ML18227D325
| ML18227D325 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/20/1976 |
| From: | Robert E. Uhrig Florida Power & Light Co |
| To: | Lear G Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18227D325 (5) | |
Text
~ ~
iN FLORIDA POWER 8( LIGHTCOMPANY September 20I 1976 L-76-335 Office of Nuclear Readtor Regulation Attention:
fir. George Lear, Chief Operating Reactors Branch/~<8 Division of Operating Reactors
~e U.
S. Nuclear Regulatory Commission /Q Washington, D.
C.
20555
Dear Nr. Lear:
Re:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 Secondary Water Chemistrv g.V 0 gC 0
IIcia g <q("
C Q ~%M COuP4I~,~~10ty Your letter of August 18, 1976 presented NRC concerns, including bases for the imposition of technical. specification requirements, regarding secondary water chemistry control.
We have reviewed the bases and effects of the proposed technical specifications and submit the following response:
We do not believe that technical specifications establishing limiting conditions for operation should be placed on econdary water chemistry.
The safety aspects of steam generator pressure.
boundary integrity are already addressed elsewhere.
For example, we are preparing a proposed technical specification in response to your September 8,
1976 letter which would require monitoring
'of primary to secondary leakage.
It would also provide for a steam'enerator tube leakage limit and would establish require-ments for plant shutdown should these limits be exceeded.
In
- addition, eddy current testing consistent with Regulatory Gu3.de L.83, 'Inservice In~per:Lien o Pres"urized W
+o Reactor Steam Generator Tubes",
provides a means by which the integrity of ind'vidual tubes can be evaluated during periodic planned outages.
The specifications which will be proposed in response to your September 8 letter will be directed toward assuring the integrity of the steam generators without idenLifying the causes, if any, of their possible degradation.
Potential causes might be deficiencies in design (including material selection),
quality assurance,.
installation, and primary or secondary environments of the steam generator.
Lengthy technical specifications could
Office of Nuclear Reactor Regulation Attention:
Nr. George Lear Page Two conceivably be written to bar each potential cause of degradation.
This would not,
- however, be consistent with our understanding of the purpose of technical specifications as authorized by the Atomic Energy Act and as utilized by the Nuclear Regulatory Commission.
Ne understand that the purpose of techni al specificat'ons is to identify those parameters of design and operation herbose violation, by some margin, would or could present an unacceptable safety risk.
- Thus, tne term "limitiflgcondit ons for opera ion" is defined in 10 CFR 50.36(c)
(2) as "the lowest functional capability or performance levels of equipment required for safe operation of the facility". lt is therefore appropriate to place a technical specification limit on the leakage through a
primary system boundary such as the steam generator tubing.
However, in our judgment, it would not be appropriate to write a technical specification addressing the potential causes of degradation of such boundaries.
Technical Specifications would be particularly inappropriate to secondary water chemistry parameters whose equilibrium conditions fluctuate during normal plant operational
- modes, such as power changes,.
- startups, and shutdowns.
There is no evidence that short-term variations in secondary water chemistry are significant to steam generator tube integrity.
Technical specification limitations on such fluctuations could only result in enforcement
- problems, lack of operational flexibility, and diminution of the safety signi-ficance of technical specifications.
Deviations from secondary
'water quality guidelines are not a safety problem and are therefore not appropriately the subject of technical specifica-tions; the condition of steam generator
- tubes, on the other hand, is appropriate for such consideration and technical specifications are being "-: 'cp " to provide for direct monitoring of the condition of the steam generator tubes in order to assure that continued integrity is maintained.
Xn. our opinion, we should avoid proliferation of tcchnica3 specifications.
Since the addition, deletion, or revision of technical specifications involves the formal, time-consuming license amendment
- process, the technical specifications should contain only those requirements that are directly relatable to safe operation.
Other means should be utilized for providing direction on matters that are indirectly related to the safety of operation.
There are many examples of this philosophy at operating plants, wherein many operating practices, procedures,
- tests, plans, etc.,
are covered by means other than the imposi-tion of technical specifications.
Office of Nuclear Reactor Regulation Attention:
Mr. George Lear Page Three Your August 18 letter also addresses the need for continual monitoring and control of steam side water chemistry in ordex.
to ensure against an accumulation of harmful impurities in the steam generators.
We agree that for long-term reliability and continued assurance of tube integrity, a chemistry control program is necessary.
The specific chemistry guidelines are periodically updated in conjunction with steam system supplier recommendations.
Chemistry date and records are maintained at the'urkey Point plant site and are subject to review by the NRC or any other autnori"ec act vi y, Regula Gry eview can then result in a critique of our ability to maintain chemistry within established guidelines and can result in corrective action when necessary.
The above arguments against limiting conditions, for operation also apply to detailed surveillance requirements,
- however, an entry into the technical specifications requiring that a
surveillance program will be practiced is not objectionable.
We are now preparing a prooosed amendment to the Turkey Point Technical Specifications along these lines and expect to have it completed by October 31, 1976.
Vexy truly yours, Robert E. Uhrig Vice President 4
REU/MAS/cpc CC'r ~
Norm n C. <<Iosele>>
Jack R.
Newman, Esquire
.w ~r