ML20052G853

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Safety Evaluation Supporting Amend 30 to License NPF-6
ML20052G853
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 05/06/1982
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20052G850 List:
References
NUDOCS 8205190074
Download: ML20052G853 (3)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 g.K ' /- l O d.

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  • SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 30TO FACILITY OPERATING LICENSE NO. NPF-6 ARKANSAS POWER AND LIGHT COMPANY ARKANSAS NUCLEAR ONE, UNIT NO. 2 DOCKET N0 50-368 INTRODUCTION By letter dated June 10, 1981, the licensee requested an amendment to the Facility Operating License to include a licensing condition for the imple-mentation of a secondary water chemistry program.

The licensee's request was in response to our letter dated August 2,1979.

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 Technical Specifi-cations for all pressurized water reactor plants that have been issued an operating license since 1974 contain either these provisions or a repirement to establish these provisions after baseline chemistry conditions have beer.

determined.

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

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 degrgdation of steam generator tubes and the tube support plates.

Based on t,his experience and the knowledge gained in recent years, we have concluded that Technical Spccification limits are not the most effective way of assuring that steam generator degradation will be minimized.

Consequently, we have determined that, in lieu of specifying limiting conditions in the Technical Specifications, a more effective approach would be to institute a license condition that required the implementation of a secondary water chemistry monitoring and control program containing appropriate procedures and administrative contF61s. The required program and procedures are to be developed by the licensee with input from their reactor vendor or other consultants to account for site and plant-specific factors that affect chemistry conditions in the steam generators.

In our opinion, plant operation following such pro-cedures would provide assurance that licensees would devote proper attention to controlling secondary water chemistry, while also providing the needed flexi-bility to allow them to deal more effectively with an off-normal condition that might arise.

By letter dated August 2,1979, we requested that the licensee propose a seconda'ry water chemistry program which would be referenced in a condition to the license.

In the letter we concluded that such a license condition in con-junction with existing Technical Specifications on steam generator tube leakage and inservice inspection, would provide the most practical and comprehensive 8205190074 820506 PDR ADOCK 05000368 P

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, means of assuring that steam generator tube integrity would be maintained.

The licensee initially responded September 20, 1979.

On lune 10, 1981, th'e licensee amended that response with an application for amendmen; of the license to include a requirement for a secondary water chemistry monitoring program in lieu of the

' current Technical Specification limiting conditions for operation and surveillance requirements for secondary water chemistry par,ameters. On April 5,.1982, the licensee provided their Overall Plant Administrative Procedure (.1000.43, Rev. 0) titled " Steam Generator Water Chemistry Monitoring Unit II."

EVALUATION We evaluated the licens'ee's program using the guidance provided in our Aug.ast 2,1979 request.

This guidance stated that to inhibit steam generator degradation, the secondary water chemistry monitoring program should include:

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;

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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.

The proposed procedure is consistent with the secondary water chemistry guide-lines of the NSSS vendor and the EPRI-PWR Steam Generator Owners Group.

It includes a clearly defined chain of authority and responsibility for analysis, interpretation and corrective actions for secondary water chemistry control.

Specific water chemistry limits are defined for the condensate, feedwater and steam generators with sampling point locations and sampling schedules. These limits cover varying plant conditions, including wet layup, startup, hot standby 5-and power operations.

Procedures are provided which define corrective actions needed to be taken based on the severity of out-of-specification conditions.

The

'T corrective actions in'clude progressively stringent actions including power reductions and ultimately plant shutdown if chemistry conditions are not returned to normal within pre-defined time frames.

To help to determine trends, plots of the various chemistry parameters are maintained by the plant chemistry staff and historical records are retained for future reference. Specific analytical chemistry procedures are referenced for each parameter which is monitored.

s CONCLUSION Based on the above evaluation, we conclude that the licensee's Unit 2 secondary water chemistry monitoring program:

a) meets the guidance in our August 2,1979 l'etter to the licensee; b) is consistent with the secondary water chemistry guidelines of tbc.NSSS vendor and the EPRI-PWR Steam Generator Owners Group; c) is capable of reduc'ing the probability of abnormal leakage in' the reactor coolant pressure boundary by inhibiting steam generator corrosion and tube degradation and thus meets the requirements of General Design 4teria 14, and thus the proposed amendment is acceptable. The amendment has been implemented by the inclusion of condition 2.C.3.P in the body of the license and the deletion of Section 3/4 7.1.6 from the Technical Specifications.

Environmental Consideration We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and Having made will not result in any significant environmental impact.

this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of

~ environmental impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement or negative declaration and environ-mental impact appraisal need not be prepared in connection with the issuance of this amendment.

Conclusion We have concluded, based on the considerations discussed above, that:

(1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a.significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is' reasonable assurance that the health and sa.fety of the public

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will not be endangered by operati,on in the proposed manner, and (3) such activities will be conducted in compliance with the Commissicn's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Date: May 6, 1982 Principal Contributors:

H. Conrad C. McCracken