ML20214J248

Proposed Tech Specs Re Secondary Water Chemistry Program

ML20214J248
Person / Time
Site:	Sequoyah
Issue date:	05/15/1987
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20214H100	List: ML20214H096 ML20214J248
References
TAC-R00134, TAC-R134, NUDOCS 8705270704
Download: ML20214J248 (7)

Text

.. .

v-ENCLOSURE 1 PROPOSED FACILITY OPERATING LICENSE CHANGE SEQUOYAH NUCLEAR PLANT UNIT 1 (TVA SQN TS-87-23)

PROPOSED CHANGE TO DELETE THE REQUIREHENTS OF SECTION 2.c.10 0F THE UNIT 1 FACILITY OPERATING LICENSE AFFECTED PAGE 0F THE OPERATING LICENSE 9

O P

l 9

1 (9) Steam Generator inspection (Section 5.3.1)

(a)

Prior to March 1,1981, TVA shall provide to the NRC the results of its tests to determine the feasibility of using a steam generatar camera device; (b)

Prior to start-up after the first refueling, TVA nest install ir.spection ports in each steam generator if the results of the camera device inspection are not satisfactory to the NRC;

~

Prior to start-up after the first refueling, TVA will plug Row (c) I of the steam generator tubes, if required by NRC.

(10) Water Chemistry Control Program (Section 5.3.2)

' ' ::r;: :t: r YW:U  : . """ :

. !-: HEGu/CEMEN7  : :::f' : ": 7 pp3 grry  ;: ofjE7ta. ,

-t

..,,.l.. ., . . . . . d . . s . . ' . . .

.......s

.,...,il f.~;:,. _. ;

iwilvo 3 ,.v. . . , . . . .

' 1,-" - ' n_; __._,

..Ufr.; -"-',*2:r. l' ';-,r r ,,-l:- --: ,7 - - ---

'

_;; - :: _y _

~~-

, 2  : ........, ..........

$ _$ $ _' ^_ _I .

7_.

2. ' ;.c't; t'_-  :.:t' g it: ': '::" 2 :. :h:_': i: ~'

^ ; :t:2  :: t'; -___. _..; ::t., , ., .

~

. $ 55  :( --' -]-f }' .E~ ~'

,:'y ; '

fi[ _ _ _ _ f_

(11) Negative Pressure in the Auxiliary Building Secondary Containment Enclosure (Aestt) (5cction c.2.3) i' After the final ABSCE configuration is determined, TVA must demonstrate to the satisf action of the NRC that a negative pressure of 0.25 inches

, of water gauge can be maintained in the spent fuel storage area and in the ESF pump room.

(12) Environmental Qualification (section 7.2.2)

No later than November 1,1980, TVA shell submit information (a) to show compliance with the requirements of NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," forImplementation safety-related equipment exposed to a harsh environment.

shall be in accordance with NUREG-0588 by June 30, 1982.

! (b) By no later than December 1,1980, complete and auditable records must be available and maintained at a central

! location which describe the environmental qualification l method used for all safety-related electrical equipment R4 in sufficient detail.to document the degree of compliance Thereaf ter, such with the DDR Guidelines or NUREG-0588.

records should be updated and maintained current as

~~

equipment is replaced, further tested, or otherwise 30,further 1982.

qualified to document complete compliance by June ehy.e ba 6 64 y b

,pwy

F-ENCLOSUDF 2 PROPOSED FACILITY OPERATING LICENSE CHANGE SEQUOYAH NUCLEAR PLANT UNIT 1 (TVA SQN TS-87-23)

JUSTIFICATION FOR PROPOSED CHANGE TO DELETE THE REQUIREMENTS OF SECTION 2.c.10 0F THE UNIT 1 FACILITY OPERATING LICENSE 4

Y t

4 i

1

- _ , . _ . - . . . , _ . _ . _ _ , __ _ _ _ . . _ _ . _ _ _ . _ , _.,. ___ .~.. .-.

m Description of Channe This change will delete the requirements of Section 2.c.10. " Water Chemistry Control Program" of the Sequoyah Nuclear Plant (SQN) unit 1 Facility Operating License. -

Reason for Change SQN license condition 2.c.10 required certain provisions be incorporated into the water chemistry program. These were accomplished as outlined by letter from L. M. Mills to A. Schwencer dated August 13, 1980. However, SQN no longer follows action levels identical to those outlined in that letter.

Instead, the impurity time operating limits and action levels are consistent with the Steam Generator Owners' Group (SGOG) Special Report EPRI-NP-2704, "PWR Secondary Water Chemistry Guidelines," to minimize steam generator tube degradation.

Justification for Chante The Secondary Water Chemistry Program at SQN presently uses the guidelines as established by the SGOG. These guidelines were recommended by Generic Letter 85-02 and referenced in section 2.5 of NUREG-0844, which stated that

" Licensees should have a secondary water chemistry program to minimize steam generator tube degradation." Also, the plant program should incorporate the secondary water chemistry guidelines in SCOG Special Report EPRI-NP-2704, "PWR Secondary Water Chemistry Guidelines," October 1982, and should address measures taken to minimize steam generator corrosion, including materials selection, chemistry limits, and control methods. In addition, the specific plant procedures should include progressively more stringent corrective actions for out-of-specification water chemistry conditions. These corrective actions should include power reductions and shutdowns, as appropriate, when excessively corrosive conditions exist. Specific functional individuals should be identified as having the responsibility / authority to interpret plant water chemistry information and initiate appropriate plant actions to adjust chemistry, as necessary.

The referenced SGOG guidelines were prepared by the Steam Generator Owners' Group Water Chemistry Guidelines Committee and represent a consensus opinion of a significant portion of the industry for state-of-the-art secondary water chemistry control.

These recommendations are in conflict with license condition 2.c.10. However, with TVA's commitment to maintain steam generator tube integrity, the SGOG guidelines were adopted. Technica: Specification 6.8.5.c, " Secondary Water Chemistry," requires a program for monitoring secondary water chemistry to inhibit steam generator tube degradation. An audit of SQN's Secondary Water

r e

Chemistry Program was performed by Bill Ross, NRC Region II, and no problems were found utilizing the SCOG guidelines. SQN's specific water chemistry limits and associated action levels are based on the SGOG guidelines and are incorporated into plant procedures. These procedures, as an integral part of the SQN Secondary Water Chemistry Program, help ensure that steam generator corrosion and fouling have been effectively controlled. Therefore, license condition 2.c.lO should be deleted.

e ENCLOSURE 3 PROPOSED FACILITY OPERATING LICENSE CHANGE SEQUOYAH NUCLEAR PLANT UNIT 1

• (TVA SQN TS-87-23)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS TO DELETE THE REQUIREMENTS OF THE UNIT 1 FACILITY OPERATING LICENSE SECTION 2.c.10 i

l l

\

l I

l -

l

SIGNIFICANT HAZARDS CONSIDERATIONS

1. Is the probability of an occurrence or the consequences of an accident previously evaluated in the safety analysis report significantly increased?

No, license condition 2.c.10 was included as a measure to ensure that steam generator tubing would not be subjected to conditions that would cause degradation of integrity. The SGOG guidelines are more sensitive to critical water chemistry to minimize steam generator tube degradation than the license condition; thus, the probability of an occurrence or the consequences of an accident previously evaluated in the safety analysis report are not significantly increased.

2. Is the possibility for an accident of a new or different type than evaluated previously in the safety analysis report created?

No, the proposed change to delete license condition 2.c.10 will not present new or different safety concerns. This change will still require the licensee to monitor critical parameters of secondary water chemistry necessary to control corrosive conditions in the steam generator and maintain tube integrity.

3. Is the margin of safety significantly re; aced?

No, the improved Secondary Water Chemistry Program will provide better control of corrosive conditions that contribute to steam generator tube degradation. Therefore, the margin of safety is not significantly reduced.

k