ML20215N417

Insp Repts 50-348/86-18 & 50-364/86-18 on 860825-28. Deviation Noted:Failure to Comply W/Fsar & Response to IE Bulletin 81-03 Re Commitments Concerning Svc Water Sys Chlorination

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: ML20215N387 ML20215N404 ML20215N417
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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. M Mcg UNITED STATES

Do NUCLEAR REGULATORY COMMISS!ON

4 / "

[ n REGION il

3 j 101 MARIETTA STREET.N.W.

• c . ATLANTA. GEORGIA 30323

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'+4 + . . . . $

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Report Nos.: 50-348/86-18 and 50-364/86-18

Licensee: Alabama Power Company

j 600 North 18th Street

Birmingham, AL 35291

! Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility Name: Farley 1 and 2

Inspection Conducted: August 25-28, 1986

4 Inspection at Farley site near Dothan, Alabama

i Inspectors: L

M. Thomas O

ttf L ~ D11104. /ODate23h/

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Date iigned

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Date Signed

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Accompanying Per e F

Approved by: < /4 2/yj d sf JD -A7 -W

F. Vape, Section Chief

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Date Signed

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

to IE Bulletin 81-03 Commitments Concerning Service Water System Chlorination

. (Paragraph 7).

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8611050382 861031

PDR 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

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

oil temperatures.

- Replace the end bells on the Unit 1 charging pump gear drive lube oil

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 I

plant operation to be started at least weekly and record steady state

gear drive 1 ce oil temperatures. i

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- Revise the preventive maintenance program for the charging pump gesr'

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.

- 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;

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Performirig service water flow measurements on selected safety-

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.

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(c) The extent of fouling if any existed.

(d) How and when fouling was discovered.

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(e) Corrective and preventive actions. l

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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

biofouling.

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.