ML19261E522

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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
ML19261E522
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 07/23/1979
From: Reid R
Office of Nuclear Reactor Regulation
To: Lundvall A
BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 7908280578
Download: ML19261E522 (4)


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"W 23 19a Dockets Nos.: 50-317 and 50-318 fir. A. E. Lundvall, J r.

Vice President - Supply Baltimore Gas & Electric Conpany P. O. Box 1475 Baltimcre,14aryland 21203

Dear fir. Lundvall:

RE: CALVERT CLIFFS STATI0ll, UNITS NOS.1 AHO 2 In late 1975 we incorporated provisions into the Standard Technical Specification (STS) that required limiting conditions for operation and surveillance requirements for secondary water caemistry paramters. The Technical Specifications for your plant (s), as well as all other Pressurized Water Reactor plants that have been issued an Operating Licenso since 1974, either contain these provisions, or a requirement to estaolish these provisions after baseline chemistry conditions have been datermined. The intent of the provisions was to provide added assurance that the operators of newly licensed plants would properly monitor and control secondary water cheuistry 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 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 conplexity of the coe rosion phenomena involved, and the state-of-the-art as it exists today, we believe that, in lieu of Technical Specifications, a cure effective approach would be to institute a license condition that requires the inplementation of a secondary water chemistry monitoring and control program containing appropriate procecures and administrative controls. A flodel License Condition that is acceptaole to the staff for this hurpose is enclosed.

The required program and procecures would be developed by the licensees, with any needed input from their reactor vendors or other consultants, and thus could more readil) account for site and plant specific factors that affect chemistry conditions in the steam generators.

In our view, such a license condition would provide assurance that licensees would devote proper attention to controlling secondarf water cnemistry, while also providing the needed flexibility to allow them to more effectively deal with any off-normal conoitions that might arise. lloreever, we have concluded that such a license condition, in conjunction witn existing Technical Specifications on steam generator tube leakage and inservice inspection, would provice the cost practical and corprehensive i. cans of assurina that steam aenerator tube inteoritv would na mi ntai nad.

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4 Baltimore Gas & Electric Conpany Consequently, we request that you submit a proposed anendiaent to your license to delete your existing Technical Specifications on secondary water ch2mistry and to incorporate the requirenents of the enclosed Model License Ccadition into the body of your license within 60 days.

If you previously submitted an application for a license amendment' concerning steam generator monitoring requirenents prior to March 22, 1976, that has yet to be issued by the NRC, you need not remit a fee for the license auenament requested by this letter.

If you have not submitted a license amendicent request prior to March 22,1976, you should remit a Class III fee with your application.

If you have any questions, please contact us.

Si ncerely,

Q$~<

n Robert W. Reid, Chief Operating Reactors Branch 54 Division of Operating Reactors

Enclosure:

Model License Conuition cc w/ enclosure:

See next page 2021 355

4 Baltimore Gas & Electric Company cc:

Janes A. Biddison, 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 Baltimore, Maryland 21203 Baltimore, Maryland 21203 George F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridae 1800 M Street, H.l!.

Washington, D. C.

20036 11r. R. C. '.. Olson Baltinore Gas and Electric Company Room 922 - G and E Building Post Of fice 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 Bechtel Power Corporation ATTH: f1r. J. C. Judd Chief Nuclear Engineer 15740 Shady Grove Road Gaithersburg, Maryland 20760 Combustion Engineering, Inc.

ATTH: fir. P. W. Kruse, flanager Engineering Services Post Office Box 500 Windsor, Connecticut 06095 Calvert County Library Prince Frederick,11aryland 20678

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4 ENCLOSURE M0CEL LICENSE CONDITION SECCNCARY '.lATER CHEMISTRY MONITORING The licensee shall implement a secondary water chemistry monitoring.

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

,1.

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

Identification of the procedures used to. quantify parameters that are critical to control points; 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 the authority responsible for the inter-pretation of the data, and the sequence and timing of adninistrative events required to initiate corrective action.

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