Information Notice 1998-40, Design Deficiencies Can Lead to Reduced ECCS Pump Net Positive Suction Head During Design-Basis Accidents
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
October 26, 1998
NRC INFORMATION NOTICE 98-40: DESIGN DEFICIENCIES CAN LEAD TO
REDUCED ECCS PUMP NET POSITIVE
SUCTION HEAD DURING DESIGN-BASIS
ACCIDENTS
Addressees
All holders of operating licenses for nuclear power reactors, except those licensees who have
permanently 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 the fact that Incorrect level instrument setpoints or other control deficiencies can
render emergency core cooling system (ECCS) pumps inoperable during certain design-basis
accidents. 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.
Description of Circumstances
Oconee Nuclear Station
In late 1997, during a self-assessment audit of the high pressure injection (HPI) and low
pressure Injection (LPI) systems, the licensee noted that the design drawing for the borated
water storage tank (BWST) did not have a zero reference point. Subsequently, the licensee's
engineering staff determined that an elevation difference between the level transmitters and the
Instrument taps for the BWSTs of all three Oconee units had resulted in up to an 18-inch non- conservative error between Indicated and actual BWST level. The difference was caused by a
failure to compensate for instrument tap height when calibrating the BWST level Instruments.
At plant construction, the magnitude of the error was approximately 4 Inches, but the error
increased to approximately 18 inches following modifications In 1989 that replaced the BWST
level transmitters. In addition, on February 19, 1998, the licensee's engineering staff
determined that the emergency operating procedures (EOPS) did not adequately account for
uncertainty in the reactor building emergency sump (RBES) wide-range level instruments, IB
P~ f Age 18-04 W
0 2°( ,
6~i013
I
October 26, 1998 which could have resulted In the Instruments reading up to 18 inches lower than the actual
level. The RBES level instrument uncertainties were caused by inadequate design analysis.
This was discussed In Inspection Report 50 50-269, 270, 287/98-12 and Licensee Event Report
(LER) 50-269/98-04, Revision 1.
St. Lucie Nuclear Plant
During the Unit 1 steam generator replacement outage in 1997, the licensee replaced the
engineered safety features actuation system (ESFAS) bistables. A system engineer later
determined that the ESFAS recirculation actuation setpoint (RAS) bistable setpoint for the
Refueling Water Tank (RWT) level was Incorrect. An Investigation of the discrepancy found
that, during a setpoint calculation enhancement effort In 1993, a new calculation was created, which changed the span of the RWT level measurement and indication Instrumentation loop.
This calculation produced a new setpoint for the RWT level by revising the measurement span
to indicate the actual tank level bottom as "0 feet'. Previously, the measurement span indicated
0 at the 1-foot level where the RWT level instrument tap is located. The new setpoint
information was not incorporated Into the procedure used to calibrate the ESFAS bistables, resulting in a RAS setpoint of 3 feet from the tank bottom instead of 4 feet required by
Technical Specifications. This was discussed In Inspection Report 50-335, 389/97-16 and LER
50-335197-11.
H.B. Robinson Nuclear Plant
Between April 7 and May 23, 1997, NRC conducted a design Inspection at Robinson and raised
several Refueling Water Storage Tank (RWST) instrumentation related Issues that Impacted
ECCS components. Plant Emergency Operating Procedures (EOPs) directed all ECCS pumps, except one safety injection (SI) pump and one containment spray (CS) pump, to be stopped
when the RWST level reached 27 percent The remaining SI and CS pumps were directed to
be stopped when the RWST level reached 9 percent. The plant evaluated and modified the
number of SI pumps starting following a LOCA. The modification resulted in two (as opposed to
three) SI pumps starting following a LOCA. With two SI pumps getting a start signal, and
assuming a single active failure of one SI pump, the NPSH requirement for the running SI pump
was higher, and this higher NPSH requirement was not considered in the modification. A
calculation to determine the level at which vortexing became a concern had not been performed
prior to the modification. The licensee regained the margin by reducing instrument
uncertainties and by raising the water level In the RWST.
The NRC design team also found that the containment sump level setpolnts utilized channel
uncertainty for normal environmental conditions rather than the adverse conditions that could
exist in the containment after an accident. This had the potential for adversely affecting
residual heat removal (RHR) pumps In the recirculation mode of operation. These Items were
discussed in Inspection Report 50-261/97-201 and LER 50-261/97-08.
Discussion
In the Oconee Nuclear Station's Final Safety Analysis Report (Sections 6.2 and 6.3), the
licensee states that during certain loss-of-coolant accidents, reactor operators must be capable
of manually providing a flowpath from either the BWST or the RBES to the HPI, LPI and reactor
October 26, 1998 building spray (RBS) pumps. The errors described above created a conflict between the
BWST and RBES levels specified in the EOPs and the BWST and RBES levels Indicated in the
control room. As a result, during certain design-basis accident scenarios, Including small-break
LOCAs, the level errors could have delayed swapover initiation. This could have caused
vortexing in the BWST or reduced NPSH to the ECCS pumps, or both.
The design basis of the St. Lucie facility requires that during certain LOCAs, ECCS subsystems
must be capable of automatically transferring suction to the containment sump on receipt of a
RAS. Because of the incorrect trip setpoint of the RWT level instrument bistables, automatic
transfer of the ECCS pumps' suction source from the RWT to the containment sump, under
certain conditions, would cause an open-channel flow condition. Without operator intervention
to initiate manual transfer to the containment sump before the open-channel condition, damage
to the ECCS pumps could occur as a result of air entrainment.
At H.B. Robinson, the cause of the reduction in SI pump NPSH was a failure to adequately
assess the impact of single SI pump operation on system flow and NPSH during a 1988 modification. Inadequate NPSH to ECCS pumps could have led to the inoperability of critical
,
safety-related systems and loss of core cooling under some design-basis LOCA conditions.
The preceding examples demonstrate the importance of thorough assessment and analysis for
any modification involving safety-related level instrumentation or ECCS pump operating
conditions. Information Notice 98-22, "Deficiencies Identified During NRC Design Inspections,"
dated June 17, 1998, also described ECCS swapover analysis errors at D.C. Cook, H.B.
Robinson, Three Mile Island, Wolf Creek, and Ginna.
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.
W. Roe, Acting Director
(Deision of Reactor Program Management
'ffice of Nuclear Reactor Regulation
Technical contact: B. Desal, RH
D. Lanyl, RII
(803) 383-4571
(561) 464-7822 E-mail: bbdinrcgov, E-mail: dri@nrc.gov
D. Billings, RlI
N. Fields, NRR
(864) 882-6927
(301) 415-1173 i
E-mall: debl@nrc.gov
E-mail: enf@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
js
t/1>STO
<2-
',Attachment i
October 26, 1998 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
98-39 Summary of Fitness-for-Duty
10/26/98
All holders of oDerating licenses
Program Performance Reports for
Calendar Years 1996 and 1997
for nuclear power reactors
98-38
98-37
98-36
98-35
98-34 Metal-Clad Circuit Breaker
Maintenance Issued Identified
By NRC Inspections
Eligibility of Operator License
Applicants
Inadequate or Poorly Controlled
Non-Safety-Related Maintenance
Activities Unnecessarily Challenged
Safety Systems
Threat Assessments and
Consideration of Heightened
Physical Protection Measures
NRC Configuration Control
Errors
10/15/98
10/01/98
9118/98
9/4/98
8128198
All holders of operating licenses
for nuclear power reactors.
All holders of operating licenses
for nuclear power reactors, except those who have
permanently ceased operations
and have certified that fuel has
been permanently removed from
the reactor vessel.
All holders of operating licenses
for nuclear power reactors
All U.S. NRC fuel cycle facilities
power and non-power reactor
licensees (Safeguard issues, not
for public disclosure.)
All holders of Operating licenses
for nuclear power reactors, except
for those who have ceased
operations and have certified that
fuel has been permanently
removed from the reactor vessel
OL = Operating License
CP = Construction Permit
October26, 1998 building spray (RBS) pumps. The errors described above created a conflict between the
BWST and RBES levels specified in the EOPs and the BWST and RBES levels indicated in the
control room. As a result, during certain design-basis accident scenarios, including small-break
LOCAs, the level errors could have delayed the initiation swapover initiation. This could have
caused vortexing in the BWST or reduced NPSH to the ECCS pumps, or both.
The design basis of the St. Lucie facility requires that during certain LOCAs, ECCS subsystems
must be capable of automatically transferring suction to the containment sump on receipt of a
RAS. Because of the incorrect trip setpoint of the RWT level instrument bistables, automatic
transfer of the ECCS pumps' suction source from the RWT to the containment sump under
certain conditions would cause an open channel flow condition. Without operator intervention
to initiate manual transfer to the containment sump before the open channel condition, damage
to the ECCS pumps could occur as a result of air entrainment.
At H.B. Robinson, the cause of the reduction in Si pump NPSH was a failure to adequately
assess the impact of single Si pump operation on system flow and NPSH during a 1988 modification. Inadequate NPSH to ECCS pumps could have led to the inoperability of critical
safety-related systems and loss of core cooling under some design-basis LOCA conditions.
The preceding examples demonstrate the importance of thorough assessment and analysis for
any modification involving safety-related level instrumentation or ECCS pump operating
conditions.
Information Notice 98-22, "Deficiencies Identified During NRC Design Inspections," dated June
17, 1998, also described ECCS swapover analysis errors at D.C. Cook, H.B. Robinson, Three Mile Island, Wolf Creek, and Ginna.
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.
0 i
/S
'Id b
Jacl W.R
Acing Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: B. Desai, RII
D. Lanyi, RHI
(803) 383-4571 E-mail dri@nrc.gov
E-mail: bbd@nrc.gov
(561) 464-7822 D. Billings, RHI
N. Fields, NRR
(864) 882-6927
(301) 415-1173 E-mail: debl@nrc.gov
E-mail: enf@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: S:\\DRPMSEC\\98-40.IN
- See previous concurrence
To receive a copy of this document, indicate in the box C=Copy wlo attachment/enclosure E=Copy with lttachmentlenciosure N = No copy
OFFICE
l PECB
I
l1 Rl(rch Contacts
I
PECB
I
R11 I
D:DSSA 1 l CPECB
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NAME
lNFieds
1 B1esaUlings/ianyi
RDenn1W
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Stole
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DATE
10/08/98
1017/8/98
10116/98
10/20/98 l 10k;_8 "
l 10/21/98 l I
OFFICIAL RECORD COPY
October 26, 1998 bul ing spray (RBS) pumps. The errors described above created a conflict between the
BWS
nd RBES levels specified in the EOPs and the BWST and RBES levels indicated in the
control rhom. As a result, during certain design-basis accident scenarios, including small-break
LOCAs, t
level errors could have delayed the initiation swapover initiation. This could have
caused vort ing in the BWST or reduced NPSH to the ECCS pumps, or both.
The design bas of the St. Lucie facility requires that during certain LOCAs, ECCS subsystems
must be capable
automatically transferring suction to the containment sump on receipt of a
RAS. Because of
e incorrect trip setpoint of the RWT level instrument bistables, automatic
transfer of the ECCSumps' suction source from the RWT to the containment sump under
certain conditions woul
cause an open channel flow condition. Without operator intervention
to initiate manual transfe o the containment sump before the open channel condition, damage
to the ECCS pumps could
ur as a result of air entrainment.
At H.B. Robinson, the cause o
e reduction in Si pump NPSH was a failure to adequately
assess the impact of single Si pu
operation on system flow and NPSH during a 1988 modification. Inadequate NPSH to CCS pumps could have led to the inoperability of critical
safety-related systems and loss of cor cooling under some design-basis LOCA conditions.
The preceding examples demonstrate th
importance of thorough assessment and analysis for
any modification involving safety-related le I instrumentation or ECCS pump operating
conditions.
Information Notice 98-22, 'Deficiencies Identified uring NRC Design Inspections," dated June
17, 1998, also described ECCS swapover analysis
ors at D.C. Cook, H.B. Robinson, Three Mile Island, Wolf Creek, and Ginna.
This information notice requires no specific action or wtitte response. If you have any
questions about the information in this notice, please conta one of the technical contacts listed
below or the appropriate Office of Nuclear Reactor Regulation NRR) project manager.
Jack W. Roe, Acting irector
Division of Reactor Pr
am Management
Office of Nuclear Reacto egulation
Technical contact: B. Desai, RII
D. Lanyi, RI\\
(803) 383-4571 E-mail drl@nrc.
v
E-mail: bbd@nrc.gov
(561) 464-7822 D. Billings, RII
N. Fields, NRR
(864) 882-6927
(301) 415-1173 E-mail: debl@nrc.gov
E-mail: enf@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: S:\\DRPM_SEC\\98-40.lN
- See previous concurrence
To receive a copy of this document, Indicate In the box C=Copy wlo attachment/enclosure E=Copy with attachment/enclosure N = No copy
OFFICE
PECB
I
RH (TchjContacts
I
l
C:PECB
I
(A)D:DRPM
[
NAME
NFields*
BDesaVBillings/Lanyi
RDennig*
LPlisco*
JStolz*
JRoe
DATE
10/08 /98
1017/8/98
10/16/98
10/20/98
10/21/98
/ /98
OFFICIAL RECORD COPY
IN 98-xx
October xx, 1998 building spray (RBS) pumps. The errors described above created a conflict between the
BWST and RBES levels specified in the EOPs and the BWST and RBES levels indicated in the
control room. As a result, during certain design-basis accident scenarios, including small-break
LOCAs, the level errors could have delayed the initiation swapover initiation. This could have
caused vortexing in the BWST or reduced NPSH to the ECCS pumps, or both.
The design basis of the St. Lucie facility requires that during certain LOCAs, ECCS subsystems
must be capable of automatically transferring suction to the containment sump on receipt of a
RAS. Because of the incorrect trip setpoint of the RWT level instrument bistables, automatic
transfer of the ECCS pumps' suction source from the RWT to the containment sump under
certain conditions would cause an open channel flow condition. Without operator intervention
to initiate manual transfer to the containment sump before the open channel condition, damage
to the ECCS pumps could occur as a result of air entrainment.
At H.B. Robinson, the cause of the reduction in Si pump NPSH was a failure to adequately
assess the impact of single Si pump operation on system flow and NPSH during a 1988 modification. Inadequate NPSH to ECCS pumps could have led to the inoperability of critical
safety-related systems and loss of core cooling under some design-basis LOCA conditions.
The preceding examples demonstrate the importance of thorough assessment and analysis for
any modification involving safety-related level instrumentation or ECCS pump operating
conditions.
Information Notice 98-22, 'Deficiencies Identified During NRC Design Inspections," dated June
17, 1998, also described ECCS swapover analysis errors at D.C. Cook, H.B. Robinson, Three Mile Island, Wolf Creek, and Ginna.
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 contact: B. Desai, RII
D. Lanyi, RII
(803) 383-4571 E-mail drl@nrc.gov
E-mail: bbd@nrc.gov
(561) 464-7822 D. Billings, RI1
N. Fields, NRR
(864) 882-6927
(301) 415-1173 E-mail: debl@nrc.gov
-
E-mail: enf@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:\\NICK\\REGION2.IN
- See previous concurrence
i coov of this document. Indicate In the box C=CoDv wlo attachment/enclosure E=Copy wfth attachment/enclosure N = No copy
To receive a
OFFICE
PEC3 I
Ril (Tch Contacts lI _J
PECB
I l
A)D:DRPM
I
NAME
NFields*
BDesaVBillings/Lanyi
RDennig*
LPlisco*
JRoe
DATE
10/08 /98
10/7/8/98
10/16/98
10/20/98 o /i498 I /98
OFFICIAL RECORD COPY
IN 98-xx
October xx, 1998 BWST and RBES levels specified in the EOPs and the BWST and RBES levels indicated in the
control room. As a result, during certain design-basis accident scenarios, including small-break
LOCAs, the level errors could have delayed the initiation swapover initiation. This could have
caused vortexing in the BWST or reduced NPSH to the ECCS pumps, or both.
The design basis of the St. Lucie facility requires that during certain LOCAs, ECCS subsystems
must be capable of automatically transferring suction to the containment sump on receipt of a
RAS. Because of the incorrect trip setpoint of the RWT level instrument bistables, automatic
transfer of the ECCS pumps' suction source from the RWT to the containment sump under
certain conditions would cause an open channel flow condition. Without operator intervention
to initiate manual transfer to the containment sump before the open channel condition, damage
to the ECCS pumps could occur as a result of air entrainment.
At H.B. Robinson, the cause of the reduction in Si pump NPSH was a failure to adequately
assess the impact of single Si pump operation on system flow and NPSH during a 1988 modification. Inadequate NPSH to ECCS pumps could have led to the inoperability of critical
safety-related systems and loss of core cooling under some design-basis LOCA conditions.
The preceding examples demonstrate the importance of thorough assessment and analysis for
any modification involving safety-related level instrumentation or ECCS pump operating
conditions.
Information Notice 98-22, uDeficiencies Identified During NRC Design Inspections," dated June
17, 1998, also described ECCS swapover analysis errors at D.C. Cook, H.B. Robinson, Three Mile Island, Wolf Creek, and Ginna.
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 contact: B. Desai, RII
D. Lanyi, RII
(803) 383-4571 E-mail drl@nrc.gov
E-mail: bbd@nrc.gov
(561) 464-7822 D. Billings, RH
N. Fields, NRR
(864) 882-6927
(301) 415-1173 E-mail: debl@nrc.gov
E-mail: enf@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:\\NICK\\REGION2.IN
- See previous concurrence
To receive a copy of this document, Indicate In the box C=Copy wlo attachmentlenclosure E=Copy with attachment/enclosure NNo copy
OFFICE
PECIl
RiII (TchContacts
c
RHIL C:PECB
l
l
L
(A)D:DRP
I
NAME
NFields*
BDesaVBillings/Lanyi
tennig s¢; JStolz
JRoe
DATE
10/08 /98
10/7/8/98 to /10/998 b/0/298 I /98 l
/98
OFFICIAL RECORD COPY
IN 98-xx
October xx 1998
Page of 3 BWST and
BES levels specified in the EOPs and the BWST and
BES levels indicated in the
control room.
s a result, during certain design-basis accident s
narios, including small-break
LOCAs, the leve rrors could have delayed the initiation swap er initiation. This could have
caused vortexing in
e BWST or reduced NPSH to the ECC pumps, or both.
The design basis of the t. Lucie facility requires that during certain LOCAs, ECCS subsystems
must be capable of autom ically transferring suction to
e containment sump on receipt of a
RAS. Because of the incorr
t trip setpoint of the R
level instrument bistables, automatic
transfer of the ECCS pumps' s ction source from thRWT to the containment sump under
certain conditions would cause a open channel fVw condition. Without operator intervention
to initiate manual transfer to the co tainment su p before the open channel condition, damage
to the ECCS pumps could occur as
result ofuir entrainment.
At H.B. Robinson, the cause of the redu
i in SI pump NPSH was a failure to adequately
assess the impact of single SI pump ope
tion on system flow and NPSH during a 1988 modification.
Inadequate NPSH to E
S
mps could have led to the inoperability of critical
safety-related systems and loss of ce coolig under some design-basis LOCA conditions. 10 CFR Part 50, Appendix B, Criterio
II, !Desig Control", requires that measures shall be
established to ensure that the de gn basis is
ectly translated into specifications, procedures, and instructions. T e preceding exa pies demonstrate the importance of
thorough assessment and an ysis for any modifi tion involving safety-related level
instrumentation or ECCS p
p operating conditions
Information Notice 98-22 Deficiencies Identified Duri
NRC Design Inspections," dated June
17, 1998, also describe ECCS swapover analysis erro at D.C. Cook, H.B. Robinson, Three Mile Island, W
Creek, and Ginna.
This information n ice requires no specific action or written esponse. If you have any
questions about the information in this notice, please contact ne of the technical contacts listed
below or the ap opriate Office of Nuclear Reactor Regulation NRR) project manager.
Jack W. Roe, Actin Director
Division of Reactor Pgram Management
Office of Nuclear Rea or Regulation
Technic
contact: B. Desai, RHI
D. Lanyi, II
(803) 383-4571 E-mail drl@nrc.gov
E-mail: bbdenrc.gov
(561) 464-7822 D. Billings, RII
N. Fields, NRR
(864) 882-6927
(301) 415-1173 E-mail: debl@nrc.gov
E-mail: enf@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:\\NICK\\REGION2.IN
To receive a cop of this document, indicate in the box C=Cop wlo attachment/enclosure E=Copy With attachmentlenclosure N =No copy
OFFICE
PeERII
(Tch Contacts
lIL
ECBI
(j D:DRPM
NAME
NFields
BDesai/Bi
nnysLanyi
RDennig
LPlisco
JStolz
JRoe
DATE
lo_
_8/1/98 I /98 1I
/98 I /98 I /98