ML19253A204
| ML19253A204 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/23/1979 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| TAC-08241, TAC-8241, NUDOCS 7908200102 | |
| Download: ML19253A204 (4) | |
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70, UNITED STATES y y3 m j'h NUCLEAR REGULATORY COMMISSION
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- w... y Docket No.: 60-336 JULY z 31973 Mr. W. G. Counsil, Vice President Nuclear Engineering & Operations Northeast kuclear Energy Conpany P. O. Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
RE: MILLSTONE !4UCLEAR POWER STATION, UNIT NO. 2 In August 1976 we sent letters to the majority of licensees who operate Pressurized Water Reactors (PWRs) regarding the control of secondary water chemistry to inhibit corrosion of steam generator tubes.
Tne letters requested the licensees to propose Technical Specification changes to incorporate limiting conditions for operation and surveillance requirenents for secondary water chemistry parar.eters. hocel Technical Specifications, which reflected the requirements contained in tne Comission's Standara Technical Specifications (STS), were included f or guidance.
Many licensees objected t the Model Technical Specifications principally on the Dasis that tney could unnecessarily restrict plant operation.
Toe majority of these licensees submitted alternative approacnes that were directed more toward monitoririg and record keeping rather than specific limits on chemistry parameters. At the time of our request, we recognizeu that a major disadvantage of the Technical Specifications was a potential oecrease in operational flexibility, but our request was motivated Dy an overriding concern for steam generator tube integrity. Our objective was to pro >ide added assurance that licensees woula properly monitor and control secondary water chemistry to Mmit corrosion of steam generator tubes.
However, baseu on the experience and knowledge gained since 1976, we have now concluded that Technical Specification limits would not be the most effective way of accorplishing this objective. Due to the conplexity of the corrosion phenomena involved, and the state-of-the-art as it exists today, we believe that a more effective approach woula be to institute a license condition that requires the irplementac'en of a secondary water chemistry monitoring and control program containing appropriate procedures and administrative controls. A hacel License Condition that is acceptaDie to the staff for this purpose is enclosed.
The required program and proceaures would be developed by the licensees, with any needed input f rom their reactor vencors or other consultants, and thus could more readily account for site and plant specific factors that affect chemistry conditions in the stean generators.
In ou r vi ew, such a license condition would provice assurance that licensees would 803 278 7 9082 00$O 2
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Northeast Nuclear Energy Cocpany devote proper attention to controlling secondary water cheraistry, while also providing the needed flexibility to alicw thera to more effectively deal with any off-normal conditions that nignt arise.
Moreover, we have concluded that such a license condition, in conjunction witn existing Technical Specifications on steara generator tube leakage and inservice inspection, would provide the nest practical and conprehensive means of assuring that steam generator tube integrity is maintained.
Consequently, we request that you submit a proposed amendment to your l'icense to incorporate the requirements of the enclosed Model License Condition into the body of your license within ou cays.
If you previously submitted an application for a license ai.enoment concerning steam generator nonitoring requirements prior to March 22.
1978, you need not renit a fee for the license amendment requested by this letter.
If you have not submitted a license amenument request prior to liarch 22, 1978, you should remit a Class 111 fee with your application.
If y% have any questions, please contact us.
140 further action will be taken on any proposed Technical Specification changes you may have submitted in response to our s;,ust 1970 request.
Such change requests will be considered withdrawn unless you express objections within 60 days.
Sincerely, L p w ?' },,. Q
~l 0-Robert W. Reid, Chief Operating Reactors Branch M Division of Operating Reactors Enclosu re:
Model License Condition cc w/ enclosure:
See next page J
803 279
Northeast Nuclear Energy Company cc:
William H. Cuddy, Esquire Day, Berry & Howard Counselors at Law-One Constitution Plaza
' Hartford, Connecticut 06103 Waterford Pu' lic Library o
I ape Ferry Road, Route 156 Waterford, Connecticut 06385 Nortneast Nuclear Energy Company ATTN:
Superintendent flillstone Plant Post Of fice Box 128 Waterford, Connecticut 06385 Northeast Utilities Service Company ATTri:
Mr. James R. Himmelwright Nuclear Engineering and Operations P. O. Box 270 Hartford, Connecticut 06101 Anthony Z. Roisman, Esq.
Natural Resources Defense Council 91715th Street, N.W.
Washington, D.C.
20005 Mr. John T. Shediosky Nuclear Regulatory Cammission, Region I Office ~ of Inspection and Enforcement 631 Park Avenue King of ' russia, Pennsylvania 19406 h
EitCLOSURE MOCEL LICENSE CONDITION SECONCARY WATER CHE'11STRY MONITCRING The licensee shall implement a secondary water chemistry monitoring program to inhibit steam generator tube degradation. This prc; ram shall include:
.l.
Identification of a sampling schedule for the critical parameters and contr;l points for these parameters; 2.
Identification of the procedures used to quantify parameters that are critical to control coints; 3.
Identification of process sampling points; Procedure for the recording and management of data; 5.
Procedures defining corrective actions for off control point chemistry conditions; and 6.
A procedure identifying the authority responsible for the inter-pretation of the data, and the sequence and timing of adninistrative events required to initiate corrective action.