ML20040B998
| ML20040B998 | |
| Person / Time | |
|---|---|
| Issue date: | 09/25/1981 |
| From: | Scinto J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Almeter F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML13319A635 | List:
|
| References | |
| FOIA-81-313 NUDOCS 8201270152 | |
| Download: ML20040B998 (4) | |
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Note to Frank Almeter, Engineering Branch, NRR My main comment on your paper relates to the discussion of water chemistry tech specs.
I think there are two separate thoughts.that do not come through well.
What seems to come across is that you think there should be no controls required on secondary water chenistry (a situation which would get us back into the lousy conditions experienced at Point Beach, Surry, Turkey Point and Millstone).
I think I know you well enough to know that you don't feel that way.
I think the problem is because there are two thoughts about denting and about Beaver Valley which get mixed up and don't come out clearly.
4 (1) We know a lot about denting - but we do not know enougt to pick numbers on chloride, etc., levels which would avoid the problem. We know it has to be kept clean but we really don't have a sound basis to pick a number such as.5 ppm, 0.1 ppm or whatever.
(2) We have a pretty good feel for numbers (ph range and Na and conductivity) which would help a lot on wastage and on caustic stress corrosion cracking (provided the generator is kept clean).
But we also have learned that before we put requirements on water chemistry - we have to provide enough flexibility to achieve good chemistry conditions for the particular plant.
I think what we learned at Beaver Valley is that we really shouldn't put i
shutdown type limits on the water chemistry.
Vhen conditions deviate from the conditions desired for long-term operation, it's harder to get stable conditions when there is a lot of up and down.
What we really need are requirements to make sure that the operator monitors the various water chemistry conditions and takes careful gradual steps to get chemistry conditions into balance.
f This will take some more careful development by NRC of what we mean by In the past, it has generally meant that the operator
" tech spec limits."
is required to do something quickly (measured in hours or days) or l
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shut down.
I think we have to find a way to req 2 ire gradual careful l
adjustment of water chemistry conditions, without the up and down situation
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that happened at Beaver Valley.
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Specific Suggestions
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l (A)
The changes mark'ed with (A) are all made to properly (reflect the status of the revisions to Reg Guides 1.44 and 1.56 they have f, g been mentioned publicly but they still haven't gone out on the e
7P PII7 street; okay by the Ratchet Conmittee).
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(B)
This sounds like ;/ou are recommending the three types of water gu j,3 chemistry.
So I suggest you change it to "have been used."
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(C)
Change this to correspond to the charjes on page 15.
Restrictive Technical Specifications which do not provide adequate flexibility to achieve desired water conditions gradually have proved to be undesirable (e.g., Beaver Valley, Unit 1).
For
" denting" there are, yet, no secondary coolant param-eters for the avoidance of denting.
Chlorides, soluble copper and/or nickel ions, and some cations in solution are suspected impurities that catalyze the formation of magnetite on the carbon steel tuba support plate and resultant denting.
Although it is clear that these impurities must be kept to e minimum, the operating experience of i
domestic plants that have developed some degree of
- j denting (Tabiere has not yet provided a solid basis to specify water chemistry control limits for these impurities.
Neverthel ss, some fann of monitoring is essential to ensure long-tenn steam generator tube integrity. NRC would be receptive l
to alternate technical specification proposals, from the utilities, that will reflect monitoring l
or surveillance programs with appropriate corrective l
actions to assure water quality control of the PWR l
l secondary coolant.
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(D
'Why "therefore?"
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(E)
I suggest you move this thought to page 14 and revise it slightly as marked.
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(F)
The statement that we "obviously" are concerned about steam purity
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is not obvious.
Give here the same reason you givc on page 15.
(G)
I suggest this change to make the tone more positive.
0 ffafa (H)
I suggest these changes to complete the thought and to connect I
more directly to the conclusion that shutdown type specs are p[Af,I ' not a good idea.
(I)
This is the place where 1 think the confusion I rientioned in my g*[lynotesetsin.
I suggest you revise it to first discuss inadequate flexibility then go on to discuss denting.
I suggest something like the following:
Restrictive Technical Specifications which do not 4
provide adequate flexibility to achieve desire.d water conditions gradually have proved to be j
undesirable (e.g.,BeaverValley, Unit 1).
Then, as a new paragraph move the material marked (E) en page 11 I
over to this point. Then go on to the steam purity point as I marked up on page 15.
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