IR 05000324/1987029

Insp Repts 50-324/87-29 & 50-325/87-29 on 870831-0904.No Violations or Deviations Noted.Major Areas Inspected:Exam of Svc Water Sys Monitoring Programs & Scram Discharge Vol Capability SER Compliance

ML20235L691
Person / Time
Site:	Brunswick
Issue date:	09/28/1987
From:	Bernhard R, Jape F, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20235L671	List: IR 05000324/1987029 ML20235L669
References
50-324-87-29, 50-325-87-29, NUDOCS 8710050565
Download: ML20235L691 (10)

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UNITED STATES ,

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J NUCLEAR REGULATORY COMMISSIOrd

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Report Nos.: 50-325/87-29 and 50-324/87-29 Licensee: - Carolina Power and Light Compan'y P. O.~ Box 1551 Raleigh,-NC 27602 j

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Docket-Nos.: :50-325 and 50-324 License Nos.- DPR-71 and DPR-62

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Facility Name: Brunswick 1 and 2 Inspection Condu ted* Ausus 31 - eptember 4,1987 .

Inspectors: /- M ~

Date Signed R. H.- Bernhard-Yd M. Thomas O M]n ~

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/M![{l Date' Signed Accompanying Personnel: ordan Approved by: M bcbsaP EM M

. F. Jape, Sect'lon Chief f -/ Date Signed Division of Reactor. Safety SUMMARY Scope: This routine, unannounced inspection was in the areas of examination of service water system monitoring- programs and scram discharge volume capability safety evaluation report complianc Results: No violations or deviations were identifie A "A889 g;ggg PDR (

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REPORT DETAILS Persons Contacted Licensee Employees

• P. W. Howe, Vice President, Brunswick Nuclear Plant

• C, R. Dietz, General Manager

• E. A. Bishop, Manager, Operations A. S. Hegler, Superintendent Operations

• E. R. Eckstein, Manager, Technical Support

• L. W. Wheatly, Engineering Supervisor (ISI)

• A. G. Cheatham, Manager E&RC

• K. E. Enzor, Director, Regulatory Compliance

• M. J. Pastva, Regulatory Compliance Other licensee employees contacted included engineers, technicians, operators, and office personne NRC Resident Inspectors

• H. Ruland

• L. W. Garner

• Attended exit interview Exit Interview The inspection scope and findings were summarized on September 4,1987, with those persons indicated in ?aragraph 1, above. The inspectors described. the areas inspected anc discussed in detail the inspection findings. No dissenting comments were received from the license i The plant management made a commitment concerning testing the Scram )

Discharge Volume capabilities as discussed in paragraph I The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection, l Licensee Action on Previous Enforcement Matters i This subject was not addressed in the inspectio . Unresolved Items Unresolved items were not identified during this inspectio i o

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' 5. ' Service Water System Monitoring' Program .This1 inspection. focused on. examination of the plant programs in place to monitor fouling and corrosion in the Service Water System. The system-engineer 'and engineering . supervisor provided names of groups and individuals that were involved in the monitoring effects for servic wate The zinspectors conducted interviews with the individuals from the

'different groups to determine what Service Water Monitoring Programs were in place to detect fouling or corrosion in the system which might effect system operability . In addition, a. partial system walkdown was performed with the system enginee The groups interviewed included those engaged in:

Biological Monitoring Chemical Monitoring and Additions Performance Group Testing Service Water Upgrade Program ASME Pump and Valve Testing-Operations A discussion of'the findings follow Service Water Upgrade In 1978 through 1980, Brunswick became aware of Service Water System degradation resulting from corrosion and fouling effect A plan

, outlined by TAR 78-092 was implemented to correct the degradation 1through flushing and pipe replacement and to monitor the service

. water system through program completio The program was divided into Phase I, II and II Phase I replaced small bore piping required to insure system operability. Phase II implemented a program for visual inspection of the accessible piping that had not yet been replaced. Phase III involved replacement of the large bore piping. Phase II and Phase III are ongoing efforts that are expected to be complete in the early 1990 Engineers responsible for Phase II and Phase III were interviewe The Phase II program examines the large bore piping, greater than 20 inches, that is accessible. The program examines only the identified problem areas or the original ~ concrete lined pipe. The inspection g method is visual inspection. Piping that has been replaced is not inspected unless it is identified as a problem area. An example of a problem area covered by the Phase II efforts is through-wall erosion l

of new pipe in high flow area '

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Phase III is the part of the upgrade program that replaces the i concrete lined large bore piping with the new copper-nickel alloy

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piping. No testing for system degradation is performed as part of Phase II The interviews revealed no permanent inspection effort is in place to j monitor for service water degradation caused by corrosion or fouling. 1 The Phase II inspection effort will expire with the completion of Phase III replacemen b. Biological Monitoring The group performing biological monitoring was interviewed to determine what programs, if any, were currently in place to monitor the service water for organisms which could cause fouling or corrosion. The group was used in the past to identify type of shellfish that was fouling service water pipin ,

The group stated that they perform no periodic monitoring for either the fouling organisms or their larva Any sampling performed ;

outside the scope of the environmental monitoring requirements is by request onl l c. Chemical Monitoring and Addition An interview was performed with the chemistry group to determine what programs were in place for monitoring service wate The chemistry monitors Service Water System chlorine levels about I five days per week. The inspectors reviewed procedure ERC3212 Revision 4, " Service Water Chlorine Sampling." The procedure specifies chlorine level in the service water system to be maintained at greater than 0.5 mg/1. No frequency of testing was specified in the procedure. Sample rate is determined by the groups superviso The chlorine levels are maintained by operations based upon the results of the chemistry testin Chemistry does not perform any other periodic testing that would help determine degradation of the service water syste d. Performance Group Testing The performance group was interviewed to determine if data gathered l' by the group was used for monitoring Service Water degradation or l

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l The performance group performs monitoring testing of many plant component Their emphasis, however, is on plant efficiency .

improvement No program in place trends the service water j components for degradatio _-_ _

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e. ASME Pump and Valve Program The. inspectors interviewed the individual who supervises the ASME pump and valve program to determine if testing- performed could be used to monitor the Service Water System degradation. Current trending of service water pump data is done with performance limits set to stay within ASME limits. The trending is not performed with the system values limiting, but with the component (i.e., the pumps)

values limiting for operability determination Service water degradation would not be noticed without major degradation having taken place. Any system blockage would have to be great enough to reduce system flow significantly before the program would pick it u Testing performed by this group is not well suited to discovering fouling or corrosion problems in the Service Water Syste f. Review of Technical Specification Surveillance Requirements The inspectors reviewed technical specification (TS) surveillance requirements to determine the extent to which related surveillance testing could be used to detect system or component foulin Subsection 4.7.1.1.a requires the verification at least once per 31 days that each residual heat removal (RHR) service water subsystem valve in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct positio Subsection 4.7.1.1.b requires verification at least once per 92 days that each RHR service water subsystem pump develops a pump differential pressure of at least 232 psid at a flow of 4000 gpm measured through the heat exchanger with a minimum suction pressure of 20 psi Subsection 4.7.1.2.a requires verification at least once per 31 days that each valve (manual, power operated or automatic) servicing safety related equipment that is not locked, sealed, or otherwise secured in position, is in its correct positio Subsection 4.7.1.2.b requires verification at least once per 18 months during shutdown that each automatic valve servicing safety related equipment actuates to its correct position on the appropriate ECCS actuation test signa The inspectors also reviewed the following periodic test (PT) and maintenance surveillance test (MST) procedures that are used to satisfy these surveillance requirements:

0-PT-8.1. RHR Service Water System Operability Test -

Loop B, Revision 16 l 0-PT-12.2D Number 4 Diesel Generator Monthly Load Test, l Revision 31 L i 1-PT-24.1-1 Service Water Pump and Discharge Valve l Operability Test, Revision 3  :

I 0-PT-24. Service Water Miscellaneous Service Water Valve l Operability Test, Revision S l

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0-MST-DG11R Diesel Generator 1 Loading Test, Revision 4 In addition to satisfying the TS surveillance requirements, the above pts are~also used to satisfy ASME Section XI pump and valve testing requirements. The inspectors concluded that of the surveillance .

requirements related to service water system operability, only those associated with the RHR service water subsystem (Subsection 4.7.1.1.b) will be useful for detecting foulin Cooling water. flow rates through the RHR heat exchangers are determined and recorded quarterly, and data can be trended to identify fouling that impedes flow. Although service water flow rates to the emergency diesel generator. (EDG) jacket water coolers are not recorded during i surveillance testing, the PT requires that a service water I differential pressure of approximately 10 psid be established across the jacket water coole In addition, jacket water temperature is one of the parameters monitored during EDG monthly testing. An-impedance of service water flow to the EDG jacket water cooler due to fouling can be detected by an increase in EDG jacket water temperatur Thus, the EDG monthly test provides measures for verifying adequate service water flow to the diesels. The other TS surveillance requirements can be satisfied as long as fouling is not so gross as to restrict valve movement or pump operation. Past histories of other operating plants have shown that flow alone may not be adequate for detecting inadequacies in the service water supplied heat exchanger J g. Review of Plant Operating Procedures {

j The inspectors reviewed the following Operating Procedures (0P) and an Abnormal Operating Procedure (A0P) for the service water system to determine if methods are specified for dealing with fouling related flow blockages within the system: 1 A0P-18.0, Nuclear Service Water System Failure, Rev. O, Unit 0 OP-21, Reactor Building Closed Cooling Water System Operating i Procedure, Rev. 9. Unit 1 OP-43, Service Water System Operating Procedure, Rev. 19, Unit 1 ,

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OP-43, Service Water System Operating Procedure, Rev. 55, Unit 2 OP-43.1, Chlorination System Operating Procedure, Rev. 12, )

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Review revealed that the ops focus on proper system alignment ( valves, pumps, electrical switchgear, etc.) and operation with i non-standard alignments. The A0P focuses on loss of pump and loss of header event None of the procedures specifically provide instructions for dealing with foulin j

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! Conclusions Brunswick responded to the problems encountered in 1978 through 1980 aggressively. The programs established for correcting the fouling -

and corrosion continue to receive attention and resources, but a 3 program to monitor the system for future degradation does not appear ,

to be formalized. Recent NUREGs addressing fouling and corrosion in l service water systems recommended periodic testing to detect system degradation. Conventional Technical Specification and ASME testing have not been - found adequate at other plants to provide early detection of system degradation. Brunswick does not, at this time, have a permanent program that monitors Service Water System performance in a way that would help prevent system deficiencies caused by fouling or blockag . Scram Discharge Volume Capability I An inspection was performed on Scram Discharge Volume (SDV) capability using Temporary Instruction (TI) 2515/9D to determine compliance with the Generic Safety Evaluation Report (SER) issued in December 1980 on the subjec The SER was written to address the long term fix for the SDV and Instrument Volume (IV) problems found as a result of the Browns Ferry Incident of June 28, 1980, in which control rods only partially inserted in response to a scram signa IE Bulletins 80-14 and 80-17 (with supplements) addressed the immediate and short term solutions to the proble The inspector performed a review of Technical Specifications, the plant FSAR, plant drawings, Alarm Response Procedures, Surveillance Instructions, and vendor drawing A walkdown of all four instrumented volumes and the north and south headers of each unit was performed. Control Room annunciators were verified against the Alann Response Procedures and position indication of the vent and drain val /es were verified. The findings are listed belo The findings are formatted using the items in Section 4 of TI 2515/9 Item 4.1 Scram Discharge Volume Header Size This item was evaluated in IE Bulletin 80-17, Supplement 1 (on page 21) and found to be adequate. The FSAR section 3.9.4.3.2 discusses the volume having adequate sizin Item 4.2 Automatic Scram on High SDV Level l The automatic scram is discussed in FSAR section 3.9.4.1. Technical Specifications sections 3.3.1, 4.3.1.1, 4.3.1.2, and 4.3.1.3 define the testing requirements to verify operability.

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c. Item 4.3 Instrument Taps Not on Connected Piping The SDV walkdown showed the physical configuration of the piping to have all instrument taps off the IV and not on connected pipin Response times of Magnetrol switches had not yet been measured to detennine if the problem described in Information Notice 87-17,

" Response Time of Scram Instrument Volume Level Detectors" exists at Brunswic d. Item 4.4 Detection of Water in the IV l

L The FSAR describes the alarm, rod block, and scram functions associated with the SD The Alarm Response Procedures and Surveillance Instructions include the actions and setpoints to be taken in the event of detection of water in the I e. Item 4.5 Vent and Drain Valve System Interfaces A review of the following drawings was performed:

" Control Rod Drive Hydrolics," D-2517, sheet 28, Rev.18

" Building NE CRW Drainage," D-2543, sheet 1A, Rev. 32 sheet 18, Rev. 32 These drawings show the overflow of the Reactor Building Equipment drain tank to be lower than the SDV by over 20 fee This would preclude backup into the SD f. Item 4.6 Vent and Drain Valves Close on Loss of Air A review was made of the following vendor prints:

0-FP-66112, Rev. A (vent valves)

0-FP-5537, Rev. A (drain valves)

These prints verified spring to open, air to clos g. Item 4.7 Operator Aid The following Alarm Response procedures were reviewed:

2-APP-A-05 1-1 " SOUTH SDV NOT DRND", Rev. 9 1-5 "DISCH V0L HI WTR LVL TRIP BYPASS", Rev. 11 1-6 "DISCH VOL HI WTR LVL CRD TRIP", Rev. 5 2-5 " NORTH SDV NOT DRND", Rev. 9 2-2 " ROD OUT BLOCK", Rev. O

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1-APP-A-05-1-1 " SOUTH SDV NOT DRND", Rev. 9 1-5 "DISCH V0L HI WTR LVL TRIP BYPASS", Rev. 11 1-6 "DISCH V0L HI WTR LVL CRD TRIP", Rev. 4 2-5 " NORTH SDV NOT DRND", Rev. 9 ,

2-2 " ROD OUT BLOCK", Rev. O t The FSAR was reviewe The setpoints listed in the Alarm Responses were:

- Alann - 45 gallons Rod Block - 72 gallons Scram - 104 gallons Under normal conditions the alann will come in first followed by the Rod Block, then the Scram, Item 4.8 Active Failure in Vent and Drain Valves Dual vents were verified through physical inspection, and through review of the following as built drawings:

0-2517 FSP-2626-C sheet 6 Dual drains were verified through review of the following drawings:

D-2517 D-25017 FSP-2627-C sheet 7 FSP-26027-0 sheet 7 1. Item 4.9 Periodic Testing of Vent and Drain Valves A review was performed of the following procedures:

IMST-RPS41R, Attachment 3, page 1, Rev. 3 2MST-RPS41R, Attachment 4, page 1, Rev. 2 There is a calibration interval of 550 days established in these procedure Item 4.10 Periodic Testing of Level Detection Instrumentation A review was performed of MST-RPS27Q, "RPS SCRAM DISCH V0L HI WTR LVL CHAN FUNCT TEST AND CHAN CAL", Rev. 3. Test interval is once per 92 day k. Item 4.11 Periodic Testing Operability of Entire System No integrated test or equivalent exists 3t this time.

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! 9 The management made a commitment at the exit interview to have a timetable for implementation of actions to satisfy this item within 30 day . Summary When Item 4.11 is ' resolved, the requirements of this TI will be complet The issue of magnetrol response time discussed in Information Notice 87-17 (see paragraph 6.c.) has not yet been responded to, but this does not impact TI 2515/9 ,

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