ML17222A278

Responds to Generic Ltr 88-05 Re Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components.Principle Locations Where Leakage Could Degrade RCS Pressure Boundary Will Be Identified & Included in New Procedure

ML17222A278
Person / Time
Site:	Saint Lucie
Issue date:	05/31/1988
From:	Conway W FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GL-88-05, GL-88-5, L-88-244, NUDOCS 8806100130
Download: ML17222A278 (8)

Text

ACCEiZRATED IHS%1BUTIDN DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8806100130 DOC.DATE: 88/05/31 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power 6 Light Co. 05000335" 50-389 St. Lucie Plant, Unit 2, Florida Power 6 Light Co. 05000389"'

AUTH. NAME AUTHOR AFFILIATION CONWAY,W.F. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control. Desk) n

SUBJECT:

Responds to Generic Ltr 88-05 re boric acid corrosion of R carbon steel reactor pressure boundary components.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR J ENCL / SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES",

I ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 0 PD2-2 PD 5 5 TOURIGNY,E 1 1 A I

INTERNAL: ACRS 6 6 ARM/DAF/LFMB 1 0 NRR/DES T/ADS 7E 1 1 NRR/DEST/CEB 8H 1 1 NRR/DEST/ESB 8D NRR/DEST/RSB 8E NRR/PMAS/ILRB12 1

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1 NRR/DEST/MTB 9H NRR/DOEA/TSB NUDOCS-ABSTRACT ll 1 1

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OGC 15-B-18 1 0 01 1 1 RES/DE/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 D

D TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 25

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@$ 53 1 $ 88 L-88-244 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundar Com onents in PWR Plants Generic Letter 88-05 By letter dated March 17, 1988, the NRC forwarded to all operating pressurized water reactors (PWRs) the above referenced generic letter (GL). In that GL the NRC stated that it was requesting information to assess safe operation of PWRs when reactor coolant leaks below technical specification limits develop and the coolant containing dissolved boric acid comes in contact with and., degrades low alloy carbon steel components.

To this end, the NRC requested assurances that a program has been implemented consisting of systematic measures to ensure that boric acid corrosion does not lead to degradation of the reactor coolant pressure boundary. FPL's response to GL 88-05 for St. Lucie Plant is attached.

If additional information is required, please contact us.

Very truly yours, W. F. Co ay Senior Vice President Nuclear WFC/EJW/gp Attachment cc: Dr. J. Nelson Grace, Regional Administrator, Region USNRC II, Senior Resident Inspector, USNRC, St. Lucie Plant EJW88-05.GL 8806100i30 88053i an FPL Group company PDR ADQCK 05000335 P DCD

STATE OF FLORIDA COUNTY OF PALM BEACH )

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) st W. F. Conwa being first duly sworn, deposes and says:

That he is Senior Vice President Nuclear, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.

W. F. C Subscribed and sworn to before me this day of

,HOTLY PUBLIC, in and for County of Palm Beach, State of Florida Notary Public, State of Rorida

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~ ' v ATTACHMENT GL 88-05 PROGRAM In response to Generic Letter 88-05 St. Lucie Plant is revising its program for dealing with Reactor Coolant System (RCS) leaks. Currently, St. Lucie performs leak inspections after the RCS has been opened for maintenance or for refueling. This program will be expanded to include inspections that may be done at power or after reactor trips.

A procedure will be written to implement these additional inspections and is expected to be in place by July 15, 1988.

Responses for, the specific generic letter items are as follows:

The program should include a determination of the principal locations where, leaks that are smaller than the allowable technical specification limit can cause degradation of the primary pressure boundary by boric acid corrosion. Particular consideration should be given to identifying those locations where conditions exist that could cause high concentrations of boric acid on pressure boundary surfaces.

Response

I The principle locations where leakage could degrade the RCS pressure boundary will be identified. These locations will be included in the new procedure.

2 ~ The program should include procedures for locating small coolant leaks (i.e., leakage rates at less than technical specifications limits). It is important to establish the potential path of the leaking coolant and the reactor pressure boundary components it is likely to contact. This information is important in determining the interaction between the leaking coolant and reactor coolant pressure boundary materials.

Response

The procedure will include actions to be taken in the event of an indication of an RCS leak (e.g., sump level, flow, leak rate) in conjunction with an unexplained increase in containment airborne activity.

Areas susceptible to boric acid corrosion will be identified.

EJW88-05.GL

3. The program should include methods for conducting examinations and performing engineering evaluations to establish the impact on the reactor coolant pressure boundary when leakage is located. This should include procedures to promptly gather the necessary information for an engineering evaluation before the removal of evidence of leakage, such as boric acid crystal buildup.

Response

An examination method will be provided in the above procedure.

(leak It will contain the necessary rates, temperatures, pressures, requirements boric acid samples, affected equipment, etc.) for engineering evaluations. Engineering procedures currently exist which provide for evaluations of non-conformances such as those which might result from RCS leaks.

4 ~ The program should include corrective actions to prevent recurrences of this type of corrosion. This should include any modifications to be introduced in the present. design or operating procedures of the plant that (a) reduce the probability of primary coolant leaks at the locations where they may cause corrosion damage and (b) entail the use of suitable corrosion resistant materials or the application of protective coatings/cladding.

Response

Corrective actions are covered under current plant procedures. Consideration of design changes will be done on a case-by-case basis.

EJW88-05.GL

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