ML18219D980

Letter Response to Request of Proposed Secondary Water Chemistry Program in Accordance with Model Technical Specifications

ML18219D980
Person / Time
Site:	Cook
Issue date:	11/29/1976
From:	Tillinghast J Indiana Michigan Power Co, (Formerly Indiana & Michigan Power Co)
To:	Rusche B Office of Nuclear Reactor Regulation
References
Download: ML18219D980 (10)

Text

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INDIANA 5 MICHIGAN POWER P. O. BOX 18 BOWLING GREEN STATION NEW YORK, N. Y. 10004 PAN'F f87@ p leap' a

November, 76 Donald C. Cook Nuclear Plant Docket No. 50-315 License No.

DPR-58 Mr. Benard Rusche, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Rusche:

This letter is in response to Mr. Dennis L. Ziemann's letter dated September 10, 1976 which was received September 13,

1976, and which requested submittal of a proposed secondary water chemistry program in accordance with his enclosed.

Model

.Technical Specifications by no later than November 29, 1976.

Mr. Ziemann's letter presented the NRC concerns and bases for secondary water chemistry control and reiterated the requirement in Technical Specification 3-7.1.6 for developing secondary water chemistry specifications.

We have reviewed his proposed model technical specifications witn the steam generator manu-factorer.

Attachment-A contains our proposed technical specifications for a secondary water chemistry surveillance program and the bases which would be included in the Technical Specifications for such a program.

We do not believe that technical specifications'stablishing limiting conditions for operations should be placed on secondary water chemistry.

The safety aspects of

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Mr. Benard Rusche November 29, 1976 steam generator pressure boundary integrity are already controlled.

The current technical specification requiring monitoring of primary to secondary leakage (4.4.6.2) and the limit of 500 gallons per day per steam generator or one gallon per minute per unit (Technical Specification 3.4.6.2c) provide the limiting condition for operation.

Eddy current testing to conform to Regulatory Guide 1.83, "Xnservice Inspection of Pressurized Mater Reactor Steam Generator Tubes" provides further means by which individual tube integrity can be determined during periodic planned outages.

The existing specifications are directed to assuring the integrity of the steam generators.

Limiting conditions for operation would be particularly inappropriate to secondary water chemistry parameters where equilibrium conditions fluctuate during normal plant operation

modes, such as power changes, startups and shutdowns.

Such limits could result in diminution of the'safety significance of technical specifications, and lack of operational flexibility.

For example, if'one of the limiting conditions for operation in your model technical specifications is

exceeded, the licensee would have to restore that parameter in a certain time or bring the Unit to a hot shutdown.

Since this condition does not, in the short-t'erm-; directly. effect--.

safe operation of the plant, we would prefer to attempt to stabilize the situation, interpret its significance to continued operation, and take corrective action, all within the plant procedures and by internal review.

Nithout this flexibility, if we deemed that no safety hazard existed, in order to keep the Unit operating, we would be required to submit an emergency request for a technical specification change, which past experience has shown to be a time-consuming process.

There are many examples of this philosophy at all of the current operating plants, wherein many operating practices,

tests, plans, etc.,

are covered by means other than the imposition of technical specification, i.e.

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plant procedures, etc.

Mr. Ziemann's letter states the NRC Staff's position that secondary water chemistry monitoring requirements are necessary to ensure the control of harmful impurity accumulation

Mr. B. C. Rusche November 29, 1976 in the steam generators.

We believe that for long-term reliability and continued assurance

.of tube integrity, secondary water chemistry monitoring and controls are necessary.

Xn Attachment A, surveillance requirements are proposed to be added to the Donald C. Cook Nuclear Plant Technical Specification on Steam Generators, Section 3.4.5 in order to assure long-term tube integrity.

This surveillance program defines secondary water sampling and monitoring requirements and provides for data recording and maintenance, formal review of the data by-qualified personnel at the Plant and corrective action for conditions which may be outside operational guidelines.

This program would assure control, records,

review, and correction of conditions and would provide audit inspectability for purposes of surveillance.

The prepared surveillance specification we are submitting requires that secondary water chemistry be monitored at a frequency of at least 5 times per week..The specific chemistry guidelines including baseline criteria will be documented in the Plant's water chemistry control procedures.

Secondary water. chemical analyses and other appropriate records will be maintained at the plant and be subject to review by the NRC.

We anticipate finalization of specific chemistry guidelines and operational criteria within 45 days arid com-pletion of any supplemental associated plant procedures that may be needed within 30 days thereafter.

Very truly yours, JT mam J

Txlli g Vice President Sworn and subscribed to before me this

<V'" day of November, 1976 in New York County, New York Notary Public cc:

see next page KATICLEKN BARRy'OTARY pUSLIC, State ot Naw yoctt No. 41.4606792 Quatifiad in Queens County Cectificatu tet~A in Naw yock County

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Mr: B. C. Rusche No~ember 29, l976 cc:

G. Charnoff R. J. Vollen R.

C. Callen P.

W. Steketee R. Walsh R. S. Hunter R.

W. Zurgensen Bridgman

Donald C.

Cook Puclear Plant Docket h'o.

5'0-31$

License No.

DFB-58 ATTACH!KI.'T A

November 29.

1976 Donald C.

Co'ok >nuclear Pla;

'-Jnit Fo.

1 Technical Specifications i:.,.indary

<later Chemistry Surveillance 3>.eauirements Delete- "SECONDLY MAT&<

CHEi~iISTSY," Sections 3.7.1.6, 4.7.1.6, and Taole 3.7-3 on pages3/4 7-11, 3/4 7-12, 3/4 7-13, a.d Section 3/4 7.1.6 on page B 3/4 7-3 Add Section 4.4.5.6 and Bases below to existing specification 3.4.5, "Steam Generators".

on page 3/4 4-11 4.4.5.6.0 Secondary water chemistry shall be in accordance with the requirements given 'oelo~r.

5.4.. 5.6.1 The steam generator blo~rdo~m for each steam generator shall be samplea and analyzed for Cation Conductivity the Sodium content and free hydroxide concentration.

The main feedwater shall be analyzed for dissolvea oxygen content.

4.4.5.6.2 The parameters listed in 4.4..5,6.1 above shall be measured at least once per day on 5 days out of seven with no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> nor less than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> between each such measurements.

4.4.5.6.3 Operational c iteria and cor ective action(s) sh-ll

.be as specified in plant procedures.

4.4.5.6.4 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of performing the required measurement of Section 4.4.5.6.1 a comparison to the operational criteria shall be made to identify any potential adverse conditions, and if necessa y, corrective action(s) shall be initiated.

4.4.5.6.5 The authority for interpre ation of data and defining corrective actions shall be established in plant operating procedures.

4.4. 5.6.6 Laboratory analyses shall be performed in accordance with plant procedu." es.

Tne c-libration of those on-line monitors used to meet the requirements of items 4.4.5.6.1 and 4.4.5.6.2 shall be checked once per week in accordance s!ith plant procedures.

Add BASES: Section 3/4.4.5 to existing section on pages B 3/4 4-2 and 4-3.

Impurities that are introauced into the steam generator seconaary side coolant can concentrate in the steam gene".ator.

The degree of concentration can reach sufficient proportions for the 'mpurity to become aggressive to the tuoing.

uoe degradation ana impairment of the integrity o the tune can result.

Fo this reason, the establishvaent of the steam

=e.,erator chemistry control prog an

specified under SURVEXLLA?~CE REJUIREME$1TS is required to assure the long term integrity of the tubing.

The program requires measurement of those parameters

~rhich provide earliest indication of chemistry conditions that could affect tube degradation.

This program also requires proper record keeping, detailed written analytical methods, and definition of appropriate corrective action for adverse chemistry conditiors.

The surveillance intervals and time periods. allowed for corrective action have been determined to be appropriate based on the Steam Generator Manufacturers recommendations and the Plant's operational ex-

, perience with AVT chemistry.