ML18116A309
| ML18116A309 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/01/1979 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Proffitt W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 7908130583 | |
| Download: ML18116A309 (6) | |
Text
i' i
- AUGUST 1
7979 Docket Nos. 50-28(.1
- and 50-281 Mr. W. L. Proff~tt**
Senior Vice President Power Virginia Electric and Power Company Post Office Box 26666
- Richmond, Virginia 23261
- oear Mr. Prbffitt:
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,_. _Docket File
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v' NRC PDR Local PDR NRR Rdg ORB:l Rdg
'"1f... Schwencer 4h Parri sh/P. Kreutzer LP-raj ect Manager
~~ J. Carter *
- ~-;- Wetm*ore lAttorney; OELD 4-&E (3)
TERA J. Buchanan -
tA'CRS In,;ugust* 1976 1.Je sent 1 etters to the majority_ of J icensees who operate Pressuri"z"ed Water Reactors (PivRs) regarding the control of secondary 1r;ater chemistry to inhibit corr.osio.11 of **steam gen(~rator tubes.
The letters requested the 1 kensees to propose Technical Specification changes to incorporate limiting conditions fo*r operation and surveillance requirements for secondar:1 t*tai;~r chemistry parameters.
Model Technical Specifications~ which reflected the requirements contained in the
- Commission's Standard Techni_cal Specifications (STS), were included* '
f:or guidance.;
Many-1 icerisees objected to* the Model Technical Specifications* principally on the basis that they could unnec~ssarily re$trict pl~nt operation. The majority of t_hese 1 i-cP.nsees sub_mitted alternative approaches that were directed more toward monitoring and record keeping ra,ther than,speci-fic l i.mits on chemistry paramc~ters.
- At the time of our request, we recognized that a major disadvantage of the Technical Specifications was a potential
- decrease in operational f1 exibil ity, but our request was motivated by an overridin9 concern for steam generator tube inte~Jritye Our objectiv.e was to provide~ agded assurance that 1 icensees would properly monitor and.
c_ontrol secondary water chemistry to 1 irnit corrosion of stear;i generatO'r tubes.
""t7T~{.
HO\\'iever, based on the e~perience and,knowledge gafned since i976, we
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have now concluded-that Technical Specification limiti woul~ not be the most effective *11ay of accomplishing this objective. Due to the cor.1plexity of the corrosiqn phenomena involved, a.nd the state-of-the-art as it exists toclay, 1,ie believe that a ri10re effective approach would be to institute a 1 icense condition that requires tbe implementation of a secondary water d1enListry monitoring and control pr-ogram conta"ining
~ppropriate proc~d~res and ad~inistrative controls. A Model Lfcense Cond"ition that* is. acceptable*to* the staff for this purpose is enc1osed.
e required p ogram am pro.eoures wou a 1,e deve ope
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,nd thus could more readily ccount for site and plant.*pecific factors DURNAMII~ fi"a'f'aJ-recf*cfi*.,.ii,.stri*c*oiiifft ions***-fn.. tiie.. s*: eafri**cienerafoi~ *~*.. *rri**our.. *vr*,;;~...................
DATE~~ WfHl*+iaen!le ~*On<-:I~-t-i-Of1**\\'K:l-t:!- *d-- Y,O\\f,~*rlC**asc: nmce,**that*+ *C*en&ee&**\\;.:@-t,J.l.:_:i.......... ::...*..** :.
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- u.s. GOVERNMENT PRINTING OFFICE:-19°78,_ ~as - 789
Mr; W. L. Proffitt*
Virgini~ Electric and Power Company devote proper attention to controlling seconda.ry*water chemistry,
_ while also prov*iding the needed flexi.bi1ity to allow them to more
- effectively deal Nith any off-normal* conditions that might adse.
Moreover, we have c6ncluded that such a.license condition, in conjunction with exis:tin9 Technical Specifications on steam generator
. tube 1 eakage and *inserv ice inspect ion 5 would provide the most practical and comprehensive means of assuring that steam generator tube integrity is maintained.
Consequent] y, we request that you submit a proposed amendrnent to your license* to incorporate the requirements of the enclosed. Model License Condition into th~ body of your license 1A1ithin 60 days.
- If you previously submitted.. an application for -a 1-ic~nse arnend~erit concerning steam generator monitoring t~equirements prior to March 22, 1978, you need not remit a fee for the license amendment *requested.,*
by this letter. If you have net submitted a license amendment request prior to* March 22, 1978, you should remit a C1ass III fee \\*lith your application *. :
If you hijVe any questions, p1~ase contact us.
No further action will be taken on any proposed Technical Specification changes you may have submitted *;n response to our August 1976 request.
Such change requests wil 1 be considered withdraM1 unless you express objections within 60 days.
Enclosure:
Sincerely,
..Original Signed By A. Schwencer, Chief Operating Reactors.Branch #1 Division of O~erating Reactors Model Licen~e Coridition cc:
v,/enc1 os1jre See next pa9e
. J,,t**.*
OFFICa~
- *. 0.0.R;.O.ReJ.......
fJURNAME~
DATE~,
. NllC PO~ 318 (9-76) NRCM.0240 U,S. GOVERNMENT PRINTING OFFIC~: 1970.. ZG!I - 769
e UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos. 50-280 and 50-281 Mr. W~ L. Proffitt AUGUST 1
1979 Senior Vice President - Power Virginia Electric and Power Company Post Office Box 26665 Richmond, Virginia 23261
Dear Mr. Proffitt:
In August 1976 we sent letters to the majority of licensees who operate Pressurized Water Reactors (nJRs) 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 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.
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
~~.
Mr. W. L. Proffitt Virginia Electric and Power Company AUGUST 1579 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 1 icense 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 \\o~ill be taken on an_y proposed Technical Specification changes you may hav:e submitted in response to our August 1976 request.
Such change requests will be considered withdrawn unless you express objections within 60 days.
Enclosure:
Mod~l License Condition cc: w/enclosure See next page Sincerely,
- a.
A. Schwencer~ Chief Operating Reactors Branch Hl Division of Operating Reactors
e Mr. W. L. Proffitt Virginia Electric and Power Company cc:
Mr. Michael W. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virginia 23213 Swem Library College of William and Mary Williamsburg, Virginia 23185 Donald J. Burke U. S. Nuclear Regulatory Commission Region II Office of Inspection and Enforcement 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 AUGUST 1
1979.
ENCLOSURE MODEL LICENSE CONDITION SECONDARY WATER CHEMISTRY MQNitORING Jhe 1 icensee shal 1 iT.plement a secondary 'tiater chemistry monitoring
- progra~ to inhibit steam generator tube degradation.
~his program shall include:
- 1.
identificaticn of a samp1ing schedule for the critical parameters and controi points for these parameters;
- 2.
Identification of the procedures used to quantify Jararneters that are :ritical to control points;
- 3.
Icent~fication of process sampling points;
- 4.
Procedure fer the recording and managesent of data;
. 5.
Procedures defining corrective actions for off control point chesistry conditions; ~nd
- 6.
A procedure identifying the author~ty responsible for the inter-pretation o the data, and the sequence and timing of administrative events requ red to initiate corrective action.