IR 05000424/1986121

Insp Rept 50-424/86-121 on 861117-21.No Violation or Deviation Noted.Major Areas Inspected:Licensee Program Addressing Nuclear Svc Cooling Water Sys Fouling

ML20215F302
Person / Time
Site:	Vogtle
Issue date:	12/11/1986
From:	Bernhard R, Jape F, Menning J, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215F268	List: IR 05000424/1986121 ML20215F265
References
50-424-86-121, NUDOCS 8612230346
Download: ML20215F302 (8)

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f UNITED STATES

[Sh na? o NUCLEAR REGULATORY COMMISSION REGION 11

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g j( 101 MARIETTA STREET, * * ATLANTA, GEORGI A 30323

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t Report No.: 50-424/86-121 Licensee: . Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424' License No.: CPPR-108

. Facility Name: Vogtle Inspection Conducted: November 17-21, 1986 Inspectors: $ - h) b&is &

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/1//t lW6 Da'te signed M.ThomYas

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R'. Bernhard Date Signed NU J. g ing }

wb\ Dat'e Signed Approved by: N. I ///[bw /L /1/it/F6 F.' Ja pe ,' Chi e f ' / Dite Signed Test Programs Section Division of Reactor Safety

. SUMMARY Scope: This routine, unannounced inspection was conducted in the area of the licensee's program addressing nuclear service cooling water system foulin Results: No violations or deviations were identifie ,

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REPORT DETAILS Persons Contacte Licensee Employees

• R. E. Conway, Senior Vice President and Project Director

• R. H.-Pinson, Vice President, Construction

• P. D. Rice, Vice President, Project Engineering

• R. M. Bellamy, Plant Support Manager, Operations

• C. W. Hayes, Project Quality Assurance (QA) Manager

• C. H. Whitney, General Manager, Project Support

• C. E. Belflower, QA Site Manager, Operations

• E. D. Groover, QA Site Manager, Construction

• L. B. Glenn, Manager, Quality Concerns

• L. Mosbaugh, Assistant Plant Support Manager, Operations

• D. Hallman, Chemistry Superintendent

• W. Jocher, Lab Supervisor

• Stalker, Nuclear Chemistry Supervisor

• J. A. Edwards, Senior Nuclear Specialist

• R. C. Walker, Senior QA Field Representative

• W. C. Gabbard, Senior Regulatory Specialist

• Sprankle, Senior Engineer

• Carter, Chemistry Foreman Other licensee employees contacted included engineers, technicians, security force members, and office personne Other Organization K. Burns, Chemical Engineering Consultant, Charles Moore and Associates NRC Resident Inspectors

*H. Livermore, Senior Resident Inspector (Construction)

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• J. Rogge, Senior Resident Inspector (Operations)

• R. J. Schepens, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on November 21, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license The following new items were identified during this inspection.

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IFI 424/86-121-01, Review of Revised NSCW Pump Surveillance Test Procedures, paragraph IFI 424/86-121-02, Review of Ultimate Heat Sink Testing, paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved items were not identified during the inspectio . Nuclear Service Cooling Water System Inspection of the nuclear service cooling water (NSCW) system involved reviews of system design requirements, preoperational testing, draft technical specification requirements, plant procedures, and programs for preventative maintenance, chemistry control, and sampling for Asiatic clam The reviews in each of these areas are discussed below along with the determinations made by the inspector Review of System Design The inspectors reviewed the NSCW system design as described in Section 9.2.1 of the Final Safety Analysis Report (FSAR), GPC's system description, and applicable drawings (Numbers IX4DB133-1 and 2, 1X4DB134, and 1X408135-1 and 2). The intent was to identify the safety-related components cooled by NSCW and subsequently determine whether GPC's plans and procedures for detecting and controlling fouling address these components. The inspectors also identified design flow requirements for the safety-related components as part of this revie The NSCW system, containing the plant ultimate heat sink, is designed to remove heat from plant auxiliaries that are required for a safe reactor shutdow The NSCW system is designed to perform its cooling function following a loss-of-coolant accident (LOCA), automatically and without operator action, assuming a single f ailure coincident with a loss of offsite powe The NSCW system provides cooling to plant components, as required, during normal operation and normal shutdown. The NSCW system flows and heat loads for essential components are given in FSAR Table 9.2.1-1.

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. Review of Preoperational Testing The inspectors reviewed preoperational. test data for the NSCW system to determine what data was collected that would provide a baseline for subsequent system flow test The NSCW's flows to it's various components are controlled by use of orifices in the component's pipin Preoperational testing was performed per Procedure No. 1-3EF-01,

'Rev. 1, " Nuclear Service Cooling Water". This procedure tests flow

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to the various NSCW loads, and verifies the NSCW cooling . tower fan's motors' performance. The procedure runs NSCW pumps 1 and 3 for the component' flow verification portion of the tes During review of the preoperational test data, the inspectors noted that the test procedure as written did not have a method to allow flow data taken at the ESF loads to be adjusted downward to take into account the higher than FSAR minimum pump performance present during the tes Components showing marginal NSCW flows during the test-could have flows below the FSAR requirements if the pump performance were allowed to degrade below that used during testin The pumps could meet minimum FSAR requirements and allow system flows to drop below their requirement After discussions of this inspector identified concern, licensee representatives indicated that the NSCW pump performance surveillance test procedures would be written to reflect .the higher than FSAR pump values as acceptance criteria. The values would be based upon the flow used in preoperational testing and would establish higher minimum pump flow requirements. Pending review of the revised procedures, this matter is identified as Inspector Followup Item 424/86-121-01, Review of Revised NSCW Pump Surveillance Test Procedure The inspectors also noted during this review that there are currently no surveillance or other periodic tests that verify all system flows to components. Pump flows, valve positions, and control room monitored l

flows to some components are the only methods of assuring adequate system performanc Review of preoperational test data also revealed that no mechanical l performance testing had been performed for the NSCW cooling towers, other then motor checks. The NSCW cooling towers are the Ultimate Heat Sink (UHS) for Plant Vogtl Regulatory Guide 1.68 requires performance testing of the UHS as part of preoperational testing. This testing should include verification of the VHS heat rejection capacity since the NSCW cooling towers are forced draft towers. A review l revealed that testing of the UHS was not included in either the Preoperational Test Program or Startup Test Program as outlined in the FSA Following discussions with the inspectors, licensee representa-tives indicated that the UHS would be tested, most likely during l

startup testing, and that this item would be addressed in the next status of fuel loading letter. Pending review of the test results, j

this matter is identified as Inspector Followup Item 424/86-121-02, Review of Ultimate Heat Sink Testin _

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4 Review of Draft Technical Specification Requirements The inspectors reviewed draft technical specification requirements to determine the extent to which related surveillance testing could be used to detect system or component fouling. Section 4.7.4.a ' requires the verification at least once per 31 days that each valve servicing safety-related equipment that is not locked, sealed, or otherwise secured in position is in its correct positio Section 4.7. requires the verification at least once per 18 months during shutdown that each automatic valve servicing safety-related equipment actuates to its correct position on a safety injection signal, and that each system pump starts automatically on a safety injection signal. In addition, Section 4.6.2.3.a requires that each group of containment cooling fans be demonstrated operable at least once per 31 days in part by verifying a cooling water flow rate of greater than c* equal to 1,359 gpm per pair of containment fan coolers. The inspectors also reviewed the following procedures that are to be used to satisfy these surveillance requirements:

(1) Procedure No. 14522-1, Rev.1, "NSCW Flow Path Verification" (2) Procedure No. 54055-1, Rev. O, " Train A Diesel Generator and ESF Actuation Test" (3) Procedure No. 54065-1, Rev. O, " Train B Diesel Generator and ESF Actuation Test" (4) Procedure No. 14490-1, Rev. 1, " Containment Cooling System Operability Test" The inspectors concluded that of the surveillance requirements related to NSCW system operability, only those associated with the containment ,

cooling fans (Section 4.6.2.3.a) will be useful for detecting foulin Cooling water flow rates through the containment fan coolers will be determined and recorded monthly, and data can be trended to identify fouling that impedes flow. The surveillance requirements of Sections 4.7.4.a and 4.7.4.b can be satisfied as long as fouling is not so gross as to restrict valve movement or pump operatio Review of Plant Operating Procedures The inspector reviewed the following abnormal operating procedure for the NSCW system to determine if methods are specified for dealing with sudden, fouling-related flow blockages within the system:

Abnormal Operating Procedure No. 18021-1, Rev. 1 " Loss of Nuclear Service Cooling Water System" Review revealed that this procedure focuses on loss of pump and loss of header events and does not specifically provide instructions for

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dealing with fouling. The inspectors did determine, however, that such guidance is provided in various annunciator response procedures (ARPs). Abnormal cooling water temperature and flow conditions i

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associated with the RHR pumps, component cooling water and auxiliary component cooling water heat exchangers, diesel generator water jackets, containment cooling air cooling units, and reactor cavity cooling coils are annunciated in the control room. The inspectors reviewed the following ARPs and determined that the instructions provided for the listed alarms address fouling:

ARP Associated Annunciator Alarms No. 17035-1, Rev. 1, "ARP's for ALB DG 1A HI TEMP JACKET WATER-IN (Annunciator Lighting Board) 35 on DG 1A HI TEMP JACKET WATER-00T EAB (Electrical Auxiliary Board) DG 1A HI TEMP JACKET WATER Panel" No. 17038-1, Rev. 1, "ARP's for ALB DG IB HI TEMP JACKET WATER-IN 38 on EAB Panel" DG 1B HI TEMP JACKET WATER-0VT DG 1B HI TEMP JACKET WATER No. 17002-1, Rev. 2, "ARP's for ALB NSCW TRAIN A DG CLR LOW FLOW 02 on Panel 1A1 on MCB (Motor Control NSCW TRAIN A RHR PMP & MTR CLR LO FLOW Board)" NSCW TRAIN A CNMT CLR 1 & 2 LO FLOW NSCW TRAIN A CNMT CLR 5 & 6 LO FLOW NSCW TRAIN A RX CAVT C/C LO FLOW No. 17003-1, Rev. 1, "ARP's for ALB NSCW TRAIN B DG CLR LO FLOW 03 on Panel IA1 on MCB" NSCW TRAIN B RHR PMP & MTR CLR L0 FLOW NSCW TRAIN B CNMT CLR 3 & 4 LO FLOW NSCW TRAIN B CNMT CLR 7 & 8 LO FLOW NSCW TRAIN B RX CAVT C/C L0 FLOW No. 17061-1, Rev. 1, "ARP's for ALB NSCW CCW AND ACCW TRAIN A TEMP ALARM 61 on Process Control Panel" NSCW CCW AND ACCW TRAIN B TEMP ALARM Review of preventative Maintenance Program The inspectors reviewed GPC's planned preventative maintenance (PM)

program for the NSCW system to identify provisions for detecting and controlling fouling. The inspectors determined that the licensee plans to periodically inspec most of the components cooled by NSCW for evidence for fouling. Only the internal coolirg coils of the pumps serviced by NSCW are excluded from the current PM schedule. The following PM checklists were reviewed:

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Checklist N Equipment Inspected Frequency (Months)

11203E4001-M-12M Component Cooling Water 12 Heat Exchanger

! 11217E4001-M-12M Auxiliary Component Cooling 12 Water Heat Exchanger i

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11208P6002-M-12M CVCS Centrifugal Charging- 60 Pump Lube Oil Cooler 11204P6004-M-12M Safety Ir.jection Pump 12 Lube Oil Cooler 11561E7001-E-12M Piping Penetration Area 12 Cooler 11592C7001-E-12M Control Building ESF 12 Chiller Train 11515A7001-E-1M Containment Building 12 Auxiliary Cooling Unit 11501A7000-E-12M Containment Building 12 Cooling Unit 11511E7001-E-24M Reactor Cavity Cooling 60 Coils 12403F4002-M-18M Diesel Generator Engine Jacket 18 Water Heat Exchanger f. Review of Chemistry Control Program The inspectors reviewed the licensee's chemistry control program to determine what measures have been established to control NSCW system fouling. This review revealed that chlorination will be used to control microorganisms and Asiatic clams. During clam spawning season continuous chlorination will be utilized for a five day period at a level of 0.7 to 1.3 ppm residual chlorine each month. At other times GPC plans to periodically inject chlorine to a level of 0.2 to 0.5 ppm residual chlorine, with treatment frequency varying with the season of the year. Scaling within the NSCW system will be controlled with both acid additions and blowdown control. Should silt control become a problem during plant operations, the licensee plans to use dispersant additions. The inspectors reviewed the-following procedure for control

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of the NSCW system chemistry:

i Procedure No. 35370-C, Rev. 2, " Chemistry Control of the Nuclear

Service Cooling Water System" g. Review of Program for Asiatic Clam (Corbicula) Sampling i The inspectors reviewed GPC's program for Asiatic clam sampling to

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determine what sampling requirements have been established for the NSCW

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L Procedure No. 32540-C, Rev. O " Sampling and Analysis of Plant l Systems for Corbicula" l

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The licensee's current program specifies that diesel generator heat exchangers are to sampled in conjunction with PM inspectinns. These heat exchangers are scheduled to receive PM inspections every 18 months, as discussed in paragraph 5.e. The licensee also plans to monitor the performance of these heat exchangers on a monthly basi Jacket cooling water inlet and outlet temperatures will be recorded monthly by operations personnel and trended. The inspectors reviewed the following procedures that provide requirements for the performance monitoring of the diesel generator heat exchangers:

Procedure No. 30050-C, Rev. 1, "Corbicula Infestation Evaluation of Plant Systems" Procedure 20018-C, Rev. 0, " Diesel Generator Trending" Conclusions of Nuclear Service Cooling Water System Review Based on the existing potential for fouling, the inspectors concluded that GPC's plans and procedures for detecting and controlling NSCW system fouling appear to be adequate. Since the system utilizes well water for normal makeup and recirculates water from the cooling towers, silt / clay should not contribute to fouling and the potential for Asiatic clam infestation is low. Corrosion products can also be eliminated as a likely fouling agent since the system's piping is stainless stee In the absence of Asiatic clams, silt / clay, and corrosion products, microorganisms appear to be the most likely fouling agent The ongoing NSCW system chlorination program and the planned PM program are capable of detecting and controlling fouling by microorganisms. The ongoing Asiatic clam sampling program coupled with the PM program provide means for detecting the presence of clams in the NSCW system in the unlikely event that Asiatic clam intrusion occurs in the futur Within the areas inspected, no violations or deviation were identified.