IR 05000333/1987009
| ML20209H372 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 04/21/1987 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20209H370 | List: |
| References | |
| 50-333-87-09, 50-333-87-9, IEIN-82-32, IEIN-83-49, NUDOCS 8705010204 | |
| Download: ML20209H372 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I-
' Report No. 87-09 Docket No.
50-333 License No. DPR-59 Priority Category C
Licensee: New York Power Authority
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10 Columbus Circle New York, New York 10019-Facility Name: James A. Fitzpatrick Nuclear Power Plant Inspection At: Scriba, New York Inspection Conducted: March 23-27, 1987 Inspectors:
M.(.b 9!Zl!87-m H.J. Bicehouse, Radiation Specialist date i
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4 b b-Approved by:
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W.J.(Pasciak, Chilf datej i'
Effldents Radiation Protection Section DRSS Inspection Summary:
Inspection on March 23-27, 1987 (Report No. 50-333/87-09)
Areas Inspected: Routine, unannounced inspection of the licensee's water chem-istry control program including previously identified items, management controls, plant water chemistry systems, sampling / measurement and implementation of the program Results: No violations were identified. The licensee appeared to be implement-ing an effective water chemistry control program including control of general corrosion, protection of fuel integrity and pressure boundaries and control of general radiation field buildup.
B705010204 870423
PDR ADOCK 0500 3-G
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DETAILS 1.
Persons Contacted 1.1 Licensee Personnel
- R. Converse, Resident Manager R. Deneve, Technical Training Specialist
- W. Fernandez, Superintendent of Power
- B. Gorman, Chemistry General Supervisor R. Grover, Supervisory Chemical Engineer
- W. Hamblin, Chemistry / Radiochemistry Supervisor L. Johnston, Quality Assurance (QA) Supervisor
- D. Lindsey, Operations Superintendent
- A. McKeen, Assistant to Radiological and Environmental Service (RES)
Superintendent
- E. Mulcahey, RES Superintendent
- R. Patch, QA Superintendent R. Penny, Operations and Maintenance Engineer J. Stone, Maintenance Turbine Engineer G. Vargo, Radiological Engineer Other licensee personnel were also contacted or interviewed.
1.2 NRC Personnel
- A. Luptak, Senior Resident Inspector
- attended the exit interview on March 27, 1987.
2.
Scope The licensee's water chemistry control program was reviewed relative to Technical Specifications, the Updated Final Safety Analysis Report (UFSAR), NRC Regulatory Guidance and industry-consensus standards.
The purpose f the review was to assess the licensee's program to control corrosioc. and out-of-core radiation field buildup, ensure long-term integ-rity of the reactor coolant pressure boundary and minimize fuel leakage caused by corrosion-induced failures.
3.
Previously Identified Items 3.1 (Closed) 25-00-13 TI-Trial Use of Water Chemistry Inspection Modules This inspection completed a series of inspections reviewing the licensee's water chemistry control program which involved the trial use of two inspection procedures.
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This item is closed.
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3.2 (Closed) Follow-up Item (50-333/86-20-01) Split Samples For Measure ment Control Evaluation Ouring Inspection 50-333/86-20, the condensate demineralizer outlet (CD0), the feedwater system and standby liquid control tanks were sampled for analyses. The CD0 sample was spiked with a standard chloride and sulfate solution and the feedwater sample was spiked with a standard metals solution. Duplicate spiked samples were sent to Brookhaven National Laboratory (BNL) for independent verification of analysis. The spike standard solutions were prepared for the NRC by BNL.
Split Sample Comparison Fitzpatrick Nuclear Power Plant Sample Chemical Licensee NRC Source Parameter Value Value I
CD0+0.5 m1 spike / liter Chloride 18.2 ppb 25.2 ppb
+1.0 mi spike / liter 47.3 ppb 46.2 ppb CD0+0.5 m1 spike / liter Sulfate 17.6 ppb 26.9 ppb'
+1.0 m1 spike / liter 46.7 ppb 61.4 ppb Feedwater+2m1 spike / liter Iron 968.5 ppb 969 ppb Copper 1032.4 ppb 989 ppb
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Nickel 970.3 ppb 957 ppb Chromium 798.5 ppb 931 ppb
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Standby Liquid Control Tanks Boron 21,923 ppm 22,900 ppm There was very good agreement between Fitzpatrick and BNL on the split samples. The slightly higher BNL sulfate values were due to BNL not subtracting the blank from the spiked samples.
Licensee's low chromium value was also the result of the licensee's analysis of the NRC standards during Inspection No. 86-20. The licensee should investigate this low chromium bias.
This item is closed.
4.
Management Controls 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 had been developed.
Licensee Technical Specifica-tions governing organization, procedures and limiting conditions for operation were used in the review.
In addition, commitments in the UFSAR and the. licensee's Quality Assurance Plan (QAP) and guidance provided by the Electric Power Research Institute (EPRI) Boiling Water Reactor Owner's Group (BWROG) Water Chemistry Guidelines Committee, (EPRI Report NP 3589-SR-LD) were also used.
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4.1 Management Policies The licensee's management policies were reviewed to determine if a-management commitment to, and support for, an effective water chem-istry control program had been provided. The BWROG Water Chemistry Guidelines Committee recommends that corporate management establish policies and procedures and provide the resources necessary to sup-port and enforce those policies.
Nuclear Administrative Policy (NUAP) 5.12 was reviewed.
There was a clear corporate commitment to maintaining high purity water in the primary system and adoption of industry-recommended
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controls for corrosion and radiation field buildup. Although formal adoption of the EPRI guidance in a corporate policy statement wasn't evident, corporate commitment was demonstrated by an extensive corp-orate-supported plant chemistry upgrade program including ongoing
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projects to improve sampling and measurement capabilities, introduce i
hydrogen water chemistry and crack arrest verification system-(CAVS)
monitoring for intergranular stress corrosion cracking (IGSCC) con-trol and decontaminate primary system piping with subsequent pass-ivations (General Electric Zinc Injection Process or."GEZIP") to control radiation field buildup. The improvements were consistent with NUAP 5.12 commitments to " good practices" for chemistry.
4.2 Corporate Chemistry The role of the corporate Radiological Health and Chemistry group in providing technical support for the plant water chemistry control program was reviewed and discussed with the Supervisory Chemical Engineer. Three chemical engineers reporting to the Supervisory Chemical Engineer provide expertise to the James A. Fitzpatrick and Indian Point-3 nuclear power plants. Their role was clearly defined in Nuclear Administrative Policy (NUAP) 1.2.5.
The corporate group reviews relevant industry experience, plant operating and chemistry problems and provides recommendations for improvements including design changes and modifications to plant systems. One Chemical Engineer is assigned to each nuclear power plant with the third available for special projects. Their involvement in the improvement projects noted in Detail 4.1 was clearly evident.
4.3 Plant Chemistry Within the Radiological and Environmental Services (RES) Department, the Chemistry General Supervisor was assigned overall responsibility for the water chemistry control program. Ten technicians reporting
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the Chemistry General Supervisor) had responsibilities as analysts and implemented the plant program.
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Chemistry staffing was reviewed relative to operational analytical /
sampling responsibilities. No backlogs of samples or analyses were noted. Technicians appeared fully cognizant of their duties and responsibilities and knowledgeable of the licensee's sampling and analyses procedures.
Laboratory analytical capabilities were reviewed relative to the BWROG Water Chemistry Committee's guidelines and typical Region I utility capabilities.
State-of-the-art analytical capabilities were noted allowing routine part per billion (ppb) measurements.
4.4 Procedures Licensee procedures were reviewed to determine if instructions were provided prescribing the nature and frequency of sampling and analy-sis, administrative control limits for common contaminants, in-line instrumentation calibration and maintenance, operation of water chemistry control systems and reporting / trending chemical parameters.
Three surveillance, five corrective action, four chemical laboratory instrumentation, three operating procedures and one maintenance procedure were reviewed and discussed with the licensee's technical staff representatives. The inspector noted that a Chemistry Manual was being developed which addressed plant system performance and operations from a chemical and chemical engineering perspective and summarized control objectives, specifications, problem diagnosis and trouble shooting.
In addition a special quality assurance / quality control procedure was reviewed which provided control of sampling and analysis, described control charts and analytical standards control and specified inter-and intra-laboratory comparison of spiked samples.
The maintenance procedure governing lapping and grinding activities on hard-faced valve seats was reviewed to determine if the licensee had initiated control / cleanup procedures to minimize the ingress of cobalt-alloy debris.
Controls (including quality control inspection)
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were provided.
The licensee continued monitoring the growth of out-of-core radiation fields, (started during the EPRI-sponsored "BRAC Program"), under the general radiation field surveillance procedure.
The systematic radiation field buildup surveillance allowed continued trending of the changes to out-of-core radiation fields The licensee also provided an administrative control procedure for solvents and other potentially harmful materials including a permit / label system governing the materials' use onsite.
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 water chemistry control
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program had been developed. Under RES " Standing Order" 11, " Chem-istry Incident Reports," the technician finding a chemical parameter exceeding an operating, administrative, fuel warranty or technical specification limit is responsible for initiating a Chemistry Inci-dent Report.
The incident report receives management review and provides the basis for followup and correction of chemical control deficiencies.
Close monitoring of chemical parameter trends was noted. Routine chemical parameters are plotted, trended and reviewed by the plant and corporate chemistry staffs.
Routine management reports of chem-ical parameter performance are issued with wide management distri-bution on the plant and corporate levels.
In 1983, the licensee contracted with the General Electric Company to provide a technical appraisal of plant water chemistry and related operational practices.
Following this appraisal, the licensee ini-tiated an extensive chemistry upgrade program to improve sampling, in-line instrumentation, procedures and condensate and reactor water cleanup (RWCU) systems operation. Most of the identified improve-ments are nearly complete with many scheduled for 1987 completion.
Several items (including sampling improvements and hydrogen water chemistry initiation) required plant modifications, engineering work and extensive capital investment and were long lead-time items.
Review of the application of the QAP to the water chemistry control
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program showed little involvement in audit or appraisal activities by the licensee's QA organization. No appraisals of the water chem-istry control program have been conducted by the corporate Opera-tional Appraisals Group. The plant Standard Audit Program had not reviewed water chemistry controls since 1983. The inspector noted that the licensee had hired a chemical engineer recently and that individual was assigned to the corporate Operational Appraisals Group.
Discussions with the licensee indicated that an appraisal of the water chemistry control program was being planned.
5.
Plant Water Chemistry Systems 5.1 Plant Description The James A. Fitzpatrick Nuclear Power Plant is a 2436 MWt,(821 MWe),
General Electric BWR-4 which began commercial operation in July 1975.
The unit has 560 fuel bundles, 137 control rods, turbine-driven feed pumps and a Reactor Core Isolation Cooling System.
Fresh water drawn from Lake Ontario is used as circulating water in the condensers.
Condensate treatment is accomplished with 8 deep-bed (7 inservice)
195 cubic feet each demineralizers containing 2:1 cation / anion ton exchange resins. The reactor water cleanup (RWCU) system utilizes 2
"Powdex" filter demineralizers run in parallel at 101 gallons per minute (gpm) providing an 0.8% full steam flow cleanup rate. Total RWCU system design allows 160 gpm or 1% full steam flow cleanup but pump restricitons resulted in the reduced cleanup capacity noted. An
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Admiralty Brass condenser (modified with titanium impingement tubes during the last outage), steel feedwater_ piping, stainless steel feedwater heaters and stellite materials in the isolation valves of the feedwater system were also noted. The licensee uses variable-speed pumps for feedwater flow control rather than feedwater control valves.
Feedwater heater drains are returned to the hotwell. During opera-
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tion, control rod drive (CRD) cooling water is taken from polished condensate. However, during shutdown, CRD cooling water is taken from the Condensate Storage Tank (CST). A line to recirculate feed-water ("longpath") prior to.startup is provided and normal startup procedure use that method to reduce corrosion products in the feed-water prior to introduction into the reactor vessel.
Radiation field / buildup patterns for the plant were considered " gen-eric" in the EPRI study.
Before 1980, " pin hole" fuel leaks result-ing from clad failures were noted.
However, since 1980, fuel leakage has not been noted. The licensee has replaced approximately 2/3 of the core with barrier fuel and plans to complete the replacement in the next refueling outage.
The licensee last experienced a condenser tube leak in October-November 1985.
Less than 1% of the licensee's condenser tubes are currently plugged. An estimated 35 standard cubic feet per minute (scfm) air inleakage rate (as measured at the Steam Jet Air Ejectors) was the licensee's best estimate of condenser inleakage rates.
5.2 Water Systems Primary and auxiliary water systems ("as built") were reviewed for familiarization relative to descriptions and drawings provided or referenced in the UFSAR. The Condensate System was reviewed to identify flow paths for the ingress of contaminants into the reactor feedwater.
In-line instrumentation, (e.g. conductivity cells) and sampling points were reviewed for representativeness and early detec-tion of condenser inleakage, escape of resin fines and air intru-
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l sions/ seal failures. The RWCU system was also reviewed.
Within the scope of this review, no problems or concerns were noted.
The licensee had a generally conservative design for water treatment systems reflecting design standards common to BWR-4 units with fresh water as circulating condenser cooling water. However, the use of deep bed demineralizers in the Condensate system provided increased deionization capacity but somewhat reduced filtration for insoluble corrosion products relative to BWR-4 designs with filter-demineral-izer condensate treatment systems.
5.3 Operation Operating schemes used for the Condensate Demineralizer and RWCU systems and for radioactive liquid waste water recycle were reviewed.
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The licensee does not routinely calculate remaining resin deioniza-i
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tion capacity in the Condensate Demineralizer System. Deep-bed
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resins are ultrasonically cleaned but are not regenerated. The fol-lowing table summarizes the licensee's criteria for demineralizer
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System Criteria s
Condensate Demineralizer
<2400 gpm;; ultrasonic
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cleaning 1-3X replace-
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anion resin and Reuse
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in Radwaste system
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I RWCU Silica breakthrough Radwaste Resins.
Conductivity >l
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micro. Siemen/ centimeter
(pS/cm); may allow up
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to 2 pS/cm for
10-20,000 gallon batches Fuel Pool Cleanup Resins Gross gamma; differ -
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ential pressure; or conductivity Demineralized water conductivity The licensee accepts the vendor's certification of resin capacity and does not test inhouse.
I Recycle of treated radioactive waste water to the CST'is contingent
on meeting the following criteria and chemistry approval:
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Total Activity
<IE-1 microcuries/ milliliter gross gamma;
Conductivity
<3pS/cm;
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<50 ppb;
Total Organic Carbon
<1 part per million:(ppm); and
pH 5.0-8,5.
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I However, the licensee hadn't provided criteria for purgable organic carbon, turbidity, silica and isotopic mix. The licensee had de-i veloped an operating scheme for radioactive waste water recycle generally responsive to concerns raised in NRC Information Notices
Nos. 82-32 and 83-49 and Institute for Nuclear-Power Operations
(INP0) guidance. The inspector.noted that ethylene glycol and
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chlorinated cleaning fluids were used by the licensee.
l 5.4 Radiation Field Buildup The primary long-term source of radiation fields in BWRs is Cobalt-60.
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The presence of high cobalt-containing alloys (e.g. stellite) in the
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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
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dominant out-of-core source of cobalt and in-core cobalt sources, l
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~(e.g. cobalt alloys in pins and rollers of control blades), contribute up to 75% of.the total cobalt-60 inventory.
The licensee has initiated a cobalt reduction program. During the refueling outage, 20 control rod assemblies were replaced with
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low-cobalt alloy-containing control rods.
The. licensee's feedwater valves are used for isolation with flow control by variable-speed
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pumps. The licensee is reviewing the isolation valves as a possible cobalt ingress concern but has no current plans to replace those valves with low-cobalt alloy valves.
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 be,kept below 0.2 pS/cm. From 1984-86, the licensee consistently kept reactor i
water conductivities during operation below 0.2 pS/cm. The licen-see's deep-bed dermineralizers are less efficient at removing insol-i uble corrosion products than filter-demineralizers. However, feed-
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water recirculation during startup, careful resin ultrasonic cleaning and close surveillance of feedwater insoluble corrosion products allowed the licensee to maintain insoluble corrosion products below EPRI and fuel warranty action levels and generally below EPRI achiev-able levels.
6.
Sampling / Measurement The licensee's sampling and inline measurement program for determining possible chemical contaminants in high purity reactor water and systems i
supplying makeup and cooling water was reviewed relative to industry-consen-
sus standards and recommendations. Special emphasis was placed on review-ing an ongoing sampling modification (Mod FL85-102) and its specification
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(No. 70420-1200-03).
Two permanent panels and one " transportable" sample
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conditioning panel were included in the modification. The following design strengths were noted:
A Hewlett-Packard (HP) 3852S computerized data acquisition system
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(replacing strip chart recorder) allowed simultaneous comparisons of
inline data and CAVS data; State-of-the-art conductivity, dissolved oxygen and hydrogen
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analyzers were provided;
Temperature control (7711 F) was provided; and Samoles and inline instruments were grouped by system sampled.
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The licensee will complete CAVS installation before hydrogen water chem-istry is initiated. Acceptance tests (similar to original testing program for existing panels) are planned to assure the modifications meet opera-
tional and personnel safety requirements.
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Within the scope of this review, no problems or concerns were noted.
7.
Implementation The licensee's implementation of the water chemistry control program was reviewed relative to Technical Specifications, commitments in the UFSAR, recommendations and guidance in NRC Regulatory Guides and Information Notices and industry-consensus standards.
7.1 Surveillance The licensee is required to determine the conductivity and chloride L
ion concentration in the reactor coolant water and maintain those parameters within limits dependent on operating conditions. Routine surveillance records and measurements made during periods of opera-tion in 1985-86 and during shutdown in 1987 were reviewed. No vio-
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lations were noted.
Reactor water conductivities during operation were consistently below 0.2 pS/cm and chlorides averaged 20 ppb or less (licensee's reporting limit).
The licensee's implementation of general chemistry sampling and analy-ses activities for feedwater silica, conductivity, dissolved oxygen, soluble / insoluble iron and soluble / insoluble copper for 1985-86 were also reviewed. No problems were noted.
Routine surveillance activ-ities were completed as described in licensee procedures and concen-trations consistent with Fuel Warranty and EPRI guidance were con-sistently demonstrated.
7.2 Hydrogen Water Chemistry (HWC)
The licensee completed a HWC test during September-October 1985. The test showed a " mitigation point" (-0.230 volt corrosion potential for 304 Stainless Steel) at 11-12 scfm hydrogen addition (one of the lowest addition rates seen in General Electric Company tests).
Main steamline radiation levels increased 20-25% (which is lower than the 300-500% increases noted in other BWRs). After 11 days of testing, the CERT specimen cracked. The licensee increased the hydrogen injection rate to 22 scfm and continued the test with excess hydro-gen.
Subsequent reviews showed that the test was sufficient to establish parameters for full-scale hydrogen use and the CERT speci-men failure did not require a retest.
The licensee plans to initiate hydrogen water chemistry in the late summer of 1987 using hydrogen supplied by trailers with compressed gas cylinders to control IGSCC.
CAVS monitoring to verify IGSCC mitigation will be instituted as a portion of the sampling panel modification.
The licensee appeared to have tested for and planned implementation of hydrogen water chemistry to reduce IGSCC concerns.
7.3 Turbine Examinations Low pressure turbine examinations conducted by the licensee showed no
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evidence of problems from carry-over of. corrosive materials in the steam. No deposits of corrosive products were noted at the " Wilson Line" (i.e. transition from dry to wet steam).
No silica buildup was noted on blades, buckets or other components. No evidence of cor-rosion cracking on the turbine buckets and wheels was observed.
7.4 Radiation Field Buildup As noted earlier, the licensee has continued the monitoring of radia-tion field buildup in the drywell started during the EPRI BWR Radia-tion Assessment and. Control (BRAC) Program. Under Radiation Protec-tion Operating Procedure (RPOP)-5, " Plant Radiation / Contamination
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Surveillance Program," routine radiation measurements are made at approximately 18 specified locations approximately one day after shutdown.
Trend graphs are prepared relating measured dose rates to effective full power years of operation. Graphs representing 7.33 effective full power years were reviewed. A " generic" pattern of radiation field buildup was noted. At present, the graphs show a plateau of slightly declining radiation levels from shutdown to shutdown. This apparent trend is believed to be due, in part, to improvements in plant chemistry and radioactive decay of the cobalt-60 and manganese-54 radioisotopes.
The effects of the. cobalt reduction program are not yet evident. Control of corrosion product ingress was evidenced by the declining trend and reduction in dose rates due to "hotspots."
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7.5 Chemical Decontamination The licensee plans a partial primary system decontamination during the 1988 Refueling Outage to reduce drywell dose rates. A study made by the licensee estimates that the decontamination will reduce col-lective occupational radiation exposures for the outage by approx-imately 300 manrem and will result in 160-190 cubic feet of addition-al solid radwaste.
Post-decontamination passivation of the piping surface using the "GEZIP" is also under consideration.
8.
Exit Interview The inspector met with the licensee's representatives (denoted in Detail 1)
at the conclusion of the inspection on March 27, 1987. During the meeting the inspector summarized the purpose and scope of the inspection and iden-
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tified findings as described in this report.
During the inspection, the inspector presented the " split sample compar-ison" results presented in Detail 3.2 to the licensee. No other written material was 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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