IR 05000220/1986027

Insp Repts 50-220/86-27 & 50-410/86-66 on 861201-05.No Violations Noted.Majors Areas inspected:organization,self- Indentification/Correction of Deficiencies,Plant Water Chemistry Sys & Sampling/Measurements

ML20207K291
Person / Time
Site:	Nine Mile Point
Issue date:	12/30/1986
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207K234	List: IR 05000220/1986027 ML20207K231
References
50-220-86-27, 50-410-86-66, NUDOCS 8701090382
Download: ML20207K291 (14)

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U.S. NUCLEAR REGULATORY COMMISSION I

REGION I

Combined Report Nos. 50-220/86-27

50-410/86-66

Docket Nos. 50-220 i 50-410

. License No. OPR-63 Priority Categcry C CPPR-112 Licensee: Niagara Mohawk Power Corporation i 300 Erie Boulevard West Syracuse New York 13202

! Facility Name: Nine Mile Point - Units 1 and 2

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Inspection At: Scriba,'New York Inspection Conducted: December 1-5, 1986

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Inspectors: (2.fZ2.f$( '

i H. J Bicehouse, Radiation Specialist date l Approved by: or ; l 3e 3(-

i W. JU Pas ~ciak, Chief idate i Effluents Radiation Protection Section Inspection Summary: Inspection on December 1-5, 1986 (Combined Reaort Nos.

, 50-220/86-27 and 50-410/86-66)

! Areas Inspected: Routine, unannounced review of the licensee's Water Chemistry 1 Control Program. Areas reviewed included previously identified items, organ-l ization, self-identification / correction of deficiencies, plant water chemistry

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systems, sampling / measurements and implementation of the program.

! Results: No violations were noted in the area reviewed. Unit 1 appeared to have developed and implemented an adequate water chemistry control progra In general, control of radiation field buildup was the weakest area of the licensee's program. Control of general corrosion and protection of fuel integrity and pressure boundaries appeared adequate.

I I 8701090332 861231

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DETAILS

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i 1. Person Contacted 1.1 Licensee Personnel

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l *T. W. Roman, Station Superintendent - Unit 1

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• C. L. Stuart Superintendent - Chemistry and Radiation Protection

• J. Blasiak, Chemistry Unit 1 Supervisor i *W. J. Connelly, Quality Assurance (QA) Program Manager l *J. N. Duell, Superintendent, Chemistry i *C. A. Gerber, Supervisor, Radwaste Operations

• T. C. Newman, Supervisor, Operations Services

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• A. M. Ross, Chemistry Unit 2 Supervisor

• K. J. Shea, QA Engineer (Surveillance Lead)

• K. J. Snyder, Generation Engineer-Nuclear, Chemistry Other licensee personnel were also contacted or interviewe .2 NRC Personnel W. A. Cook, Senior Resident Inspector

• C. S. Marschall, Resident Inspector

• Attended the Exit Interview on December 5, 1986 Scope

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This routine inspection reviewed the licensee's water chemistry control program including implementation of the Unit 1 program and' development of

the Unit 2 program. The purpose of the inspection was to review the

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licensee's pregram to control corrosion and out-of-core radiation field

, buildup, ensure long-term integrity of the reactor coolant pressure i

boundary and minimize fuel leakage caused by corrosion-induced failure The licensee's water ihemistry control program was reviewed relative to Technical Specifications (Unit 1), Final Safety Analysis Report (FSAR)

commitments (both units), NRC Regulatory Guidance (Unit 2) and 4 industry-consensus standards (both units). The licensee's actions

, regarding previously identified items-in chemistry / radiochemistry were also reviewe . Previously Identified Items i

3.1 (Closed) 25-00-13 TI- Trial use of water chemistry inspection modules

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This inspection completed a series of inspections of the licensee's water chemistry control program which involved trial use of two

inspection procedures.

I This item is closed.

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3.2 (Closed) Followup Item (50-220/84-24-01) - Include control charts in

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Procedure NI-PSP-15

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! The licensee replaced Procedure NI-PSP-15 with Procedure NI-CSP-15V

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and included control chart requirements in the latter procedur This item is close .3 (Closed) Followup Item (50-220/84-24-02) - Include QC in Chemistry

. Technician Training Program

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The licensee incorporated laboratory quality control (QC) in a 9 hour1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> training session presented to station chemistry technicians in May 1985. Each technician's performance of laboratory QC activities was

verified by tests performed on-the-job. Interviews of technicians indicated that the technicians were aware of the licensee's bases for a laboratory QC program including why control measurements are per-formed and how to evaluate them.

This item is closed.

3.4 (Closed) Followup Item (50-220/84-24-03) - Update Gamma Spectroscopy

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Library The licensee updated the computer-based gamma spectroscopy library

. using Radioactive Decay Data Tables, (1981) by D.C. Kocher.

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The inspector reviewed printouts of the computer software used to

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radionuclidic identify and branching ratios and determined that the

gamma spectroscopy library for each units GeLi detectors had been updated.

f This item is close . Organization

The organization of the licensee's water chemistry control program was j reviewed to determine if an effective, documented program for controlling .

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the quality of the primary coolant water in each unit had been develope '

The licensee's Technical Specifications (Unit 1) and FSAR commitments (Unit 2) governing organization, procedures and limiting conditions for i operation concerning primary chemistry were used in the review. Guidance l provided by the Electric Power Research Institute (EPRI) Boiling Water

! Reactor (BWR) Owner's Group Water Chemistry Guidelines Committee, (i.e.

! EPRI Report NP 3589-SR-LD, April 1, 1984) was also used in the review.

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4.1 Management Meeting

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The licensee's management policies relative to the water chemistry j control program were reviewed to determine if the licensee had

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provided a management commitment to, and support for, an effective

water chemistry control program. The BWR Owner's Group Water

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Chemistry Guidelines Committee recommends that corporate management establish policies and procedures and provide the resources necessary to support and enforce these policies. Although there appeared to be a corporate commitment to and support for an adequate chemistry control program, a clear corporate policy statement was not eviden This is considered a weakness in the licensee's water chemistry control progra At the exit interview on December 5, 1986, the licensee's represent-ative indicated that a corporate commitment to and support for the program were present obviating the need for a corporate policy statemen .2 Corporate Chemistry The role of the corporate chemistry organization in providing tech-nical support to the station chemistry group was briefly reviewe There was little objective evidence of corporate involvement in the water chemistry control program at the station. Periodic, documented reviews of the station water chemistry control program and recom-mendations for improvements were not evident. The exact role of the corporate office in providing technical support and overview of the station program appeared unclear (see related item in Detail concerning audit activities under the auspices of the offsite review group).

4.3 Chemistry / Radiation Protection Reorganization The licensee was reorganizing the Chemistry / Radiation Protection department at the station. Under the reorganization, chemistry and radiation protection activities were separated reporting through individual section managers to the newly-appointed (December 1, 1986)

Superintendent - Chemistry and Radiation Protection. The licensee was preparing a request for changes to Technical Specifications to reflect the new organization. At the exit interview in December 5, 1986, the licensee's representative indicated that the request for changes to the Technical Specifications were undergoing final review and would be submitted to NRC-NRR by early January 1987 for review and approval. Changes to station administrative procedures reflecting the altered duties and responsibilities of the supervisors and managers were reviewed and approved by the onsite review committee on December 9,198 .

4.4 Procedures NRC Regulatory Guide 1.33, (" Quality Assurance Program Requirements-Operations") recommerds, 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 caus corrosive attack or fouling of heat transfer surfaces or that may

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become sources of radiation hazards due to activation. The Nuclear Steam Supply System (NSSS) vendor, -(i.e. General Electric Company)

recommends control of certain impurities as a condition of the licensee's fuel warrant Licensee procedures related to administrative controls of water chemistry, sampling and analysis, in-line instrumentation calibration and maintenance, operation of each unit's water chemistry systems and reporting / trending and record-keeping were reviewed. Within the scope of this review, the licensee appeared to have developed adequate procedures for both units consistent with the differences in design and available systems and instrumentation. Surveillance procedures (related to Technical . Specifications and FSAR commitments)

generally consistent with EPRI Guidelines were inplace (Unit 1) and under development (Unit 2). No specific concerns related to procedures were note .5 Resources The inspector reviewed station chemistry staffing relative to the identified duties and responsibilities of each unit's chemistry sections. The licensee appeared to have sufficient staff to provide the necessary sampling, analysis and surveillance activities described in the licensee's procedure The inspector also reviewed analytical capabilities relative to the

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EPRI Guidelines and general Region I utilities capabilities. Within the scope of this latter review, the following apparent weakness was noted:

Although generally adequate sampling and in-line instrumentation capability was noted, the licensee's analytical program was hindered by lack of state of the art analytical capabilities. An example of this weakness was the licensee's inability to. measure chloride ion at the 1 part per billion (ppb) range. The licensee's method of analysis allowed reporting to about 20 ppb whereas most Region I licensees are able to detect chloride to 1 ppb (i.e. through use of an ion chromatograph). The licensee indicated that plans were being formulated to use Specific Ion Electrode (SIE) techniques to lower the levels of detection to about 10 ppb in the near term and to obtain an ion chromatograph to further enhance capabilitie . Self-Identification / Correction of Deficiencies The licensee's program to identify and correct chemical control deficien- i cies was reviewed to determine it a program to identify, investigate, document, report, track, close and trend discrepancies in the chemistry control program at each unit had been develope . _ . _ _, ___ _ __ ___ _

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5.1 Audits The inspector reviewed the licensee's audit program (as it related to water chemistry control) under Unit 1 Technical Specifications, the licensee's QA Plan and FSAR commitments. The following audit reports were reviewed and discussed with the licensee:

Audit No. SY-RG-IN-85010, " Audit of Radiation Protection /

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Chemistry Department at Nine Mile Point Station, Unit 1,"

(September 20,1985),and Audit No. SY-RG-IN-86012, "SRAB Audit B - Nine Mile Point 1 -

Operations," (joint offsite review group /QA audit October 13,1986).

The inspector noted that review of chemical parameters (other than chlorides and conductivities required by Unit 1 Technical Specific-ations) were not included in either audit. The licensee indicated that no other audits of the chemistry program had occurred during 1985-86 which reviewed chemical parameters or the water chemistry control programs as a whole. Lack of systematic review of the water chemistry control program is considered a weakness of the licensee's progra .2 Surveillance Activities Approximately monthly surveillances of the chemistry operation are completed by the onsite QA group. Review of surveillance records

, indicated that QA reviewed precedural adherence by the chemistry group including sampling, analyses, control of reagents and general laboratory QC activitie Interviews of QA personnel indicated that the surveillances were scheduled activities and were closely coordinated with ongoing chemistry group activities. The licensee appeared to have an adequate surveillance program with strong procedural compliance content.

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5.3 SORC Review Review of the Station Operations Review Committee's (SORC) activities showed that the SORC routinely reviewed conductivity trends during periods of operation and discussed chemistry problems when these problems were presented to i .4 Management Review The inspector reviewed corporate and site management review of the water chemistry control program and the onsite chemical control administrative program. The inspector noted that senior corporate and site management received a monthly operations report which included trends of Unit 1 conductivities covering an approximately 3

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year interval. The licensee stated that similar conductivity trend data for Unit 2 will be included in the report when Unit 2 g6es on line. This trend data presentation and review as an important plant parameter is considered a strength of the licensee's water chemistry control program. The Unit-1 Station Superintendent included a review of onsite chemicals in weekly management audits and walk through .5. Trending Program Data from the licensee's sampling and analysis program were recorded in a computer program which allowed tabular and graphical presenta-tions of trends. The licensee expressed some dissatisfaction with the current program for computer-trending and indicated that additional trending capabilities were being considere "

6. Plant Water Chemistry Systems 6.1 Plant Descriptions Unit 1 is a 610 MWe (net) General Electric BWR that began commercial operation in December 1969. Fuel failures and chemical transients were experienced with the unit in 1970's. In 1982-83, the licensee replaced recirculation piping to restore primary system pressure boundary integrity which had been compromised by intergramular stress corrosion cracking (IGSCC) phenomeno The condenser had also been replaced and was operating with approximately.12 plugged tube Plant water chemistry systems reflect designs'from the 1960's for BWR-2 reactors. The design includes deep bed demineralizers in the Condensate System, a deep bed demineralizer Reactor Water Cleanup (RWCU) System and up to 6% flow through the RWC Unit 2 is a 1,100 MWe (net) General Electric BWR currently, undergoing preoperational tests with projected initial criticality and startup testing projected for 1987. Plant water chemistry systems reflect designs from the 1970's for BWR-5 reactors. The design includes deep bed demineralizers in the Condensate System, shallow-bed filter demineralizer in the RWCU System and 2% flow through the RWC The inspector noted that the licensee had employed generally conser-vative water chemistry system designs with considerable demineralizer capacity margins in plants employing fresh water in the condenser .2 Water Systems Primary and auxiliary water systems ("as-built") were reviewed relative to descriptions, design criteria and Piping and Instrumenta-tions Drawings (P&ID) provided or referenced in the units' FSAR Each unit's Condensate System was reviewed for familiarization with i major components and to identify potential flow paths for the ingress of contaminants into the reactor fecdwater. Sampling and inline instrumentation was reviewed for representativeness and early

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detection of the possible failure of condenser tubes, air inleakage through condensate pump seals and turbine gland seals and escape of condensate demineralizer resins into the feedwate Within the scope of this review, no problems or concerns were identifie t

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6.3 Operation

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! Operating schemes employed or planned for the units' Condensate Deminearlizer and RWCU Systems and radwaste water recycle were reviewed. Unit I doesn't regenerate its resins, ultrasonically ,

cleans the resins every 700-900 hours of operations and discards the l

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resins to radwaste. Unit 2 plans to regenerate its deep-bed resins and discard when reduced capacity is noted. The licensee purchases .

l regenerated bead resins from the vendor in hydrogen or hydroxyl ion '

i for Both units draw their control rod drive (CRD) cooling water from processed, demineralized condensate rather than from the condensate storage tanks. The licensee's operating scheme limits ingress of impurities via the CRD cooling water by ensuring passage through the demineralizer beads prior to us '

Although Unit i returns its Feedwater (FW) heater drains to its hotwell, Unit 2 design pumps the FW heater drains forward for thermal efficienc Forward pumped FW heater drains have been shown to be a

, source of chemical contaminants in other plants and their presence is considered a weakness in the Unit 2 design from a chemical control

point of vie j Both units have established conductivity, total organic carbon (TOC)

and purgable organic carbon (POC) criteria for radwaste recycle to i

the Condensate Storage Tanks (CST). Unit 2 also uses criteria for

! chlorides and turbidity. Radwaste water recycle is conditional on

Chemistry approval which is considered a strength. The licensee appeared to have developed an operating scheme for radwaste water recycle responsive to concerns raised in NRC Information Notices No and 83-49 and Institute of Nuclear Power Operation (INPO)

guidanc .4 Radiation Field Buildup i

i The primary long-term source of radiation fields in BWR's is j cobalt-60. The presence of high cobalt-containing alloys ( Stellite) in the primary system in the hard facing alloys used in j applications requiring resistance to mechanical wear have been l associated with general radiation field buildup in 8WRs. EpRI l studies have shown that valve wear is the dominant out-of-core source

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of cobalt and in-core cobalt sources, (i.e. cobalt alloys in pins and ,

I rollers of BWR control blades) contribute up to 75% of the total '

j cobalt-60 inventor l

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Both units were reviewed for materials of construction containing 1 high cobalt alloys. Both units contained control rod roller and FW control valve materials with high cobalt conten '

EPRI recommends that during hot functional testing, water conductivity should be maintained as low as possible with oxygen controlled between 200 and 400 ppb, EPRI also recommends that FW quality be maintained as high as possible during operation with

! particular attention to minimizing corrosion product ingress which forms hot spots in crud trap Reactor water conductivity should be kept below 0.2 microSiemen per centimeter (uS/cm). Zinc injection is also recommended.

, Unit l's performance in maintaining low reactor water conductivity during operation from 1984 through 1986 was reviewed. Unit l's

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reactor water conductivity was consistently below 0.2 pS/cm during that period. The inspector noted that the following contributed to maintaining the low conductivities:

Condensate dimineralizer resin beds were changed out when their

effluent conductivity increased above the other beds and when

! an increase was detected in reactor water conductivity.

A " closed cycle" was used, i.e. makeup water was seldom added from outside the primary system and CSTs.

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Condensate demineralized resin beds were discarded rather than i regenerate *

Ultrasonic cleaning was performed on the condensate

demineralizer resin beds every 700-900 hours.

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j Condenser tubes were tested before reactor startup and during

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the drawing of a condenser vacuu *

Cation conductivity was used for detection of cooling water leaks.

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During the 1982-83 outage, the FW and Condensate Systems were laid up dry and then were flushed prior to reactor startu *

Cooling water for the CRDs was supplied from the condensate demineralizer outlet rather than the CST *

, RWCU System demineralizers were operated at about 300 gallons

per minute (gpm) which amounted to about 3% of FW flo ,

! RWCU resins were changes out on silica break-through rather than at conductivity break-through.

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3 Review of Unit 2 startup planning indicated that attention was being paid to maintaining reactor water conductivity as low as possible and controlling oxygen. The General Electric Zinc Injection Process (GE ZIP) was being used to passivate Unit 2 piping surfaces and internals. The licensee indicated that the GE ZIP was being considered for Unit 1 as wel The licensee didn't passivate the replaced recirculation pipe in Unit 1 prior to exposure to reactor water containing cobalt-60. As a result, the new recirculation piping at Unit I showed radiation fields as high as those observed after 10 years of operation after one cycle. A fresh, rapidly corroding surface was exposed to reactor water already containing cobalt-60 which resulted in rapid contamina-tion of the pipe with cobalt-6 The licensee plans to decontaminate Unit 1 piping during the 1988 outage and passivate the pipe prior to restar Review of " corrosion product" concentrations in the FW for the period 1984-86 in Unit I showed a downward trend in input for the past 3 years and " corrosion product" concentrations which met guidance provided by General Electri Steady improvement in FW quality were-note . 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 units' FSARs and industry-consensus recommendations and guidelines, (e.g. EPRI Guidelines and American Society For Testing And Materials (ASTM)). Each review included frequency of surveillance of control room monitors, sample stream temperature control, quality control of inline instrumentation accuracy, acceptance and correction criteria for conductivity measurements and the ranges of inline instrumentatio .1 Unit 1 The Urit 1 process sampling and in-line instrumentation system design and operation were reviewed, observed and discussed with the licensee. The following sampling locations were reviewe *

Turbine building sampling /in-line instrumentation monitoring condensate demineralizers, feedwater, reactor water and main steam; Turbine building condensate demineralizer conductivity l monitoring station; l Radwaste Control Room sampling station; and l

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Note: Sample panel number were not posted on Unit 1 by the license j The inspector noted that the sampling design was consisted with the j designs for 1960's vintage plants although additional sampling cap-i abilities (including " corrosion product" samplers) had been added.

, In-line instrumentation at the sampling points was reviewed. Sample j coolers did not maintain reference temperature for in-line instru-mentation (including conductivity cells). Temperature readings

', ranged over 15 degrees Fahrenheit (F) from conductivity cell to conductivity cell. Since a constant reference temperature of 251 degrees centigrade (77 1 F) reduces error in conductivity measure-ments and facilitates trending conductivity measurements, the lack of 1 temperature control is considered a weakness in the licensee's j continuous measurement program. The inspector calculated the' temp-j erature corrections for in-line measurements and' concluded that, ,

I although errors in conductivity measurements were present, the

, licensee's performance in maintaining reactor water conductivities

)j less 0.2 pS/cm remained after these errors were taken into account.

) Licensee Procedure No. S-SP-1, " Liquid Grab Sample-Sample Station,"

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the licensee. No procedural problems were note ; 7.2 Unit 2 l

l The Unit 2 process sampling and in-line instrumentation system design

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and operation were reviewed, observed and discussed with the j licensee. The following sampling panels were observed:

Panel Number Location j 2 SST-IPNL-154 250 foot elevation, Turbine Building

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2 SST-IPNL-284

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2 SSW-IPNL-154 261 foot elevation, Radwaste Building

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2 SSW-IPNL-165 i 2 SSR-IPNL-145 240 foot elevation, Reactor Building i

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! In addition to the above, sample panels associated with the GE ZIP j were also briefly reviewe Unit 2 inline conductivity instrumentation was temperature compensated and sample panel instruments were temperature controlle ,

Grab sample flush volumes were posted at each valve for obtaining sample flow. Flush sample volumes appeared to meet ASTM guidanc '

The inspector was unable to review followup item 50-410/85-20-05 on

collection of representative samples since the systems were not at

! pressure. Licensee Procedure no. S-SP-2, " Liquid Grab Sample - Local  ;

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Sample Point," (Revision 5, August 22,1986) was also reviewed. No procedural problems were note $

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8. Implementation The licensee' implementation of the water chemistry control program was

reviewed relative to Unit 1 Technical Specifications, commitments in the j Unit 2 FSAR and recommendations and guidance in NRC Regulatory Guides, NRC

! Information Notices and industry consensus standards.

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8.1 Unit 1 Surveillances

! Under Technical Specifications 3/4.2.3, " Coolant Chemistry," the i

, licensee is required to determine the conductivity and chloride ion

concentration in the reactor coolant water and maintain those para-

meters within limits dependent upon reactor operating condition.

i Surveillances of conductivities and chloride ion concentrations under t Licensee's Procedure No. N1-CSP-1V, Reactor Water Sampling and j Analysis," (Revision 1, October 28,1986) were reviewed relative to

the Technical Specifications requirements. No violations were noted.

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The 1.icensee' general chemistry sampling and analysis program for oxygen, iron, copper, silica, pH and nitrates was also reviewed. No

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problems were noted. Surveillance activities at Unit 1 appeared to

] be generally consistent with Fuel Warranty and EPRI guidance for the

! parameters reviewe !

Unit 2 Startup Tests NRC Regulatory Guide 1.68, " Initial Test Program For Water-Cooled

! Nuclear Power Plants," recommends, in part, chemical and radio-

! chemical tests and measurements to demonstrate the design capability j of chemical control systems to maintain reactor water quality within

, limits. The following licencee test procedures were reviewed relative l

to that guidance:

i Procedure No. N2-SUT-1-0V, " Chemical And Radiochemical Open

! Vessel Testing," Revisions 2, October 24, 1986; i *

Procedure No. N2-SUT-1-1, " Chemical And Radiochemical - 5% to 20% Power Testing," Revision 0, August 5, 1986;

Procedure No. N2-SUT-1-3, " Chemical And Radiochemical - 45% to 75% Power Testing," Revision 0 August 5, 1986 and l

l Procedure No. N2-SUT-1-5, " Chemical And Radiochemical - 50% to

, 70% Power Testing, " Revision 0, August 5, 1986, i The inspector noted that the licensee was discussing alteration of the test program to omit RWCU System isolation performance test '

Although it was unclear that the licensee had committed to conducting

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this test, the inspector cautioned the licensee to ensure that I NRC-NRR had not included this test under the FSAR test program. No additional concerns were identified in the review of the licensee's proposed tests.

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8.3 Unit 2 Regulatory Guide 1.56 Program In the licensee's FSAR, the licensee described a program for condensate and RWCU System resins meeting the guidance of NRC Regulatory Guide 1.56, " Maintenance of Water Purity in Boiling Water Reactors." Planned adherence to criteria established for resin changes, conductivities of treated effluents from resins and other aspects of the licensee's program were reviewed and discussed with the licensee. The licensee appeared to be planning to meet perfor-mance and reserve ion-exchange capacity standards consistent with NRC Regulatory Guide 1.56 recommendations. However, the following apparent weakness was noted and discussed with the licensee:

Item C.3 of NRC Regclatory Guide 1.56 recomdends, in part that the initial total capacity of new anion and cation demineralizer resins be measured. For resins that are to be regenerated, the determinations should be repeated at least semiannually. For resins that are not regenerated but are instead replaced periodically with material of the same type, measurements of initial capacity should be made on a sample at least once a year or at each replacement when the time between replacements exceeds one year. In addition, the inspector noted that the licensee should ensure that the resins were in the assumed ionic form ( i.e. hydrogen or hydroxylon form) since regenerated ion exchange resins were being purchased. The licensee indicated that tests as described were not routinely conducted and indicated that such test would be considere .4 Unit 2 Surveillance Program Surveillance of the Unit 2 reactor coolant under licensee's Procedure No. N2-CSP-IV, " Reactor Chemistry Surveillance At Unit 2," (Revision 1, October 30,1986) was reviewed. The licensee appeared to have developed a chemistry surveillance program of the reactor coolant consistent with Standard Technical Specification The licensee's general chemistry sampling and analysis program for Unit 2 was briefly reviewe The licensee appeared to be developing a generally adequate program relative to consensus-industry practice .5 Valve Maintenance Procedures EPRI studies have shown that lapping and grinding hard faced valve seats can contribute 10% of total cobalt input from debris lef t after standard cleanup procedures are completed. EPRI Report NP-3220, " Cobalt Contamination Resulting From Valve Maintenance",

(1983) indicated that post-maintenance cleaning procedures can effectively remove this debris. Discussions with the licensee indicated that standard cleanup procedures were employed in Unit 1 following valves maintenance. The lack of post-maintenanco cleaning procedures following lapping and grinding hard faced valve seats is

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considered a weakness in the licensee's radiation field buildup control progra .6 Crud-Induced localized Corrosion (CILC)

J Since 1979, fuel cladding corrosion failures at some BWRs have been associated with heavy plant corrosion product (CRUD) seals deposits with high copper concentrations. These crud-induced localized l corrosion (CILC) failures have been limited to plants with copper alloy condenser tubes and filter-demineralizer condensate cleanup systems. The inspector noted that deep-bed demineralizers were used in both units' condensate systems, copper levels in Unit 1 feedwater were consistent with fuel warranty requirements and general corrosion buildup was being monitored and controlled. The design and monitoring activities at the two units appeared to be responsive to minimize concern over CILC failure .7 Microbiologically-Induced Corrosion (MIC)

i NRC Information Notice 85-30, "Microbiologically Induced Corrosion of Containment Service Water System," alerted licensees to the sig-

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nificant corrosion pitting due to microbiologically induced corrosion identified in the stainless steel piping of a service water system

<i after an extended plant outage. Microbiological activity has been detected in the licensee's Unit 1 Reactor Building Closed Loop Colling (RBCLC) system and in the torus water. Relatively rapid flow rates, low bacterial counts and nearly continuous operation have apparently prevented MIC from becoming a significant problem in the RBCLC System. Ultrasonic measurement and visual inspection of the inner torus surfaces by the licensees indicated that both pitting and general corrosion had occurred. Two species of bacteria which

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sludge removed when the torus was draine The licensee used an ultraviolet sterilizer to treat water drained from the torus during the 1981 refueling and 1982-83 recirculation pipe replacement outages. The licensee has also tested the condensate storage tanks, fire protection, makeup demineralizer, reactor closed loop cooling and turbine closed loop cooling systems for bacteria. A sampling program from May 12-Oct. 12, 1986 did bacterial counts on those systems. The licensee is planning additional sampling and corrosion monitoring activitie Within the scope of the review, the licensee's action appeared responsive to concerns raised in Information Notice 85-30, 9. Exit Interview The inspector met with the licensee's representatives (denoted in Detail 1) at the conclusion of the inspection on December 5,1986. During the meeting, the inspector summarized the purpose and scope of the inspection and identified findings as described in this repor *

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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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