IR 05000443/1986035

Preoperational Insp Rept 50-443/86-35 on 860609-13.No Violations or Deviations Noted.Major Areas Inspected: Chemistry Effluent Controls & Radwaste Programs,Including Preoperational & Acceptance Testing

ML20203E553
Person / Time
Site:	Seabrook
Issue date:	07/14/1986
From:	Bicehouse H, Kottan J, Mark Miller, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203E538	List: IR 05000443/1986035 ML20203E533
References
50-443-86-35, NUDOCS 8607240174
Download: ML20203E553 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-35 Docket N License N CPPR-135 Priority -- Category B Licensee: Public Service of New Hampshire P. O. Box 330 Manchester, New Hampshire 03105 Facility Name: Seabrook Nuclear Power Station-Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: June 9-13, 1986 Inspectors: N- ~' [A/ [[Nh J. Kottan,/ a ati n Laboratory Specialist

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l ()7,ji. Bicehouse, Radiation Specialist 7$h

     / da'te d412/  deb er, Rabfation Specialist 7/E//4
     'dtte Approved by: '

Ww  ?[IV![(C, W. Pasciak, Chief, Effluents Radiation fate / Protection Section, EP&RPB, DRSS Inspection Summary: Inspection on June 9-13, 1986 (Report No. 50-443/86-35).

Areas Inspected: Announced preoperational inspection of the applicant's chemistry, effluent controls and radioactive waste programs including: water chemistry control program, effluent measurement and control, process and effluent radiation monitor calibration, chemistry program, and preoperational and acceptance testin Results: Of the areas inspected, no violations or deviations were identifie PDR ADOCK 05000443 G PDR

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DETAILS 1. Individuals Contacted Principal Licensee Employees

*J. Linville, Chemistry Department Supervisor
*G. Kingston, Compliance Manager
*J. Marchi, QC Manager
*J. Warnock, Nuclear Quality Manager
*W. Sullivan, QA Engineer
*S. Buchwald, QA Supervisor
*T. Pucko, Licensing
*D. McLarn, Startup Manager J. Gallagher, Chemistry Operations Supervisor R. Litman, Chemistry Support Supervisor L. Rabideau, Chemist R. Campi on, Chemistry Foreman
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M. Anderson, Radwaste/ Utilities Department Supervisor L. Walsh, Operations Manager M. Yargeau, Radwaste Engineer W. Cash, Health Physics Supervisor Yankee Atomic Electric Company

* Middleton, QA Staff Engineer
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*R. Guillette, Assistant Construction QA Manager
*V. Sanchez, Site Licensing Suoervisor United Engineers and Constructors
*D. Lambert, Project Field QC Manager
*S. Dunphy, Startup Supervisor i *R. Gregory, Licensing Engineer t
* Denotes those present at the exit interview.

l 2. Status of Previously Identified Items l '

(Closed) 25-00-13 TI: This inspection completed preoperational review of the applicant's water chemistry control progra (Closed) Followup Item (443/86-22-01): ODCM formalization to include effluent sampling and analysis schedule, and implementation of system of l

procedures for actions required by Technical Specification limiting con- ! ditions for operation (LCO). The licensee's latest version of the ODCM contains effluent sampling and analysis frequency schedules. The licensee has also implemented procedures for actions required by LCOs. These pro-l cedures implement repetitive task sheets for the actions required by LCO . - . - . - - - - . - _ - _ ._. - - - -

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(Closed) Followup Item (443/86-22-02): Use of control charts for the gamma spectroscopy system and acceptance criteria for spiked and split sample intercomparison. The licensee is modifying procedure CD0904.04, Labora-tory Control Charts, to include control chart use for the gamma spectro-scopy system. Procedure 0904.10, Interlaboratory Performance Verification,
; has also been modified to include acceptance criteria for chemical and radiochemical intercomparisons, as well as the intercomparison frequenc (Closed) Followup Item (443/86-22-03): Radiochemistry items including:

hand plotting calibration curves, use of high efficiency Ge detectors for gamma spectroscopy effluent analyses, and review of tritium and strontium analysis procedures. The licensee is hand plotting the gamma spectroscopy efficiency calibration curve Procedure CX0930.01, Gamma Spectrcmetry System Operation and Calibration, has been modified to ensure that effluent surveillance samples are analyzed using only the most efficient

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detectors. Review of the tritium and strontium analysis procedures indicated that the procedures appear to be adequate to meet Technical , Specification and ODCM requirement (Closed) Followup Item (433/86-22-04): Installation of isolation valves on drain lines from the steam generator blow down monitors. The inspectors examined the steam generator blowdown monitors and noted that the isola-tion valves on the drain lines had been installe (0 pen) Followup Item (433/86-22-05): Complete installation of process sampling stations. The inspectors examined the reactor coolant and steam generator sampling stations and noted that these stations were still being installed. The licensee stated that upon completion of the installation, the sample stations would be tested in accordance with pre-operational test procedures. The pre-operational test procedure would meet the commit-ments stated in Chapter 14 of the FSAR. (See Section 6.)

! (Closed) IE Bulletin 80-10: Containment of Nonradioactive System and

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Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity

to Environment. The inspector verified the applicant had addressed the actions recommended to prevent an unmonitored and uncontrolled release of

, radioactivity to the environmen Implementation cf these actions will be reviewed during a subsequent inspection prior to power ascension testing.

l (Closed) IE Circular 79-21: Prevention of Unplanned Releases of Radio-l activit The inspector verified the applicant had addressed the design i ' considerations and preoperational testing to prevent unplanned releases of radioactivit Review of results of testing program to verify cross-connects do not exist between Units 1 and 2 will be reviewed during a subsequent inspection prior to power ascension testin ' I l t

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(Closed) IE Circular 80-18: 10 CFR 50.54 Safety Evaluations for Changes to Radioactive Waste Treatment Systems. The inspector reviewed procedure DC.1.1, " Design Evaluations" which adequately addressed the performance of 10 CFR 50.59 reviews for design changes. The applicant stated that a generic procedure to address any required safety evaluation would be com-pleted by July 1986. This procedure will be reviewed during a subsequent inspectio . Effluent Measurement and Control The inspectors reviewed the licensee's program for the measurement and control of radioactive effluent This review was conducted with respect to the requirements contained in the licensee's proposed Technical Speci-fications (TS) and Offsite Dose Calculation Manual (00CM). The licensee's effluent sampling and analysis schedule has been written into the ODCM rather than the TS. The licensee has written two procedures for ODCM and TS implementation: CX0917.01, Liquid Effluent Releases, and CX0917.02, Gaseous Effluent Releases. These procedures provide for controlling effluent releases in accordance with ODCM and TS requirements including effluent monitor alarm set points and composite sample preparation. The licensee has also written Procedure CX0908.01, Offsite Dose Assessment, which uses the approved methods in the ODCM to calculate and estimate the doses occurring beyond the plant boundaries due to liquid and gaseous effluent releases during normal plant operations. This procedure provides for the periodic dose assessments which are required by T The above procedures CX0917.01, CX0917.02, and CX0908.01 when coupled with Administrative Procedure CP 4.1, Effluent Surveillance Program, provide a method for implementing the ODCM methodology and complying with TS radio-active effluent requirement The inspectors noted that the licensee's ODCM and TS were not yet finalized and approved. This might result in changes to the above procedure However, based on the inspectors' review of the proposed ODCM and TS, any required changes to the procedures would be minor in natur . Process and Effluent Radiation Monitor Calibration The inspectors reviewed the calibration data for selected process and effluent radiation monitors. The review was conducted with respect to the FSAR chapters 11 and 12; ANSI N13.1 - 1969, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities; ANSI 13.10-1974, Specifi-cation and Performance of On Site Instrumentation for Continuously Moni-toring Radioactivity in Effluents; and proposed TS and ODCM. The actual monitor calibrations are performed under a general test procedure, GT-I-106X, where X is a letter denoting a specific monitor or type of monitor. The calibrations are performed using actual liquids or gases in geometries which duplicate the normal monitor counting geometr The calibration data for the following selected effluent radiation monitors was reviewed: RM 6519, steam generator blowdown flash tank; RM 6530,
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. 5 spectral correctional effluent monitors (plant vent); RM 6528, plant vent wide range gaseous effluent monitor; and RM 6521, Turbine building sum The calibration data was reviewed and accepted by the licensee as required by the licensee's procedures. In addition to the calibration data, data for gain and high voltage adjustments were also reviewed by the inspector . The inspectors toured the facility and examined certain monitors with respect to the criteria contained in the above paragraph. The monitors examined were: RM 6530, spectral correctional monitor; RM 6528, plant vent wide range gaseous effluent monitor; RM 6510, RM 6511, RM 6512, RM 6513, steam generator blowdown monitors; and RM 6526, containment air-borne radioactivity monito No deviations from the FSAR or applicable standards were note . Chemistry Program The inspectors reviewed the licensee's chemistry and radiochemistry program with respect to items noted in Inspection Report 50-443/86-22 conducted on May 9-31, 198 In addition to the items identified in Section 2, the following items were also reviewed and discusse Measurement of any distribution of iodine on charcoal cartridge The licensee has ordered an additional uniformly distributed charcoal cartridge so that gamma spectrometer calibrations could be performed for any distribution of iodine encountered on a cartridg Use of two standard stock solutions, one for performing calibrations and one for use as a control standard. The licensee is modifying procedure C. P. 8.1, Verification of Analytical Systems Performance, to incorporate the use of two stock standard solution Elimination of the use of a reagent blank when performing fluoride analysis using an ion specific electrode (ISE). The use of a reagent blank for ISE fluoride analysis yields results which are low by the amount of the blank. Procedure CX0921.21, Determination of Fluoride by Orion 901, has been modified to eliminate the reagent blank ste Development of both ISE and spectrophotometric methods for low level chloride analysis. The licensee has committed to develop b th methods for low level chloride analysis by June 30, 198 Reanalysis of NRC ropper standar The licensee has not yet reana-lyzed the NRC copper standar The inspectors noted that the liter.see's action in response to the above items, which were identified during a previous inspection, was both prompt and technically sound. The inspector had no further questions in this area.

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, Water Chemistry Control Program i 6.1 Requirements The applicant's water chemistry control program was reviewed relative to criteria, commitments and recommendations provided in:

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Seabrook Station Final Safety Analysis Report, (FSAR); '

',   NUREG-0896, " Safety Evaluation Report Related To The Operation i

Of Seabrook Station Units 1 And 2," and its supplements; NUREG-0452, " Standard Technical Specification For Westinghouse Pressurized Water Reactors;"

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Electric Power Research Institute (EPRI) Report NP-2704-SR,

   "PWR Secondary Water Chemistry Guidelines, " Revision 1 (1984);

NRC Regulatory Guide 1.33, " Quality Assurance Program Require-

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ments (Operation), " Revision 2 (February 1978); NRC Regulatory Guide 1.37, " Quality Assurance Requirements For Cleaning Of Fluid Systems And Associated Components Of Water-Cooled Nuclear Power Plants," (March 1973); NRC-NRR Generic Letter 85-02, " Staff Recommended Actions Stemming From NRC Integrated Program For The Resolution Of Unresolved Safety Issues Regarding Steam Generator Tube Inte-4 grity," (April 17,1985); Applicant's Letter dated June 13, 1985, W. P. Johnson, Public Service Of New Hampshire to H. L. Thompson, Jr., NRC-NRR in response to Genetic Letter 85-02;

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ANSI /ANS 3.1-1978, "American National Standard For Selection, Qualification And Training Of Personnel For Nuclear Power

Plants; "and

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American Society For Testing And Materials (ASTM), Section 11,

   " Water Standards."

6.2 Scope Of The Review The applicant's water chemistry control program was reviewed in the

following areas: Organization;

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Selection, Training And Qualification Of Personnel;

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i Plant Water Chemistry Systems; Sampling And Measurement; and Implementation Of The Water Chemistry Control Progra The applicant's performance in each area was determined by interviews and discussions with the Chemistry Department staff and represen-tatives of the applicant's startup organization, review of proce-dures, drawings and records, and observations of plant facilities j and equipment during walkdowns and tours of the applicant's Unit 1

facilities.

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.      7 6.3 Organization The inspectors examined the program organization with regard to policies, goals / objectives, assignment of responsibilities and authorities, resources to implement the program and procedures controlling the water purity in the primary, secondary and balance of plant water systems. Although there appeared to be a corporate management commitment to and support for an effective water chemistry control program, the applicant's representatives were unable to provide a documented policy statement and corporate goals / objectives for the water chemistry control program. Station administrative procedures covering water chemistry specifications, corrective actions in the event of water impurities exceeding specifications, sampling and analysis, in-line instrumentation and data / records management and reporting had been develope Chemistry control program responsibilities were assigned to the Station Chemistry Department. Generally adequate resources of personnel, instrumen-tation, laboratory equipment and plant sampling equipment were provided. The organizational structure of the Chemistry Department was clearly defined and interfaces with other station organizations for communication of water chemistry data and trends were under developmen Chemistry procedures were selectively reviewed to determine if:

Critical chemical variables and limit / action levels for control of those variables had been identified; Sampling schedules and locations for obtaining those samples had been provided; Analytical methods and their basis had been identified; Recording and trending of data and reporting requirements were present in the procedures; and Investigative and corrective actions to be taken when critical i chemical variables exceeded action levels were established.

1 The following procedures were reviewed ir detail, discussed with the i Chemistry Department staff and provided the basis for review of the ! implementation of the water chemistry control program: ! ! Chemistry Procedure (CP) 3.1, " Primary Chemistry Control l Program," Revision 1 (Ar ' 29, 19E6);

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i CP 3.2, " Secondary Chemist.y Controi Program," Revision 1 (April 29, 1986); CP 3.3, " Miscellaneous Systems Chemistry Control Program," Revision 1 (April 29, 1986); and

CP 8.1 " Verification Of Analytical Systems Performance,"

Revision 1 (April 29, 1986).

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The inspectors noted that the applicant was revising these procedures and planned full implementation at fuel load.

< The applicant's program to identify and correct water chemistry con-trol deficiencies was reviewed to determine if a program to identify, investigate, document, report, track, close and trend discrepancies in water chemistry control parameters had been established and imple-

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mented. The inspector noted that Chemistry Department Directives and i Startup procedures provided a program to identify and correct water chemistry control deficiencie Within the scope of this review, no deviations were note .4 Selection, Training And Qualification The applicant utilizes chemistry technicians in roles which require skills as analysts and instrument technician In addition, chemis-try technicians provide advise and direction to operators of plant water chemistry systems. Working Foremen pr6 vide first-line super-vision of the technicians and make initial recommendations concern- , ing corrective action of action levels for chemical parameters are reached. During Inspection No. 50-443/86-22, the applicant's selec-

,  tion, training and qualification program for chemistry personnel was reviewed for conformance to commitments and consensus standard During this inspection, selected chemistry technicians and working foremen were interviewed and their qualification records were

, reviewed to assess the applicant's training and qualification program.

, The inspector noted that oral qualification boards under ANSI /ANS 3.1-1978 were being conducted and that those boards were scheduled to completion by June 30, 198 Within the scope of this review, no deviations were identifie .5 Plant Water Chemistry Systems i The applicant's primary, secondary and auxiliary water systems were reviewed for familiarization and conformance to the descriptions in the FSAR. The as-built design was reviewed for potential pathways of impurity ingress and transport of contaminants to the Steam Gene-r rator Unit 1 is a four-loop Westinghouse Pressurized Water Reactor (PWR) utilizing Model F Steam Generators. A Chemical And Volume Control System with a mixed bed demineralizer is used for primary water chemistry contro Steam generator recirculation / blowdown provides the means for secondary system impurity removal. The applicant plans to use all volatile treatment (AVT) for secondary water treatment. The main steam reheater tubes are 90/10 copper / nickel alloy. Condenser circulating water is sea water taken from

the Atlantic Ocean. A condensate polishing system for treating the i

feedwater was not provided. A floating cover is used to control

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. 9 Industry experience has shown that a PWR with recirculating steam generators, copper materials in the secondary system and sea water condenser cooling has a high probability of steam generator damag The inspector discussed this observation with the applicant. The applicant's Chemistry Department conducted a technical review of the design in 1981-82 and reached similar conclusions concerning the desig .6 Sampling And Measurement The applicant's process sampling system was reviewed. The sample system provides liquid and gas samples for analysis of the water chemistry of the reactor coolant system, steam generator blowdown, secondary steam and water systems and other auxiliary systems during normal operations. In-line instrumentation for continuously monitor-ing chemical parameters was also reviewed. During Inspection N /86-22, acceptance testing of the process sampling system was reviewed. The applicant had determined that the reactor coolant and steam generator sampling stations had to be redesigned. Those re-designs and installation / testing were reviewed and found to be in progress during this inspection. The applicant's identification of chemical variables to be continuously monitored, grab sample loca-tions, sampling schedules and provisions for obtaining representative samples were reviewed relative to guidance and recommendations in the EPRI and ASTM documents. The applicant's helium leak detection pro-gram for the condenser was also reviewed and discussed with the applicant. Within the scope of this review, no deviations were noted. Previously identified item 50-443/86-22-04 related to process sampling stations remains ope .7 Implementation The implementation of the applicant's water chemistry control program during preoperational testing and layup of plant water systems was reviewed. Within the scope of this review, the following items were noted:

The applicant's construction group used water meeting the nuclear steam system supplier's (NSSS) criteria rather than more restrictive station criteria during filling and flushing operations on the reactor coolant systems. The difference in chemistry parameters is shown in the following table: Parameter Station Criteria NSSS Criteria pH 6-8 6-8 Chloride <0.15 parts per million (ppm) 0.15 ppm Fluoride <0.15 ppm 0.15 ppm Conductivity 2 micro mhos 20 micro mhos Turbidity <1 NTU not specified

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. 10 This discrepancy was identified by the Chemistry Department and correcte *

Microbiological 1y induced corrosion was noted approximately four years ago in the fire protection system. The applicant devel-oped a sampling and control program which was reviewed during Inspection No. 50-443/85-35. The Inspector noted that the applicant had installed an ultraviolet sterilizer for the makeup demineralized water system to control ingress of the bacteria into primary and secondary plant water system . Preoperational and Acceptance Testing 7.1 General

The inspectors examined preoperational and acceptance testing of the

following systems:

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i Ventilation Systems

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! Gaseous Radioactive Waste System ! Radiation Monitoring System.

The review was with respect to criteria contained in the following: ! Final Safety Analysis Report, Chapter 14, " Initial Tests Program"

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Regulatory Guide 1.68, Revision 0, "Preoperational and Initial i Startup Test Program for Water Cooled Power Reactors" { Seabrook Power Station Unit 1, Technical Specifications !, (proposed).

The evaluation of the applicant's performance in this area was based on review of documentation, observations by the inspectors, and 1 discussions with cognizant applicant personnel.

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Procedures, test objectives and acceptance criteria j Status of Testing Program

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! Evaluation of test exceptions and field test change notices '

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Adherence to test procedures

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Adequacy of applicant review and resolution of test exception , 7.2 General Findings Within the scope of the review, the inspector determined that pre-operational testing and review of test results was being performed ! in an adequate manne No breakdowns in the testing program or , results review was identified.

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. . 11 The inspectors noted that the initial test program procedures were designed as either Preoperational Tests (PT) for safety related systems, and Acceptance Tests (AT) for non-safety related plant systems and equipmen .3 Ventilation Systems The inspectors reviewed the licensee's preoperational testing of the following systems:

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Fuel Storage Building HVAC

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Waste Processing Building HVAC

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Primary Auxiliary Building HVAC

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Containment Structure Recirculating Filter Subsystem

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Containment Structure Air Purge and Heating

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Containment On-Line Purge Subsyste The review consisted of a preliminary P&ID drawing review in com-parison to the Seabrook FSAR Chapter 9.4 design basis, identifica-

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tion of filters and non-filtered ventilation systems and status of testing progra Within the scope of this review, no deviations or unacceptable con-ditions were identified by the inspector. With the exception of the Fuel Storage Building, operational and filter train testing, has not baen completed. Status of the testing program for the above listed systems was as follows: Fuel Storage Building HVAC PT 27.1 Fuel. Storage Building Ventilation System-Completed February 24, 1986, One Test Exception PT 27.2 Fuel Storage Building Exhaust Filter System-Completed February 14, 1986, Seven Test Exceptions PT 44 Plant Ventilation System Filter Testing; Filter F-74-Completed February 13, 1986, No Test Exception Waste Processing Building AT-20.1 Waste Air Handling Ventilation System-Procedure Approved October 23, 1984-Scheduled for mid-June 1986 PT 44 PVS Filter Testing; Filter F-143-Scheduled for mid-July 198 Primary Auxiliary _Butiding PT-45 Primary Auxiliary Building Ventilation-Procedure Approved August 8, 1985-Scheduled for July 1986, Projected Completion: 4 weeks PT-44 PVS Filter Testing; Filter F-16-Performance To Be Determined

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Containment Structure PT-26 Containment Air Recirculation-Completed April 16, 1986, One Test Exception PT-44 PVS Filter Testing; Filter F-8-Scheduled for early July 1986 AT-22 Containment Purge-Completed April 23, 1986, Open Test Exceptions PT-44 PUS Filter Testing; Filter F-40-Scheduled for early July 198 The inspectors noted that most of the test exceptions would be closed upon completion of the Phase I air balance testing program which is documented as General Test GT(I)-M-0 The licensee stated that the ventilation testing program as described in FSAR Chapter 14 would be completed prior to core loadin This area will be reviewed during a subsequent inspectio .4 Gaseous Radioactive Waste System The inspectors reviewed the gaseous waste processing system which includes the waste gas vent header, gas chiller, iodine guard bed, dryer, carbon beds, particulate filter (HEPA), and gas compresso The inspectors toured the gaseous waste system and verified that the system was generally installed as described in Seabrook FSAR Chapter 11. One ALARA installation problem was identified concerning the inability to remotely manipulate test and purge line valves located in close proximity to unprocessed waste gas piping. The applicant initiated a radiation source term study to determine if a re-design would be warrante The waste gas processing system will be tested by 1-AT-14, " Radio-active Gaseous Waste," approved May 30, 1986. Performance testing was scheduled for June 16, 1986 to be completed pricr to core loa Test results and resolution of any open test except ons will be i reviewed during a subsequent inspectio . Exit Interview The inspectors m'et with the applicant's representatives denoted in Sec- - tion 1 at the conclusion of the inspection on June 13, 1986. The inspec-tors summarized the purpose and scope of the inspection and the inspection finding . }}