ML19247B815
| ML19247B815 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/01/1979 |
| From: | Rubenstein L Office of Nuclear Reactor Regulation |
| To: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 7908130557 | |
| Download: ML19247B815 (4) | |
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Sh August 1,1979 Docket fc.: 50-329/330 Mr. S. H. Howell Vice President Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201
Dear Mr. Howell:
SUBJECT:
SECONDARY WATER CHEMISTRY CONTROL (Midland)
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 thenistry conditions have been determined. The intent of the provisions was to provide added 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 nunber of instances the Technical Specifications have significantly restricted the operational flexibility of some plants with little or no benefit with regard to 1imiting 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.
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 chenistry 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. S. H. Howell 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. Ve have concl uded that such a license condition, in conjunction with existing Technical Specifications on stear.i 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.
Sincerely, huWAW b
L. S. Rubenstein, Acting 01ief Light Water Reactors Branch ho. 4 Division of Project Management
Enclosure:
Model License Condition cc w/ enclosure:
See next page
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Consumers Power Company ccs:
Michael I. Miller, Esq.
Isham, Lincoln & Beale Suite 4200 One First National Plaza Chicago, Illinois 60603 Judd L. Bacon, Esq.
Cons trers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Mr. Paul A. Perry Secret ary Consumers Pover Company 212 W. Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq.
One IBM Plaza Chicago, Illinois 60611 Mary Sinclair 5711 Summerset Drive Midland, Michigan 48640 Frank J. Kelley, Esq.
Attorney General State of Michigan Environmental Protection Division 720 Law Building Lansing, Michigan 48913 Fr. Wendell Marshall Route 10 Midland, Michigan 48640 Grant J. Merritt, Esq.
Thompson, Niel sen, Klaverkanp & James 4444 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 Mr. Don van Farove, Chief Division of Radiological Health Department of Public Health P. O. Box 33035 Lansing, Michigan 48909
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ENCLOSURE F00EL LICENSE CONDITION SECONDARY WATER CHEMSTRY FONITORING 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 incl udes:
1.
Identification of a sampling schedule for the critical parameters and of control points f or 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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