IR 05000219/1987006
| ML20207S605 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/05/1987 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207S600 | List: |
| References | |
| 50-219-87-06, 50-219-87-6, NUDOCS 8703200088 | |
| Download: ML20207S605 (10) | |
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U.S. NUCLEAR' REGULATORY COMMISSION
REGION I
Report No. 87-06 Docket No. 50-219 License No. OPR-16 Priority Category C
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Licensee: GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 Facility Name: Ovster Creek Nuclear Generating Station Inspection At:
Forked River, New Jerses Inspection Conducted:
February 9-13, 1987 Inspectors:
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3f6!517 H. Bittehouse, Radiation Specialist date
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Approved by: b b h M./A.
J[f[87 W
J. Pasciak, Chpf, Effluents Radiation
'dite Protection Section, DRSS Inspection Summary:
Inspection on February 9-13, 1987 (Inspection Report No.
50-219/87-06)
Areas Inspected: Routine, unannounced review of the licensee's Water Chemistry Control Program. Areas reviewed included management controls, plant water chemistry systems, sampling / measurements and implementation of the program.
Resultq: No violations were noted. Control of general corrosion and pro-tectf on of fuel integrity and pressure boundaries appeared adequate. Control of rfdiation field buildup was generally adequate although the licensee lacked a systematic program to monitor growth of radiation fields associated with the recirculation piping, reactor water cleanup system, residual heat removal piping and associated components.
8703200088 870306 PDR ADOCK 05000219 G
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DETAILS 1.0 Persons Contacted 1.1 Licensee Personnel
- J. J. Barton, Deputy Director W. Dunphy, Senior Chemist
- C. J. Halbfoster, Maneger, Plant Chemistr,idwaste
- M. Heller, Licensing Engineer R. Hillman, Senior Chemist
^J. Kowal ski, Oyster Creek Licensing Manager A. Rone, Acting Plant Engineering Director
- J. L. Sullivan, Jr. Plant Operations Director Other licensee personnel were also contracted or interviewed.
1.2 NRC Personnel
- S. Peleschak, Reactor Engineer J. Wechselberger, Resident Inspector
- Attended the Exit Interview on February 13, 1987.
2.0 Scope The licensee's water chemistry control program was reviewed during this routine inspection. The purpose of the review was to assess the licensee's program to control corrosion and out-of-core radiation field buildup, ensure long-term integrity of the reactor coolant pressure boundary and minimize fuel leakage caused by corrosion-induced failures.
The licensee's program was reviewed relative to Technical Specifications, the Updated Final Safety Analysis Report (UFSAR) commitments, NRC Regulatory Guidance and industry-consensus standards.
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3.0 Previously Identified Item (Closed) 25-00-13 TI - Trial Use Of Water Chemistry Inspection Modules This inspection completed a series of inspections of the licensee's water chemistry control program which involved trial use of two inspection procedures.
This item is closed.
4.0 Management Controls The organization of the licensee's water chemistry control program was reviewed to determine if an effective, documented program for controlling the quality of the primary coolant water at Oyster Creek had been l
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developed. The licensee's Technical Specifications, UFSAR commitments and Quality Assurance Plan (QAP) governing organization, procedures, limiting conditions for operation and application of quality assurance procedures to maintenance of high purity water.were used in the review. Guidance provided by the Electric Power Research Institute (EPRI) Boiling Water Reactor Owner's Group (BWROG) Water Chemistry Guidelines Committee, (EPRI NP 3589-SR-LD) was also used in.the review.
4.1 Management Policies The licensee's management policies relative to the water chemistry control program were reviewed to determine if the licensee had provided a management commitment to, and support for, an effective water chemistry control program. The BWROG Water Chemistry Guidelines Committee recommends that corporate management establish policies and procedures and provide the resources necessary to support and enforce those policies.
Although there appeared to be a clear corporate commitment to and support for an effective water chemistry control program, the licensee was unable to provide a policy statement from GPU Nuclear supporting that commitment. Goals and objectives for the program were provided in a GPU Nuclear Specification, (SP)-1302-28-001,
" Water Quality", Revision 2 (7/1/82).
The inspector noted that the licensee was revising and updating SP-1302-28-001.
4.2 Corporate Chemistry The roles of the corporate chemistry organizations in providing technical support to the Station Chemistry Department were briefly reviewed. Clear corporate involvement was evident in special analytical support for resin analyses, laboratory intercomparison studies and chemistry specifications.
4.3 Chemistry Department The organization of the station's Chemistry Department was reviewed and appeared to be clearly defined. The department reported through the Manager - Plant Chemistry to the Plant Operations Director.
Within the department,11 Chemistry Technicians and 4 Assistant Technicians reporting to 2 Group Chemistry Supervisors provided implementation of the sampling and analysis program.
In addition, 2 Senior Chemists and a Senior Engineer were available to provide technical expertise to the Group Chemistry Supervisors and technical oversight of the program.
Chemistry Department staffing was reviewed with regard to routine operational analytical and sampling responsibilities. No backlogs of samples or analyses were noted indicating that adequate staffing had
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been provided.
Laboratory analytical capabilities were reviewed re-lative to the BWROG Water Chemistry Committee's guidelines and general Region I utilities' capabilities. State-of-the-art analyti-cal capabilities were noted allowing routine part per billion (ppb)
measurements to be made of critical chemical parameters.
Tecnnicians were interviewed to determine their understanding of the sampling and analytical methods used by the licensee. The technicians appeared to be fully knowledgeable of the licensee's methods. The inspector noted that the licensee's Chemistry Technician training program had received Institute for Nuclear Power Operations (INPO) accreditation.
4.4 Procedures NRC Regulatory Guide 1.33, (" Quality Acurance Program Requirements-Operations"), recommends, in part, chemical and radiochemical procedures to prescribe the nature and frequency of sampling and analysis, instructions maintaining water quality within prescribed limits and limitations on concentrations of agents that may cause corrosive attack or fouling of heat transfer surfaces or that may become sources of radiation hazard due to activation. The fuel vendors recommend control of certain impurities as a condition of the licensee's fuel warranty.
Licensee procedures related to administrative control of water chemistry, sampling and analysis, in-line instrumentation calibration and maintenance, operation of plant water chemistry control systems and reporting / trending were reviewed and discussed with the licensee.
The inspector noted that general rules and specific instructions governing implementation of the licensee's water chemistry control program were consistent with Technical Specification surveillance requirements and the BWROG Water Chemistry Committee's guidelines. Operating procedures for water chemistry control systems appeared to make full use of the plant's design including increased Reactor Water Clean-up (RWCU) System flow rates and recirculation of feedwater (FW) prior to introduction into the reactor vessel.
Although routine intercomparisons of in-line conductivity cells and laboratory reference conductivity cells were required by the licensee's procedures, the licensee did not provide acceptance criteria to determine that the in-line conductivity cells were performing satisfactorily. At the exit interview on February 13, 1987, the licensee indicated that acceptance criteria would be provided.
Maintenance procedures governing lapping and grinding activities on hard-faced valve seats were reviewed to determine if the licensee had initiated control / cleanup procedures to minimize the ingress of
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i cobalt-alloy debris. Procedures included instructions for retaining and removing debris and quality control inspection holdpoints to ensure cleanliness prior to reestablishment of water flow through the valve.
The licensee's procedures for monitoring the growth of out-of-core radiation fields were reviewed. Although the licensee conducts surveys of radiation fields in support of work activities under radiation control procedures, the licensee hadn't provided a radiation monitoring program to monitor the growth of radiation fields associated with transport of corrosion products, deposition on out-of-core surfaces of those corrosion products and long-term buildup of associated radiation fields from those corrosion Surveys taken in suppo,t of routine work rarely monitor products.
radiation fields at set locations which are needed to systematically trend radiation field buildup.
GPU Nuclear Specification (SP)-1302-08-012, (" Consumable Materials Chemistry Control", Revision 1,10/17/84) provided the basis for administrative controls of onsite chemicals / materials which could be harmful to personnel or plant equipment. However, the licensee had not completed review of an implementing procedure (Procedure At the exit interview on February 13, 1987, the licensee 119.4).
stated that review and initial implementation of Procedure 119.4 was scheduled to be completed by April 1987.
4.5 Self-Identification / Correction of Deficiencies The licensee's program to identify and correct chemical control deficiencies was reviewed to determine if a program to identify, investigate, document, report, track, close and trend discrepancies in the chemistry control program had been developed. The licensee's QAP classified the maintenance of high water purity in the reactor coolant system as "important to safety" and " nuclear safety related".
The licensee's quality assurance / quality control personnel conducted 8-10 surveillances per month, annual audits and routine inspection activities in the water chemistry control program area.
Review of the activities conducted under the QAP indicated that the bases for the program, adherence to procedural and surveillance requirements and general program implementation were routinely reviewed by the licensee's quality assurance and quality control organizations.
Data from the licensee's sampling and analysis program were routinely entered in a computer program which provided graphical Corporate and site management review of presentations of trends.
the trends was evident.
In addition, site management reviewed daily chemistry data, (particularly conductivities and isotopic data on fuel performance), and routinely toured the plant to examine equipment and personnel performance.
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cobalt-alloy debris.
Procedures included instructions for retaining and removing debris and quality control inspection holdpoints to ensure cleanliness prior to reestablishment of water flow through the valve.
The licensee's procedures for monitoring the growth of out-of-core radiation fields were reviewed. Although the licensee conducts surveys of radiation fields in support of work activities under radiation control procedures, the licensee hadn't provided a radiation monitoring program to monitor the growth of radiation fields associated with transport of corrosion products, deposition h
on out-of-core surfaces of those corrosion products and long-term buildup of associated radiation fields from those corrosion products. Surveys taken in support of routine work rarely monitor radiation fields at set locations which are needed to systematically trend radiation field buildup.
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GPU Nuclear Specification (SP)-1302-08-012, (" Consumable Materials (
Chemistry Control", Revision 1,10/17/84) provided the basis for administrative controls of onsite chemicals / materials which could be harmful to personnel or plant equipment. However, the licensee had not completed review of an implementing procedure (Procedure 119.4). At the exit interview on February 13, 1987, the licensee stated that review and initial implementation of Procedure 119.4 was scheduled to be completed by April 1987.
4.5 Self-Identification / Correction of Deficiencies The licensee's program to identify and correct chemical control deficiencies was reviewed to determine if a program to identify, investigate, document, report, track, close and trend discrepancies in the chemistry control program had been developed. The licensee's QAP classified the maintenance of high water purity in the reactor coolant system as "important to safety" and " nuclear safety related".
The licensee's quality assurance / quality control personnel conducted 8-10 surveillances per month, annual audits and routine inspection activities in the water chemistry control program area. Review of the activities conducted under the QAP indicated that the bases for the program, adherence to procedural and surveillance requirements and general program implementation were routinely reviewed by the licensee's quality assurance and quality control organizations.
Data from the licensee's sampling and analysis program were routinely entered in a computer program which provided graphical presentations of trends.
Corporate and site management review of the trends was evident.
In addition, site management reviewed daily chemistry data, (particularly conductivities and isotopic data on fuel performance), and routinely toured the plant to examine equipment and personnel performanc _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _
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5.0 Plant Water Chemistry Systems 5.1 Plant Description Oyster Creek is a 1930 MW, (620 MW,), General Electric BWR-2 which t
began commercial operation in December 1969. The unit has 560 fuel bundles, 137 control rods, motor-driven feeJ pumps and an isolation condenser. Condensate treatment is accomplished with deep bed demineralizers. Circulating water uses seawater in the con-densers. The RWCU system utilizes prefilters and 150 cubic feet deep bed demineralizers designed to accommodate up to 6% flow, (normally operated at 3% flow).
Fuel failures and chemical transients result-ing from condenser tube failures were experienced in the 1970's.
In 1979, the licensee raplaced the Admiralty Brass condenser with ti-tanium tubes. During operation, control rod drive (CRD) cooling water is drawn from polished condensate. During shutdown, CRD cool-ing water is taken from the Condensate Storage Tank (CST).
Radiation field buildup patterns for the plant were considered " generic" in the EPRI study. The inspector noted that the licensee had a generally conservative design for water treatment systems reflecting 1960's design standards for BWR-2 plants with seawater as circulating condenser water.
5.2 Water Systems Primary and auxiliary water systems ("as built") were reviewed relative to descriptions and drawings provided or referenced in the UFSAR. The Condensate System was reviewed for familiarization with major components and to identify potential flow paths for the ingress of contaminants into the reactor feedwater.
Sampling and in-line instrumentation were reviewed for representativeness and early de-tection of the possible failure of condenser tubes, air inleakage through seals and escape of condensate demineralizer resins into the feedwater.
Within the scope of the review, no problems or concerns were identified.
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5.3 Operation
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Operating schemes used for the Condensate Demineralizer and RWCU Systems and liquid radioactive waste water recycle were reviewed.
The inspector noted that resins were not regenerated and ultrasonic (
cleaning wasn't used. The following table summarizes the licensee's criteria for demineralizer resin replacement:
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SYSTEM CRITERIA (1) RWCU resins (1) Filter demineralizer monthly; effluent conductivity <0.1 uS/cm; Silica <20 ppb (2) Condensate Demineralizer (2) Replaced every outage; NRC resins Regulatory Guide 1.56 program to track remaining capacities (3) Radioactive Waste System (3) Silica breakthrough resins (4) Fuel Pool Cleanup resins (4) Differential pressure buildup (5) Demineralized Water (5) Conductivity; Silica; Total Organic Carbon Note: Licensee plans to re-place the demineralized water plant with a mobile unit in 1987.
The licensee's resin laboratory tests replacement resins prior to use ensuring good quality control of replacement resins.
The licensee appeared to have established adequate control of resin performance.
By drawing CRD cooling water from processed, demineralized condensate rather than the CST, the licensee limited ingress of impurities via the CRD cooling water during operation. During startup, the licensee recirculates condensate water from the effluent of the condensate demineralizers to the hotwell and, thus, avoids introduction of cor-rosion products from the feedwater system into the reactor vessel.
Resins are then discarded before feedwater flow to the reactor is established.
Feedwater heater drains are returned to the hotwell avoiding the containment ingress problems associated with forward pumped feedwater heater drains.
Recycle of treated radioactive waste water to the CST is continsent on meeting the following criteria and chemistry approval:
- Conductivity
< 1 uS/cm
< 400 ppb
- Turbidity
< 0.5 NTU
< 50 ppb
- Silica
< 20 ppb The licensee had not established criteria for purgable organic carbon although total organic carbon criteria were provided.
The licensee appeared to have developed an operating scheme for radioactive waste
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water recycle generally responsive to concerns raised in NRC Infor -
mation Notices Nos. 82-32 and 83-49 and Institute of Nuclear Power Operation (INP0) guidance. The inspector noted that TOC measurements were started in April 1986 in response to an INP0 Audit finding.
5.4 Radiation Field Buildup The primary long-term source of radiation fields in BWRs is cobalt-60.
The presence of high cobalt-containing alloys (e.g.,
Stellate) in the primary system in the hard facing alloys used in applications requiring resistance to mechanical wear have been associated with general radiation field buildup in BWRs. EPRI studies have shown that valve wear is the dominant out-of-core source of cobalt and in-core cobalt sources, (i.e., cobalt alloys in pins and rolle,s of BWR control blades) contribute up to 75% of the total cobalt-60 inventory. The unit was reviewed for materials of construction containing high cobalt content alloys. The review indicated that control rod roller and feedwater valve materials with high cobalt content were present.
EPRI recommends that feedwater quality be maintained as high as possible during operation with particular attention to minimizing corrosion product ingress which forms hot spots in crud traps.
EPRI also recommends that reactor water conductivity should be kept below 0.2 microsiemen per centimeter (uS/cm). The unit's performance in maintaining low conductivity during periods of operation in 1986-87 was reviewed.
Reactor water conductivity was generally below 0.2 uS/cm during operation.
Feedwater corrosion products were also consistently low.
6.0 Sampling / Measurement The licensee's sampling and in-line measurement program for determining possible chemical contaminants in high purity reactor water and systems supplying makeup and cooling water was reviewed relative to commitments in the UFSAR and industry-consensus standards and recommendations. The
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inspector noted that sample sinks rather than sample sink / ventilation hood cabinets were used throughout the plant.
The following sampling points were reviewed:
- Reactor Building Sample Sink (51 foot elevation);
- Fuel Pool Sampler (23 foot elevation, Old Radwaste Precoat Filter Room);
- Condensate Sampler (23 foot 6 inch elevation, Turbine Building);
- Condensate Pump Discharge (transparent tubing from each pump);
- Condensate Effluent samples (Condensate Demineralizer Control Room); and,
- Samplers for the Demineralized Water Tank, CST and makeup system.
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The inspector noted that the sampling design was consistent with the designs for 1960's vintage plants although additional sampling capabilities (including " corrosion product" samplers) had been added.
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i Inline conductivity' cells were briefly reviewed for' temperature control / compensation.,Although state-of-the-art temperanure control wasn't provided, conductivity cril readings corrected for temperature variation were well-below 0.2 uS/cm.
7.0 Implementation The licensee's implementation of the water chemistry' control program was reviewed reHative to Technical Specifications, commitments in the UFSAR, recommenda'tions and guiJance in NRC Regulatory Guides and Information
' Notices and industry-consensus standards.
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g 7.1 Surveillance \\
Thelicenseeisrequiredtodeterminetheconductivityandchhoride ton concentration in the reactor coolant water and maintain those parameters within.l.imits depende_nt on re' actor operating tondition.
Routine surveillance of. these parameters during 1986-87 was reviewed and no violations were noted.
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c The licensee's genical chemistry samplira, and analysis, prograr; for dissolved oxygen, pH, silica, sylphate and corrosion prpducts was reviewed during periods of operation and shut (bwn/layup of the'
systems during 1985-87.
No problams were not'ed.
Surveillance activities appeared. to be generally consistent with Fcel Warranty ar.d EPRI guidance for the parameters; reviewed.
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7.2 Hydrogen Water Chemistry (HWC) Test
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From January 17-20, 1986, the licensee conducted a test of the intro-duction,of hydrogen gas into the feedwater to miti. gate and control Intergranular Stress Corrosion Cracking (IGSCC).3 A Technical Data Report (TDR) summarizing the test was reviewed ar.d discussed with the licensee. The licensee's test indisfated that the "4 tigation point",
(-0.230 volt corrosion potential for 304 stainless (teel) was reached at approximately 9.6 standard cubic feet per minut6 (SCFM) hydrogen gas flow at full load operation. Hydrcgen was avied into the suction lines of each of the three reactor feed pumps.
Chemistry tests showed that reactor water'cranged from an oxidizirg to a reducing environment during the test and the licensee corcluded that HW': could be used as an IGSCC mitigator.
Radiation level _s and offgas rolease rates were also measured an,d shown to be acceptable.
7.3 Fuel Failures
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Duringcycle11,thelicenseeexperiencedfuelhailures(see Licensee Event Report (LER) No.86-016, July 30,1986).
The inspector noted that the licensee had experienced fuel failu'res during the 1970's thought to be due to pellet-clad'*nteractions and.
zircalloy hydriding probieres. The failure mechalnisni for the cladding
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failures in the 47 fuel bundles discussed in LER No.86-016 was
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discussed with the licensee. Reviews by the licensee (subsequent to
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LER No.86-016) have concluded that the failures were the probable
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result of pellet-clad interactions and the licensee intends to issue a revision to LER No.86-016 to identify that cause. As a corrective measure, the licensee has ordered barrier fuel for Cycle 12R.
Review of plant chemistry data did not show excessive corrosion product ingress (particularly copper) and alternative failure modes (e.g.,
crud-induced localized corrosion) weren't probable (given the titanium condensers and deep-bed demineralizers).
7.4 Turbine Examinations The latest low pressure turbine examinations conducted by the
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licensee were reviewed briefly. No evidence of low pressure turbine problems resulting from carry over of corrosive materials in the
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steam were noted. Deposits were not noted at the wet-dry zone, (i.e., " Wilson Line") and no evidence of corrosion cracking was noted on the buckets and wheels.
7.5 Chemical Decontamination Deposition of radioactive material on the inside surfaces of recir-culation system piping resulted in increasing dose rates inside the licensee's Drywell. A chemical decontamination was performed from May 15, through June 4, 1986 on the piping using a three step low oxidation-state metal ion, ("LOMI"), process.
Review of the TDR describing the decontamination showed that approximately 55 curies
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of total activity was measured resulting in dose rate reductions by factors of approximately 3, 2.1 and 1.4 at the 13 foot, 23 foot and 51 foot elevations of the licensee's Drywell. However, post-decontamination passivation of the pipe inner surfaces wasn't done.
The decontami-nation resulted in approximately 300 cubic feet of solidified resins (used in the process) as additional radioactive waste. The licensee plans to monitor radiation field buildup on the decontaminated pipe during the next outage.
8.0 Exit Interview
'he inspector met with the licensee's representatives (denoted in Detail T
1) at the conclusion of the inspection on February 13, 1987. During the mieting, the inspector summarized the purpose and scope of the inspection
'and identified findings as described in this report.
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.At no time during this inspection was written material provided to the
' licensee by the inspector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this report.
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