ML20076B656

ECCS Repts (F-47) TMI Action Plan Requirements,Boston Edison Co,Pilgram Nuclear Power Station, Technical Evaluation Rept

ML20076B656
Person / Time
Site:	Pilgrim
Issue date:	09/28/1982
From:	Ludington B, Overbeck G, Vosbury F FRANKLIN INSTITUTE
To:	Chow E NRC
Shared Package
ML20076B658	List: ML20076B656
References
CON-NRC-03-80-130, CON-NRC-3-80-130, RTR-NUREG-0737, RTR-NUREG-737, TASK-2.K.3.17, TASK-TM TER-C5506-210, NUDOCS 8210010071
Download: ML20076B656 (15)

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l TECHNICAL EVALUATION REPORT ECCS REPORTS (F-47)

TMI ACTION PLAN REQUIREMENTS BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION o

.g NRC DOCKET NO. 50-293 FRC PROJECT C5506 FRC ASSIGNMENT 7 NRC CONTRACT NO. NRC-03-81-130 FRC TASK 210 Freparedby . .F. W. Vosbury Franklin Researcn Center Author: G. J. Overbeck 20tt'and Race Streets B. W. Ludingeon Phliadelphia, PA 19103 FRC Group Leader: G. J. Overbeck Prepared for .

Nuclear Regulatory Commission Lead NRC Engineer: E. Chow Washington, D.C. 20555 September 28, 1982 This report was prepared as an account of work sponsored by an agency of the United States Govemment. Neither the United States Govemment nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legst liability or responsibility forany third party's use, or the results of such use, of any information, appa-ratus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights.

Prepared by: Reviewed by: Approved by:

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, _ . .c-CONTENTS Section Title Page

. 1 INTRODUCTION . . . . . . . . . . . . . 1 1.1 Purpose of Review . . . . . . . . . . . 1 1.2 Generic Background. . . . . . . . . . . 1 1.3 Plant-Specific Background . . . . . . . . . 2 2 REVIBf CRITERIA. . . . . . . . . . . . . 3 3 TECHNICAL EVALUATION . .. . . . . . . . . . 4 1.1 ~1tev'iew of completeness of the Licensee's Report . . . 4 3.2 Comparison of ECC System Outages with Those of Other Plants . . . . . . . . . . 5 3.3 Review of Proposed Changes to Improve the Availability of ECC Equipment . . . . . . . . 8 4 CONCLUSIONS. . . . . . . . . . . . . . 9 5 REFERENCES . . . . . . . . . . . . . . IO l

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!?ORENORD l

This hchnical. Evaluation Repo::t was prepared by Franklin Research Center under a contract with the U.S. Nuclear Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NRC operating reactor licensing actions. The technical evaluation was conducted in accordance with criteria established by the NRC.

Mr. G. J. Overbeck, Mr. F. W. Vosbury, and Mr. B. W. Ludington contributed to the technical preparation of this report through a subcontract with WESTEC Services, Inc.

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1. INTRODUCTION 1.1 PURPOSE OF REVIEW This technical evaluation report (TER) documents an independent review of the outages of the emergency core cooling (ECC) systems at Boston Edison Company's (BEC) Pilgrim Nuclear Power Station. The purpose of this evaluation is to determine if the Licensee has submitted a report that is complete and satisfies the requirements of TMI Action Item II.K.3.17, " Report on Outages of Emergency Core-Cooling Systems Licensee Report and Proposed Technical Specification Changes."

1.2 GENERIC BACKGROUND

' Tbilowing the Three Mile Dland Unit 2 accident, the Bulletins and Orders

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Task Force reviewed nuclear steam supply system (NSSS) vendors' small break loss-of-coolant accident (IOCA) analyses to ensure that an adequate basis existed for develcping guidelines for small break IOCA emergency procedures.

During these reviews, a concern developed about the assumption of the worst sineyle failure. Typically, the small break IOCA analysis for boiling water reactors (BWRs) assumed a loss of the high pressure coolant injection (HPCI) system as the worst single failure. However, the technical specifications permitted plant operation for substantial periods with the HPCI system out of service with no limit on the accumulated outage time. There is concern not only about the HPCI system, but also about all ECC systems for which substantial outages might occur within the limits of the present technical specification. 'Dierefore, to ensure that the small break IOCA analyses are ,

consistent with the actual plant response, the Bulletin and Orders Task Pbrew re-nded in NUREG-0626 [1], " Generic Evaluation of Feedwater Transients and Small Break Ioss-of-Coolant Accidents in GE-Designed Operating Plants and _

Near-Tern Operating License Applications," that licensees of General Electric (GE)-designed NSSSs do the following:

" Submit a report detailing outage dates and lorsths of the outages for all ECC systems. The report should also include the cause of the outage (e.g., controller failure or spurious isolation) . The outage data for uklin Research Center

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l TER-C5506-210 l-ECC components should include all outages for the last five years of operation. The end result should be. the quantification of historical unreliability due to test and maintenance outages. This will establish if a need exists for cumulative outage requirements in technical specifications."

Later, the recommendation was incorporated,into NUREG-0660 [2], "NBC Action Plan Developed as a Result of the M-2 Accident," for all light water reactor plants as TMI Action Item II.E.3.17. In NUREG-0737 [3], "Clarifica-tion of TMI Action Plan Requirements," the NRC staff added a' requirement that licensees propose changes that will improve and control availability of ECC m

systems and components. In addition, the contents of the reports to be submitted by the licensees were further clarified as follows:

"The report should contain (1) outage dates and duration of outagest (2) cause of the outage; (3) ECC systems or components involved in the outages and (4) corrective action taken."

1.3 PLANT-SPECIFIC BACEGROUND On January 22, 1981 [4], BEC submitted a report in response to NUREG-0737, Item II.E.3.17, " Report on Outages of Energency Core-Cooling Systems Licensee Report and Proposed Technical Specification Changes." The report submitted by BEC covered the period from January 1975 to De$ ember 1979 for- Pilgrim Nuclear Power Station. BBC did not include any recommendations in its report to improve the availability of ECC system components.

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2. REVIBt CRITERIA The Licensee's response to NUREG-0737, Item II.K.3.17, was evaluated against criteria provided by the NRC in a letter dated July 21, 1981 (5].

outlining Tentative Work Assignnent F. Provided as review criteria in Reference the NRC stated that the Licensee's responsc should contain the following eformation:

1. A report detailing outage dates, causes of outages, and lengths of outages foe all ECC systems for the last 5 years of operation. This report was to include the ECC systems or components involved and corrective actions taken. Test and maintenance outages were to be included.

2. A quantification of the historical unavailability of the ZCC systems and components due to test and maintenance outages.

3. Proposed changes to improve the availability of ECC systems, if

, necessary.

The t,ype of information required to satisfy the review criteria was clarified by the NRC on August 12, 1981 (6]. Auxiliary systems such as component cooling water and plant service water systems were not to be considered in deter =4ains the unavailability of ECC systems. Only the outages of the diesel generators were to be included along with the primary ECC system outages. Finally, the "last five years of operation" was to be loosely interpreted as a continuous 5-year period of recent operation.

On July 26, 1982 (7], the NRC further clarified that the purpose of the review was to identify those licensees that have experienced higher ECC system outages than other licensees with similar NSSSs. 'Jhe need for improved

• reliability of diesel generators is under review by the NRC. A Diesel Generator Interim Beliability Program has been proposed to effect improved performance at operating plants. As a consequence, a comparison of diesel generator outage information within this review is not required.

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3. TEdHNICAL EVALUATION 3.1 REVIDF OF COMPLETENESS OF THE LINMPP'S REPORT The BCC systems at BEC's Pilgrim Nuclear Power Station consist of the following four separate systems:

o high pressure coolant injection (HPCI) system o

automatic depressurization system (ADS) o core spray (CS) system o

low pressure coolant injection (LPCI) system.

In Reference 4, BEC also included the following systems and components that support the ECC systems in carrying out their design functions under various accident conditions o RER system o saltywater service system o

reactor building closed cooling water system -

o standoy diesel generators. ~.

'In addition to outage data on four ECC systeac and the support systems ,

BEC also included data on the reactor coolant isolation cooling (RCIC) system.

The RCIC system is a non-safety-related high pressure system available for high pressure injection.

Although the BCIC system.nitigates the consequences of a loss of normal feedwater, this system is not required to prevent core damage and therefore is not considered to be an ECC system.

l-In establishing the type of events that constitute an ECC system outage ,

hI BBC considered an outage to be any event that results in a Limited Conditio n  ;

cf Operation (ICD) as defined by the technical specifications. Se BCC system

outage data were estracted from the following plant records:

o Licensee Event Reports o maintenance requests and work orders >=-

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For each ECC system outage event, BEC provided the outage dates, the duration, and the cause, plus sufficient description to discern the corrective action taken. Maintenance and surveillance testing activities were included in the ECC system outage data, unless these activities were performed during a shutdown condition in which the affected ECC system was not required to be operational. The results of BEC's review were provided for the period from January 1975 to December 1979 for Pilgrim Nuclear Power Station.

Based on the preceding discussion, it is concluded that BEC has submitted a report which fulfills the requirements of review criterion 1 without exception.

3.2 COMPARISON OF ECC SYSTPM OUTAGES WITH THOSE OF OTHER PLANTS The outages of ECC systems can be categorised as (1) unplanned outages due to equipment failure or (2) planned outages due to surveillance testing or preventive maintenance. Unplanned outages are reportable as Licensee Event Reports (LERs) under the technical specifications. Planned outages for periodic maintenance and testing are not reportable as LERs. The technical specifications identify the type and quantity of ECC equipment required as well as the maximum allowable outage times. If an outage exceeds the maximum allowable time, then the plant operating mode is altered to a lower status consistent with the available ECC system components still operational. The purpose of the technical specification maximum allowable outage times is to prevent extended plant operation without sufficient ECC system protection.

The maximum allowable outage time, specified per event, tends to limit the unavailability of an ECC system. However, there is no cumulative outage time limitation to prevent repeated planned and unplanned outages from accumulating extensive ECC system downtime.

Unavailability, as defined in general terms in WASE-1400 [8], is the probability of a system being in a failed state when required. However, for this review, a detailed unavailability analysis was not required. , Instead, a l bu Franidin Reseech Center

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f preliminary estimate of the unavailability of an ECC system was made by calcu-lating the ratio of the ECC system downtime to the number of days that. the plant was in operation during the last 5 years. To simplify the tabulation of operating time, only the period when the plant was in operational Mode 1 was considered.

This simplifying assumption is reasonable given that the period of time that a plant is starting up, shutting down, and cooling down is small compared to the i p,

. time it is operating at power. In addition, an ECC system was considered down Qg whenever an ECC system compca%t was unavailable due to any cause.

It shculd be noted that the ratio calculated in this manner is not a true measure of the ECC system unavailability, since outage events are included that appear to compromise system performance when, in fact, partial or full function of the system would be expected. Full function of an ECC system would be expected if.the design m =hi11ty of the system exceeded the capacity required for the system to fulfill its safety function. For example, if an ECC system consisting of two loops with multiple pumps in each loop is designed so that only one pump in each loop is required to satisfy core cooling requirements, then an outage of a single pump would not prevent the system from performing its safety function. In addition, the actual ECC system unavailability is a function of planned and unplanned outages of essential support systems as well

&J of planned and unplanned outages of primary ECC system components. In accordance with the clarification discussed in Section 2, only the effects of outages associated with primary ECC system components and emergency diesel generators are considered in this review. The inclusion of all outage events assumed to be true ECC system outages tends to overest mate the unavailability, while the exclusion of support system outages tends to underestimate the unavailability, of ECC systems and components. Only a detailed analysis of each ECC system for each plant could improve the confidence in the calculated.

result. Such an analysis is beyond the intended scope of this report.

The planned and unplanned (forced) outage times for the four ECC systems (HPCI, ADS, CS, and LPCI) and the standby diesel generators were identified from the outage information in Reference 4 and are shown in number of days and as percentage of plant operating time per year in Table 1 for the Pilgrim i

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TER-C5506-210 j Nuclear Power Station. Outages that occurred during nonoperational periods were eliminated as well as those caused by failures or test and maintenance of support systems. Data on plant operating conditions were obtained from the annual reports, "teaclear Power Plant Operating Experience" [9-12), and from monthly reports, " Licensed Operating Beactors Status Summary Reports" 113].

The remaining outages were segregated into planced and unplanned outages based on an interpretation of BBC's description of the causes. H e outage periods for each category were calculated by summing the individual outage durations.

Included for informational purposes are the aCIC system outage data.

Observed outage times of various ECC systems at the Pilgrim Nuclear Power Station were compared with those of other BNRs. Based on this comparison, it was concluded that the historical unavailability of the ADS, CS, HPCI, and LPCI systems has been consistent with the performance of those systems throughout the industry. Me observed unavailability was less than the industrial mean for the ADS and less than about one standard deviation above the industrial mean for CS, HPCI, and LPCI systems, assuming that the underlying unavailability is' distributed lognormally. 24 outage times were also consistent with existing technical specifications. The outages of the standby diesel generators and the acIC system were not included in this comparison.

3.3 REVIN1 OF PROPOSED CHANGES TO IMPROVE THE AVAILABILITY OF ECC EQUIPMENT In Reference 4, BEC did not include any recommendations to improve the availability of ECC systems and components.-

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4. CONCI.USIONS Boston Edison Company (BEC) has submitted a report for Pilgrim Nuclear

. Power Station which contains (1) outage dates and duration of outages, (2) causes of the outages, (3) ECC systems or components involved in the outages, and (4) corrective actions taken. It is concluded that' BEC has fulfilled the requirements of NUREG-0737, Item II.K.3.17, and that changes to improve the availability of ECC systems are not required.

In addition, the historical unavailability of the ADS, CS, HPCI, and LPCI systems has been consistent with the performance of those systems th2oughout the industry. The observed unavailability was less than the industrial mean for the ADS and less than the one standard deviation above the industrial mean

- forW CE, EPCI, ^3nd LPCI systsen. ' Ste outages were also consistent with existing technical specifications.

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5. REFERENCES

1. NUREG-0626

" Generic Evaluation of Feedwater Transients and Small Break Ioss-of-Coolant Accidents in GE-Designed Operating Plants and Near-Tera Operating License Applications" NBC, January 1980 -

2. NUREG-C660 "NRC Action Plan Developed as a Result of the 1MI-2 Accident" NRC, March 1980 3$ NUREG-0737

" Clarification of 1MI Action Plan Requirements" NBC, October 1980

4. A. V. Norisi (BEC)

Letter to Director of Licensing, D. G. Eisenhut.

Eutrjects Ad31tional Information in 1tesponse to EUREG-0737 January 22, 1981

5. J. N. Donchew, Jr. (NBC)

Letter to Dr. S. P. Carfagno (FRC) . Subject Contract No.

NBC-03-81-13 0, Tentative Assignment F July 21, 1981 *

6. NBC Meeting between NRC and FRC.

Subject:

C5506 Tentative Work Assignment F, Operating Reactor PORV and ECCS Outage Reports August 12, 1981

7. NRC Meeting beteeen NRC and FRC.

Subject:

Resolution of Review Criteria and Scope of Work July 26, 1982 8 NASH 1400 -

"Beector Safety Study" NBC, October 1975

9. NUREG-0366

.' "lanclear Power Plant Operating Experience 1976" NBC, December 1977

10. NUREG-0483 "Insclear Power Plant Operating Experience 1977"

{ NBC, Ptbruary 1979

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11. NUREG-0618

• thclear Power Plant Operating Experience 1978" NBC, December 1979

12. NURI./CR-1496

, "lktclear Power Plant Operating Experience 1979" NRC, May 1981

. 13. NU1URG-0020

" Licensed Operating Reactors Status Summary Report" Volume 4, Noe.1 through 12, and Volume 5, No.1 N10, December 1980 through January 1981 1

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