Information Notice 1997-33, Unanticipated Effect of Ventilation System on Tank Level Indications and Engineering Safety Features Actuation System Setpoint
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
June 11, 1997
UNANTICIPATED EFFECT OF VENTILATION
SYSTEM ON TANK LEVEL INDICATIONS AND
ENGINEERING SAFETY FEATURES ACTUATION
SYSTEM SETPOINT
Addresses
All holders of operating licenses or construction permits for nuclear power reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert
addressees to the potential to affect instrumentation output for certain transmitters by varying
ambient pressure with the operation of plant ventilation equipment. 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
Loss-of-coolant accident (LOCA) mitigation design at most pressurized-water reactors
involves the injection of borated makeup water from a safety-related tank into the reactor
coolant system from emergency core cooling system (ECCS) pumps. When the tank level
falls to a predetermined setpoint, a signal automatically shifts the suction source for the
ECCS pumps to the containment safety injection sump for long-term recirculation. This
swapover setpoint prevents the loss of net positive suction head (NPSH). A delay in the
swapover to the containment sump could result in the common-mode failure of the ECCS
pumps from cavitation or air binding, which would in turn result in the inability to mitigate the
LOCA.
Description of Circumstances
On February 23, 1997, the controlled ventilation area system (CVAS) at Waterford
Generating Station, Unit 3, was undergoing routine testing. The CVAS is a standby system
designed to automatically start following a safety injection signal to provide high-efficiency
particulate filtration and iodine absorption from areas within the reactor auxiliary building
(RAB) subject to potential leakage of post-accident reactor coolant (i.e., high-pressure safety
'injection and low-pressure safety injection pump rooms, shutdown cooling heat exchanger
rooms, etc.). The safety injection signal also simultaneously stops the RAB normal
ventilation system fans. This action stops the flow of all normal ventilation air to the RAB to
permit the CVAS to effectively evacuate its ventilation spaces to a negative pressure of at
least 0.25 inch of water gauge.
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IN 97-33 June 11, 1997 During the CVAS test, control room operators observed an indicated change in refueling
water storage pool (RWSP) level (source of injection water for ECCS) when a CVAS fan was
started. The RWSP level trend recorder indicated a level increase of approximately
2 percent. The shift supervisor contacted the instrumentation and control (I&C) technician on
duty to help investigate why the indicated RWSP level changed when a CVAS fan was
started. The l&C technician determined that the four RWSP level transmitters (Rosemount
Model 11 52DP5A22PB) were located in valve gallery rooms that were part of the CVAS
ventilation spaces. The technician also noted that the reference leg for these transmitters
was vented to the valve gallery room, rather than being routed back to the RWSP, and that
the RWSP was vented to the RAB normal ventilation inlet plenum (which was not subject to
CVAS effects). The operators and the l&C technician determined that the observed level
change had been caused by the slight vacuum produced in the valve gallery rooms by the
CVAS operation; in that the vacuum on the reference leg affected the overall differential
pressure output of the level transmitter. When the CVAS fan was secured, the shift
personnel observed the RWSP indicated level return to is previous position. The control
room operators recognized that the RWSP level instruments provide the input to the
engineering safeguards actuation system to generate a recirculation actuation signal (RAS) at
10-percent RWSP level.
The licensee subsequently determined that the effect of CVAS operation on the RAS setpoint
had not been considered when the setpoint was established. On March 8, the licensee
conducted a series of tests to determine the extent of the interaction between CVAS and
RWSP level instrument output. The tests consisted of running various combinations of RAB
normal and CVAS ventilation trains and measuring the effect on the output of the four RWSP
level transmitters. The tests revealed that, with one train of CVAS running, RAS would occur
within the Technical Specifications allowable value of 9.08 percent. With both trains of CVAS
running, the actual level at the RAS would be below the Technical Specifications
requirements.
The licensee subsequently revised the instrument loop calibration data sheets for the RWSP
instruments to account for/bound the CVAS ventilation effects, and calibrated all four
channels using the new data sheets. The instruments were recalibrated to account for the
worst-case scenario in terms of effect on the RAS; this scenario was determined to be both
trains of CVAS running coincident with a failed makeup damper (would increase vacuum
where instruments were vented). The calibration activity was an interim fix until the level
transmitter reference legs could be rerouted to the RWSP during an outage.
The licensee performed additional tests which revealed that other safety-related system level
indications were affected by ventilation system operation because of the venting arrangement
of the level transmitters.
Discussion
Criterion 13, "Instrumentation and Control," of Appendix A, "General Design Criteria for
Nuclear Power Plants," to 10 CFR Part 50, requires that instrumentation be provided to
monitor variables and systems and that controls be provided to maintain these variables and
S
IN 97-33 June 11, 1997 systems within prescribed operating ranges. Criterion 20, "Protection System Functions,"
requires that the protection system be designed to initiate operation of appropriate systems
to ensure that specified acceptable fuel design limits are not exceeded. Regulatory
Guide 1.105, "Instrument Setpoints," Revision 1, states that the accuracy of all setpoints
should be equal to or better than the accuracy assumed in the safety analysis, which
considers the ambient temperature changes, vibration, and other environmental conditions.
Transmitters that monitor tank level typically route the reference leg tubing to the top of the
tank in order to cancel the effect of tank overpressure on level indication. However, for tanks
that are vented, the level instrument reference legs are often vented to the atmosphere. It is
important that the reference leg accurately reflect the pressure that exists in the space above
the fluid level in the tank so that false levels are not indicated. It does not appear that
Waterford 3 appropriately accounted for the potential effects of different ventilation system
lineups on the RWSP level instruments. Such failure to appropriately account for all potential
environmental effects on protection system setpoints could result in an inability to mitigate
certain accidents.
Because additional testing at Waterford revealed that safety-related systems other than
RWSP level indications were affected by ventilation system operation, other licensees are
reminded that the level instrumentation for many systems at their plant may be subject to
similar problems.
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.
Marylee M. Slosson, Acting Directo
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Phil Harrell, Region IV
(817) 860-8250
E-mail: phhenrc.gov
Lee Keller, Region IV
(504) 783-6253 E-mail: lakenrc.gov
Charles D. Petrone, NRR
301-415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
X#a
2 A' by(
A
Attachment
June 11, 1997 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
95-36, Supp. 1
97-32
97-31
97-30
Potential Problems
with Post-Fire Emer- gency Lighting
Defective Worm Shaft
Clutch Gears in
Limitorque Motor-
Operated Valve
Actuators
Failures of Reactor
Coolant Pump Thermal
Barriers and Check
Valves in Foreign
Plants
Control of Licensed
Material During Reorgan- izations, Employee- Management Disagreements, and Financial Crises
06/10/97
06/10/97
06/03/97
06/03/97
All holders of OLs or CPs
for nuclear power reactors
All holders of OLs or CPs
for nuclear power reactors
All holders of OLs or CPs
for pressurized-water
reactor plants
All material and fuel
cycle licensees
97-29
Containment Inspection
Rule
05/30/97
All holders of OLs or CPs
for nuclear power reactors
OL = Operating License
CP = Construction Permit
IN 97-33 June 11, 1997 systems within prescribed operating ranges. Criterion 20, "Protection System Functions,"
requires that the protection system be designed to initiate operation of appropriate systems
to ensure that specified acceptable fuel design limits are not exceeded. Regulatory
Guide 1.105, "Instrument Setpoints," Revision 1, states that the accuracy of all setpoints
should be equal to or better than the accuracy assumed in the safety analysis, which
considers the ambient temperature changes, vibration, and other environmental conditions.
Transmitters that monitor tank level typically route the reference leg tubing to the top of the
tank in order to cancel the effect of tank overpressure on level indication. However, for tanks
that are vented, the level instrument reference legs are often vented to the atmosphere. It is
important that the reference leg accurately reflect the pressure that exists in the space above
the fluid level in the tank so that false levels are not indicated. It does not appear that
Waterford 3 appropriately accounted for the potential effects of different ventilation system
lineups on the RWSP level instruments. Such failure to appropriately account for all potential
environmental effects on protection system setpoints could result in an inability to mitigate
certain accidents.
Because additional testing at Waterford revealed that safety-related systems other than
RWSP level indications were affected by ventilation system operation, other licensees are
reminded that the level instrumentation for many systems at their plant may be subject to
similar problems.
This information notice requires rio 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.
original signed by S.H. Weiss for
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Phil Harrell, Region IV
Lee Keller, Region IV
(817) 860-8250
(504) 783-6253 E-mail: phh@nrc.gov
E-mail: lak@nrc.gov
Charles D. Petrone, NRR
301-415-1027 E-mail: cdpenrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:ICDP\\WAT3.INF- *SEE PREVIOUS CONCURRENCE - OFFICIAL RECORD COPY
To receive a copy of this document, Indicate In the box C=Copy wlo attachment/enclosure E=Copy wit attachment/enclosure N = No copy
OFFICE
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IN 97-XX
June,
1997 systems within prescribed operating ranges. Criterion 20, "Protection System Functions,"
requires that the protection system be designed to initiate operation of appropriate systems
to ensure that specified acceptable fuel design limits are not exceeded. Regulatory
Guide 1.105, "Instrument Setpoints," Revision 1, states that the accuracy of all setpoints
should be equal to or better than the accuracy assumed in the safety analysis, which
considers the ambient temperature changes, vibration, and other environmental conditions.
Transmitters that monitor tank level typically route the reference leg tubing to the top of the
tank in order to cancel the effect of tank overpressure on level indication. However, for tanks
that are vented, the level instrument reference legs are often vented to the atmosphere. It is
important that the reference leg accurately reflect the pressure that exists in the space above
the fluid level in the tank so that false levels are not indicated. It does not appear that
Waterford 3 appropriately accounted for the potential effects of different ventilation system
lineups on the RWSP level Instruments. Such failure to appropriately account for all potential
environmental effects on protection system setpoints could result in an inability to mitigate
certain accidents.
Because additional testing at Waterford revealed that safety-related systems other than
RWSP level indications were affected by ventilation system operation, other licensees are
reminded that the level instrumentation for many systems at their plant may be subject to
similar problems.
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.
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Phil Harrell, Region IV
Lee Keller, Region IV
(817) 860-8250
(504) 783-6253 E-mail: phh@nrc.gov
E-mail: lak@nrc.gov
Charles D. Petrone, NRR
301-415-1027 E-mail: cdpenrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:%CDP\\WAT3.INF- *SEE PREVIOUS CONCURRENCE - OFFICIAL RECORD COPY
To receive a copy of this document, Indicate in the box C=Copy wlo attachment/endosure E=Copy with attadiment/endosure N = No copy
OFFICE
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[5/09/97
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5/09/97
5/30/97
6/ /97
IN 97-XX
May,
1997 monitor variables and systems and that controls be provided to maintain these variables and
systems within prescribed operating ranges. Criterion 20, "Protection System Functions,"
requires that the protection system be designed to initiate operation of appropriate systems to
ensure that specified acceptable fuel design limits are not exceeded. Regulatory Guide
1.105, "Instrument Setpoints," Revision 1, states that the accuracy of all setpoints should be
equal to or better than the accuracy assumed in the safety analysis, which considers the
ambient temperature changes, vibration, and other environmental conditions.
Transmitters that monitor tank level typically route the reference leg tubing to the top of the
tank in order to cancel the effect of tank overpressure on level indication. However, for tanks
that are vented, the level instrument reference legs are often vented to the atmosphere. It is
important that the reference leg accurately reflect the pressure that exists in the space above
the fluid level in the tank so that false levels are not indicated. It does not appear that
Waterford 3 appropriately accounted for the potential effects of different ventilation system
lineups on the RWSP level instruments. Such failure to appropriately account for all potential
environmental effects on protection system setpoints could result in an inability to mitigate
certain accidents.
Because additional testing at Waterford revealed that safety-related systems other than
RWSP level indications were affected by ventilation system operation, other licensees are
reminded that the level Instrumentation for many systems at their plant may be subject to
similar problems.
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.
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Phil Harrell, Region IV
Lee Keller, Region IV
(817) 860-8250
(504) 783-6253 Email: phh@nrc.gov
Email: lak@nrc.gov
Charles D. Petrone, NRR
301-415-1027 E-mail: cdp@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:\\CDP\\WAT3.INF- *SEE PREVIOUS CONCURRENCE - OFFICIAL RECORD COPY
To receive a copy of this document, indicate in the box C=Copy wfo attachment/endosure E=Copy wbi attachmentenclosure N =
copy
1 OFFICE
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IN 97-XX
May , 1997 requires that the protection system be designed to initiate operation of appropriate systems to
ensure that specified acceptable fuel design limits are not exceeded. Regulatory Guide
1.105, "Instrument Setpoints," Revision 1, states, in part, that the accuracy of all setpoints
should be equal to or better than the accuracy assumed in the safety analysis, !ich
considers the ambient temperature changes, vibration, and other environmen
conditions.
Transmitters that monitor tank level typically route the reference leg tu
g to the top of the
tank in order to cancel the effect of tank overpressure on level i di
ion. However, for tanks
that are vented, the level instrument reference legs are often ye d to the atmosphere. It is
important that the reference leg accurately reflect the pressu
at exists in the space above
the fluid level in the tank so that false level indications are
generated. It does not appear
that Waterford 3 appropriately accounted for the potentia
ifects of different ventilation
system lineups on their RWSP level instruments. The
ilure to appropriately account for all
potential environmental effects on protection system etpoints could result in the inability to
mitigate certain accidents.
This information notice requires no specific a on 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 clear Reactor Regulation (NRR) project manager.
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
P Harrell, Region IV
17) 860-8250
mail: phhenrc.gov
Lee Keller, Region IV
(504) 783-6253 Email: lak@nrc.gov
Attachme
List of Recently Issued NRC Information Notices
D9 UMENT NAME: DOCUMENT NAME: G:XCDPWAT3.INF
To receive a py of this document, indicate in tem box C-Copy wlo attachment/endosure E=Copy with attachmentlendosure N = No copy
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