Management Responsibility and Program Ownership

It is recognized that a specific CCW monitoring program applicable to all plants cannot be defined due to differences in design, experience, management structure, and operating philosophy. However, there are standard programs that are used across the industry and most systems can use one of these standard programs. The overall goal is to minimize corrosion and maximize the availability and operating life of CCW systems. To meet this goal, an effective water chemistry control program is essential and should be based upon the following:

• Recognition of the long-term benefits of, and need for, proper water chemistry control to avoid or minimize corrosion degradation of piping, heat exchangers, and other components • Clear management support for operating procedures designed to establish and maintain water

chemistry control (as provided in Sections 4, 5, 6, and 7)

• Adequate resources of staff, equipment, funds, and organization • Careful evaluation of site-specific needs and circumstances • Continuing review of plant and industry experience and research • Initiating revisions to the program as appropriate

1.7.1 Water Chemistry Management Philosophy

Management endorsement and support of the CCW strategies is key for successful

implementation. Without it, failure is likely. Management should require predefined methods to establish and maintain good chemistry for asset preservation.

Nuclear station management is periodically faced with the problem of either keeping a unit available to produce power and meet short-term power demands, or shutting down to repair system problems that affect good control of water chemistry, thus helping to ensure the long- term integrity of system components. The water chemistry philosophy must be effectively communicated to management so that it is understood that operating with off-normal chemistry might eventually result in loss of availability of that unit. Limiting the magnitude and duration of

off-normal chemistry can maximize plant availability and system integrity. A program document, which describes this philosophy, can effectively communicate these concepts to utility management. This document identifies any deviations that a plant takes from the control parameters in these guidelines, either permanently or for interim periods when plant conditions do not allow a prompt return to the control parameter band. Such deviations should be based on an engineering evaluation, which identifies how the proposed deviations do not have an effect on system operation. This would be of particular importance for those systems that fall under the Maintenance Rule.

The information presented in this section is based on the observation that operating and

maintenance philosophies regarding chemistry can significantly affect the integrity and longevity of CCW systems components. The philosophy and policies discussed reflect the desirability of operating in a proactive rather than a reactive mode. The costs associated with maintaining CCW chemistry within these industry recommendations are likely to be less than those associated with the repair or replacement of heat exchangers and piping, and the outages associated with those efforts.

Although it is recognized that variety among individual utility organizations exists, there are basic goals and functions common to all. This section addresses key management considerations but makes no attempt to specify how they should be integrated into a specific organizational structure. Additional organizational and administrative guidelines are presented in the INPO

Guidelines for Chemistry at Nuclear Power Stations, Rev. 2 (INPO 88-021, Rev. 2) October

1995. Utility personnel are encouraged to consider both the recommendations in this section and INPO recommendations when developing or revising their site-specific programs.

1.7.2 Generic Management Considerations

This section lists and discusses the considerations that are common to most utilities, including the elements of organizations that are needed to carry out a water chemistry program effectively. Utility-specific implementation policies and procedures should assign responsibilities to specific positions within the organization. One major element of these guidelines is the need for every level of management to understand the importance of the site-specific performance goals and effective chemical treatment presented in Sections 4, 5, 6, and 7. Effective chemical treatment has great benefits for the utility company by having a positive impact on CCW system integrity. An important ingredient of a successful management plan for CCW chemistry control is a set of documents that specify operating guidelines. The documents should:

• State the need for the document

• State the goal regarding CCW chemistry and station operation • Highlight management support for the document

Introduction

– Assessment of the effectiveness of chemistry control in minimizing component degradation

– Monitoring, analysis, and data evaluation for the chemistry program – Surveillance and review functions

– Implementing corrective actions

Utility personnel responsible for plant design in chemistry-related areas should:

• Understand CCW systems materials and the operational chemical treatment relationship with the system materials

• Ensure that the system design is reviewed by knowledgeable plant operating personnel, vendors, and/or consultants as appropriate

Procedures should include:

• A plant-specific monitoring program to ensure long-term system integrity

• Control limits, sampling frequency, specific corrective action responses, and corrective action notification and responsibilities

• Standardized analytical procedures to ensure accurate laboratory results • Provisions for data review

1.7.3 Training of CCW Chemistry Control Personnel

A program for training all personnel involved with CCW chemistry control should be

established. This program should incorporate the latest information available from EPRI, other utilities, NSSS suppliers, water treatment vendors, and industry expert consultants. Some

instruction in the basics of the program should be considered for all employees who, by virtue of their job responsibilities, can affect water chemistry. The training programs should be designed for the level and qualifications of personnel being trained. The following elements should be included:

• A clear statement of the policy regarding CCW chemistry control, including clarification of the impact of this policy upon the various responsibility areas.

• Identification of the impact of poor chemistry control.

• Identification of the chemical treatment control ranges for each program in use in the plant. • Techniques for recognizing unusual conditions and negative trends, particularly for the

station chemists and laboratory technicians. Potential corrective actions and their consequences should be thoroughly discussed.

• The interaction of system operations, engineering, radiation protection, maintenance, and chemistry departments.