IR 05000400/1986018
| ML18019A768 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/28/1986 |
| From: | Ross W, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18019A767 | List: |
| References | |
| 50-400-86-18, NUDOCS 8604080219 | |
| Download: ML18019A768 (17) | |
Text
0
~It,8 4EG(1(
Wp.
+
O~
t 0O n <<>>*<<>>
UNITED STATES NUCLEAR REGULATORY COMMISSION'EGION II 101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 APR Oi 1986 Report No.:
50-400/86-18 Licensee:
Carolina Power and Light Company P.
0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris Unit 1 Inspection Conduc ed:
March 10-14, 1986 Permit No.:
CPPR-158 Inspector:
J.
os Date Signed Approved by:
A'Q
~
~
~
~
~
~
~
~
r
.
P.
G. Stoddart, Act)ng Sect)on Chief Date Signed Emergency Preparedness and Radiologica'I'
Protection, Branch Division of RadiatioII Safety and Safeguards" ti (r t
r rt rt
- '
,
"
ISUMMARY I
Scope:
This routine'unannoUncted inspection involved 35 inspector-hours onsite in the area of plant,'chemist'ry."
r
'esults:
No violations!'Or,deviations were identified'.(,
tt i
- '. tt t
~DOC 840401 p>>9 aa
,8 N 05pppypp PDR
I
"I
'n'It
.
p
~t'
I l',I
~ t I
tt I'
tt
II I
fs,'>
g Ittl M
I,ting I
I 1,t
'
I I
I
'I
'I, It tt.f
I l
I t
I'rtl f ~'It II b-I tt
REPORT DETAILS Persons Contacted Licensee Employees
~J.
L. Willis, Plant General Manager
"E. J.
Wagner, Manager, Engineering J.
R. Sipp, Manager, Environmental and Radiological Control (E8RC)
B. Fender, Chemistry Specialist, E8RC
"W.
M. Langlois, Supervisor, Engineering
"H. Lipa, Supervisor, E8RC
~G. Nathan, Chemistry Specialist, E8RC D. Piner, Laboratory Supervisor, E8RC B. Sear, Laboratory Supervisor, E8RC M. Turner, Engineer, Nuclear Engineering and Licensing Other licensee employees contacted included chemistry technicians.
NRC Resident Inspectors
"G. Maxwell S. Burris
"G.
Humphrey
~Attended exit interview Exit Interview The inspection scope and findings were summarized on March 14, 1986, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
Unresolved Items Unresolved items are matters about which more information is required to determine whether it is acceptable or may involve violations or deviations.
Three new unresolved items identified during this inspection are discussed in paragraphs 5. c(1) and 5.c(2).
h
'
5.
Plant Chemistry (79701 and 79502)
This inspection was a
followup of Inspection Report No. 50-400/85-50 (December 9-13, 1985)
and provided further review of efforts being taken to bring the primary and secondary coolant systems to operational status as well as a
reassessment of both the efforts being taken to complete the development of a water chemistry control program and the resources to implement this program.
a ~
Readiness of Coolant Systems Since the last inspection, the hot functional tests (HFTs) of the primary (reactor)
coolant system had been completed successfully.
Subsequently, the head of the reactor was removed to allow the reactor internals to be inspected for hydraulic damage, and the reactor coolant system had been drained so that the primary side of the steam generators could be entered.
On the secondary side, the steam generators were layed up with chemically controlled water (ammonia and hydrazine)
after the HFTs were completed.
The auxiliary feedwater system had been used to feed the steam generators during the HFTs, and these lines remained filled with chemically treated water.
The condensate/feedwater train had been filled with water for over a year and was be'ing cycled periodically through a condensate polisher to remove solid and soluble impurities.
The inspector was informed that the dissolved oxygen concentration in this train had not been controlled.
The inspector reviewed the status of the reactor coolant system and three components of the secondary water system where additional work will be required before the secondary system can be considered fully operational; i.e.,
the water makeup system, the AVT chemistry control system, and the steam generators.
(1)
Primary Coolant System During the HFTs, the primary coolant had been maintained at 550 F
for nearly 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> to "passivate" the inner surfaces of the stainless steel pipe.
Through this action, a protective layer of dense, non-porous iron oxide (magnetite)
was formed which will reduce subsequent release of corrosion products (and accompanying radioactive
"crud") throughout the primary system.
It is the vendor's (Westinghouse)
position that "the longer the exposure at temperature, the thicker and crystallographically more perfect would be the protective layers formed."
The inspector was informed that a period of about 790 hours0.00914 days <br />0.219 hours <br />0.00131 weeks <br />3.00595e-4 months <br /> (33 days)
was chosen after discussions with Westinghouse.
During the HFTs, both oxygen and pH were controlled to maximize the passivating process.
Subsequent to the HFTs, the reactor coolant system remained in chemically controlled wet layup until the reactor head was removed and the system drained to allow the steam generator work to be performe II t
II
The inspector discussed with the licensee the probability that, while the reactor coolant system was open and drained, the protective magnetite film would be vulnerable to deterioration.
Consequently, increased attention should be given to the lay-up environment..
Water Treatment and Makeup Water Systems Since the last inspection, the following events had occurred which had caused the licensee to reassess the effectiveness of the makeup water system.
First, the water in the Demineralized Mater Stoi age Tank (DMST) had been contaminated with sulfuric acid that is used to regenerate the cation exchange resin bed in the Water Treatment Plant.
High quality water in the DWST had been restored through
'bleed and feed'rocedures, using demineralized water from the water treatment plant.
This procedure was costly in time and water inventory; however, the DMST could not be completely drained and refilled without affecting several plant components that required a constant supply of demineralized water.
The second event occurred during the HFTs.
The water in the Condensate Storage Tank (CST) became contaminated with ammonia and hydrazine when these AVT chemicals were inadvertently pumped, through the auxiliary feed pump mini-flow line, to the CST.
At the time, the auxiliary feedwater pumps were being used to supply chemically controlled water from the CST to the steam generators.
The inspector was informed that the design of the AVT chemical injection system was being reviewed to ensure that this type of event cannot recur.
Inasmuch as the CST may be completely drained, the quality of water specified in the licensee's water chemistry program was restored more rapidly than in the DWST event, but with a waste of a large volume of water.
Finally, the inspector was informed that difficulty had been encountered in maintaining the desired low level (<100 ppb) of dissolved oxygen in water used for makeup for condensate and reactor coolant.
Contrary to plans discussed during the last inspection, nitrogen bubbler systems had not been installed in the CST or in the reactor water makeup storage tank (RNST), and the use of bladders to prevent ingress of air had not been effective in maintaining low levels of dissolved oxygen.
These deficiencies were being addressed by the E8RC and Engineering Departments.
AVT chemicals were being added to the CST water to control pH and dissolved oxygen and to increase protection against corrosion of the carbon steel pipe from this tank to the auxiliary feedwater pumps.
The inspector also reviewed steps that were being taken to prevent the water in the CST from being contaminated through re-use of
It
water recovered through the Radwaste Cleanup System.
A chemical tracking program was under development to monitor the presence and use of all chemicals (especially organic chemicals) within the pl ant.
AVT Chemical Addition System The licensee had encountered problems with the injection system for ammonia and hydrazine.
The inspector was informed that these problems resulted from the need for different pump flows and valve alignments when these chemicals were required for the following purposes:
chemistry control of auxiliary feedwater (from the CST)
during plant startup and shutdown; control of condensate/feedwater chemistry during pl'ant operation; and for providing controlled lay-up conditions for the three steam generators.
The inspecto'r reviewed several proposals for resolving the perceived deficiencies in the present pumping capabilities and piping designs that were also under review by 'the E8RC and Engineering Departments.
This matter was discussed with plant management as a
design problem that would impact chemistry control of the
.secondary coolant and, thus, should receive priority attention.
Roto-peening of Steam Generator Tubes During this inspection, the inspector observed activities that were directed toward the elimination of residual stresses from the inner surfaces of all steam generator tubes within the tube-sheet regions of the tubes.
These actions were being taken to prevent primary-side, stress induced cracking of the Alloy-600 (inconel)
steam generator tubes.
This type of cracking had been observed within the tube sheet at other Westinghouse steam generators of similar design to those at Harris and has been attributed to a combination of stress, high temperature, and probably, a lengthy incubation period.
The roto-peening process was developed to transfer stress from the inner surfaces of the tubes, which would be in contact with the hot reactor coolant, to the outer diameter of the tubes, and thereby prevent initiation of cracking.
Although actual cracks had not been observed, the steam generator tubes at Harris were considered to be vulnerable because of the following reasons:
The tubes probably were stressed in the tube sheet region because the tubes had been mill-annealed and then rolled twice through the length of the tube sheet to eliminate crevices and voids.
The temperature (620 F) of the reactor coolant in the hot legs at full power (T t) is several degrees higher than in most Westinghouse plan III r
This type of cracking has been found in other Westinghouse steam generators with designs similar to the 0-4 steam generators at Harris.
No means for preventing this type of corrosion by chemistry control has been developed.
(5)
Summary The HFTs gave the licensee the opportunity to develop a passive layer of magnetite on the stainless steel surfaces of the reactor coolant system (RCS)
and thus, provide protection against further oxidation of these pipes after the Harris unit becomes operational.
However, the extent to which this protective layer was deteriorating after the RCS was opened to air was conjectural.
The HFTs also involved testing the effectiveness of the subsystems of the secondary water cycle that are required to ensure that the water which is pumped into the steam generator always would meet the stringent purity specifications that have been adopted to prevent corrosion.
Problems related to control of oxygen in the CST and with the design of the AVT chemical addition system remained to be resolved before chemistry control could be assured.
b.
Water Chemistry Program Since the previous inspection, the corporate and plant management directives for controlling chemistry, that had been listed in Inspection Report No.
85-50, had been promulgated.
The inspector reviewed the approved chapters of the Harris Chemistry Guideline Manual that had been developed in compliance with these management directives.
Only the chapter entitled
"Cleanup-Layup and Startup" had not been completed and approved.
Special emphasis was given to the review of the two chapters of this Manual that related to primary and secondary chemistry.
After further clarificatio'n of a
number of items, the inspector considered this Manual included all the key elements of a water chemistry program that had been recommended by the Steam Generator Owners Group (SGOG)
and the Electric Power Research Institute (EPRI).
Consequently, the proposed water chemistry program also met the intent of NRC Generic Letter 85-02 that recommended licensee endorsement of the SGOG guidelines for secondary water chemistry.
The Manual Chapter "Primary Water Chemistry" had been developed principally from guidance provided by Westinghouse; however, the licensee was also actively involved in the development of primary water guidelines by SGOG/EPRI.
(Westinghouse is also involved in the SGOG/EPRI effort.)
Several chapters of the Chemistry Manual contained guidance that required interactions of the E8RC Department with other departments in the plant, especially with the Operations Department and Control Room Supervisors and Operators.
As part of'he overall implementation of this Manual (per Plant General Order 026)
procedures of other departments were being reviewed for consistency with the Manual,
especially with the concepts of Action Levels and Action Statements that could effect the way the plant would be operated during abnormal chemistry situations.
The inspector emphasized the advantages of incorporating the Chemistry Manual as part of the training of plant personnel other than those in the E8RC Department.
Program Implementation For planning purposes, the licensee had set a fuel loading date for July 1986.
This date was used by the inspector to assess the licensee's capability to fully implement a chemistry control program that is based on the Harris Chemistry Manual.
(1)
Physical Facilities The status of construction of the primary and secondary laboratories was the same as during the previous inspection.
A significant amount of work would be required before either of these laboratories could be used to control 'radiochemistry or non-radiochemistry samples for an operating plant.
The licensee stated that completion of these facilities was scheduled for the near future; however, this situation was designated as Unresolved Item 50-400/86-18-01, Incomplete Construction of Chemistry Laboratories and should be given priority attention by the licensee.
As discussed in Inspection Report No. 85-50, the licensee was in the process of replacing several in-line analytical instruments in the primary and secondary chemistry sampling rooms and on the condensate polisher control panel.
These instruments would be used to monitor dissolved oxygen, sodium, hydrazine, and cation conductivity in the secondary water system at such key points as the condensate, influent and effluent of the deep-bed condensate polishers, feedwater, and steam generator blowdown.
Because this instrumentation would be of critical importance to the licensee's chemistry control program, and since both their installation and procedures for monitoring these instruments are not complete, the operability of the sample rooms was designated Unresolved Item 86-18-02, Incomplete Installation of Sample Rooms.
(2)
Staffing The inspector established that at the time of this inspection, the E8RC staff consisted of 12 CP8L personnel and ten contract technicians and specialists.
Authorization had been received to hire six additional contract technicians before fuel loading and up to a total of 22, if needed later.
The Chemistry Supervisor and the Primary and Secondary Chemistry Specialists report to the Manager, E8RC; however, the responsibilities of these three supervisors/specialists had remained flexible while the chemistry program was still under development.
Because it is critical that
't N
l
(3)
key positions would be identified and filled and the authorities and responsibilities would be well defined as early as possible before the plant becomes operational, the establishment of a permanent staff organization was designated Unresolved Item 86-18-03, Finalizing Chemistry Staffing.
Training The HFTs afforded the E8RC Department an opportunity to apply chemical procedures to a dynamic primary coolant system as well as to activities related to filling the steam generator.
Training under these conditions were more beneficial than when the hydraulic systems were static or the systems was drained.
The inspector established that the licensee had initiated an extensive (five year duration) Craft Technical Training Program for all CP8 L chemistry technicians (but not for contract personnel),
and approximately 15% of each CP8 L technician's time was to be devoted to training.
In addition to the formalized training at the Corporate Training Center, each technician (both CP8L and contract personnel)
would participate in on-the-job qualification activities within the ten stages of the overall program.
The inspector was informed that more than half of the CP8L technicians also had at least two years of experience at other operating plants.
The inspector, re-emphasized the importance of having the E8RC staff trained to the maximum extent possible in all aspects of the Chemistry Manual before the fuel loading date.
The licensee's progress in this area will be reassessed at each future inspection as part of Inspector Followup Item 85-50-01, Harris Mater Chemistry Program.
Procedures (5)
'Essentially all Administrative, Chemistry, and Operations procedures required to operate the plant and to control plant chemistry had been written before the Harris Chemistry Manual was approved.
The inspector observed that these procedures were being reviewed for consistency with the Manual and with each other.
Data Management The licensee was establishing a computer-based data management program to be used for trending of key chemical variables, archiving chemistry information, and for informing plant management of the status of chemistry contro (6)
Summary During this portion of the inspection, no violations or dev'iations were identified.
This assessment showed that the licensee's capability to implement a water chemistry program that would meet the requirements of corporate directives and the Harris Water Chemistry Manual was still evolving and remained deficient in several critical areas.
Through discussions with BRC supervision and plant management, the inspector emphasized the need to end this evolution as early as possible so that a stable and experienced staff could be developed before fuel is loaded.
Three of the deficient areas were considered of sufficient importance that Unresolved Items were opened pending their resolution.
In addition, the development of a satisfactory water chemistry program will remain an Inspector Followup Item.
d.
Plant Lay-Up As discussed early in this report, the stainless steel pipe in the reactor coolant system had been
"passivated" to minimize future deterioration of the primary coolant pressure boundary and also to minimize future ex-core radiation levels.
However, after the HFTs had been completed and the protective magnetite layer installed on the pipe, the reactor coolant system was drained and exposed to air.
On the secondary side, the low-pressure pipes had been filled with water for more than a year in a more or less stagnant condition.
However, licensee had taken precautions to lay-up the steam generators under chemical controlled and dynamic conditions to prevent degradation of the carbon-steel structural components.
It is known that corrosion of carbon-steel is accelerated if the metal is in contact with stagnant oxygenated water, as is the potential to develop localized corrosion cells that result in pitting.
Consequently, NRC regulations flO CFR 50.34(b)(6)(ii)j require managerial and administrative controls to be in place to insure that
CFR Appendix B, Criterion XIII is met.
The licensee was reminded of this requirement by IE Information Notice No. 85-56 (July 15, 1985)
and again, during this inspection.
The inspector was informed that lay-up procedures that had been employed by other utilities during extended outages were under review.
The inspector emphasized that until a
better wet or dry lay-up procedure was implemented, increased attention should be directed toward the current lay-up conditions, especially where carbon-steel components were involve