ML18346A103

Response to Request for Additional Information Concerning Proposed Technical Specification Changes

ML18346A103
Person / Time
Site:	Palisades
Issue date:	02/20/1975
From:	Sewell R Consumers Power Co
To:	Purple R Office of Nuclear Reactor Regulation
References
Download: ML18346A103 (24)

Text

consumers Power company General Offices: !21!2 West Michigan Avenue, Jackson, Michigan 49!201

• Area Code 517 788-0550 February 20, 1975

~

• -~--

Mr. Robert A. Purple Division of Reactor Licensing Re:

1:1 Rf CE/V[D

, --J F~B~ 41975..

D.ocket 50-255l~.-.s.cu;i;:*.,,,1ur US Nuclear Regulatory Conunission Washington, DC 20555

Dear Mr. Purple:

License DPR-'

R-~

1 11

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14

~~U;J~,-'j' Pali sades P1 ai1 Sect1iia x

By letter dated February 4, 1975 you requested additional information concerning our proposed technical specification changes for the Palisades Plant dated December 13, 1974 and January 23,* 1975.

Attached are the responses to items of additional information requested.

Responses to the first four items of ~dditional information requested were provided by letters dated January 31, 1975 and February 6, 1975.

The seventh and only remaining item of your request for additional information is not provided at this time.

As discussed in our meeting of January 21, 1975, the development of a new tube plugging criteria will require a significant amount of engineering effort.

This effort has peen initiated; however, at the present time a projection of a firm schedule for completion of the effort and submittal to the NRC is not possible.

We will provide an estimated date for submittal of this information to the NRC when a reasonable schedule is developed.

Yours very truly, RBS/snun Ralph B. Sewell Nuclear Licensing Administrator CC:

JGKeppler, USNRC

Question 5 RESPONSES TO USNRC Request of February 4, 1975 for Additional Information "Compare the all-volatile treatment (AVT) chemistry specifica-tions with the secondary coolant chemical condition established from the start of AVT treatment to the present. "

Response

Initial objectives for steam generator chemistry during the steam generator flushing program were given in Attachment C to our August 20, 1974 submittal and are sfuninarized as follows:

pH in Range 8.2 ~ 9.0 Suspended Solids ~ 20 ppm Conductivity ~ 100 µmhos/cm P04 as Low as Possible.

(Target of.S 5 ppm)

Further acceptable chemistry (with respect to power level in-creases during the flushing program) would be considered to have been achieved when further actions did not result in moving chemistry toward normal operation.

Further, an ultimate objective was conformance with more stringent specifications to achieve typical industry practices regarding all vola-ti ve treatments of "fresh" steam generators.

Prior to the start of the flush program, it was felt that these specifications could not be achieved until long periods of prolonged operation following completion of the*

flushing program.

These specifications are as follows:

pH Conductivity (Specific)

Suspended Solids Silica Notes Normal Specifications(l) 8.2 - 9.0 7 µmhos/cm

< 1.0 ppm

< 1.0 ppm Abnormal Limits(2) 7.5 - 9.5 15 µmhos/cm 10 ppm 10 ppm (l)Normal specifications are those which should be.maintained by contin-uous steam generator blowdown during proper operation of secondary systems.

(2)Abnormal limits indicate a fault condition exists and plant shutdown shoUld be commenced if abnormal limits are exceeded for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and it appears likely that these specifications ca.nnot be a.chieved within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2 At the start of the flushing 'program, August 14, conductivity in the steam generator was about 700 to 800 µmhos/cm.

Phosphate concen-tration was 700-:800 ppm, silica ranged from 0.1 to 2.8 ppm and suspended solids generally were below 1 ppm.

Steam generator solution pH during the flush was typically in the 7.5 to 9.5 range.

On the first day of power operation, October 1, conductivity was about 30 µmhos/cm.

Suspended solids were 120 ppm and phosphate was 10-18 ppm.

By October 3, phosphates had been reduced to less than 1 ppm.

Conductivity had been reduced to less than 7 µmhos/cm (the ultimate limit) by October 10. Silica had been consistently below 0.5 ppm during these first few days of operation.

There had been no difficulties maintaining the operating pH.

Suspended solids gradually decreased to normal operating level over a period of a week.

From October 10 until October 17 the Palisades steam generator operated with all-volatile chemistry.

The only chemicals added were hydrazine and morpholine.

During this one-week oper-ation, Palisades steam generator chemistry was well within the ultimate specification.

Condenser tube leaks as experienced on October 7, 17 and 30 have a devasting influence on steam generator chemistry (condenser has been retubed since October 30 shutdown).

Conductivities increased to the 30 to 40 µmhos/cm range and silica went as high as 30 ppm.

It was not pos-sible to maintain steam generator chemistry by blowdown.

The pH was not affected to any extent since the alkalinity in the towers is fairly low

• At no time since the start of the flush has there been measureable phenol-phthalein alkalinity in the steam generators.

We believe, based on the foregoing summary of results, that we have achieved the ability to maintain an all-volatile secondary water chemistry treatment.

Question 6 "Provide a graph or plot showing the following as a function of time for both steam generators from the onset of isothermal flushing operations to the present:

a.

Phosphate and sulfate concentration,

b.

pH and,

c.

pounds of phosphate and sulfate removed.

Response

The attached graphs, supplemented by the notes listed below, are provided in response to this request.

Notes

1. 'The letter "D" on several of the graphs indicates a sample (generally a composite) taken during a generator drain.

-~ '.' e 3

2.

The first accounting of t,otal #P04 and #S04 removed from the generators took place in early September; however, due to the error noted late in September with the P04 analysis, the total P04 removed starts in October.

Quite a lot of work would be required to go back and add up the results for the missing four data points (September) and, therefore, it was not done.

1974, the culated.

fate from leakage.

3.

Due to circulating water leakage (high in S04) after October 1, pounds of sulfate removed from the generators were no longer cal-It would be impossible to determine whether we are removing sul-the "old siudge" or from the "new sludge" caused by condenser

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