ML20076C571

ECCS Repts (F-47):TMI Action Plan Requirements,James a Fitzpatrick Nuclear Power Plant, Technical Evaluation Rept

ML20076C571
Person / Time
Site:	FitzPatrick
Issue date:	04/28/1983
From:	Overbeck G, Vosbury F FRANKLIN INSTITUTE
To:	Chow E NRC
Shared Package
ML20076C572	List: ML20076C571
References
CON-NRC-03-81-130, CON-NRC-3-81-130, RTR-NUREG-0737, RTR-NUREG-737 TER-C5506-187, NUDOCS 8305030455
Download: ML20076C571 (14)

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TECHNICAL EVALUATION REPORT ECCS REPORTS (F-47)

TMI ACTION PLAN REQUIREMENTS

' POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FITZPATRICK NUCLEAR POWER PLANT NRC DOCKET NO. 50-263 FRC PROJECT C5506 FRC ASSIGNMENT 7 NRC CONTRACT NO. NRC-03-81-130 FRC TASK 187 Preparedby Franklin Research Center Author: F. W. Vosbury 20th and Race Streets Philadelphia, PA 19103 G. J. Overbeck FRC Group Leader: G. J. Overbeck Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer: E. Chow April 28, 1983 This report was prepared as an account of work sponsored by an agency of the Unite Government. Neither the United States Government nor any agency thereof, or any o employees, makes any warranty, expressed or implied, or assumes any legal liability responsibility for any third party's use, or the results of such use, of any information appa-ratus, product or process disclosed rights. in this report, or represents that its use by such third party would not infringe privately owned Prepared by: Reviewed by:

Approved by:

T o.U A Principal Author A Ad Ll Group I,e$ der #PMw Date:_ 4 en- Dep'artment Ol/ectd)

Date:. I~E#'#1

_ Date:_ A - 2 7- P 3 XA Copy Has Been Sent to PDR 4

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TER-C550 6-18 7 CONTENTS Section Title Page 1 INTRODUCTION . . . . . . . . . . . . . I 1.1 Purpose of Review . . . . . . . . . . . 1 1.2 Generic Background. . . . . . . . . . . 1 1.3 Plant-Specific Background . . . . . . . . . 2 2 REVIEW CRITERIA. . . . . . . . . . . . . 3 3 TECHNICAL EVALUATION . . . . . . . . . . . 4 3.1 Review of Completeness of the Licensee's Report . . . 4 3.2 Comparison of ECC System Outages with ,

Those of Other Plants . . . . . . . . . . 4 3.3 Review of Proposed Changes to Improve the Availability of ECC Equipment . . . . . . . . 8 4 CONCLUSIONS. . . . . . . . . . . . . . 9 5 REFERENCES . . . . . . . . . . . . . . 10 i

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TER-C550 6-18 7 FOREWORD This Technical Evaluation Report 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 evalua-tion was conducted in accordance with criteria established by the NBC.

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

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l. 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 Power Au'thority of the State of New York's (PASNY) James A. FitzPatrick Nuclear Power Plant. The purpose of this evaluation is to determine if the Licensee has submitted a raport 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

, Following the Three Mile Island Unit 2 accident, the Bulletins and Orders Task Force reviewed nuclear steam supply system (NSSS) vendors' small break ,

loss-of-coolant accident (LOCA) analyses to ensure that an adequate basis existed for developing guidelines for small break LOCA emergency procedures.

During these reviews, a concern developed about the assumption of the worst single failure. Typically, the small break LOCA 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. Therefore, to ensure that the small break LOCA analyses are consistent with the actual plant response, the Bulletin and Orders Task Force recommended in NUREG-0626 [1] , " Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in GE-Designed Operating Plants and i Near-Term Operating License Applications," that licensees of General Electric (GE)-designed NSSSs do the following:

" Submit a report detailing outage dates and lengths 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

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TER-C550 6-18 7 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 TMI-2 Accident," for all light water reactor plants as TMI Action Item II.K.3.17. In NUREG-0737 [3] , " Clarification of TMI Action Plan Requirements," the NBC staf f added a requirement that licensees propose changes tnat will improve and control availability of ECC 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 outages; (2) cause of the outage; (3) ECC systems or components involved in the outage; and (4) corrective action taken."

1.3 PLANT-SPECIFIC BACKGROUND On January 8, 1981 (4), PASNY cubmitted a report in response to NUREG-0737, Item II.K.3.17, " Report on Outages of Emergency Core-Cooling

. Systems Licensee Report and Proposed Technical Specification Changes." The report submitted by PASNY covered the period from January 1,1976 to December

• 31, 1980 for FitzPatrick Nuclear Power Plant. On January 26, 1983 (5], PASNY ,

provided a revised report for this review but did not provide any recommenda-tions to improve and control availability of ECC systems.

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2. REVIEW 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 [6]

outlining Tentative Work Assignment F. Provided as review criteria in Reference 6, the NRC stated that the Licensee's response should contain the following information:

1. A report detailing outage dates, causes of outages, and lengths of outages for 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 ECC systems and components due.to test and maintenant e outages.

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

The type of information required to satisfy the review criteria was clarified by the NRC on August 12, 1981 (7]. Auxiliary systems such as component cooling water and plant service water systems were not to be considered in determining 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 (8], the NRC further clarified that the purpose of the reviu was to identify those licensees that have experienced higher ECC system outages than other licensees with similar NSSSs. The need for improved reliability of diesel generators is under review by the NBC. A Diesel Generator Interim Reliability 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. TECHNICAL EVALUATION 3.1 REVIEW OF COMPLETENESS OF THE LICENSEE'S REPORT The ECC systems at PASNY's FitzPatrick Nuclear Power Plant 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 residual heat removal (RHR) system in the low pressure coolant injection (LPCI) mode.

In Reference 5, PASNY also included the reactor coolant isolation cooling (RCIC) system. The BCIC system is a non-safety-related high pressure system available for high pressure injection and is not considered a primary ECC system for this review.

For most ECC system outages, PASNY provided the date, the duration, a brief description, the cause, and the corrective action taken. Maintenance and surveillance testing activities were included in the ECC system outage data.

The results of PASNY's review were provided from January 1,1976 to December 31, 1980 for the FitzPatrick Nuclear Power Plant.

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

3.2 COMPARISON OF ECC SYSTDi OUTAGES WITH THOSE.OF OTHER PLANTS The outages of ECC systems can be categorized 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 LE.Rs. The technical specifications identify the type and quantity of ECC equipment required as 4 dbd Franklin Research Center a mon or n. n n n u.

TER-C550 6-187 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 j 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 WASH-1400 [9], 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 preliminary estimate of the unavailability of an ECC system was made by calculating the ratio of the ECC system downtime to the number of days that

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the plant was in operation during the last 5 years. To simplify the tabula-tion 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 time it is operating at power. In addition, an ECC system was considered down whenever an ECC system component was unavailable 4

due to any cause.

It should 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 i

l would be expected if the design capability of the system exceeded the capacity required for the system to fulfill its safety function. For example, if an ECC system consisting cf two loops with multiple pumps in each loop is designed so that only one pump in each loop is required to satisfy core l

I cooling requirements, then an outage of a single pump would not prevent the I

system from performing its safety function. In addition, the actual ECC system unavailability is a function of planned and unplanned outages of i

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TER-C550 6-187 essential support systems as well as 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 BCC 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 overestimate 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 forl. die four ECC systems S

(HR:I, ADS, CS, and LPCI) and the emergency diesel generators were identified from the outage information in Reference 5 and are shown l,in numbers of days and as percentage of plant operating time per year in Table N for the FitzPatrick

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Nuclear Power plant. Outages that occurred during nonoperational periods were eliminated, as were those caused by failures or test and maintenance of support systems. Data on plant operating conditions were obtained from the annual reports, " Nuclear Power Plant Operating Experience" (10-13] , and from monthly re ports, " Licensed Operating Reactors Status Summary Report" [14]. The remaining outages were segregated into planned and unplanned outages based on PASNY's description of the causes. The outage periods for each category were calculated by summing the individual outage durations. Included for informational purposes are the RCIC system outage data.

Observed outage times of various ECC systems at FitzPatrick Nuclear Power Plant were compared with those of other BWRs. Based on this comparison, it was concluded that the historical unavailiability of the ADS, HPCI, LPCI, and CS systems has been consistent with the performance of those systems throughout I

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7 HPCI LPCI ADS CS RCIC EDG fQ sg Days of Plant Operation Outage in pays Outage in Days Ou'vje_in Days _ Outage in Days Outage in Days Outage in Days Year Ebreed Planned Forced Planned Forced Planned Ebr eed Planned Forced Planned Forced Planned 4

1976 261.8 1.0 0.0 2.8 0.0 2.4 0.0 0.0 0.0 6.5 0.0 11.5 0.0 (0.4) (1.1) (0.9) (2.5) (4.4) 1977 190.3 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 20.0 0.3 5.0 0.0 (0.3) . (10.5) (0.2) (2.6) g

-J 1978 263.2 3.7 0.0 1.1 1.7 0.0 0.0 0.3 0.0 0.7 M.=

~0 .0 0.2 0,2 I

(1.4) (0.4) (0.6) (0,1) (0.3) (0.1) (0.1) 1979 249.7 0.1 2.3 0.2 0.0 0.0 0.0 0.5 0.0 2.0 0.0- 4.9 0.0

(< 0.1) (0.9) (<0.1) (0.2) (0.8) (2.0) 1980 262.1 5.2 0.2 3.6 2.7 0.0 0.0 1.1 0.2 0.4 1.0 2.1 0.0 (2.0) (0.1) (1.4) (1.0) (0.4) (0.1) (0.2) (0.4) (0.8)

Total 1227.1 11.5 2.5 7.7 4.4 2.4 0.0 1.9 0.2 23.7 1.3 35.2 0.2 (0.9) (0.2) (0.6) (0.4) (0.2) (0.2) (<0.1) (1.9) (0.2) (2.9) (<0.1)

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TER-C550 6-187 the industry. We observed unavailability was less than ti)e industrial mean for all ECC systems, assuming that the underlying unavailability is distributed lognormally. Se outage times were also consistent with existing technical specifications.

The outages of the standby diesel generators and PCIC system were not included in this comparison. -

3.3 REVIEW OF PRTOSED CHANGES TO IMPROVE THE AVAILABILITY OF ECC EQUIPMENT In Reference 4, PASNY did not provide recommendations to improve and

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4. CONCLUSIONS Power Authority of the State of New York (PASNY) has submitted a report for James A. FitzPatrick Nuclear Power Plant which contains (1) outage dates and durations, (2) causes of the outages, (3) ECC systems or components

. involved in the outages, and (4) corrective actions taken. It is concluded that PASNY has fulfilled the requirements of NUREG-0737, Item II.K.3.17. In addition, the historical unavailability of the ADS, HPCI, LPCI, and CS systems has been consistent with the performance of those systems throughout the indus try. The observed unavailability was less than the industrial mean for all ECC systems.

The outage times were also consistent with existing technical specifications.

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5. REFERENCES j 1. NUREG-0626

' ' " Generic Evaluation of Feedwater Transients and Small Break Insa-of-Coolant Accidents in GE-Designed Operating Plants and Near-Term Operating License Applications"

, NRC, January 1980

2. NUREG-066 0 "NBC Action Plan Developed as a Result of the TMI-2 Accident" NBC, March 1980 s 3. NUREG-073 7

" Clarification of TMI Action Plan Requirements" NRC, October 1980

4. J. P. Bayne (PASNY)

Iatter to T. A. Ippolito (NRR, ORB 42)

Subject:

Post-DtI Requirements Janua ry 8, 19 81

5. J. P. Bayne (PASNY)

• IAtter to D. B. Vassallo (NRR, ORB 9 2)

Subject:

Additional Information on Outages of ECC Systems, Item II.K.3.17 January 26, 1983

6. J. N. Donohew, Jr. (NRC)

Letter to Dr. S. P. Carf agno (FRC) .

Subject:

Contract No.

N BC-0 3 13 0, Tentative Assignment F July 21, 19 81

7. NRC Meeting between NBC and FRC.

Subject:

C5506 Tentative Work Assignment F, " Operating Reactor PORY and ECCS Outage Reports" August 12, 1981 .

8. NRC l Meeting between NIC and FRC.

Subject:

Resolution of Review

. Criteria and Scope of Work Ju ly 26, 19 82 f

9. WASH-140 0

" Reactor Safety Study" NRC, October 1975 l

l 10. NUREG-036 6 l " Nuclear Power Plant Operating Experience 1976" NRC, December 1977

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11. NUREG-0483 "Nucimar Power Plant Operating Experience 1977" NBC, February 1979

, 12. NUREG-0 618

" Nuclear Power Plant Operating Experience 1978" NBC, December 1979.

13. NUREG/CR-1496

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

14. NUREG-0020

" Licensed Operating Reactors Status Summary Report" Volume 4, Nos.1 through 12, and Volume 5, No.1 NBC, Year 1980 and January 1981

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