ML19247B814

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Requests Util Submit Proposed Secondary Water Chemistry Program to Be Incorporated in New License Condition. Current STS for All PWRs Are Ineffective Re Steam Generator Tube Degradation.Model License Condition Encl
ML19247B814
Person / Time
Site: Byron, Braidwood  
Issue date: 08/01/1979
From: Rubenstein L
Office of Nuclear Reactor Regulation
To: Reed C
COMMONWEALTH EDISON CO.
References
NUDOCS 7908130554
Download: ML19247B814 (4)


Text

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August 1,1979 Docket ho.:

STN50-454/45,5/456/457 5

Mr. Cordell Reed Assistant Vice President Commonwealth Edison Company P. O. Box 767 Cnicago, Illinois 60690

Dear Mr. Reed:

SUBJECT:

SECONDARY WATER CHEMISTRY CONTROL (Byron /Braidwood)

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 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 det erm ined. The intent of the provisions was to provide acaed assurance that the operators of newly licensed plants would properly monitor and control secondary water chemistry to limit corrosion of steam generator tubes.

In a nteber of instances the Technical Specifications have significantly restricted the operational flexibility 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 asst. ring 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..gproach 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.

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 effectively with any of f-normal conditions that might arise.

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Mr. Cordell Reed August 1,1979 Consequently, we request that you submit within 60 days your proposed secondary water chemistry program which will be referenced in a condition to your operating license and will replace any proposed Technical Specifications on secondary water chemistry. A model license condition is enclosed. We have concl uded 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 would be maintained.

If you have any questions, please contact us.

Si ncerely, W 'ff. 'fhCv 4;,-

L. S. Rubenstein, Acting Chief Light Water Reactors Branch No. 4 Division of Project Management

Enclosure:

Model License Condition cc w/ enclosure:

See next page h.

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Commonwealth Edison Company cc:

Mr. Williaa Kortier Atomic Power Distribution Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 John W. Rowe, Esq..

Isham, Lincoln & Beale One First National Plaza 42nd Floor Chicago, Illinois 60690 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 Ms. Marilyn J. Shinefl ug 1816 Judy Lane DeKalb, Illinois 60115 Ms. Beth L. Galbreath 734 Parkview Rockford, Illinois 61107 C. Allen Bock, Esq.

P. O. Box 342 Urbana, Illinois 61801 Thomas J. Gordon, Esq.

Waaler, Evans & Gordon 2503 S. Neil Champaign, Illinois 61820 L18100

ENCLOSURE F0 DEL LICENSE CONDITION SECONDARY LATER CHEFUSTRY FONITORING The licensee shall implement a secondary water chemistry nonitoring 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 paraneters and of control points for these parameters; 2.

Identification of the procedures used to measure the value of the critical par ameters ;

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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