IR 05000400/1986047
| ML18004A296 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/25/1986 |
| From: | Ross W, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18004A295 | List: |
| References | |
| 50-400-86-47, NUDOCS 8607180321 | |
| Download: ML18004A296 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 JUL 03 II[
Report No.:
50-400/86-47 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Con uct d:
June 2-6, 1986 Inspector:
'tjt. J.
Approved by:
.
G.
odda
, Acting Section Chief License No.:
CPPR-158 Date Signed Date Signed Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection involved the area of plant chemistry.
Results:
No violations or deviations were identified.
S6071S0321 S60703 PDR
- DOCK 05000400
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Ml k.'!) al REPORT DETAILS Persons Contacted Licensee Employees AJ
- J 4'J R.
B.
- W.
- H.
G.
E.
G.
D.
~
L. Willis, Plant General Manager Harness, Assistant Plant General Manager R. Sipp, Manager, Environmental and Radiological Control (E&RC)
Bassett, Procedures Coordinator',
Operations Fender, Chemistry Specialist, E&RC M. Langoi s, Supervisor, Engineering Lipa, Supervisor, Chemistry Meyer, Engineering Morgan, Chemistry Specialist Supervisor, E&RC Nathan, Chemistry Specialist, E&RC Piner, Chemistry Foreman, E&RC Sears, Chemistry Foreman, E&RC Other licensee employees contacted included construction craftsmen, chemistry technicians and water plant operators.
NRC Resident Inspectors
"G. Maxwell S. Burri s G.
Humphrey
- Attended exit interview Exit Interview The inspection scope and findings were summarized on June 6,
1986, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected, and discussed the inspection findings in detail.
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 (Closed)
URI 50-400/86-18-01 Incomplete Construction of Chemistry Labs (Section 5.C(l))
(Closed)
URI 50-400/86-18-02 Incomplete Instal 1 ation of Sample Rooms (Section. S.e)
(Closed)
URI 50-400/86-18-03 Finalizing Chemistry Staffing (Section 5.f)
4.
Unresolved Items Unresolved items were not identified during the inspection.
5.
Plant Chemistry (79502, 79701)
At the conclusion of the. inspector's previous site visit ( Inspection Report 50-400/86-18, dated Apri 1 1, 1986)
the licensee's progress toward establishing the elements of a chemistry monitoring and control program did not appear to support a July, 1986 fuel loading date.
Inspection Report No. 50-400/86-18 identified three major components of this program as unresolved issues requiring significant attention by the licensee.
These components were laboratory facilities, sampling capability, and staffing.
In addition, the licensee had not completed the development of chemistry procedures to implement the water chemistry program.
During the referenced inspection, the inspector had emphasized the importance of having the elements of a
water chemistry program in place in time to allow the chemistry staff to be trained thoroughly before fuel was loaded and the plant became operational.
The licensee's fuel load date was scheduled for July 25, 1986.
The purpose of the current inspection was update the regional assessment of the licensee'
capability to control plant chemistry by the projected fuel load date.
The inspection focused on three areas:
the design of the balance of plant components with emphasis on the makeup water treatment system and the steam generators; the construction of physical facilities for sampling and analyzing samples; and the development of an effective staff and chemistry procedures for implementing the necessary surveillance and control activities required by a water chemistry program that had been developed to include the guidelines developed by the Steam Generator Owners Group (SGOG)
and the Electric Power Research Institute (EPRI).
These guidelines have been endorsed by the NRC as providing an acceptable level of protection against corrosion of steam generators and degradation of steam generator tubes.
a.
Makeup Water Storage Tanks Since the previous inspection, the licensee had taken two actions to improve the control of oxygen in the water that is used for makeup in the primary and secondary coolant systems.
New diaphragms and nitrogen sparger systems were to be installed in the Demineralized Water Storage Tank (DWST)
and in the Reactor Water Makeup Storage Tank (RWMST).
Before these modifications could be started, bypass lines were to be installed so that water could be provided directly from the discharge of the water treatment plant.
At the time of this inspection, a
new diaphragm and two repair kits had been acqui red for replacing the diaphragm in the Condensate Storage Tank (CST); however, the inspector was informed that the present diaphragm might be left in the CST until a later date, and only the N~ sparger system would be installed.
The
new sparger tubes were to be fabricated from sintered stainless steel and should be more effective in removing dissolved oxygen than the present nitrogen bubbler systems.
During the interim period, the dissolved oxygen content of the water in the CST and associated pipes to the condenser hotwell and to the suction of the auxiliary feedwater pumps would be maintained at a minimum level by adding hydrazine and ammonia to the CST.
In addition, a
new alarm was to be installed on the discharge of the water treatment plant and would be actuated if the oxygen content of the product should exceed 100 ppb.
'he inspector considered that these actions would increase the degree, of protection of the carbon steel pipes from the CST against oxidation, would improve the quality of water provided to the reactor coolant system and to the condensate as makeup, and would relieve the difficulty of regulating the AVT chemicals injection pumps each time the steam generators were supplied with water from the CST by the auxiliary feedwater pumps.
Steam Generator Integrity During the last inspection, the tubes in all three steam generators were being roto-peened to eliminate stresses on the inner walls of the tubes within the lower tube sheets.
Since the last inspection, all tubes in the two innermost rows had been heat treated to relieve potential stress points that may have been created when the
"U" bends were formed.
(This treatment is discussed in greater depth in Inspection Report 50-400/86-18).
The tubes were eddy-current tested after the roto-peening treatment and were to be further tested after the heat treatment.
During the initial eddy-current tests a
loose object, suspected to be an aluminum guide pin, was located within the tube bundle of Steam Generator C.
The four tubes surrounding this object showed indications of denting.
The inspector was informed that efforts to eliminate this object (by crushing or hydrolazing)
would begin in the near future.
These actions were considered evidence that, the licensee was making extensive effort to eliminate all possible causes of future tube degradation by eliminating the causes of corrosion, erosion, and cracking that had been observed in other PMRs.
Completion of Chemistry Facilities (1)
Laboratories The inspector observed that a significant amount of effort had been expended since the last inspection to make the primary chemistry laboratory ready for use.
On the basis of the current inspection, the laboratory was considered to be fully functional and was well equipped with instruments for both radiochemical and
~
non-radiochemical analyses.
Since the laboratory was orginally designed for a four-unit, plant, the amount of benchspace, fume
hoods, and other work space was considered to be more than adequate.
With the completion of the air conditioning and ventilation system, the secondary chemistry laboratory was also considered to be fully operational.
On the basis of this inspection, Unresolved Item 50-400/86-18-01, Incomplete Construction of Chemistry Laboratories, is considered closed.
Sampling Rooms The inspector assessed the readiness of the four facilities that were being constructed for the monitoring of inline analytical instrumentation as well as for obtaining 'grab'amples of water from key control points in the primary and secondary. coolant systems.
Sampling Room 'A'as a shielded room in the Auxiliary Building and was less than a
5 minute walk from the Primary Chemistry and Secondary Chemistry Laboratories located in the Radwaste Building.
This sampling station will be considered
"hot" because it contains sample taps for taking pressurized water samples from the following systems:
RCS hot legs, the Pressurizer liquid and steam spaces, and the Volume Control Tank.
Within the same sampling hood are taps for unpressurized samples from the RHR (hot leg),
from the Pressurizer liquid and steam space, from the accumulators and from the Reactor Makeup Water Storage Tank (RMWST).
The enclosed sink in Sampling Room A also contained taps for sampling blowdown from the steam generators and also for sampling the three main steam lines.
Inline instrumentation was provided for monitoring the blowdown for cation conductivity, pH,'nd sodium and for monitoring main steam for cation conductivity and sodium.
Sampling Room 'B'as another area within the Auxiliary Building where samples associated with the CVCS system will be taken.
Associated with the condensate polishing demineralizers and water treatment control panel in the Turbine Building were sample taps and inline instrumentation for monitoring the effectiveness of the polishers for the determination of cation conductivity, specific conductivity, sodium, and dissolved oxygen.
The Secondary System Sampling Room was also located in the Turbine Building..
In this room were grab sample taps and inline instrumentation for determining sodium and for providing surveillance for the key points in the secondary water system;
i.e., hotwells, condensate pump discharge, No.
4 feedwater heater, and feedwater heater drain pump discharge.
The inspector verified that all the inline instrumentation in all four sampling rooms was operable.
Although the secondary coolant system must be monitored in three separate sampling rooms and care must be tak'en not to contaminate grab samples of blowdown, the licensee was considered to have the necessary facilities for adequately controlling the chemistry of both the primary coolant and secondary coolant systems.
The inline instruments wi 11 facilitate rapid, identification of abnormal conditions and longer trends as well as providing an element of quality control through comparison of results achieved with these instruments with the analyses of grab samples.
On the basis of this inspection, URI 50-400/86-18-02,
"Incomplete Installation of Sample Rooms," is hereby closed.
d.
Development of Chemistry Procedures The inspector reviewed the hierarchy of guidance documents upon which the licensee had developed the Harris Water Chemistry Program.
The lowest tier of directives and guidance consists of over 200 Chemistry and Radiochemistry (CRC) procedures that have been established to cover all responsibilities and actions to be performed by the Chemistry Department.
Selected portions of the procedures listed below were reviewed by the inspector and discussed with the Chemistry Foremen and also compared with the next higher tier document; i.e.,
the Shearon Harris Chemistry Manual.
CCRC-001
- CRC-002 SHNPP (Shearon Harris Nuclear Power Plant) Environmental and Chemistry Sampling and Analysis Program, Rev.
1, February 28, 1986 Chemistry Corrective Actions Program, Rev.
1, February 27, 1986 CRC-003 CRC-004 CRC-020 CRC-022 CRC-040 CRC-100 Chemical Safety Program, Rev.
1; November 15, 1985 Chemistry Logs, Records, and Sample Handling, Rev.
1, November 15, 1985 Chemistry (equality Control Program, Rev.
2, March 31, 1986 Control Charts, Rev.
0, July 19, 1985 General Laboratory Practices, Rev.
1, October 31, 1985 Reactor Coolant System Chemistry Control, Rev.
1, January 16, 1986
"1
CRC-149 Condensate Poli sher Chemi stry Control, Rev.
1, October 31, 1985 CRC-150 CRC-151 Secondary System Chemistry Control and Steam Generator Met Layup, Rev.
1, January 16, 1986 Operation of Secondary System Chemical Addition, Rev.
1, December 10, 1985 CRC-154 Plant In-Line Instrumentation Surveillance, Rev.
0, July 17, 1985 CRC"155 Chemical Control of Circulating Mater, Service Water, and Cooling Tower Basin, Rev.
1, January 2,
1986
"Procedures being revised.
To the extent to which these key procedures were reviewed, the inspector considered them adequate to implement the surveillance and control requirements in the Draft Technical Specifications; e.g.,
TS 4. 1. 1; TS 3/4.4/7, 4/8.
and 9. 1.
This assessment will be repeated when the Harris Technical Specifications are finalized.
These procedures were also considered to reflect the guidance in the Harris Chemistry Manual and to endorse the recommendations of the SGOG/EPRI guidelines.
Although Procedure CRC-002 was being revised at the time of the inspection, the inspector verified that the concepts of action levels and corresponding action statements, as described in Revision 1, would be retained in Revision 2.
From this review, it appeared that the licensee'
procedures had been developed to be consistent with higher tier directives and to provide the guidance and criteria required for diagnostic and control purposes.
Procedures that describe process sampling and specific determinations will be addressed during future inspections.
On the basis of this review, Inspector Followup Item 50-400/85-50-01, Harris Water Chemistry Program, is considered closed.
Development of Operating Procedures The inspector was informed that since the last inspection members of the Chemistry Department and Operations had jointly reviewed selected operating procedures for consistency with chemistry procedures.
The inspector reviewed actions that were being taken by Operations to revise the following Operating procedures on the basis of these earlier discussions.
GP-002 GP-004 GP-005 Startup Normal Plant Heatup Star tup Hot Standby to Criticality Power Operations
GP-006 Shutdown Modes 1 to
GP-007 Shutdown Modes 3 to
All three of the startup procedures (GP-002, 003, and 004) specify that the secondary water chemistry must meet certain chemistry criteria before the plant is taken to a higher mode of operation.
The inspector was informed that the use of "chemistry holds" during cooldown, so that
"hideout return" could be removed through blowdown, would not be practical because blowdown from the steam generators would be required to be isolated when the pressure within the steam generators drops
" below -
650 psi.
(Operating Procedure 183)
This interlock was designed as a means to ensure containment isolation in case of rupture of the high pressure blowdown line.
Without the capability to remove hideout return during plant cooldowns, the licensee will be limited in means to maintain minimum amounts of corrosive species, such as sulfates, in the steam generators.
The licensee proposes to provide such capability by "feeding and bleeding" the steam generators when the plant is in cold shutdown, whenever the concentration of hideout return warrants such action.
The inspector was informed that abnormal Operating Procedure 33,
"Primary/Secondary Chemistry Out of Tolerance,"
Rev.
0, 9/27/85 was the principal vehicle used by Operations to reference the Action Levels defined in CRC-003; however this procedure was not reviewed during this inspection.
The review of operating procedures showed that precautions have been included to prevent the plant from being operated in any mode under conditions that would cause corrosion of the steam generators.
In addition, the procedures provided for protection of the steam generators through wet lay-up whenever the steam generators are cooled below 190'F (Operating Procedure 126).
Chemistry Staffing The inspector reassessed the progress being made by the licensee to develop an adequately staffed and trained Chemistry Department.
The licensee estimated that a staff of 25-30 people would be required to fulfill the responsibilities of the Chemistry Department.
This Department was observed to be organized into two groups, a line organization under the Chemistry Supervisor and a support group under a
Specialist Supervisor.
Both supervisors reported to the Manager, Environmental and Radiological Control.
Within the line and support groups there were 12 Carolina Power and Light employees and approximately 15 contract Chemistry Technicians.
Several of the Support Specialists, including the supervisor, had been transferred from the licensee's Corporate Training and Support Center on detached duty until the plant has achieved full power.
Additionally, the Chemistry Department had been authorized additional
contract personnel, if needed, to achieve full power.
No one associated with the Chemistry program was able to inform the inspector of plans for staffing after the plant achieved full power.
The inspector observed that both the line organization under the Primary and Secondary Laboratory Foremen and the Specialists in the Support Group were active in performing current surveillance requirements, training in the use of instruments and in qualification requirements.
A summary review of qualification cards showed that all Technicians had fulfilled the requirements for 80-90% of the 100 tasks that had been established for fully trained analysts.
This exemplary condition had been achieved through training of CP&L employees in the year-old Craft Program and on-the-job training (at the Harris and Robinson plants)
and through the acquisition of contract personnel with equivalent experience and training.
After interviewing several CP&L and contract technicians and observing their activities in the laboratory, the inspector concluded that, with continued training on shift duties, the Chemistry Department appeared to be capable of meeting the responsibilities as defined in the Harris Chemistry Manual and procedures.
The shift rotation schedule had already been initiated utilizing five shifts with either 3 or 4 technicians on each shift.
Approximately 25 percent of each technician's time was being devoted to formal training.
Each shift was staffed with a senior CP&L technician and one or two technicians with responsibilities in each of the three areas:
Primary Water Chemistry, Secondary Water Chemistry, or Environmental Chemistry.
Several senior technicians also had collateral duties such as quality control management and as the lead analyst and instructor for such state-of-the-art instrumentation as atomic absorption and ion chromatography.
On the basis of this inspection, URI 50-400/86-03, Finalizing Chemistry Staffing, is considered closed.
guality Control During the review of Procedures CRC-020, "guality Control Program,"
and CRC-022,
"Control Charts,"
the inspector assessed the quality control program that had been implemented.
This program was the responsibility
'f a
senior technician who ensured that analyses of standards and unknowns, as well as analyses of the corporate-wide round-robin samples, were being performed as required by procedures.
This technician also maintained the calibration and control charts associated with the quality control program.
Data Management The inspector observed the licensee's procedures for controlling the documentation,.
archiving and management of analytical data.
In addition to the use of work sheets and log books, the results of all analyses were being entered into a
computerized data bank on each shift, usually by the analyst who obtained the data.
The inspector was
+
i
informed that key chemistry data was being distributed to plant management each day.
The computeri zed system al so had the capabi 1 ity of displaying data in ways that would facilitate short 'and long-term trending of plant operation and chemistry control.
i.
Housekeeping The inspector found the chemistry laboratories, office space, and sampling rooms to be adequately maintained.
Ninor construction work was still proceeding in the Primary Chemistry Laboratory, but this relatively large, room, was in,good order.
The inspector emphasized the importance of good laboratory technique and housekeeping'o prevent contamination of wor'king areas and to ensure a 'clean environment'or the analysis of trace constituents in cooling water samples.
j.
Summary The licensee'
capability to provide chemi stry control and prevent degradation of plant components through corrosion was considered to be adequate.
Although the plant was designed before much of the current corrosion technology was deVeloped, the as-built plant, except for the copper alloy condenser tubes, is considered amenable to achieving the degree of chemical control recommended by the SGOG and EPRI.
The presence of copper has been considered to contribute to tube denting and stress corrosion in steam generators; however, the deep bed condensate polishers should provide an effective barrier to the transport of solid or soluble copper from the main condenser tubes to the steam generators.
The design of this plant is unique in that an electromagnetic filter has been included in the steam generator blowdown system to support cleanup and recovery of the blowdown.
This filter had already been used successfully during the feedwater pump tests.
The water chemistry program appeared to meet the criteria established by the licensee in the hierarchy of directives and instructions and also to fulfill the intent of NRC recommendations, in Generic Letter 85-02, to use the guidelines developed by the SGOG and EPRI.
Adequate procedures for implementing this program had been developed and a
competent chemistry staff had been organized and had received operating experience during the hot functional and feedwater pump test ~ C i