ML20215N417
| ML20215N417 | |
| Person / Time | |
|---|---|
| Site: | Farley |
| Issue date: | 10/23/1986 |
| From: | Macdonald J, Menning J, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215N388 | List: |
| References | |
| 50-348-86-18, 50-364-86-18, IEB-81-03, IEB-81-3, NUDOCS 8611050382 | |
| Download: ML20215N417 (9) | |
See also: IR 05000348/1986018
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UNITED STATES
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NUCLEAR REGULATORY COMMISS!ON
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101 MARIETTA STREET.N.W.
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Report Nos.: 50-348/86-18 and 50-364/86-18
Licensee: Alabama Power Company
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600 North 18th Street
Birmingham, AL 35291
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Docket Nos.:
50-348 and 50-364
Facility Name:
Farley 1 and 2
Inspection Conducted: August 25-28, 1986
Inspection at Farley site near Dothan, Alabama
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Inspectors:
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M. Thomas O
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Accompanying Per
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Approved by: <
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F. Vape, Section Chief
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Test Programs Section, Engine ring Branch
Division of Reactor Safety
SUMMARY
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Scope: This special, announced' inspection involved the areas of service water
system fouling problems and followup on previously identified enforcement <1tems.
Results: One deviation was identified - Failure to Comply with FSAR and Response
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to IE Bulletin 81-03 Commitments Concerning Service Water System Chlorination
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(Paragraph 7).
8611050382 861031
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ADOCK 05000348
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REPORT DETAILS
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1.
Persons Contacted
Lie nsee Employees
- J. D Woodard, General Manager, Farley Nuclear Plant
- R. G. Berryhill, System Performance Manager
- R. M. Coleman, System Performance Supervisor
- H. Garland,. Maintenance supervisor
- R. D. Hill, Operations Manager
- D. R. Klasing, System Performance Group
- D. Morey, Assistant General Manager, Operations
- C. D. Nesbitt,~ Technical Manager
- J. K. Osterholtz, Supervisor, Safety Auditing and Engineering Review
- W. B. Shipman, Assistant General Manager, Support
- L. M. Stinson, Manager, Plant Modifications Department
- L. A. Ward, Maintenance Manager
Other licensee employees contacted included engineers, technicians,
cperators, mechanics, security force members, and office personnel.
NRC Resident Inspectors
- W. H. Bradford, Senior Resident Inspector
- B..Bonser, Resident Inspector
- Attended exit interview
2.
. Exit Interview
The inspection scope and findings were summarized on August 28, 1986, and by
telecon on September 9 and 11,1986, with those persons indicated in
paragraph 1 above.
The inspector described the areas inspected and
discussed in detail the inspection findings.
The following new items were
identified during this inspection.
Deviation 348 and 364/86-18-01, Failure to Comply with FSAR and
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Response to IE Bulletin 81-03 Commitments Concerning Service' Water
System Chlorination - Paragraph 7.
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Inspector Followup Items (IFI) 348 and 364/86-18-02, Review Status of
Actions Implemented by the Licensee to Address Service Water System
Fouling Problems - Paragraph 6.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by tne inspectors -during this inspection.
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3.
Licensee Action on Previous Enforcement Matters
(Closed) Violation 364/85-04-01, concerning failure to provide a procedure
for spent fuel examination within the spent fuel pit.
The inspectors
reviewed the licensee's response to the violation (March 4,1985) which
stated that fuel inspection procedures for both units had been revised to
provide for the use of underwater video cameras and recorders.
The
inspectors reviewed procedure FNP-0-ETP-3636, Fuel Assembly Visual
Inspection During Core Unload, dated April 8,
1986, which includes
provisions for the use of underwater video cameras and recorders in the
spent fuel pool area.
4.
Unresolved Items
Unresolved items were not identified during the inspection.
5.
Service Water System Description
The Farley Final Safety Analysis Report (FSAR) states that the service water
system provides cooling water to various heat exchangers throughout .the
plant during various modes of plant operation.
The service water system
takes suction from the service water intake structure located at the storage
pond.
The service water system, along with the storage pond, comprise the
ultimate heat sink for the plant.
The service water system is a nonshared
system between the two units except for the intake structure, recirculation
line to the pond, recirculation line to the wet pit, and the discharge
piping and structure to the river.
Five service water pumps are provided
for each unit. The system is designed to remain operable during'(1) loss of
river system water with or without offsite power, and (2) loss of coolant
accident (LOCA) in.one unit while the other unit is in normal operating mode
or normal shutdown mode with or without offsite power.
In the event ~of a
loss of offsite power, the service water pumps will automatically be
supplied from the emergency diesel generators in order to supply the cooling
water required to hold both units at hot shutdown conditions.
The non-
safety-related portions of the service water system are. automatically
isolated on a safety injection signal by motor operated valves.
6.
Event Description
The inspection at Farley Nuclear Plant (FNP), was held partially in response
to the fouling problem associated with the Unit 1 charging pump oil coolers
on August 1,1986, which resulted in a reduction of service water flow to
the charging pump oil coolers, and to a planned review of ~ service water
system problems at all facilities.
The fouling problem is described in
detail in Licensee Event Report No. LER 86-014-00, dated September 2, 1986.
The following was reviewed to determine the licensee's corrective actions:
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a.
FNP method of identifying the problem
b.
Size and number of clams found within the affected coolers
c.
Future inspection plans of other heat exchangers
d.
Determination of other corrective actions
e.
Other associated service water fouling
A review of the documentation provided by FNP attributed the cause of their
problems to corrosion of service water piping, an influx of silt / mud and
growth of corbicula, (Asiatic clams) in the service water piping.
The
documentation reviewed included FNP's response to IE Bulletin 81-03, dated
May 26, 1981, the service water task force report (report precipitated as a
result of the recent event), response to Institute of Nuclear Power
Operations SOER 84-1, and FNP memorandum, dated October 19, 1983, which
dealt with a corbicula investigation at FNP.
As noted. in the task force report, the blockage in the charging pump oil
cooler was discovered af ter investigation into a high oil temperature alarm
received in the control room on August 1, 1986. The blockage which effected
the oil temperature, consisted of mud and clams in various quantities.
During the event, the IB charging pump oil cooler was cleaned twice.
The
first time, several quarts of mud were flushed out and the second time, four
clams were found.
During the event, the IC charging pump oil cooler was
also cleaned twice; the first time, several quarts of mud were flushed out
and the second time, approximately 50 small clams (11 mm dia. - which are
considered adult) and one pint of mud were flushed cut.
A review of other-
plant systems utilizing service water did not reveal any. abnormal operating
performance.
The licensee stated that future inspections of coolers will
occur based on the analysis of trended data and during maintenance work.
Corrective Actions
The inspectors were made aware of a number of actions being considered by
the licensee in the task force report and through discussions with licensee
personnel which are aimed at controlling service water fouling to assure
minimal impact on plant safety and operation. The actions have been grouped
as short term and long term.
The short term recommendations include the
following:
Establish a program't.o trend charging pump gear drive and bearing lube
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oil temperatures.
Replace the end bells on the Unit 1 charging pump gear drive lube oil
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heat exchangers with the same type end bells as installed on Unit 2.
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Initiate a program for the charging pump not being used for normal
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plant operation to be started at least weekly and record steady state
gear drive 1 ce oil temperatures.
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Revise the preventive maintenance program for the charging pump gesr'
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drive and bearing lube oil heat exchangers.
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Determine the amount of sludge buildup and clam infestation in the
service water wet pit and perform cleaning operation if required.
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Make on shift personnel aware that service water fouling can occur not
only over a long period of time, but over short periods of time also.
The licensee stated that most of the short term recommendations were either
in progress or had been completed.
The long term corrective actions will focus on the following three major
areas:
(1) System modifications being considered include:
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Converting the cooling water from service water to component
cooling water for all charging pump lube oil heat exchangers on
both Unit 1 and Unit 2.
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Expedite current production change notices (PCN) for replacing,
where necessary, 2-inch and under carbon steel service water
piping with stainless steel.
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Installation of isolation valves and flush points in selected
service water piping 4-inches and less diameter which would allow
chemical cleaning and high velocity flushing.
(2) Upgrade surveillance and monitoring program to include;
Performirig service water flow measurements on selected safety-
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related heat exchangers and room coolers.
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Perform trending of ' selected heat exchanger data in order to
detect early signs of fouling problems.
(3) Upgrade preventive maintenance program to include inspection and
cleaning of heat exchangers based on trend data as well as the routine
inspection.
The licensee stated that some of the long term recommendations are expected
to be completed during the upcoming refueling outage for Unit 1, which is
scheduled to start October 4, 1986.
The inspectors expressed concern that, prior to this incident, it appeared
that adequate attention had not been given to the Asiatic clam aspect of
fouling.
This was evident by previous recommendations discussed in a
memorandum, dated October 19, 1983.
The recommendations resulted from a
corbicula investigation at FNP.
Some of the recommendations from the 1983
investigation were also recommended by the task force in this latest report.
It appears that the recommendations in the October 19, 1983 memorandum were
not acted on when they were identified. The effects of this inattention can
be reflected in the chargit.g pump gear oil cooler incident.
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The inspectors noted that the level of attention currently being given to
service water fouling has increased.
This increased level of attention and
the proposed action plan are positive steps in ensuring the operability of
the charging pumps and other components receiving service water.
The. inspectors will review the status of the licensee's short term and long
term action plan for controlling service water system fouling during a
followup inspection.
This item will be tracked as Inspector Followup. Item
50-348, 364/86-18-02, Review Status of Actions Implemented by the Licensee
to Address Service Water System _ Fouling Problems.
No violations or deviations were identified.
7.
Actions in Response to IE Bulletin 81-03
IE Bulletin 81-03 specifically addressed the issue of flow blockage of
service water system components by Corbicula and Mytilus.
The bulletin
required holders of operating licenses to respond to five items including:
a.
Determination of the presence of Corbicula or Mytilus in the vicinity
of the station,
b.
Determination of the presence of these species within the service water
systems,
c.
Determination of a method to monitor individual component performance
in potentially effected systems, if the presence or absence of these
species was not confirmed.
d.
Descriptions of the methods in use or planned for detecting or
preventing future blockage or degradation due to Corbicula or Mytilus
or shell debris.
e.
Descriptions of the actions taken in items 1 through 3 above, including
the following information:
(a) Applicable portions of the environmental monitoring program
including last sample date and results.
(b) The effected components and systems.
(c) The extent of fouling if any existed.
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(d) How and when fouling was discovered.
(e) Corrective and preventive actions.
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On May 26, 1981, the licensee responded to IE Bulletin 81-03 and it was
formally closed in NRC Inspection Report 50-348/81-24 and 50-364/81-27.
Corbicula were found to be present in the Chattahochee River, the service
water storage pond and the cooling towers.
But upon inspection of selected
safety-related service water system heat exchangers, only small quantities
of clam shell debris had intruded into the system, without apparent effect
on system performance.
The licensee credited the minimizing of biofouling
to the routine chlorination program, which for both units consisted of
three, 45-minute batch chlorinations per day to a concentration of 0.5 ppm
at the service water intake structure.
The licensee's response to Item 5,
Part e of IE Bulletin 81-03 was that the proper corrective and preventive
actions to minimize biofouling was to maintain the current chlorination
program.
The chlorination system is described in FSAR subsection 9.2.1.6. _ The FSAR
states that prevention of organic fouling in the plant service water system
piping and equipment will be accomplished by intermittent chlorination of
the service water with a chlorine concentration of 0.5 ppm.
The chlorina-
tion system was experiencing many functional periods of disrepair and
chlorination activities were stopped for the entire time between January
1982 and March 1983.
During this period, a new chlorine dioxide gasifica-
tion system was installed.
Since March 1983, the system has operated
continuously with very little down time.
Although the chlorination system was inoperable for approximately 15 months,
licensee personnel stated that no other compensatory actions were implement-
ed to control service water system biofoulings, nor was any other action
taken to control the entry of clams into the service water system.
It
appears that this contributed to larval clams entering the plant through
the service water system, causing fouling of service water system piping
and components.
Chlorination and surveillance of pump performance give
assurance of system operability. Loss of either item reduces the ability to
ascertain system operability.
The inspectors informed the licensee that
failure to provide other means for chlorinating the service water system
during the time that the chlorination system was inoperable is a deviation
from the commitment stated in response to IE Bulletin 81-03, and the conunit-
ment in FSAR Subsection 9.2.1.6.
The item is identified as Deviation 348,
364/86-18-01, Failure to Comply With FSAR Subsection 9,2.1.6 and Response to
IE Bulletin 81-03 Commitments Concerning Service Water System Chlorination.
During a followup telephone conversation on September 11, 1986, the licensee
stated that during the time the chlorination system was inoperable, they
were actively working on the system in order to return the system to service
as quickly as possible.
In addition to the numerous problems associated
with the chlorination system itself, other problems encountered included
long lead times in obtaining parts, and personnel safety considerations
involved in working with the gaseous chlorine system.
After considerable
effort by the licensee and the vendor to repair the system, and given the
hazards associated with using the chlorine gas, the decision was made to
install the chlorine dioxide system.
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0n March 28,1984, INP0 issued SOER 84-01, Cooling Water System Degradation
Due to Aquatic Life. The INP0 report encompassed IE Bulletin 81-03 items as
well as recommendations on design, procedures and training and inspection of
service water system degradation due to biofouling. The licensee evaluated
INP0 SOER 84-01 and again came to the same conclusions of the investigations
and inspections performed in response to IE Bulletin 81-03:
that there was
no degradation of the service water system and associated components due to
Based on the recent Corbicula fouling of the 18 and 1C charging pump gear
oil cooler and increased incidence of clam and shell debris in other Unit 1
charging pump coolers and other service water system components, the
licensee has committed to reevaluate their response to INP0 SOER 84-01. The
new response will be incorporated into the action plan developed as a result
of the recent events involving the service water system.
8.
Technical Specification Surveillance Testing
The inspectors reviewed the licensee's test procedures for the service water
systems to determine if these procedures are consistent with the require-
ments of the Technical Specifications and Section XI of the ASME Boiler and
Pressure Vessel Code. The following procedures were reviewed:
FNP-1-STP-24.1, Revision 11, January 12, 1986, " Service Water Pump 1A,
1B and 1C Inservice Test"
FNP-2-STP-24.1, Revision 7, April 16,1986, " Service Water Pump 2A, 28,
and 2C Inservice Test"
FNP-1-STP-24.2, Revision 12, May 29,1986, " Service Water Pump ID, IE,
and 1C Inservice Test"
FNP-2-STP-24.2, Revision 6, April 16, 1986, " Service Water Pump 20, 2E,
and 2C Inservice Test"
FNP-1-STP-24.3, Revision 12, May 6, 1986, " Service Water Pump 1A, 1B,
and 1C Annual Inservice Test"
FNP-2-STP-24.3, Revision 7, April 16, 1986,." Service Water Pump 2A, 2B,
and 2C Annual Inservice Test"
FNP-1-STP-24.4, Revision 13, May 29,1986, " Service Water Pump 1D,1E,
and 1C Annual Inservice Test"
FNP-2-STP-24.4, Revision 6, April 15, 1986, " Service Water Pump 2D, 2E,
and 2C Annual Inservice Test"
FNP-1-STP-24.5, Revision 9, May 21,1986, " Service Water System Flow
Path Verification Test"
FNP-2-STP-24.5, Revision 5, June 23,1986, " Service Water System Flow
Path Verification Test"
FNP-0-STP-24.6, Revision 1, May 11,1985, " Service Water Buried Pipe
Inspection"
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FNP-1-STP-24.7, Revision 11, May 11, 1985, " Service Water Valves
Inservice Test"
FNP-2-STP-24.7, Revision 10, April 18,1986, " Service Water Valves
Inservice Test"
FNP-1-STP-24.8, Revision 3, December 12, 1984, " Service Water Pumps 1A,
1B, and IC Monthly Operability Check"
FNP-2-STP-24.8, Revision 2, December 21, 1984, " Service Water Pumps 2A,
28, and 2C Monthly Operability Check"
FNP-1-STP-24.9, Revision 4, July 23,1985, " Service Water Pumps ID, IE,
and 1C Monthly Operability Check"
FNP-2-STP-24.9, Revision 3, May 7, 1985, " Service Water Pumps 2D, 2E,
and 2C Monthly Operability Check"
FNP-1-STP-40.0, Revision 13, December 3,1985, " Safety Injection With
Loss of Off-Site Power Test"
FNP-2-STP-40.0, Revision 0, June 28, 1986, " Safety Injection With Loss
of Off-Site Power Test"
The inspectors determined that the licensee's service water system test
procedures adequately addresses the surveillance testing requirements of the
Technical Specifications and the inservice testing requirements of
Section XI of the ASME Boiler and Pressure Vessel Code.
The current
requirements provide for the periodic verification of valve and- pump
operability, proper valve positions, proper operation of certain automatic
valves on a safety injection signal, and of the leak tightness of buried
piping.
The licensee's test program does not provide the flow-related test data
necessary to assess fouling within the service water system due to the
nature of the current test requirements.
Licensee representatives indicated that a Standing Order had recently been
issued to provide operations personnel with instructions for dealing with
service water fouling problems.
The inspectors reviewed the Standing Order
that was dated August 21, 1986.
These instructions require the'backwashing
of the A and 8 train strainers prior to a planned transient on the service
water system and require the monitoring of charging pump gear box lube oil
temperatures during and following such a transient.
Additionally, methods
are identified for cooling the exteriors of the gear box lube oil coolers in
the event that all charging pump coolers become clogged / fouled simulta-
neously.