ML19253B813

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Requests That Util Amend FSAR to Include Proposed Secondary Water Chemistry Program Which Will Be Referenced in Condition to OL & Will Replace Any Proposed Tech Specs on Secondary Water Chemistry.Model License Condition Encl
ML19253B813
Person / Time
Site: Prairie Island, Waterford  
Issue date: 08/24/1979
From: Baer R
Office of Nuclear Reactor Regulation
To: Aswell D
LOUISIANA POWER & LIGHT CO.
References
NUDOCS 7910220271
Download: ML19253B813 (4)


Text

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Docket Nos. 50-382 Mr. D. L. Aswell Vice President, Powr Froduction Louisiana Power and Light Canpany 142 Delaronde Street New Orleans, Louisiana 70174

Dear Mr. Aswell:

SUBJECT:

SECONDARY WATER CHEMISTRY CONTROL (Waterford Stean Electric Station, Unit 3)

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 detennined. The intent of the provisions was to provide added assurance that the cperators of newly licensed plants would properly monitor and control secondary water chemistry to limit corrosion of steam generator tubes.

In a number 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 experien:e and the know' edge gained in recent years, we have concluded that Technical Specification limits are not the most effective

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way of. assuring that steam generator tube corrosion will be minimized.

Due to the ccmplexity of the corrosion phencmena 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.

\\\\bD 371 79102202 7/

Mr. D. L. Aswell 2-AUG 2 41979 The requ'*ed program and procedures would be developed by the licensee (or applicanti 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 allcw them to deal more effectively 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 existing 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, RA 6 uutd Robert L. Baer, Chief Light Water Reactors Branch fio. 2 Division of Project Management

Enclosure:

Model License Conditf or.

cc w/ enclosure:

See next page f

  • 1150 078

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Mr. D. L. Aswell Vice President, Powr Production Lcuisiana Power & Light Ccmpany 142 Delarande Street New Orleans, Louisiana 70 174 cc:

W. Malcolm Stevenson, Esq.

Monroe & Lemann 1424 Whitney Building New Orleans, Louisiana 70130 Mr. E. Bl ake Shaw, Pittman,,Potts and Tro4 ridge 1800 M Street, N. W.

Washington,D. C.

20036 Mr. D. B. Lester Production Engineer Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Lym an L. Jones, Jr., Es q.

Gillespie & Jones 910 Security Homestead Building 4900 Veterans Memorial Boulevard Metairie, Louisiana 70002 Luke Fontana, Esq.

Gillespie & Jones 824 Esplanade Avenue New Orleans, Louisiana 70116 Stephen M. Irving, Esq.

One American P1 ace, Suite 1601 Baton Route, Louisiana 70825 1150 379

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  • s' 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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1150 080

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