Information Notice 1997-90, Use of Nonconservative Acceptance Criteria in Safety-Related Pump Surveillance Tests

Use of Nonconservative Acceptance Criteria in Safety-Related Pump Surveillance Tests

ML031050012
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	12/30/1997
From:	Roe J Office of Nuclear Reactor Regulation
To:
References
IN-97-090, NUDOCS 9712290018
Download: ML031050012 (17)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 December 30, 1997 NRC INFORMATION NOTICE 97-90: USE OF NONCONSERVATIVE ACCEPTANCE

CRITERIA IN SAFETY-RELATED PUMP

SURVEILLANCE TESTS

Addressees

All holders of operating licenses for nuclear power reactors except those who have ceased

operations and have certified that fuel has been permanently removed from the vessel.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert

addressees to potential problems associated with safety-related pump surveillance testing. It is

expected that recipients will review the information for applicability to their facilities and consider

actions, as appropriate, to avoid similar problems. However, suggestions contained in this

information notice are not NRC requirements; therefore, no specific action or written response

is required.

Background

Several recent inspections in the area of safety-related pump performance have resulted in the

issuance of Notices of Violation of Appendix B, Criterion Xi, "Test Control," of Part 50 of Title 10

of the Code of Federal Regulations (10 CFR Part 50) because licensees have concentrated on

inservice testing (IST) requirements without ensuring that design requirements were met.

There are two applicable primary requirements for safety-related pump testing: (1) to ensure

that Criterion Xl is met in that each safety-related pump achieves its minimum design-required

performance and (2) to ensure that each safety-related pump meets the requirements of

Section Xl, "Inservice Testing,' of the American Society of Mechanical Engineers Boiler and

Pressure Vessel Code (ASME Code). Criterion Xi of Appendix B to 10 CFR Part 50 requires

that a test program be established with written test procedures that incorporate the

requirements and acceptance limits contained in applicable design documents. Although

licensees have established IST acceptance criteria that meet the requirements specified in the

ASME Code, the criteria at some plants allowed safety-related pumps to degrade below the

performance assumed in the accident analyses.

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IN 97-90

December 30, 1997

Description of Circumstances

In June 1996, the NRC staff found that the licensee for the Point Beach Nuclear Plant had failed

to ensure that the safety-related pump tests for several pumps had acceptance criteria that

incorporated the acceptance limits from applicable design documents (Inspection Report

50-266/96-06 and 50-301/96-06, dated September 5, 1996 [Accession 9609170044]). These

tests were used to ensure operability of the pumps, but the acceptance criteria were based only

on the ASME Code requirements. The NRC staff found that the average performance of the

service water pumps documented as acceptable by IST tests was 12.4 percent below the

average performance assumed in the large-break, loss of coolant accident (LOCA) analysis.

The NRC staff also noted that the IST-based acceptance criterion of 10-percent degradation

would have allowed the safety injection (SI) pumps to degrade more than the 5 percent

specified in the final safety analysis report (FSAR) small-break LOCA analysis. The NRC staff

found that other pumps would also have been allowed to degrade below minimum

requirements.

In December 1996, a system operational performance inspection (SOPI) at the Donald C. Cook

Nuclear Power Plant revealed a similar situation (Inspection Report 50-315/96-13 and

50-316/96-13, dated February 4, 1997 [Accession 9702070476]). NRC inspectors reviewed the

ability of the centrifugal charging pumps (CCPs) to satisfy design requirements. One of these

requirements, as specified in the plants technical specifications, was the ability to provide

adequate reactor coolant system boration from the refueling water storage tank (RWST).

During this inspection, the licensee performed a charging system flow calculation and

determined that the allowable CCP degradation to ensure adequate reactor coolant system

boration from the RWST was 8.5 percent for Unit 1 and 2.5 percent for Unit 2, rather than the

10-percent degradation limit specified by the ASME Code. The ASME Code acceptance limits

would have allowed the CCP performance to degrade to less than the technical specification

requirements.

In January 1997, a SOPI at the Kewaunee Nuclear Power Plant identified inadequate auxiliary

feedwater (AFW) and residual heat removal (RHR) pump surveillance testing (Inspection

Report 50-305/97-02, dated March 28, 1997 [Accession 9704040065]). In the AFW instance, the licensee was using an IST acceptance limit of 160 gallons per minute (gpm) delivered to the

steam generator for each of the pumps, although the license-basis requirement was 200 gpm

(not including 40 gpm of recirculation flow). The surveillance procedure used the original

vendor's pump performance curve with an acceptance criterion of 10-percent degradation from

IN 97-90

December 30, 1997 these curves. When this criterion was applied to the AFW pumps, it was determined that all

AFW pumps were performing below license-basis requirements. This situation resulted in the

plant being outside of its accident analysis and requiring an operability determination for the

AFW pumps. For the RHR pumps, the IST lower band acceptance limit was 1330 gpm, which

was below the accident analysis required flow of 1400 gpm. In this case, the pumps were

shown to be operating right at the accident analysis limit.

In March 1997, an inspection at Grand Gulf Nuclear Station determined that the surveillance

test procedure acceptance criterion for one of the standby service water (SSW) pumps and the

high-pressure core-spray (HPCS) service water pump did not ensure that they were capable of

meeting their accident analysis criterion (Inspection Report 50-416/97-05, dated May 29. 1997

[Accession 9706030042]). The reference values for the surveillance test procedure acceptance

criterion for the SSW pumps were based on initial preoperational testing because this testing

demonstrated better performance than predicted by the vendor curves [124 pound per square

inch differential (psid) at 10,500 gpm]. The accident analysis was based on the vendor curves.

The SSW pumps were rebuilt in April 1996. Post-maintenance testing of the "A" pump revealed

hydraulic performance of 131.9 psid at 10,500 gpm, which was 5 percent below the previous

reference value. The licensee established this performance point as the new reference value.

With the ASME Code allowable degradation of 10 percent, the new minimum ASME Code

acceptance criterion at 10,500 gpm was 118.8 psid, which was below the value on the vendor's

curve. The accident analysis criterion for the HPCS service water pump of 83.8 psid at

700 gpm was based on the vendor's pump curves. The surveillance test procedure acceptance

criterion for this pump considered a developed head of 81.9 psid acceptable. Therefore, both

surveillance procedures would have considered their respective pumps to be operable, even

though their performance did not satisfy the accident analysis criterion.

In April 1997, an inspection at Fort Calhoun Station determined that the surveillance test

procedure acceptance criteria for pumps in five safety-related systems did not ensure that they

were capable of meeting their accident analysis performance criteria (Inspection Report

50-285/97-06, dated June 27,1997 [Accession 9707010011]). These pumps were the AFW

pumps, the high- and low-pressure Si pumps, the containment spray pumps, and the raw water

pumps. In particular, the motor-driven AFW pump's minimum performance criterion for delivery

to the steam generators was 1033 psid at 200 gpm. Since this analysis did not account for the

errors due to main steam safety valve set point tolerance and accumulation, the errors changed

the minimum performance requirements to 1079 psid at 200 gpm. However, using the

degradation of 10 percent allowed by the ASME Code, the surveillance test procedure

acceptance criterion considered the pump to be operable with 990 psid at 200 gpm.

Subsequent to these inspection findings, the licensee initiated a review of all safety-related

pumps in its IST program. Four other pumps were found to have surveillance procedure

minimum performance acceptance criteria lower than the criteria specified in their respective

accident analyses.

IN 97-90

December 30, 1997 In May 1997, a SOPI at the Prairie Island Nuclear Generating Plant found that the lower

acceptance limits for the IST for the AFW pumps were below the most limiting accident analysis

value specified in the updated FSAR (Inspection Report 50-282/97-08 and 50-306/97-08, dated

July 16, 1997 [Accession 9707220149]). The maximum degradation allowed by design from

the reference pump curve was about 4 percent, whereas the IST acceptance criteria allowed

10-percent degradation. Because the AFW pumps appeared to be operating close to the

accident analysis limit (200.8 gpm vs. 200 gpm), a specific evaluation had to be performed to

ensure operability.

Discussion

These examples identify inadequacies in surveillance test procedure acceptance criteria that

had the potential for, and in some cases did result in, pumps not meeting their accident analysis

acceptance criteria. IST is intended to monitor degradation of components. The ASME Code

does not require that pumps be tested at design-basis conditions. Many licensees use the

ASME test to verify compliance with the ASME Code and the pump design requirements

contained in plant design-basis documentation such as the FSAR. The ASME Code allows a

specific percentage of degradation of pump hydraulic performance from an established

reference value before action must be taken. If the minimum design performance as specified

in the plant design documentation is more stringent than the ASME Code acceptance criteria, then the test acceptance criteria must be adjusted to avoid the actual pump performance being

allowed to degrade below the minimum acceptable design performance. In addition, licensees

need to ensure that original plant design-basis calculations, or revisions to these calculations, are properly integrated into surveillance test procedure acceptance criteria. The NRC

published guidance on this issue in NUREG-1482, "Guidelines for Inservice Testing at Nuclear

Power Plants." Section 5.6, "Operability Limits of Pumps," states that operability limits must

always meet, or be consistent with, licensing-basis assumptions in a plant's safety analysis.

Related guidance can also be found in ASME OM-SG-1997, Part 15, "Standard for

Performance Testing of Emergency Core Cooling Systems in Pressurized Water Reactor Plants

(OM Part 15)," which will be published in late 1997. A similar standard for boiling-water

reactors (OM Part 20) is scheduled to be published in 1998.

IN 97-90

December 30, 1997 This information notice requires no specific action or written response. However, recipients are

reminded that they are required to consider industry-wide operating experience (including NRC

information notices) where practical, when setting goals and performing periodic evaluations

under Section 50.65, "Requirement for monitoring the effectiveness of maintenance at nuclear

power plants," to Part 50 of Title 10 of the Code of Federal Regulations. If you have any

questions about the information in this notice, please contact one of the technical contacts listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

W. T-

/Jkck W. Roe, Acting Director

ivision of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Eric R. Duncan, Rill Robert M. Lerch, Rill

(630) 829-9739 (630) 829-9759 E-mail: erd@nrc.gov E-mail: rml5@nrc.gov

Gerard F. O'Dwyer, Rill Thomas F. Stetka, RIV

(630) 829-9624 (817) 860-8247 E-mail: gfo~nrc.gov E-mail: tfs@nrc.gov

Joseph Colaccino, NRR

301-415-2753 E-mail: jxcl@nrc.gov

Attachment: List of Recently Issued NRC Info ces

K-,--, Attachment

IN 97-90

December 30, 1997 Page 1 of I

LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

97-89 Distribution of Sources and 12/29/97 All sealed source and device

Devices Without Authorization manufacturers and distributors

97-88 Experiences During Recent 12116/97 All holders of OLs for pressurized- Steam Generator Inspections water reactors except those who

have permanently ceased

operations and have certified that

fuel has been permanently

removed from the reactor

97-87 Second Retrofit to 12/12197 All industrial radiography

Industrial Nuclear Company licensees

IR 100 Radiography Camera, to Correct Inconsistency in

10 CFR Part 34 Compatibility

97-86 Additional Controls for 12/12/97 Registered users of the Model

Transport of the Amersham No. 660 series packages, and

Model No. 660 Series Nuclear Regulatory Commission

Radiographic Exposure Devices industrial radiography licensees

97-85 Effects of Crud Buildup 12111/97 All holders of OLs for pressurized- and Boron Deposition on water reactors, except those

Power Distribution and licensees who have permanently

Shutdown Margin ceased operations and have

certified that the fuel has been

permanently removed from the

reactor vessel

97-84 Rupture in Extraction 12/11/97 All holders of OLs for nuclear

Steam Piping as a power reactors except those

Result of Flow-Accelerated who have permanently ceased

Corrosion operations and have certified

that fuel has been permanently

removed from the reactor vessel

95-49, Seismic Adequacy of 12/10/97 All holders of OLs for nuclear

Sup. 1 Thermo-Lag Panels power reactors

OL = Operating License

CP = Construction Permit

IN 97-90

December 30, 1997 This information notice requires no specific action or written response. However, recipients are

reminded that they are required to consider industry-wide operating experience (including NRC

information notices) where practical, when setting goals and performing periodic evaluations

under Section 50.65, "Requirement for monitoring the effectiveness of maintenance at nuclear

power plants," to Part 50 of Title 10 of the Code of Federal Regulations. If you have any

questions about the information in this notice, please contact one of the technical contacts listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

original signed by

Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Eric R. Duncan, Rill Robert M. Lerch, Rill

(630)829-9739 (630) 829-9759 E-mail: erd@nrc.gov E-mail: rml5@nrc.gov

Gerard F. O'Dwyer, Rill Thomas F. Stetka, RIV

(630) 829-9624 (817) 860-8247 E-mail: gfo@nrc.gov E-mail: ffsenrc.gov

Joseph Colaccino, NRR

301-415-2753 E-mail: jxcl@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

OFC PECB:DRPM* TECH ED* RII/DRS* RIII/DRS l

NAME T. Greene R. Sander P. Pelke M. Ring

DATE 12/11 /97 111/25/97 j 11/26 /97 12/ 1 /97 OFC I EMEB:DE* SC/EMEB:DE* C/EMEB:DE* RIV/DRS*

NAME J. Colaccino D. Terao R. Wessman T. Stetka

DA 12/ 10 /97 12/ 12 /97 12/ 15 / 97 11/ 26 /97

• 1F. i

OFC SC/PECB:DRPM C/PECB:DRPM D/DRPM

NAME R. Dennig* S. Richards* J. Roe*

DATE 12/ 16 /97 12 / 22 /97 112/ 22 /97

• - See previous concurrence

[OFFICIAL RECORD COPY]

DOCUMENT NAME: 97-90.IN

IN 97-XX

December XX, 1997 This information notice requires no specific action or written response. However, recipients are

reminded that they are required to consider industry-wide operating experience (including NRC

information notices) where practical, when setting goals and performing periodic evaluations

under Section 50.65, "Requirement for monitoring the effectiveness of maintenance at nuclear

power plants," to Part 50 of Title 10 of the Code of Federal Regulations. If you have any

questions about the information in this notice, please contact one of the technical contacts listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Eric R. Duncan, Rill Robert M. Lerch, Rill

(630)829-9739 (630) 829-9759 E-mail: erd@nrc.gov E-mail: rml5@nrc.gov

Gerard F. O'Dwyer, Rill Thomas F. Stetka, RIV

(630) 829-9624 (817) 860-8247 E-mail: gfo~nrc.gov E-mail: tfs@nrc.gov

Joseph Colaccino, NRR

301-415-2753 E-mail: jxcl@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

OFC PECB:DRPM* TECH ED* RIII/DRS* RIll/DRS*

NAME T. Greene R. Sander P. Pelke M. Ring

DATE 12/11 /97 11/25/97 11/26 /97 12/ 1 /97 OFC EMEB:DE* SC/EMEB:DE* C/EMEB:DE* RIV/DRS*

NAME J. Colaccino D. Terao R. Wessman T. Stetka

DATE 12/ 10 /97 12/ 12 /97 12/ 15 / 97 11/ 26 /97 OFC SC/PECB:DRPM C/PECB:DRPM D/DRPM

NAME R. Dennig* S. Richards J. oe

DATE 112/ 16 / 97 1 2-/ 4V7

9 1 tl- / 97

• - ee pevius

cncurenc

• - See previous concurrence

'JtS. /qI'/?f 7

[OFFICIAL RECORD COPY]

DOCUMENT NAME: G:\TAG\INIST

2IN 97-XX

December XX, 1997 This information notice requires no specific action or written response. However, recipients

are reminded that they are required to consider industry-wide operating experience (including

NRC information notices) where practical, when setting goals and performing periodic

evaluations under Section 50.65, "Requirement for monitoring the effectiveness of

maintenance at nuclear power plants," to Part 50 of Title 10 of the Code of Federal

Regulations. If you have any questions about the information in this notice, please contact

one of the technical contacts listed below or the appropriate Office of Nuclear Reactor

Regulation (NRR) project manager.

Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Eric R. Duncan, Rill Robert M. Lerch, Rill

630-829-9739 630-829-9759 E-mail: erd@nrc.gov E-mail: rml5@nrc.gov

Gerard F. O'Dwyer, RilI Thomas F. Stetka, RIV

630-829-9624 817-860-8247 E-mail: gfo@nrc.gov E-mail: ffs@nrc.gov

Joseph Colaccino, NRR

301-415-2753 E-mail: jxcl@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

-

VI4k

OFC PECB:DRPM* TECH ED* RIII/DRS* RIII/DRS*

NAME T. Greene R. Sander P. Pelke M. Ring

DATE [ 12/11 /97 11/25/97 11/26 /97 12/ 1 /97 l

OFC l EMEB:DE* SC/EMEB:DE* C/EMEB:DE* RIV/DRS*

NAME J. Colaccino D. Terao R. Wessman T. Stetka

DATE l 12/ 10 /97 l 12/ 12 /97 12/ 15 / 97 l 11 /26 /97

- .. II

OFC SC)~ggowM C/PECB:DRPM D/DRPM

NAME R.ti4endig S. Richards J. Roe

DATE I -- / (v / 97 I / 97 I /97 I - bee previous concurrence

[OFFICIAL RECORD COPY]

DOCUMENT NAME: G:\TAG\INIST

K-i- S~ 97-XX

December XX, 1997 This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact one of the technical contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

Jack W. Roe, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: Eric R. Duncan, Rill Robert M. Lerch, Rill

630-829-9739 630-829-9759 E-mail: erdenrc.gov E-mail: rml5@nrc.gov

Gerard F. O'Dwyer, Rill Thomas F. Stetka, RIV

630-829-9624 817-860-8247 E-mail: gfo@nrc.gov E-mail: ffs@nrc.gov

Joseph Colaccino, NRR

301-415-2753 E-mail: jxclnrc.gov

Attachment: List of Recently Issued NRC Information Notices

[OFC PECB:DRPM TECH ED* RIII/DRS* RIII/DRS*

NAME T. Greene (Q) R. Sander P. Pelke M. Ring

l DATE

_ 12/11 /97 111/25/97 11/26 /97 J12/ / 97 l OFC EMEB:DE SC/EMEB:DE C/EMEB:DE) RIV/DRS*

NAME J. Colaccino 7i

D. Terao R. W an J T. Stetka

lDATE _la_ _ _ /97 fN Z-f 97 l A/ 1s / 97 l 11 / 26 /97 OFC SC/PECB:DRPM C/PECB:DRPM DIDRPM

NAME R. Dennig S. Richards J. Roe

DATE I_____ I /97 1 / /97 J

• - See previous concurrence

[OFFICIAL RECORD COPY]

DOCUMENT NAME: G:kTAG\INIST

(301) 41' 3 E-mail: jxcl@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

OFC PECB:DRPM TECH EDITOR RIII/DRS RIII/DRS

NAME T. Greene M!svW~ M. Ring P. Pelke

DATE I 197 /(/1 197 I /97 I /97 OFC IRillIDRS EMEB:DE SLIEMEB:DE CIEMEB:DE

NAME jJ. Colaccino T. Derao JR. Dennig R.Wessman

DAE j 197 I /97 i /971 / /97 OFC C/PECB:DRPM D/DRPM

NAME l S. Richards J. Roe

DATE l /97 I /97 l

[OFFICIAL RECORD COPY]

DOCUMENT NAME: G:\TAGUNIST

-Mail Envelope Inf847C3667.2A0 : 14  : 10767)

Subject: IN REVIEW (TAC M99024)

Creation Date: 11/26/97 9:47am

From: Thomas Greene

Created By: WND2.WNP4:TAG

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Recipients Action Date & Time

ERD (Eric Duncan) Delivered 11/26/97 09:54a

Opened 11/26/97 03:13p

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Subject: IN REVIEW (TAC M99024)

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Subject: IN on IST testing for review

Creation Date: 12/11/97 9:14am

From: Thomas Greene

Created By: WND2.WNP4:TAG

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GFO (Gerard O'Dwyer) Delivered 12/11/97 09:22a

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- Mail Envelope Inf847C380C.2A0  : 14 : 10767)

Subject: IN REVIEW (TAC M99024)

Creation Date: 11/26/97 9:54am

From: Thomas Greene

Created By: WND2.WNP4:TAG

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. Mail Envelope InL047C38BF.2AO : 14 : 10767)

Subject: IN REVIEW (TAC M99024)

Creation Date: 11/26/97 9:57am

From: Thomas Greene

Created By: WND2.WNP4:TAG

Routed Slip

Recipients Action Date & Time

MAR (Mark Ring) Delivered 11/26/97 10:04a

Opened 11/26/97 01:47p

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- From: Thomas Stetka

To: WND2.WNP4(TAG)

Date: 11/26/97 1:44pm

Subject: IN REVIEW (TAC M99024) -Reply

I reviewed the proposed IN and concur with no comments.