical Specification 3.1.5 was made to eliminate test well 4 without prior Commission approval.
A. Response:
As described in the text of the inspection report (Para. 5.b and 5.c),
Florida Power Corporation was precluded from taking samples required by ETS 3.1.5 as a result of construction activities which inadvertently closed test well 4.
'A ' K iAL COP" 8011050227
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I Notice of_ Violation Ref:
RII: TFS 50-302/80/24 g
Page 2 Crystal River Unit #3 has been physically isolated from this
' release point since October 1979, and thus, no releases of industrial waste to the ponds, which test well 4 monitored, originated from Unit #3 throughout the period in question, nor will such occur in the future.
Therefore, no damage to the environment could have occurred during this period as a result of Crystal River #3 operation. While this did not legally relieve us of the responsibility to monitor the pond, it eliminated any technical basis for doing so.
However, test well 4 j
was reestablished on August 19, 1980.
l In addition, the State of Florida approved, by letter dated July 7, 1980,' deletion of test well 4 from the monitoring program required by National Pollution Discharge Elimination System (NPDES) Permit No.
FL0000159.
This infraction has been discussed with the Resident Inspector, and Florida Power Corporation now realites that not reestablishing the test well as soon as possible is a change to the Environmental Technical Specifications without prior Commission approval even though other avenues of action were being pursued on a technical basis.
In the future, Florida Power Corporation will move to resolve similar occurrences in a manner consistent with the Operating License.
Should there be further questions, please contact us.
Very truly yours, Florida Power Corporation
/1}f J. A. Hancock, sst. Vice President Nuclear Operations Yih'f Nuclear Plant Manager
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