ML19209B779
| ML19209B779 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/24/1979 |
| From: | Baer R Office of Nuclear Reactor Regulation |
| To: | Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 7910100446 | |
| Download: ML19209B779 (5) | |
Text
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UNITED STATES j)s,(,
NUCLEAR REGULATORY COMMISSION g.;
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AUG 2 41979 Docket Nos. 50-445 and 50-446 Mr. R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Bryan Towers Dallas, Texas 75201
Dear Mr. Gary:
SUBJECT:
SECONDARY WATER CHEMISTRY CONTROL (Comanche Peak Steam Electric Station)
In late 1975 we incorporated provisions into the Standard Technical Specifi-cations (STS) that required limiting conditions for operation and surveillance requirements for secondary water chemistry parameters. The proposed Technical
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Specifications for your plant (s), as well as for other Pressurized Water Plants that have been issued an Operating License since 1974 or are now under review for an Operating License, contain either 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 ple.nts would properly monitor and coni.rol secondary water chemistry to limit corrosion of steam generator tubes.
In a number of instances the Technical Specifications have significantly restricted the operational fle"ibility of 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 admin-istrative controls.
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2-AUG 211979 Mr. R. J. Gary The required program and procedures would be developed by the licensee (or applicant) 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, plant operation following such procedures would provide assurance that licensees would devote proper attention to controlling secondary water chemistry, while also providing the needed flexibility to allow them to deal more effectivelf with any off-normal conditions that might arise.
Consequently, we request that you amend your FSAR to include your proposed secondary water chemistry program which will be referenced in a condition to your operating license and will replace any proposed Technical Specifi-cations on secondary water chemistry. A model license condition is enclosed.
We have concluded that such a license condition, in conjunction with exist'ng Technical Specifications on steam generator tube leakage and inservice inspec-tion, would provide the most practical and comprehensive means of assuring that steam generator tube integrity would be maintained.
If you have any questions, please contact us.
Sincerely, f
oY Robert L. Baer, Chief Light Water Reactors Branch No. 2 Division of Project Management
Enclosure:
Model License Condition cc w/ enclosure:
See next page h
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Mr. R. J. Gary I/
Mr. R. J. Gary Executive Vice President and
, j General Manager Texas Utilities Generating Company 1
2001 Bryan Towers Dallas, Texas 75201 Nicholas S. Reynolds, Esq.
Debevoise & Liberman 1200 Seventeenth Street Washington, D.C.
20036 Spencer C. Relyea, Esq.
Worsham, Forsythe & Sampels 2001 Bryan Tower Dallas, Texas 75201 Mr. Homer C. Schmidt Project Manager - Nuclear Plants Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Mr. H. R. Rock Gibbs and Hill, Inc.
393 Seventh Avenue New York, New York 10001 Mr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 Richard W. Lowerre, Esq.
Assistant Attorney General Environmental Protection Division P. 0. Box 12548, Capitol Station Austin, Texas 78711 Mrs. Juanita Ellis, President Citizens Association for Sound Energy 1426 South Polk Dallas, Texas 75224 Geoffrey M. Gay, Esq.
West Texas Legal Services 406 W.T. Waggoner Building
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810 Houston Street Fort Worth, Texas 76102
Mr. R. J. Gary Ms. Nancy Holdam Jacobson 4
Citizens for Fair Utility Regulation J
1400 Hemphill Fort Worth, Texas 76104 Mr. Richard Fouke 1668-B Carter Drive Arlington, Texas 76010 S
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ENCLOSURE MODEL LICENSE CONDITION SECONDARY WATER CHEMISTRY MONITORING The licensee shall implement a secondary water chemistry monitoring program in accordance with (reference Licensee's Procedure) to inhibit steam generator tube degradation. This program includes:
1.
Identification of a sampling schedule for the critical parameters and of control points for these parameters; 2.
Identification of the procedures used to measure the value of the critical parameters; 3.
Identification of process sampling points; 4.
Procedure for the recording and management of data; 5.
Procedures defining corrective actions for off-control point chemistry conditions; and 6.
A procedure identifying (1) the authority responsible for the interpretation of the data and (2) the sequence and timing of administrative events required to initiate corrective action.
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