ML17317B425

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Requests Util Submit Proposed Secondary Water Chemistry Program to Be Incorporated in New License Condition. Current STS for All PWRs Are Ineffective Re Steam Generator Tube Degradation.Model License Condition Encl
ML17317B425
Person / Time
Site: Cook  
Issue date: 08/01/1979
From: Schwencer A
Office of Nuclear Reactor Regulation
To: Dolan J
INDIANA MICHIGAN POWER CO.
References
NUDOCS 7908130577
Download: ML17317B425 (8)


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$(55MI:~~-8'P) oc;et AUGUST 1

1979 Local'DR, NRR Rdg ORBl Rdg A. Schwencer Docket Hos MO 5

C. Parrish/P.

Kreutzer an 50-31 Project t1anager 11r. John Dolan, 'lice President T. J. Carter Indiana and Hfchigan'Electric Compy@rney OELD Indiana and Hfchfgan Power Company>E (3)

Post Office Box 18 TERA Bowling Green Station thew York, Hew York 10004

Dear Yir. Dolan:

In late 1975 we incorporated provisfons. into the Standard Technical Specification,(STS) that required limiting conditions for operation and surveillance requirements for secondary water chemistry parameters.

The Technical Specifications for your plant(s),

as well as all other Pressurized'ater Reactor plants that have been.issued an Operating License since 1974,,

either contain these provisions, or a requirement to establish these'rovisions after baseline chemistry conditions have been determined.

The intent of the provisions was to provide added assurance that the operators of newly licensed plants would properly monitor and control secondary water chemistry to limit corrosion of stean generator tubes.

In a number of instances the Technical Speciffcations have sirjnificantly restr'feted the operational flexibilityof some plants with little or no benefit ufth regard to limiting corrosion of steam generator tubes.

Based on 'this experience, and the knowledge gained in recent years, we have concluded that Tectinfcal Specification limits are not the most effective way of assuring that stean generator tube corrosion will be minimized.

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Due to the complexity of the corrosion phenomena involved, and the state-of-the-art as it exists today, we believe that, in lfeu of Technical Specifications,'

more effective approach would be to institute

a. license condition that requires the implementation of a,secondary water chemistry-monitorfng and control program containing appropriate procedures and adminfstrative controls.

A t<odel License Condition that-is acceptable to the staff-for this purpose is enclosed.

The required program and procedures would be developed by the licensees, with any, needed input

,ram their reactor vendors or other consultants, and thus could,more readily account for site and plant specific factors that affect cheraistry conditions in the stean generators.

In onr vien, /d4 g such a license condition would provide assurance that licensees would devote proper attention.to contro11ing secnndary IIater chenistry, Ivhile also providi'ng the needed flexibility to allow then to more effectively NRC PORN 518 (976) NRCM 0240

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ttr. John Dolan Indiana and f5ichigan Electric Company Indiana and thichigan Power Company Consequently, we request that -you submit a proposed amendment to your license to delete your existing Technical Specifications on secondary water chemistry and to incorporate the requirekents of the enclosed Viodel License Condition into the body of your license within 60 days.

If you previously sub~itted an application for a license amendment concerning stean generator monitoring requirements prior to harch 22, 1978, that has yet to be issued by the HRC, you need not remit a fee

,for the license amendment requested by this letter. If you have not submitted a licen'se amendment request prior to Harch 22, 1978, you should remit a Class III fee with your application.

If you have any questions, please contact us.

Sincerely,

Enclosure:

Hodel License Condition

h. Schwencer, Chief Operating Reactors Branch 81 Division of Operating Reactors cc:

w/enclosure See next page OFFICC~

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'I 1979 Docket Nos.

50-315 and 50-316 Mr. John Dolan, Vice President Indiana and Michigan Electric Company Indiana and Michigan Power Company Post Office Box 18 Bowling Green Station New York, New York 10004

Dear Mr. Dolan:

In late 1975 we incorporated provisions into the Standard Technical Specification (STS

) that required limiting conditions for operation and surveillance requirements for secondary water chemistry parameters.

The Technical Specifications for your plant(s),

as well as all other Pressurized I ater Reactor plants that have been issued an Operating License since 1974,

~

either contain these provisions, or a requirement to establish these provisions after baseline chemistry conditions have been determined.

The intent of the provisions was to provide added assurance that the operators of newly licensed plants would properly monitor and control secondary water chemistry to limit corrosion of steam generator tubes.

In a number of instances the Technical Specifications have significantly restricted the operational flexibilityof some plants with little or no benefit with regard to limiting corrosion of steam generator tubes.

Based on this experience, and the knowledge gained in recent years, we have concluded that Technical Specification limits are not the most effective way of assuring that steam generator tube corrosion will be minimized.

Due to the complexity of the corrosion phenomena

involved, and the state-of-the-art as it exists today, we believe that, in lieu of Technical Specifications, 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.

The required program and procedures would be developed by the licensees, with any needed input from their reactor vendors or other consultants, and thus could more readily account for site and plant specific factors that affect chemistry conditions in the steam generators.

In our view, such a license condition would provide assurance that licensees would devote pr oper attention to controlling secondary water chemistry, while also providing the needed flexibilityto 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 would be maintained.

I h

Mr. John Dolan Indiana and Michigan Electric Company Indiana and Michigan Power Company AUGUST

]

)979 Consequently, we request that you submit a proposed amendment to your

'license to delete your existing Technical Specifications on secondary water chemistry and to incorporate the requirements of the enclosed Mode1 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, that has yet to be issued by the NRC, you need not remit a fee for the license amendment requested by this letter.

If you have not submitted a 1icense 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.

Sincerely,

Enclosure:

Hode1 License Condition A. Schwencer, Chief Operating Reactors Branch 81 Division of Operating Reactors cc:

w/enclosure See next page

Mr. John Dolan Indiana and Michigan Electric Company Indiana and Michigan Power Company AUGUST 1

1979 cc:

Mr. Robert M. Jurgensen Chief Nucl ear Engineer American Electric Power Service Corporation 2 Broadway New York, New York 10004 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.

Mashington, D.

C.

20036 Citizens for a Better Environment 59 East Van Buren Street Chicago, Illinois 60605 Maude Preston Palenske Memorial Library 500 Market Street St.,Joseph, Michigan 49085

, Mr. D. Shaller, Plant Manager Donald C.

Cook Nuclear Plant P.

0.

Box 458

Bridgman, Michi gan 49106 Hr.

R.

Masse Donald C.

Cook Nuclear Plant P.

0.

Box 458 Bridgman, Michigan 49'l06

E.'fC'RDURE

'!ODEL L IC:-WSE COf<OITION SECO'<OVARY "..', ER CH-"1!5 RY "ONITGR'G The licensee shall im"le.:.ent a secondary 'inter chemistry monitor'ng program to inhibit steam gererator tube degradation.

n'.s program shall include:

l.

Identi icati n o a

s pp)ing schedule for the critical para.,eters and control points =or these parameters; 2.

Identification of.he procedures used 'to quantify =are-;e ers that are critical to control ooin.s; 3.

Identifica.ion of process sampling oints; 4.

"rocedure.or

.he recording and manage.ent o, data;

5. 'rocedures defining corrective actions for off control point cnemis.ry condi G ~cs'nd A procedure identifyino the author-',ty responsible

-or :he inter-pretation 0

h~ da a, and the sec~Jence and t.mirg G

a m nistrative events requirec to inii ia.e correc ive ac.)on.