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FloridaPowerCOnPORAis0%

October 14, 1980.

File: 3-0-3-a-4

Mr. J. P. O'ReillyDirectorOffice of Inspection and EnforcementU.S. Nuclear Regulatory CommissionSuite 3100101 Marietta StreetAtidnta, GA 30303

Subject: Crystal River t3Docket No 0 an9Operating License No. DPR-72IE Bulletin 80-10CONTAMINATION OF NONRADI0 ACTIVE SYSTEM AND RESULTING POTENTIALFOR UNM0NITORED, UNCONTROLLED RELEASE OF RADI0 ACTIVITY TOENVIRONMENT

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

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!Ronald M. Bright -Acting ManagerNuclear Support Services

Attachments'

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8011040 147General Office 3201 Tnirty-fourtn street soutn . P O Box 14042. st Petersburg. Florida 33733 813,t66 5151.YE. S;i?2],t' n :: *" .- -- . - - = ' -- - -

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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), butcould possibly become radioactive through interface with radioactive

- systems, i.e., a nonradioactive system that could become contaminated dueto leakage, valve errors, or other o,",erating conditions in radioactivesystems. 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 airsystem, and the sanitary waste system.

RESP 0 HSE

We have reviewed the design and operation of the following systems andfound 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 endfound that cross-ties exist with ccntaminated systems. These systems areseparated from the contaminated systems by check valves and isolationvalves 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 1

(f) Condensate & Demineralizer Water Supply-Nuclear Plant

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During the design phase of the facility "e above systems were categorizedto be ncnradioactive. However, as a re: alt of leakage in the Once ThroughSteam Generators during operation of the plant, all secondary cycle systemshave become contaminated or are treated as potentially core:.aminated. As aresult of leakage from the Core Flood System into the Nitragen System, theNitrogen 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 arenot considered to be contaminated at this time.

ITEM 2

Establish a routine sampling / analysis or monitoring program for thesesystems in order to promptly identify any contaminating events which couldleak 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 theenvirorcent, 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 forany increase in primary to secondary leak rate.

- Record count rate on RML-3 monitor on Nuclear ServicesClosed Cycle Cooling Water System to detect any increasein activity.

- Record count rate on RML-5 and RML-6 monitors on DecayHeat 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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(4) Weekly:

- Perform gross beta analysis on both Main Steam Loops.

- Perform gross beta analysis on demineralized water due tocontamination of the Nitrogen System.

(5) Monthly:.

- Perform gross beta analysis on: Secondary Services ClosedCycle Cooling Water System, Condensate Storage Tank, Sec-ondary Sample Room Demineralized Water, Domestic WaterStorage Tank, Nuclear Services Closed Cycle Cooling WaterSy stem, Decay Heat Closed Cycle Cooling Water, nuclearServices Area Sump, Industrial Cooler Closed Cycle CoolingWater, 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 BoratedWater Storage Tank.

- Perform gross nta analysis on the NaOH Storage Tanks.

(8) In addition, af*.er any trip or any time the reactor _iscritical at less than 15% power, the shell side of the steamgenerators 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 flowthrough a set of HEPA and charcoal filters. This also allowedfor accountability of the noble gases released to the environ-ment.

(c) The Turbine Building Sump Discharge System has been piped to theNuclear Services Seawater system. This flow is munitored by aliquid radution monitor. The Turbine Building Sump receives allleakage that could be generated on the secondary side of theplant.

(d) The designed flow path from the Turbine Building drains to thenonradioactive settling ponds are being administratively con-trolled. The applicable valves have been placed on the plantlocked valve list.

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(e) The floor area at the sewage lift station has been diked to pre-vent any inadvertent Turbine Building leakage with the sewagesystem.

(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 wastecapabilities. 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 ofthe system shall be restricted until the cause of the contamination isidentified 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, animmediate safety evaluation of the operation of the system as a radioactivesystem must be performed in accordance with the requirements of10 CFR 50.59. The 10 CFR 50.59 safety evaluation must consider the levelof 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 limitsof 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. Therecord of the safety evaluation must set forth the basis and criteria onwhich 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 asa radioactive or contaminated system. And, either the systems have beenmodified or appropriate changes have been made in the procedures so that10 CFR 20 and/or 40 CFR 190 limits would not be exceeded due to operationof these systems.

ITEM 4

If it is determined in the 10 CFR 50.59 safety evaluation that operation ofthe system as a radioactive system is acceptable (i.e., does not involve anunreviewed 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 thefacility's Technical Specifications. In specific, any potential releasepoints must be monitored and all releases must be controlled, and maintainedto "As Low As is Reasonably Achievable" levels as addressed in Appendix 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 constitutean unreviewed safety questions or does require a change to the TechnicalSpecification, the system shall not be operated as a contaminated without

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Commission approval.

RESPONSE-

It has been determined in the safety evaluation that operation of thesystems as radioactive systems is acceptable and provisions have been madeto monitor and control all releases.

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