ML19249A323

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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
ML19249A323
Person / Time
Site: Calvert Cliffs  
Issue date: 07/23/1979
From: Reid R
Office of Nuclear Reactor Regulation
To: Lundvall A
BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 7908220059
Download: ML19249A323 (4)


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JULY 2 3 sg Dockets Nos.: 5 % 31 7 and i,0- 31 0 f.tr. A. E. Lundvali, J r.

Vice President - Supply Baltimore Gas & Electric Conpany P. 0. Box 1475 Baltimore, Ilaryland 21203

Dearfir. Lundvall:

RE: CALVERT CLIFFS STAT 10ll, UNITS HOS. 1 A!JD 2 In late 1975 we incorporated provisions into the Standard Technical Specification (STS) tnat required limiting conditions for operation ano surveillance requirements for secondary water chemistry parameters. The Technical Specifications for your plant (s), as well as all other Pressurized Water Reactor plants that have Deen issued an Operating License since 1974, either contain these provisions, or a requirement to estaolish these provisions af ter baseline chemistry conditions have been determined.

The intent of the provisions was to provide added assurance that the operators of newly licensad plants would properly monitor and control secondary water cheuistry to limi corrosion of steam generator tuaes.

In a number of instances the Te:hnical Specifications have significantly iestricted 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 assuring that steam generator tube corrosian will be minimized.

Due to the conplexity of the corrosion phenomna involved, and the state-of-the-art as it exists today, we believe that, in lieu of Technical Specifications, a ' core effective approach would be to institute a license condition that requires the ir.plementation of a secondary water chemistry monitoring and control program containing appropriate procecures and acministrative controls.

A tlodel License Condition that is acceptable to the staff for this purpose is enclosed.

The required program and prccedures would be developed by the licensees, 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 steau generators.

In ou r vi ew, such a license condition would provide assurance that licensees woulo devote proper attention to controlling secondary water cnemistry, while also providing the needed flexibility to allow them to more effectively deal with any off-normal conditions that might arise. Iloreover, we have concluded that such a license condition, in conjunction with existing Technical Specifications en steam generator tube leakage and inservice inspection, would provide the most practical and cotprehensive neans of assurina that steam cenerator tune intearitv would na ma i ntai nad.

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Baltimore Gas & Electric Cocpany Consequently, we request that you submit a proposed acendaant to year license to delete your existing Technical Specifications on secondary water chemistry and to incorporate the requirements of the enclosed 14odel License Condition into the body of your license within 60 days.

If you previously submitted an application for a license anerdment concerning steam generator monitoring requirecents prior to March 22, 1970, that has yet to be issued by the NRC, you need not remit a fee for the license auendment requested by this letter.

If you have not submitted a license amnduent request prior to Ilarch 22,1970, you should remit a Class III fee with your application.

If you have any questions, please contact us.

Sincerely, n!U h% s ?

Robert W. Reid, Chief Operating Reactors Branch v4 Division of Operating Reactors

Enclosure:

flodel License Conuition cc w/ enclosure:

See next page 844 <Lb A

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Baltimore Gas & Electric Company cc:

Jar.es A. Biodj son, Jr.

Mr. R. M. Douglass, Manager General Counsel Quality Assurance Department G and E Building Room 923 Gas & Electric Building Charles Center P. O. Box 1475 8altimore, Maryland 21203 Baltimore, Maryland 21203 George F. Trowbridge, Esquire Shaw, Pittnan, Potts and Trowbridge 1800 M Street, H.l!.

Washington, D. C.

20036 11r. R. C. '.. Ol son Baltimore Gas and Electric Company Room 922 - G and E Building Post Office Box 1475 Baltimore, Maryland 21203 fir. Leon B. Russell, Chief Engineer Calvert Cliffs Huclear Power Plant Baltinore Gas and Electric Company Lusoy, liaryl and 20657 I

Bechtel Power Corporation ATTH:

fir. J. C. Judd Chief Nuclear Engineer 15740 Shady Grove Road Gaithersburg, Maryland 20760 Combustion Engineering, Inc.

ATTH: !!r. P. W. Kruse, flanager Engineering Services Post Office Box 500 Windsor, Connecticut 06095 Calvert County Library Prince Frederick, liaryland 20678 f

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ENCLOdURE MOCEL LICENSE CONDITION SECCNCARY '<!ATER CHEMISTRY MONITORING The licensee shall implement a secondary water chtmistry conitoring.

program to inhibit steam generator tube degradation. This program shall include:

,1.

Identification of a sampling schedule for the critical carameters and control points for these parameters; 2.

Identification of the procedure: used to. quantify parameters that are critical to control points; 3.

.Icentification of process sampling points; 4.

Procedure for the recording and ma;agement of data; 5.

Procedures defining corrective actions for off contrcl point chemistry conditions; and 6.

A procedure identifying the authority s esponsible for the inter-pretation of the data, and the requence and timing of acministrative events required to initiate corrective action.

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