IR 05000387/1986022
| ML17146A592 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/20/1986 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17146A591 | List: |
| References | |
| 50-387-86-22, 50-388-86-23, NUDOCS 8610270453 | |
| Download: ML17146A592 (20) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
- Report Nos.
50-387/86-22 50-388/86-23 Docket Nos.
50-387 50-388 License Nos.
NPF-14 NPF-22 Priority Category C
Licensee:
Penns lvania Power
& Li ht Com an 2 North Ninth Street Al 1 entown Penns 1 vani a 18101 Facility Name:
Sus uehanna Steam Electric Station Inspection At:
Berwick Penns lvania Inspection Conducted:
Se tember 22-26 1986 Inspector:
H. J.
icehouse, Radiation Specialist date Approved by:
W. J.
P sciak, Chief Efflue ts Radiation Protection Section ate Ins ection Summar
Combined Ins ection Nos.
50-387/86-22 and 50-388/86-23
~d:
i, i
i f
h chemistry control program including: previously identified items; organization; self-identification/correction of deficiencies; plant water chemistry systems; sampling and measurement; and implementation of the water chemistry control program.
Results:
Within the scope of the review, no violations or deviations were noted.
The licensee appeared to be developing an adequate program for maintaining high purity water in the primary coolant loops of Units 1 and 2.
gOOOSH7 l
PDR ADOCK 05
'I
P
'll l
,e DETAILS 1.
Persons Contacted During the course of this routine inspection, the following personnel were contacted or interviewed:
1. 1 Licensee Personnel
'T.
M. Crimmins, Plant Superintendent G. A. Appel, Chemistry Consultant
~C.
E. Burke, Chemistry Supervisor
"T. R. Clymer, guality Assurance (gA) Supervisor-Operations
- R. L. Doty, Health Physics/Chemistry Supervisor D. Ganderberger, Power Production Engineer
"R.
D. Kichline, Project Licensing Specialist
~D.
F.
McGann, Compliance Engineer
~D.
K. McGarry, Senior Analyst-gA D. Morgan, Senior Project Engineer, Chemistry, Metallurgy 5 Welding D. Srna, Chemistry Consultant L. K. Vnuk, Senior Chemist J. Wolfer, Senior Chemist Other licensee personnel were also contacted or interviewed during this inspection.
1.2 U.S. Nuclear Re viator Commission Personnel
"S..Kuchagski, Resident Inspector - Limerick
"W. J.
Pascal,'ak, Chief, Effluents Radiation Protection Section
~L.
R. Plisco, Senior Resident Inspector - Susquehanna J.
R. Stair, Resident Inspector Susquehanna
- Attended the Exit Interview on September 26, 1986.
2.
~Pur ose The purpose of this routine safety inspection was to review the licensee's Water Chemistry Control Program with respect to the following areas:
Previously Identified Items Organization; Self-Identification/Correction of Deficiencies; Plant Water Chemistry Systems; Sampling and Measurement; and Implementation of the Water Chemistry Control Progra I'
Previ'ousl Identified Items 3. 1 (Closed)
25-00-13 TI:
This inspection completed review of the licensee's water chemistry control program.
\\
3.2 (Closed)
Followup Item (50-388/84-15-04).
Review completion of pre-operational testing of Unit 2's Process Sampling System.
The licensee tested operability of the Reactor Building and Turbine Building sampling stations thermal baths and verified flows to the in-line instruments at those sampling stations.
In addition,.sampling cap-abilitiess of the two sampling stations were also demonstrated.
The testing was completed under Procedure No. HF-276-083,
"Process Sampling" Revision 0 (8/7/84).
This item is closed.
3.3 (Closed)
Followup Item (50-387/84-39-03; 50-388/84-49-02).
Review
'licensee's lower limits of detection (LLD).
The licensee reviewed and updated the gamma spectroscopy computer libraries used to deter-mine radionuclides.
The method of counting, pretreatment off-gas samples was changed to include monthly counts at 15 minutes and
hours post sampling time to ensure identification of the 6 noble gas radionuclides.
This item is closed.
3.4 (Closed)
Followup Item (50-387/85-22-03).
Chemistry surveillance program not fully established.
The licensee changed the administra-tive procedure, (i.e AD-422), to include a cover sheet for each surveillance to be reviewed and approved by the chemistry foreman.
Changes were also made to ensure that pH sampling frequency would be increased whenever increased conductivity was noted in reactor coolant samples.
This item is closed.
3.5 (Closed)
Followup Item (50-387/85-27-01; 50-388/85-22-01).
Split sample comparison.
The licensee. provided results of their analyses of split samples for comparison with NRC analyses.
The results of the comparison are shown below:
Susquehanna
- Split Samples BNL/NRC Sus uehanna Boron (%)
U1"SBLC (86-2711)
U11-SBLC (86-1625)
Analytics (¹3430)
14.82 15.33 8.81 12.99 13.58 8.20 Iron (ppm)
RWCUINF (864028)
Feedwater (865049)
RWCUINF (864023)
Nickel (ppm)
RWCUINF (864028)
Feedwater (865049)
RWCUINF (864023)
1.065 41.0 6.85.
<.025 1.53
<.025 0.62 41.4 6.54 0.20 1.36 0.29
P f,'
4 ~
R
Copper (ppm)
RWCUINF (864028)
0.069 Feedwater (865049)
0. 160 RWCUINF (864023)
0.250
0 0.07 Chromium (ppm)
RWCUINF (864028)
Feedwater (865049)
RWCUINF (864023)
0.17 0.26 0.12 0.09 0.19
Silica (ppm)
Collection Tanks A&B 1.90 Collection Tanks C&D 2. 65 3.01 2.25 Comparison differences could be due to sampling.
4.
0~i*
The inspector examined the water chemistry control program organization with regard to policies, goals/objectives, assignment of responsibilities and authorities-,
resources to implement the program and procedures.
Cor orate Chemistr Pro ram The licensee-'s corporate Nuclear Plant Engineering group has the lead responsibility for development of a water chemistry control program with close participation by the station chemistry staff.
Monthly meetings to discuss the chemistry control prog'ram are held between the corporate and station chqmistry staffs.
Responsibilities for the program are provided in Nuclear Department Instruction (NDI)-gA-15.3.5,
"Nuclear Department Chemistry Responsibilities,"
Revision 0 (2/4/82).
The licensee is developing the "Susquehanna Chemistry Manual" which will provide a discussion of and technical basis for the water chemistry control program.
The inspector reviewed the draft manual and noted that the chapter discussing policy and philosophy was in-complete although other technical chapters on systems had been completed or were in final comment revisions undergoing review.
Although there appeared to be a corporate'anagement commitment to and support for an effective water chemistry program, explicit docu-mentation for the commitment and support were under development.
4.2 Station Chemistr Pro ram Chemistry control program responsibilities were assigned to the Sta-tion Chemistry Group (within the Health Physics/Chemistry Depart-ment).
The organizational structure of the Chemistry, Group, (as defined in AD-RA-440), was being changed to reflect altered responsi-bilities within the group.
Interfaces with other station organiza-tions for communication of water chemistry data and trends appeared defined.
Chemistry Action Requests (CAR) provided a mechanism to request corrective action by other station groups, (e.g. Operations),
whenever chemical analyses showed control parameters were out of specification.
A computer-based trending program, (i.e.
DIGI"CHEM by
Midwest Radiochemistry, Inc.), was used to follow plant chemical parameter changes and trends.
4.3 Procedures Chemistry procedures were selectively reviewed to determine if:
Critical chemical parameters and limit/action levels for control of those parameters had been identified; Sampling schedules and locations for obtaining those samples had "
been provided; Analytical methods and their bases had been identified;
Recording and trending of data and reporting requirements were established; and
Investigative and corrective actions to be taken when critical chemical variables exceeded action levels were present in the procedures.
Administrative Procedure (AD-gA)-440, "Conduct of Chemistry," Revi-sion 0 (ll/16/84) and the "Sampling Schedule, Analysis and Control Matrix, "("Chem Matrix"), were reviewed in detail, discussed with the chemistry staff and provided the basis for the review of the imple-mentation of the water chemistry control program.
The inspector noted that the
"Chem Matrix" was being continually revised and up-dated.
Revision 5 of the
"Chem Matrix" (9/19/86)
was used during review of the program implementation.
Selected surveillance procedures for conductivity, pH and chloride analyses were reviewed relative to Technical Specification require-ments.
AD-00-441, "Chemistry Sampling Analyses.and Work Schedule,"
Revision 0 (1/8/85)
was reviewed for administrative control of rou-tine work activities.
Selected procedures for in-line instrument calibration, resin analyses and water chemistry control system opera-tion were also reviewed.
Within the scope of this review, no violations were noted.
The licensee's procedures appeared to be in agreement with Technical Specifications, fuel warranty operating limits and the Boiling Water Reactors Owners'roup Guidelines for Water Chemistry (EPRI NP-3589-SR-LD, 4/1/84).
5.
Sel f-Identif i cation/Cor recti on of Deficienci es The licensee's program to identify and correct water chemistry control deficiencies was reviewed to determine if a program to identify, investi-gate, document, report, track, close and trend discrepancies in water chemistry control parameters had been established and implemented.
The
licensee's program was reviewed relative to criteria in 10 CFR'50, Appendix B and Technical Specification 6.5,
"Revi,ew and Audit".
5 ~ 1 ualit Assurance A
Audits The inspector reviewed gA Audit Nos. 84-12, 85-42 and 86-31.
The audits reviewed implementation of the chemistry program including conduct of the program, training, qualification, sampling, guality Control and Technical Specification compliance.
Each audit was con-ducted by a technically-qualified corporate audit team.
The station appeared to have taken timely effective action on findings as pre-sented in the 1984 and 1985 audit reports.
5.2 Si nificant 0 eratin Occurrence Re orts SOOR Under AD-gA-424, the licensee issues significant operating occurrence reports when chemical parameter s exceed control values.
Twelve chemistry-related occurrence reports were reviewed and discussed with the licensee, (i.e.
10 related to Unit 1 and 2 related to Unit 2).
- Occurrences resulting in reactor water conductivity measurements exceeding limits in Technical Specification 3/4.4.4,
"Chemistry," are summarized below:
The Reactor Water Clean-Up (RWCU) system was isolated inadver-tently on two occasions (SOOR Nos.
1-82-129 and 1-83-15);
Apparent organic intrusions were noted (SOOR Nos.
1-85-019, 1-85-022, 1-85-341 and 2-84-299);
and Condenser leaks of circulating water into the feedwater (SOOR No. 1-82-123).
The Technical Specification allows reactor water conductivity to be.
greater than 1.0 micromho per centimeter for up to 72 consecutive hours or up to 336 hours0.00389 days <br />0.0933 hours <br />5.555556e-4 weeks <br />1.27848e-4 months <br /> per year.
The inspector noted that reactor water conductivities were restored in a timely manner for each of the occurrences.
The inspector also noted that SOOR No. 1-83-15 was also reported as Licensee Event Report (LER)83-006.
The licensee appeared to be implementing AD-gA-424 appropriately for chemical events.
6.
Plant Water Chemistr S stems The licensee's primary and. auxiliary water systems were reviewed for fami-liarization and conformance to the descriptions in. the licensee's Final Safety Analysis Report (FSAR).
The Susquehanna generating plant consists of two General Electric BWR/4 boiling water reactors rated at 3293 MW thermal power, nominal 1050 MW(net) electric output each.
Primary system water purity is maintained by full-flowCondensate Demineralizer and 1%
'k C,
P1
"f C
Circulating water is taken from the Susque-hanna River.
The as-built designs of Unit 1 and 2 were briefly reviewed for potential pathways of impurity ingress including:
failure of condenser tubes; exposure to air during plant outages; accidental loss of resin fines from the Condensate Demineralizer or RWCU Systems; metallic oxides via the feedwater system;
-leaching of regenerative chemicals from deminera'lizer beds; and organic intrusions via the plant drains and radwaste system recycle of water to the Condensate Storage Tank.
In each instance, the licensee's sampling/monitoring design appeared adequate to identify the source of the contaminant.
6.1 Condensate Demineralizer S stems At 100% condensate flow, the licensee's Condensate Demineralizer Systems are designed to remove dissolved (by ion exchange)
and suspended (by filtration) contaminants from the condensate using
deep resin bed filter-demineralizer s each (with a seventh in stand-by).
Operation of the systems was reviewed relative to NRC Regula-tory Guide 1.56,
"Maintenance of Water Purity In Boiling Water Reactors."
The inspector noted that the licensee ultrasonically cleans the resin beds but does not regenerate them.
Resins are re-placed when a computer program tracking remaining capacity indicates approximately 10% of the initial capacity has been exhausted.
The replacement period for resins averages about 16 months, i.e. approxi-mately 1 resin bed per month (on average)
is sent to radwaste for disposal.
The licensee appeared to be maintaining a program for the Condensate Demineralizer System consistent with the guidance in Regulatory Guide 1.56.
6.2 RWCU S stems The RWCU Systems remove solid and dissolved impurities from the reactor coolant and measure the reactor coolant conductivity.
The systems take their suction from the inlet of each reactor main recir-culation pump and from the reactor pressure vessel bottom head train line (when the recirculation pumps are unavailable).
The reactor coolant is circulated by the cleanup pumps through the regenerative and non-regenerative heat exchangers for cooling, through the filter-demineralizers for contaminant removal and back through the regenera-tive heat exchanger for reheating.
The processed reactor coolant is
L I
normally returned to the reactor pressure vessel through the feed-water lines.
Normal operation of the RWCU Systems maintains water quality in the units in accordance with Regulatory Guide 1.56 using less than 1% of the main steam line flow rates.
Apparent installation problems with the RWCU filter-demineralizer units have resulted in precoat application problems with the powder resins.
Uneven coating has led to short run lengths between powder resin replacements.
An apparent pressure transient during precoat causing unevenness in the coating has been noted by the licensee.
The licensee was attempting to optimize RWCU system performance in both units.
7.
Sam lin /Measurement The licensee's program for sampling and measurement of possible chemical contaminants in high-purity reactor water and systems supplying makeup and cooling water was reviewed against commitments in the FSAR and consensus standards provided in:
EPRI NP-3589-SR-LD,
"BWR Water Chemi stry Guidelines," (4/1/84);
General Electric Specifications On Water guality; American Society For Testing and Measurements (ASTM)
D 1066-82,
"Sampling Steam";
American Society For Testing and Measurements (ASTM) D 3370-82,
"Sampling Water";
American Society For Testing and Measurements (ASTM) D 1125-82,
"Conductivity";
American Society For Testing and Measurements (ASTM) 0 3864-79,
"Standard Guide For Continual Online Monitoring Systems For Water Analysi s";
American Society For Testing and Measurements (ASTM) 0 888-81,
"Standard Test Methods For Dissolved Oxygen In Water;" and American Society For Testing and Measurements (ASTM)
D 1293-78,
"Standard Test Methods for pH of Water."
The following sample panels and associated in-line instrumentation were observed:
Unit 1 Reactor Building Sample Panel (1C-210);
Unit 1 Turbine Building Sample Panel (1C-132);
I
,P,
~
'C
Unit 2 Reactor Building Sample Panel (2C-210);
Unit 2 Turbine Building Sample Panel (2C-132);
and Radwaste. Building Sample Panel (OC-303)
Each, panel was reviewed for conformance with industry consensus standards.
Valve alignments for obtaining grab samples were reviewed relative to the Sample System Piping and Instrumentation Drawing and Chemistry Procedure (CH-SY)-008, "Sampling System Operation,
"Revision 0 (draft 9/16/86).
Maintenance and calibration activities relative to in-line instrumentation were reviewed and discussed with the licensee.
Sample flush times were also reviewed.
Within the scope of this review, no problems were noted.
The licensee was undertaking a sampling system upgrade to improve and optimize sampling activities.
The licensee'
implementation of a water chemistry control program for Unit 1 since 1982 and Unit 2 since 1984 was reviewed relative to technical specification-related surveillance and licensee procedural requirements.
Each units history of impurity ingress was'riefly reviewed.
8.1 Or anic Intrusions As noted in Detail 5.2, several apparent intrusions of organic conta-minants have occurred.
On January 18 and 19, 1985, transfers of water
'rom the Radwaste Sample Tanks "A" and "B" to the Unit 1 Condensate Storage Tank caused spikes in reactor coolant conductivity.
On December 5,
1985, during a liquid radwaste transfer, the conductivity of the Unit 1 reactor coolant increased to near the Technical Speci-fication limit.
On December 8, 1985, also during a radwaste transfer, the conductivity of the reactor coolant exceeded the Technical Speci-fication limit.
During these transfers, water which had been filtered and demineralized, was sent from the Radwaste Storage.
Tanks to the Condensate Storage Tank discharge line.
The water eventually empties into the bottom of the high pressure condenser mixing with condensate water.
Samples of the reactor water showed the presence of nitrates but samples from the Radwaste Storage Tanks did not.
The licensee exposed a sample of water taken from the Radwaste Storage Tank to an intense ultraviolet (UV) light source.
Following exposure to the UV, the sample showed nitrates were present.
The results of this test indicate that a nitrate-bearing compound was present in the Radwaste Storage Tank and the high fluxes present in the reactor core caused that compound to break down.
The licensee has modified radwaste transfer procedures to include sampling the Radwaste Storage Tanks, exposing the sample to intense UV and analysing for the presence of nitrates routinely.
The inspector noted that analyses of water from
T a"
the Radwaste Storage Tanks for Total Organic Carbon (TOC) had been completed as r'ecommended in NRC IE Information Notices Nos. 82-32 and 83-49, and General Electric Service Information Letter No. 381.
8.2 Oil Intrusion During pre-commercial operation of Unit 2, oil intrusions from the reactor feedpumps lube oil were noted which caused increased conduc-tivity and decreased dissolved oxygen in the reactor water.
Modifi-cations to relieve a vacuum (measured at 3 to 8 inches water)
on the Primary Seal Drain Chamber were completed by the licensee which appeared to have lessened the problem of oil inleakage.
The licensee had noted that the floating seals in Unit 2 were passing 90-110 gallons per minute (GPM).
The design specification for the floating seals is 40 GPM.
8.3 Silica Problem The licensee has been unable to meet the guidelines for Silica in the BWR Owner's Group Guidelines (EPRI NP 3589-SR-LD).
The licensee believes that the silica problem was caused by a lack of cleanliness in the condenser during construction which allowed build-up of silica-containing materials in the condensers.
The licensee has done extensive debris removals from the condensers during recent outages to reduce the problem.
Condenser Tube Leak On March 30, 1983, Unit 1 reactor coolant conductivity exceeded
micromho per centimeter while the unit was operating at 97% power.
Conductivity measurements showed that Condenser Waterbox "B" was the apparent source of the problem and it was isolated.
The leak was located and plugged on March 31, 1983.
Conductivity of the reactor water fell below 1 micromho per centimeter on March 30, 1983.
8.5 Surveillance Surveillance records for conductivity, chloride and pH in the Unit 1 and 2 reactor water were reviewed on a sampling basis for the period 1984 to September 19, 1986 against criteria provided in tech-nical Specification 3/4.4.4,
"Chemistry".
Surveillance procedures were also reviewed and discussed with the licensee.
9.
Exit Within the scope of this review, no violations were noted.
Interview The inspector met with the licensee's representatives (denoted in Para-graph 1) at the conclusion of the inspection on September 26, 1986.
The inspector summarized the scope of the inspection and findings at that tim t Y
~%
Cl j
o
At no time during the inspection was written material provided to the licensee by the inspector.
No information exempt from disclosure under
CFR 2.790 is discussed in this report.