ML13333A400
| ML13333A400 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/23/1979 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | James Drake Southern California Edison Co |
| References | |
| TAC-06491 NUDOCS 7908170193 | |
| Download: ML13333A400 (4) | |
Text
JUL 2 3 1979 Docket No. 50-206
'Mr. James H. Drake Vice President Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770
Dear Mr. Drake:
In August 1976 we sent letters to the majority of licensees who operate Pressurized Water Reactors (PWRs) regarding the control of secondary water chemistry to inhibit corrosion of steam generator tubes. The letters requested the licensees to propose Technical Specification changes to incorporate limiting conditions for operation and surveillance requirements for secondary water chemistry parameters. Model Technical Specifications, which reflected the requirements contained in the Commission's Standard Technical Specifications (STS), were included for guidance.
Many licensees objected to the Model Technical Specifications principally on the basis that they could unnecessarily'restrict plant operation. The majority of these licensees.submitted alternative approaches that were directed more toward monitoring and record keeping rather than specific limits on chemistry parameters. At the time of our request, we recognized that a major disadvantage of the Technical Specifications was a potential decrease in operational flexibility, but our request.was motivated by an overriding concern for steam generator tube integrity. Our objective was to provide added assurance that licensees would properly monitor and control secondary water chemistry to limit corrosion of steam generator tubes.
However, based.on the experience and knowledge gained since 1976, we have now concluded that Technical Specification limits would not be CD the most effective way of accomplishing this objective. Due to the complexity of the corrosion phenomena involved, and the state-of-the-art as it exists today, we believe that a more effective approach would be to institute a license condition that requires the implementation of a secondary water chemistry monitoring and control program containing appropriate procedures and administrative controls. A Model License Condition that is acceptable to the staff for this purpose is enclosed. C The required program and procedures would be developed by the licensees, with any needed input fron their reactor vendors or other consultants, ownes that affect chemistry condit ons in the stleam generator:.
In our viev, suh"feense rnithion" ou.d.p.o.idase Fadeh'Nt"1't HNGS'Woold.....
DATE NRC FORM 318 (9-76) NRCM 0240 u.s. GOVERNMENT PRINTIGm OPeICff: 1974 - 2S
- 709
Mr. James JUL 23 1979 devote proper attention to controlling secondary water chemistry, while also providing the needed flexibility to allow them to more effectively deal:with any off-normal conditions that might arise.
Moreover, we have concluded that such a license condition, in conjunction with existing Technical Specifications on steam generator tube leakage and inservice inspection, would provide the most practical and comprehensive means of assuring that steam generator tube integrity is maintained.
Consequently, we request that you submit a proposed amendment to your license to incorporate the requirements of the enclosed Model License Condition into the body of your license within 60 days.
If you previously submitted an application for a license amendment concerning steam generator monitoring requirements prior to March 22, 1978, you need not remit a fee for the license amendment requested by this letter. If you have not submitted a license amendment request prior to March 22, 1978, you should remit a Class III fee with your application.
If you have any questions, please contact us.
No further action will be taken on any proposed Technical Specification changes you may have submitted in response to our August 1976 request.
Such change requests will be considered withdrawn unless you express objections within 60 days.
Sincerely, Original Signed by:
Dennis L. fiemann Dennis L. Ziemann, Chief
.Operating Reactors Branch #2 Division of Operating Reactors TCarter SEPB
Enclosure:
D WRussell Ac-S Model License Condition ocket 50-206 Attorney, OELD OI&E(3) cc w/enclosure:
Local PDR DLZiemann See next page
.ORB#2 RDG ABurger NRR RDG HSmith DEisenhut JWetmore BGrimes JRBuchanan RVoll TERA OF" DOR:ORB#2 D
- 2 l.DOR:ORIA2
.. RNAM..
- Aurger
. JWet re DLZiemann DATE 7/
79 7 / 9
/2./79.......
WRC FORM 318 (9-76) NRCK 0240 U.S. GOVERNMENT PRINTING OFFICE: 1978 - 245 -769
Mr. James JUL 23 1979 cc Charles R. Kocher, Assistant General Counsel Southern California Edison Company Post Office Box 800 Rosemead, California 91770 David R. Pigott Samuel B. Casey Chickering & Gregory Three Embarcadero Center Twenty-Third Floor San Francisco, California 94111 Jack E. Thomas Harry B. Stoehr San Diego Gas & Electric Company P. 0. Box 1831.
San Diego, California 92112 U. S. Nuclear Regulatory Commission ATTN: Robert J. Pate P. 0. Box 4167 San Clemente, California 92672 Mission Viejo Branch Library 24851 Chrisanta Drive Mission Viejo, California 92676
ENCLOSURE MODEL LICENSE CONDITION SECONDARY WATER CHEMISTRY MONITORING The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This program shall include:
- 1. Identification of a sampling schedule for the critical parameters and control points for these parameters;
- 2. Identification of the procedures used to quantify parameters that are critical to control points;
- 3. Identification of process sampling points;
- 4. Procedure for the recording and management of data;
.5. Procedures defining corrective actions for off control point chemistry conditions; and
- 6. A procedure identifying the authority responsible for the inter pretation of the data, and the sequence and timing of administrative events required to initiate corrective action.