ML20151E063
| ML20151E063 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/11/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mcdonald R ALABAMA POWER CO. |
| References | |
| NUDOCS 8807250353 | |
| Download: ML20151E063 (33) | |
See also: IR 05000348/1988005
Text
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July 11, 1988
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Docket Nos. .50-348, 50-364
' License'Nos. NPF-2 and NPF-8
,
Alabama Power Company
ATTN: Mr. R. P. Mcdonald
Executive Vice President
P.O. Box 2641
Birmingham, AL 35291-0400
Gentlemen:-
SUBJECT: MEETING SUMMARY OF ENFORCEMENT CONFERENCE - NRC INSPECTION REPORT.
NOS. 50-348/88-05 AND 50-364/88-05
This . letter refers to the-Enforcement Conference held at our request 'at the
Region II Office on .May 25, 1988.
- This meeting concerned activities
authorized by NRC Operating License Nos. NPF-2 and NPF-8 for Farley Units 1
and 2. .The meeting was held to discuss concerns documented in NRC Inspection
Report Nos. 50-348/88-05 and 364/88-05 involvir,g the accumulation of hydrogen
gas in the residual heat removal system crossover piping to the high head safety
injection (HHSI) pum,) and in the HHSI pump suction piping, and the resulting
impact on the operability of the HHSI pumps.
Enclosed is a meeting summary including a list of attendees and a copy of the
handouts provided to the NRC at the meeting.
In accordance with Section 2.790 -of NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its
enclosures wil.1 be placed in the NRC Public Document Room.
Should you have any questions concerning this matter, we will be pleased to
-discuss them.
'
Sincerely,
CTM'J. SICNED Bh
J. IdLSOll GitACE
,
J. Nelson Grace
Regional Administrator
Enclosures:
1.
Meeting Sumary
2.
List of Attendees
.3.
Licensee Meeting Notes
cc w/encls: (See page 2)
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Alabama Power Company
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July 11, 1988
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cc.w/encls:
8. M. Guthrie, Executive Vice President
J. .D. Woodard, Vice President
W. G. Hairston,-III, Senior Vice President
J. W. Gowan, Manager
Safety Audit
and Engineering Review
S. Fuher, Supervisor - Safety Audit
and Engineering Review
D. N. Morey, General Manager -
Farley Nuclear Plant
'bec w/encis:
-
NRC Resident Inspector
DRS Technical Assistant
E. Reeves, Project Manager, NRR
Document Control Desk
State of Alabama
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ENCLOSCRE 1
MEETING SUWARY
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On-May 25, 1988, representatives of Alabama Power Company (APCo) attended an
Enforcement Conference at the request of the NRC in the NRC Region II Office
in Atlanta, Georgia.
The meeting was held to discuss NRC concerns pertaining
6
.to a.- February 1988 event where a significant amount of hydrogen gas was
' discovered in the -crossover piping (from the residual heat removal system (RHR
to the high head safety injection HHSI) pumps (charging pumps) in Unit 1 and
Unit 2 of the Farley Nuclear Plant.
LER 88-006-01 was submitted by the
licensee on April 25, 1988 discussing the event.
Previous NRC review of this
event and details of the event are documented in NRC Inspection Report Nos.
348,364/88-05.
Individuals attending the meeting are listed in Enclosure 2.
The NRC -Region II Deputy Regional Administrator opened the meeting by
reviewing the NRC concerns pertaining to the accumulation of hydrogen gas in
the RHR to HHSI pump crossover piping and the HHSI pump suction piping; and,
the resulting impact on the operability of the HHSI pumps.
The Senior Vice President then gave an opening statement for APCo.
He
requested that the NRC consider the time frarre associated with tne pre-
operational testing and HHSI pump shaft failure.
He stated that the scope
of the hydrogen formation problem had not been recognized early on and
maintained that calculational techniques available at that time were unable to
predict the subsequent events.
APCo representatives then provided a presentation discussing those topics
indicated in the attached handout which was distributed to meeting attendees
by APCo (Enclosure 3). Highlights of this presentation are provided below:
'
A system description was provided.
The history of previous HHSI pump failures
(including the 1980 pump shaft failure), testing, and hydrogen gas fonnation
indications and a sequence of events for the February event were discussed.
The licensee noted that the eventual redesign of the charging pump shaft
corrected the shaft failure problem.
The licensee's presentation emphasized
-management's concern with the shaft failure, noting occurrences at other
facilities, and the licensee indicated that the shaft failure problem received
significant management attention.
The licensee discussed the likelihood of pump failure based on the amount of
hydrogen gas entrapped in the crossover piping and amount of gas formed during
normal pump operation.
The licensee stated that a value of five percent or
less by volume of gas entrained in the fluid nas a negligible effect on the
pumps'. mechanical performance, with no long or short term effects evident.
Values of greater than five percent added to the propensity for catastrophic
failure.
Testing had been performed to establish a maximum amount of
allowable hydrogen to assure that pump damage did not occur. The licensee had
established a venting program to limit hydrogen to less than this maximum
amount (6.0 cubic feet) which should limit the void fraction to less than
5 percent as an interim measure.
Details of plant modifications to provide
a
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Enclosure 1
2-
venting for the pump suctions and a loop seal to prevent hydrogen formation in
the crossover piping were presented. -The modifications have been completed
for Unit I and will be installed on Unit 2 during the next refueling outage.
The effect of hydrogen on the pumps was discussed and additional information
was presented on the effects of the loss of the HHS1 during a large and a
small break loss' of coolant accident.
The licensee maintained that the
ability to safely bring the plant to a safe shutdown condition was
insignificantly effected.
The licensee's presentation on the _ effect of the hydrogen gas on the charging
pump provided no conclusive evidence that the pumps would not fail due to the
flow of gas which would have occurred when the pumps were started during the
recirculation phase.
The licensee did state that the "charging pump may
survive" the surge of gas during recirculation.
In addition, the NRC pointed
out that Operating Change Request 2-3514, dated November 6,
1979, had
documented the potential for the problem and had recommended further review.
The licensee -provided no new information to indicate that reviews of the
accumuation of hydrogen gas in the crossover piping had been conducted prior
to the February 1988 event.
The NRC is presently considering enforcement action on this issue.
This
meeting served to enhance the NRC's understanding of the event and corrective
actions taken to assure operability of the HHS! pumps.
J
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ENCLOSURE 2
LIST OF ATTENDEES
Alabama Power Company Representatives:
S. Fulmer.-Supervisor Safety Audit and Engineering Review Group-
^
W. Hairston, III, Senior Vice President - Nuclear Support
R. Mcdonald, Executive Vice President - Nuclear Operations
B. McKinney,-Manager, Licensing
D. Morey, General Manager - Farley Nuclear Plant (FNP)
J. Woodard, Vice President, FNP
,
Vendor Representatives:
,
J. Cononie, Plant De:,ign Group Supervisor, Bechtel
C. Eicheldinger, Project Manager, FNP, Westinghouse
W. Engel, Mechanical / Process Group Supervisor, Bechtel
J. Grigsby, Nuclear Safety Engineer, Westinghouse
M. Hitchler, Manager, Plant Analysis, Westinghouse
D. Kitch, Principal Engineer, Westinghouse
J. Love, Assistant Project Engineer, Bechtel
R. Moyee, Fluid Systems, Westinghouse
B. McIntyre, Manager, Product Licensing, Westinghouse
S. Prokopovich, Systems Engineer, Westinghouse
NRC Representatives:
E. Adensam, Proj9ct Director, Directorate II-1, Division of Reactor
Projects I/II, Office of Nuclear Reactor Regulation (NRR)
B. Breslau, Reactor Inspector, Operational Programs Section (OPS), Division of
'
ReactorSafety(DRS)
H. Dance, Chief, Project.s Section IB, Division of Reactor Projects (DRP)
0. DeMiranda, Allegation Coordinator, Enforcement and Investigation Coordination Staff
(EICS)
M. Ernst Deputy Regional Administrator
A. Gibson, Diractor, Division of Reactor Safety
R. Goddard, Regional Counsel
G. Jenkins, Director, EICS
C. Julian, Chief, Operatiuns Branch, DRS
B. Miller, Jr., NRC Resident Inspector - FNP, DRP
L. Modenos, Project Engineer, Projects Section 18, DRP
T. O'Connor, Reactor Engineer, OPS, DRS
E. Reeves, Senior Project Manager, NRR
L. Reyes, Director, Division of Reactor Projects
L. Slack, Assistant, EICS
D. Starkey, Reactor Engineer, OPS. DRS
0. Verre111, Chief, Reactor Projects Branch No. 1 DRP
L. Watson, Reactor Engineer, CPS, DRS
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ENCLOSURE 3
LICENSEE MEETING NOTES
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Agenda for May 25, 1988
APCo - NRC Rydrogen Accumulation Meeting
1.
Introduction and Overview
2.
System Description
3.
History and Sequence of Events
4.
Engineering Support Sequence of Events
5.
Basis for Short Term Corrective Action
6.
Postulated Consequences of Gas Accumulation
7.
Conclusion
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J.M. FARLEY NUCLEAR PLANT-
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~ PUMP SUCTION
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8811A
8706A
D
8817A
RHR PUMP
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HCV603A
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8809A
PUMP SUCTION
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88118
8706P
8812e
B
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DISCHARGE '
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CHARGING PUMPS
LCVi15C
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8132A
LCV1150
LCv115E
81328
81308
[B
N_.
813M
8131A
8133B
81318
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LCVl150
DISCHARCE '
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SUMMARY OF ISSUES
H2 GAS MAY ACCUMULATE IN TWO LOCATIONS
1)
PUMP 2B SUCTION PIPING
2)
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EVALUATION OF MECHANISM
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HYDR 0 GEN OVERPRESSURE IN VCT
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VAPOR PRESSURE = PRESSURE VCT
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TRADITIONAL CALCULATIONAL TECHNIQUES
UNABLE TO PREDICT THE EVENT
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LOCAL EFFECTS
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PIPING LAYOUT
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FARLEY I HORIZONTAL PIPING ELEVATIONS
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FARLEY 2 HORIZONTAL PIPING ELEVATIONS
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INITIAL RECOMMENDATIONS
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INITIATE A VENTING PROGRAM TO LIMIT H2
GAS IN RHR TO CCP CROSS-TIE TO LESS THAN
6.0 FT3
PRECLUDES CATASTROPHIC FAILURE
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EXPECTED TO LIMIT VOID FRACTION TO
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BETWEEN 5% - 10%
UNCERTAINTY OF STRATIFIED 2-PHASE
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FLOW ACCELERATION
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CCP B & C SHOULD BE THE OPERABLE PUMPS
MINIMIZE ACCUMULATION IN RHR TO CCP
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CROSS-TIE
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CCP 2B SHOULD PROVIDE NORMAL CHARGING
DUTY
PREVENTS ACCUMULATION IN 2B SUCTION
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PIPING
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EVALUATE A VENTING PROGRAM
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PLANT MODIFICATIONS
1)
LOOP SEAL IN "A" PUMP SUCTION PIPING
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UNIT 1 INSTALLED
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UNIT 2 NEXT REFUELING OUTAGE
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2)
SAMPLING VENTS IN EACH CCP SUCTION
PIPING
UNIT 1 INSTALLED
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UNIT 2 NEXT REFUELING OUTAGE
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3)
UNIT 1 VENTING (WITH LOOP SEAL)
LOOP SEAL APPEARS TO BE EFFECTIVE
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ADDITIONAL TESTING
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LOOP SEAL IN "A" PUMP SUCTION PIPING
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TEST VERIFICATION
1)
OBJECTIVE - DETERMINE IF THERE IS AN
ALLOWABLE VOLUME OF H2 GAS, WHICH IF
ACCUMULATED IN THE RHR TO CCP CROSS-TIE
WILL LIMIT PUMP VOID FRACTIONS TO LESS
THAN 5%
2)
TEST FACILITY
3)
CONCLUSION:
6 FT3 WILL LIMIT PUMP
VOID FRACTION TO LESS THAN 5%
(I.E.,
NO
POTENTIAL FOR PUMP DAMAGE
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HDLDING
VATER SUF2 FACE
(375 GALLONS)
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AIR INJECTION TAP
12 INCH
. LEVEL HETER
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4 INCH
+ DIRECTION DF FLOV
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CLEAR PVC PIPE
--
VUID
METER
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SECTION
2 INCH
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PVC PIPE
FLOV
FLOV
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CONT
THETER
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4 INCH PVC PIPE J
4 INCH
PUHP
PVC PIPE
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RHR/ CHARGING PUMP -TIE ~ LINE
VAPOR
ENTRAINMENT TEST
@
TEST
SCHEMATIC
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EFFECT OF GAS ON CCPS
1. LONG TERM FAILURE IS DUE TO SHAFT CRACK
PROPAGATION.
2. SHORT TERM FAILURE DUE TO LOSS OF LUBRICATION.
3.<5%GASVOLUNEHASNEGLIGIBLEEFFECTON
MECHANICAL PERFORMANCE
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BASED ON CONSERVATIVE INDUSTRY PRACTICE
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NO LONG OR SHORT TERM EFFECTS
4. > 5% (VITH ADEQUATE LUBRICATION)
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LONG TERM ISSUE
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UNKNOVN SHORT TERM EFFECTS
5. > 5% (VITHOUT ADEOUATE LUBRICATION)
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LONG AND SHORT TERM ISSUE
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ALTHOUGH THE PUMP MAY ONLY RUN FOR A SHORT
PERIOD OF TIME VITH NO VATER LUBRICATION,
SMALL AMOUNTS OF WATER VILL EXTEND THE TIME
CONSIDERABLY.
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ENGINEERING EVALUATION OF EFFECT
OF
GAS ON TRAIN A RECIRCULATION PHASE
THE CHARGING PUMP MAY SURVIVE THE FLOV 0F GAS
DURING RECIRdVLATION (N0 SHORT TERM FAILURE)
PUMP A IS THE PRIMARY A TRAIN DESIGNATED PUMP
LAYOUT V00LD PERMIT SOME MIXING OF H
GAS AND
2
WATER PRIOR TO REACHING PUMP SUCTION
1A AND 2A PIPING ARE SELF VENTING
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SEQUENCE OF EVENTS (A PUMP RUNNING)
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INITIAL CONDITIONS
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RHR PUMPS STARTED
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H, GAS COMPRESSION / ACCELERATION
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PARTIAL MIXING AT RVST/RHR TEE
s
H
SLUG ENTERS PUMP AND DEVELOPED HEAD FALLS
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2
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SUCTION PIPING REFLOODED AFTER A PERIOD OF
TIME
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RHR DISCHARGE PUMP ASSISTS IN RE-PRIMING
CHARGING PUMP
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IF PUMP HAS NOT TRIPPED OUT, HEAD CAN
REC 0VER AND PUMP MAY CONTINUE TO PUMP AGAIN
PROVIDING LUBRICATION.
H
GAS EVENTUALLY
2
PURGED.
CONCLUSION:
THE PUMP MAY SURVIVE THE
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INITIAL EVENT WITHOUT CATASTROPHIC (SHORT
TERM) FAILURE.
HHSI RECIRCULATION IS A SHORT TERM
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OPERATION.
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KEY POINTS
1. TRADITIONAL CALCULATIONAL TECHNIQUES UNABLE TO
PREDICT THE MECHANISM.
2. < 5% VOID NO EFFECT ON PUMP.
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3. >> 5% UNKNOVN EFFECTS ON LONG TERM OPERATION.
4. SHORT TERM FAILURE IS DUE TO INADEQUATE
LUBRICATION.
3
5.
< 6 FT
IN RHR TO CCP A HEADER VILL PREVENT BOTH
LONG AND SHORT TERM FAILURE.
6. THE CHARGING PUMP MAY SURVIVE SURGE OF GAS
DURING RECIRCULATION.
(N0 SHORT TERM FAILURE)
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RETROSPECTIVE PLANT RESPONSE TO POTENTIAL INCIDENTS
INTRODUCTION
THE CHARGING PUMP MAY NOT' FAIL DUE TO THE
PASSAGE OF HYDROGEN.
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THIS ASSESSHENT LOOKS AT VHAT HAPPENS IF A PUMP
DID FAIL.
THE PUMPS VHICH ARE POSTULATED TO BE AFFECTED
ARE:
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2B DUE TO ACCUMULATION IN SUCTION -
INJECTION PHASE ISSUE
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"A-TRAIN" DUE TO ACCUMULATION IN THE RHR
CROSS-TIE - RECIRCULATION
PHASE ISSUE.
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A. INJECTION PHASE ISSUE
1. H2 IS NOT EXPECTED TO ACCUMULATE IN DAMAGING
AMOUNTS IN THE 2B CHARGING PUMP SUCTION.
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2B, IF OPERABLE, IS KEPT RUNNING WHICH SWEEPS
THE H2 FROM THE SYSTEM.
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THE TIME WHEN 2B IS OPERABLE BUT IDLE IS
INFREQUENT AND OF SHORT DURATION.
LITTLE OR
NO GAS ACCUMULATION IS EXPECTED.
0
2B IS VENTED PRIOR TO RETURNING FROM IDLE TO
CHARGING DUTY.
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RECIRCULATION PHASE FAILURE
THE ACCUMULATION OF GAS IN THE "TRAIN A" RHR TO
CHARGING CROSS-TIE COULD 'ONLY AFFECT THE "TRAIN
A" CHARGING PUMP.
TWO TRAINS OF ECCS ARE OPERABLE, THE DESIGN
BASIS ASSUMES ONLY ONE TRAIN OPERATES.
THE RANDOM FAILURE OF AN ECCS TRAIN (LOSS OF
POVER, RHR PUMP FAILS TO RESTART) WOULD AFFECT
BOTH TRAINS EQUALLY.
IT IS LIKELY THAT THE "B TRAIN" V0ULD BE
AVAILABLE, THUS HEETING THE DESIGN BASIS.
ONLY THE FAILURE OF "TRAIN A" DUE TO GAS, AND A
RANDOM FAILURE IN "TRAIN B" VILL LEAVE NO BHSI
RECIRCULATION CAPABILITY.
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B. RECIRCULATION PHASE ISSUE
1. HYDROGEN ACCUMULATION IN THE RHR TO CHARGING
CROSS-TIE DOES NOT AFFECT THE MITIGATION OF A
LBLOCA AND HAS ONLY A SMALL AFFECT ON THE
MITIGATION OF A SBLOCA.
0
LBLOCA DEPRESSURIZES THE RCS TO LHSI CUT-IN
PRIOR TO RECIRCULATION.
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RELIABILITY OF THE SBLOCA MITIGATION IS
REDUCED SLIGHTLY.
IF OPERATORS TAKE ACTION, THE RELIABILITY
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OF MITIGATING A SBLOCA IS REDUCED BY LESS
THAN ONE PERCENT.
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2. ACCIDENT EVENTS ARE NOT EXPECTED TO BE A RISK TO
THE PUBLIC.
(A) LARGE BREAK LOCA:
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THE RCS DEPRESSURIZES TO LHSI CUT-IN PRIOR TO
RECIRCULATION
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(B)
SMALL BREAK LOCA:
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E0PS (ES-1.2) WILL START TO
COOLDOWN/DEPRESSURIZE THE RCS
DURING THE ECCS INJECTION PHASE.
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- CHARGING /HHSI MAY BE THROTTLED OR
TERMINATED DURING THE C00LDOWN.
- RCS DEPRESSURIZATION TO ACCUMULATORS
AND THEN LHSI CUT-IN IS EXPECTED PRIOR TO
RECIRCULATION FOR MOST BREAK SIZES.
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IF NOT, LOSS OF ALL HHSI CASE STUDIED
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DURING WOG ERG DEVELOPMENT WILL BOUND THE
LOSS 0F HHSI RECIRCULATION.
RCS COOLDOWN/DEPRESSURIZATION WILL
CONTINUE TO ACCUMULATOR AND THEN LHSI
CUT-IN.
NO DEGRADED CORE CONDITION IS
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EXPECTED.
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RETROSPECTIVE PLANT RESPONSE TO POTENTIAL INCIDENTS
CONCLUSIONS
INJECTION PHASE:
o
NO DAMAGE TO THE ECCS IS EXPECTED SINCE HYDROGEN
DID NOT ACCUMULATE IN DAMAGING AMOUNTS IN CHARGING
SUCTION.
RECIRCULATION PHASE:
o
RCS WILL ALLOW RECIRCULATION ON THE LHSI PUMPS FOR
MOST LOCA PRIOR TO RECIRCULATION.
o
LOSS OF HHSI RECIRCULATIO., EXPECTED TO BE HANDLED
BY E0Ps WITHOUT ALLOWING DEGRADED CORE CONDITIONS
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FARLEY CHARGING PUMP RELIABILITY ASSESSMENT
Results:
Farley experience is equal to or better than industry record.
No cannon-cause failure modes seen at Farley.
Leading Pump Failure Causes
- Shaft Failures *
- Seal Leaks
- Vibration
- Lubrication cooling / pump problems
- Bearing Wear
- Motor / Gear problems
Experience in All Years
Industry
Farley
Failure rate
1.3(-4)/hr(NPRDS)
1.3 (-4; (NPRDS *)
- 5 failures not in NPRDS added
Experience since 1981
Industry
Farley
Failure rate
1.6 (-4)/hr
1.1 (-4)/hr (NPRDS)
Failure probability
0.0033
0.0021
(24-hrmission)
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PROBABILISTIC ASSESSMENT OF IMPACT
ON SMALL LOCA MITIGATION
FAILURE OF TRAIN A HPSI PUMP OCCURS DURING RECIRCULATION
PHASE; INJECTION PHASE IS NOT IMPACTED
MITIGATION OF SMALL LOCA EVENT REQUIRES 1
1.
HIGH PRESSURE INJECTION
2.
A)
HIGH PRESSURE RECIRCULATION
0
CONTAINMENT SUMP VALVES OPEN
0
LOW PRESSURE PUMPS FEED HIGH PRESSURE PUMPS
0
HIGH PRESSURE PUMPS PROVIDE FLOW TO RCS
B)
DEPRESSURIZATION AND LOW PRESSURE
'
RECIRCULATION
THREE HIGH PRESSURE PUMP CASES EXAMINED:
A.
N0 HYDR 0 GEN IN SYSTEM (BASE CASE)
B.
HYDR 0 GEN FAILS HPSI PUMP A AT RECIRCULATION -
NO CREDIT FOR HPSI PUMP B
C.
HYDR 0 GEN FAILS HPSI PUMP A AT RECIRCULATION -
l
OPERATOR ACTION TO ALIGN HPSI PUMP B TO TRAIN A
RESULTS:
FAILURE OF HPSI PUMP A DURING RECIRCULATION DUE TO
HYDR 0 GEN ACCUMULATION DOES NOT ADVERSELY IMPACT
l
MITIGATION OF A SMALL LOCA
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.
-
--
.- -
--
..
_ _ _ _ -
- - _ _ _ _ _ _ _ _ _ _ _ _ - _ - - - _ _ _ _ _
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SMALL LOCA EVENT TREE
HIGHLIGHTING RECIRCULATION PHASE
ET1
HHI
SHP
HHR
LHR
i
1
SUCCESS
2
SUCCESS
,
I
3
..-
4
5
6
_-_
7
EVENT
EVENT NAME
ET1
INITIATING EVENT
leil
HIGH HEAD INJECTION
SUMP VALVES OPEN
LUV HEAD PUMPS RESTART IN RECIRC
HHR
HIGH HEAD RECIRCULATION
DEPRESSURIZATION UCCURS
LHR
LDV HEAD RECIRCULATION
PLRA058
05/I7/88
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SMALL LOCA
CORE DAMAGE FREQUENCY ESTIMATES
CASE
DESCRIPTION
CORE DAMAGE
PERCEP.
FREQUENCY
CHANGE
BASE
NORMAL SYSTEM OPERATION
2.18E-05
-
.
(NO PUMP DEGRADATION
DUE TO HYDROGEN)
1
CHARGING PUMP A FAILS
2.52E-0
16
DUE TO H2
(NO CREDIT FOR
ISOLATED CHARGING PUMP B)
2
CHARGING PUMP A FAILS
2.19E-05
<1
DUE TO H2
OPERATOR
ACTION TO REALIGN
CHARGING PUMP B)
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- -
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.
- -
-. -
_ _ _ -__ _ _
_ _ _
___
-.
!
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SMALL LOCA
'
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ACCIDENT SEQUENCE COMPARISONS
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S50. No.
SEQUENCE DESCRIPTION _
BASE
CASE 1
CASE 2
--
1 FAILED NODES)
FREQUENCY
FREQUENCY
FREQUENCY
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3
ET1 HHR LHR
3.35E-10
4.79E-08
1.16E-09
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(<1%)
(<1%)
(<1%)
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4
ET1 HHR DEP
2.35E-08
3.36E-06
8.13E-09
(<1%)
(13%)
(<1%)
5
ET1 LHS
2.46E-06
2.46E-06
2.46E-06
(11%)
(10%)
(11%)
6
ET1 SMP
1.06E-05
1.06E-05
1.06E-05
(49%)
(42%)
(48%)
7
ET1 HHI
8.80E-06
8.80E-06
8.80E-05
(40%)
(35%)
(40%)
TOTALS
2.18E-05
2.52E-05
2.19E-05
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