L-94-021, Evaluation of Util Response to Suppl 1 to NRC Bulletin 90-01:Millstone-2/-3

Evaluation of Util Response to Suppl 1 to NRC Bulletin 90-01:Millstone-2/-3

ML20078N592
Person / Time
Site:	Millstone
Issue date:	11/30/1994
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20078N596	List: L-94-021, Evaluation of Util Response to Suppl 1 to NRC Bulletin 90-01:Millstone-2/-3
References
CON-FIN-L-1695 IEB-90-001, IEB-90-1, INEL-94-0214, INEL-94-214, TAC-M85409, TAC-M85410, NUDOCS 9412070142
Download: ML20078N592 (22)

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Evaluation of Utility Response to Supplement 1 to NRC Bulletin 90-01:

Millstone-2/-3 Idaho National l Engineering Laboratory MLockfieed

~~ldaho Technologies Company

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INEL-94/0214 TECHNICAL EVALUATION REPORT Evaluation of Utility Response to Supplement 1 to NRC Bulletin 90-01: M111 stone-2/-3 Docket No. 50-336 and 50-423 Alan C. Udy Published November 1994 Lockheed Idaho Technologies Company Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 1

Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 and for the U.S. Department of Energy Under DOE Idaho Operations Office Contract DE-AC07-941013223 FIN Nos. L1695, Task No. 11a TAC Nos. M85409 and M85410

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SUMMARY

This report documents the Lockheed Idaho Technologies Company review of the Northeast Nuclear Energy Company submittals that respond to Supplement 1 to NRC Bulletin 90-01 for the Millstone Nuclear Power Station, Unit Nos. 2 and

3. This NRC Bulletin provides information on the loss of fill-oil in certain pressure and differential pressure transmitters manufactured by Rosemount, Inc. This report finds the licensee complies to the requested actions and the reporting requirements of the Supplement. i FIN No. L1695, Task No. 11a B&R No. 320-19-15 05-0 '

Docket Nos. 50-336 and 50-423 TAC Nos. M85dO9 and M85410 11

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PREFACE  !

This report is supplied as part of the " Technical Assistance in Support of the Instrumentation and Controls Systems Branch." It is being conducted for the U.S. Nuclear Regulatory Comission, Office of Nuclear Reactor Regulation, Division of Reactor Controls and Human Factors, by Lockheed Idaho Technologies Company, National Nuclear Operations Analysis Department.

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4 CONTENTS

SUMMARY

................................................................ 11 PREFACE ................................................................ 111

1. INTRODUCTION ..................................................... 1

2. NRC SPECIFIED REQUESTED ACTIONS .................................. 4

3. EVALUATION ....................................................... 7 3.1 Evaluation of Licensee Response to Reporting Requirements .. 7 3.2 Evaluation of Licensee Response to Requested Actions ....... 8

4. CONCLUSIONS ...................................................... 13

5. REFERENCES ....................................................... 14 1

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O Evaluation of Utility Response to Suoolement I to NRC Bulletin 90-01: M111 stone-2/-J

1. INTRODUCTION The NRC issued Bulletin 90-01 on March 9, 1990 (Reference 1). That Bulletin discussed certain Rosemount pressure and differential pressure transmitter models identified by the manufacturer as prone to fill-oil leakage. The Bulletin requested licensees to identify whether these transmitters were or may later be installed in safety-related systems.

Actions were detailed for licensee implementation for certain identified transmitters installed in a safety-reiated system. These same actions apply to those identified transmitters presently held in inventory for later installation in a safety related system, With the gradual leakage of fill-oil, the transmitter would not have the long term accuracy, time response, and reliability needed for its intended  :

safety function. Further, this condition could go undetected over a long '

period. Redundant instrument channels are subject to the same degradation mechanism. This increases the potential for a common mode failure. Thus, this potential failure mechanism raised concern for the reliability of reactor protection systems (RPS), engineered safety features (ESF) actuation systems, ,

and anticipated transient without scram (ATWS) mitigating systems. To achieve high functional reliability, there must be a low probability of component [

failure while operating, with any failures readily detectable.

Supplement I to NRC Bulletin 90-01 (Reference 2) was issued on December 22, 1992. The Supplement informed licensees of NRC staff activities regarding the subject transmitters, and noted continuing reports of transmitter failures. The NRC requested licensee action to resolve the issue.

The Supplement also updated the information contained in the original Bulletin. The licensee was requested to review the information and determine if it was applicable at their facility. Further, the licensee was requested to modify their actions and enhanced surveillance monitoring programs to conform with the direction given. Finally, the licensee was instructed to 1

respond to the NRC. The Reauested Actions in Supplement 1 to NRC Bulletin 90-01 supersede the original NRC Bulletin 90-01 Reauested Actions.

In responding to Supplement 1 to NRC Bulletin 90-01, the licensee is directed to address three items.

1. A statement either committing the licensee to take the NRC Bulletin 90-01, Supplement 1, Reauested Actions or taking exception to those actions.

2. Addressing the actions committed to in the above statement, provide:

a. a list of the specific actions, including any justifications, to be taken to complete the commitment,

b. a schedule for completion, and

c. after completion, a statement confirming the actions comitted to are complete.

3. A statement identifying the NRC Bulletin 90-01, Supplement 1, l

Reauested Actions not taken, along with an evaluation providing the basis for exemption. t In implementing the replacement option of the NRC Reauested Actions, plant shutdown exclusively for replacing the transmitters is not required.

This allowance infers that replacements can be scheduled. With replacement in a timely manner, enhanced surveillance monitoring for interim operation is not l required.

The Northeast Nuclear Energy Company, the licensee for the Millstone j Nuclear Power Station, Unit Nos. 2 and 3, responded to Supplement 1 of NRC l

Bulletin 90-01 with a letter dated March 4, 1993 (Reference 3). That submittal also provided the responses for Unit No.1 of the Millstone Nuclear Power Station and for the Haddam Neck Plant. These two units (Unit No. 1 of the Millstone Nuclear Power Station and the Haddam Neck Plant) do not have 2

Rosemount transmitters that are subject to the Supplement. The response incorporated information from carlier responses to the Bulletin dated July 3, 1990 (Reference 4), and March 26, 1991 (Reference 5). The licensee provided additional information on August 12, 1994 (Reference 6). This technical evaluation report evaluates the completeness of those submittals. It also determines whether proposed surveillance methods are adequate to determine fill-oil loss-caused degradation of the transmitter. Finally, this report addresses the interval of surveillance proposed by the licensee for any transmitters included in the enhanced surveillance monitoring program.

Many Rosemount transmitter failures have been attributed to the use of stainless steel "0"-rings between the sensing module and the process flanges.

Rosemount improved the manufacturing process for transmitters manufactured after July 11, 1989. Those improvements included a limit of the torque ,

applied to the flange bolts. This limits the stress caused in the sensing module by the "0"-ring. Post-production screening, including pressure testing of the sensing module for this potential latent defect, was also implemented at that time. Therefore, as described in Supplement I of NRC Bulletin 90-01, those Rosemount transmitters manufactured after July 11, 1989, are not subject to this review.

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2. NRC SPECIFIED REQUESTED ACTIONS i

The NRC staff specified the following Reauested Actions of licensees of  !

operating reactors.

1. Review plant records and identify the following Rosemount transmitters (if manufactured before July 11,1989) that either are used in or may be used in either safety-related or ATWS mitigating systems.

• Rosemount Model 1153, Series B

• Rosemount Model 1153, Series D

• Rosemount Model 1154 Following identification, the licensee is to establish the following:

a. For those identified transmitters having a normal operating pressure greater than 1500 psi, and are installed as part of

, reactor protection trip systems, ESF actuation systems, or ATWS mitigating systems, either replace the transmitter in an expedited manner,. or monitor monthly, for the life of the transmitter, using an enhanced surveillance program.

l If the identified transmitter exceeds the 60,000 psi-month or the l 130,000 psi-month criterion (depending on the range code of the transmitter) established by Rosemount, enhanced survsillance on a l refueling (not exceeding 24 months) basis is acceptable. Under i this option, justification must be based on the service record and  :

That the specific safety function of the transmitter.

justification can be based on high functional reliability provided i by redundancy or diversity.

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b. For those identified transmitters having a normal operating  :

pressure greater than 1500 psi, and are installed as part of a  :

I safety-related system other than reactor protection trip systems, l ESF actuation, or ATWS mitigating systems, either replace the l transmitter or monitor quarterly, for the life of the transmitter, <

l using an enhanced surveillance program.

1 i If the identified transmitter exceeds the 60,000 psi-month or the 130,000 psi-month criterion (depending on the range code of the transmitter) established by Rosemount, enhanced surveillance on a l refueling (not exceeding 24 months) basis is acceptable. Under i this option, justification must be based on the service record and the specific safety function of the transmitter. That 4 ,

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justification can be based on high functional reliability provided by redundanc) or diversity.

c. For boiling water reactors (BWR)--

For those identified transmitters having a normal operating pressure greater than 500 psi and less than or equal to 1500 psi, and are installed as part of' reactor protection trip systems, ESF actuation systems, or ATWS mitigating-systems, either replace the transmitter, or monitor monthly with an enhanced surveillance monitoring program, until the transmitter reaches the designated (by Rosemount) psi-month "

criterion (60,000 psi-month or 130,000 psi-month, depending on the transmitter range code).

For transmitters that provide signals to the RPS or ATWS trips for high pressure or low water level, the enhanced surveillance must be monthly. For other transmitters in t this classification, enhanced surveillance on a refueling (not exceeding 24 months) basis is acceptable. Under this option, justification must be based on the service record and the specific safety function of the transmitter. That justification can be based on high functional reliability provided by redundancy or diversity.

For pressurized water reactors (PWR)--

For those identified transmitters having a normal operating pressure greater than 500 psi and less than or equal to 1500 psi, and are installed as part of reactor protection trip systems, ESF actuation systems, or ATWS mitigating  ;

systems, either replace the transmitter, or monitor with an enhanced surveillance monitoring program, until the transmitter reaches the designated (by Rosemount) psi-month criterion (60,000 psi-month or 130,000 psi-month, depending on the transmitter range code) cn a refueling (not exceeding 24 months) basis,

d. For those identified transmitters having a normal operating pressure greater than 500 psi and less than or equal to 1500 psi, and are installed as part of a safety-related system other than reactor protection trip systems, ESF actuation, or ATWS mitigating systems, either replace the transmitter or monitor with an enhanced surveillance monitoring program, until the transmitter reaches the designated (by Rosemount) psi-month criterion (60,000 psi-month or 130,000 psi-month, depending on the transmitter range code) on a refueling (not exceeding 24 months) basis.

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e. Those transmitf.ers.having a normal operating pressure greater than 500 psi and less than or equal to 1500 psi, and have accumulated sufficient psi-month operating history to exceed the criterion established by Rosemount, may be excluded from the enhanced surveillance monitoring program at the discretion of the licensee.

However, the licensee should retain a high level of confidence that a high level of reliability is maintained and that transmitter failure due to loss of fill-oil is detectable.

f. Those transmitters having a normal operating pressure less than or equal to 500 psi may be excluded from the enhanced surveillance monitoring program at the discretion of the licensee. However,  :

the licensee should retain a high level of confidence that a high level of reliability is maintained and that transmitter failure due to loss of fill-oil is detectable.

2. Evaluate the enhanced surveillance monitoring program. The evaluation is to ensure the measurement data has an accuracy commensurate with the accuracy needed to compare the data to the manufacturers drift data criteria. It is this comparison that determines the degradation threshold for loss of fill-oil failures of the subject transmitters.

The Supplement also states the NRC may conduct audits or inspections in the future to verify compliance with the established requirements.

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3. EVALUATION The licensee responded to Supplement I of NRC Bulletin 90-01 on March 4, 1993. That response referred to earlier responses to the Bulletin dated July 3, 1990, and March 26, 1991. The licensee furnished additional information on August 12, 1994. Those responses were compared to the Bulletin Reportina Raouirements and Reauested Actions as described below. The licensee reports having 2 Rosemount transmitters in Unit No. 2 and 105 Rosemount transmitters in Unit No. 3 of the Millstone Nuclear Power Station that are subject to the' Reauested Actions of the Supplement. The licensee also noted, in Reference 3, that Millstone-1 and Haddam Neck had no Rosemount transmitters that are subject to the Reauested Actions of the Supplement. Other Rosemount  !

transmitters at Unit Nos. 2 and 3 of the Millstone Nuclear Power Station are outside the scope of the Supplement due to replacement, refurbishment, or use in non-safety applications. 3 3.1 Evaluation of Licensee Response to Reportina Reauirements The licensee states they have taken the Reauested Actions detailed in Supplement 1 of NRC Bulletin 90-01. Included with that statement is clarification, interpretation, and the limits piaced on that commitment. The licensee described the specific actions taken in response to the Requested Actions in Reference 3. The licensee also refers to previous submittals (References 4 and 5) in response to the original NRC Bulletin 90-01 that ,

describe the enhanced surveillance program.

The Reference 3 submittal identifies where the licensee action deviates from the requirements of the Supplement. The licensee provides evaluation and justification supporting that the deviation is acceptable. The licensee has determined that, based on the existing enhanced surveillance program, the specific applications, and available backup displays, replacement of  !

transmitters in any transmitter classification is not necessary.

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The licensee submittals conform to the Reportina Reauirements of Supplement 1 of NRC Bulletin 90-01.

3.2 Evaluation of Licensee Response to Reauested Actions Supplement 1 of NRC Bulletin 90-01 requested licensee action to resolve the issue of fill-oil leakage in Rosemount transmitters. This Technical Evaluation Report summarizes the Reauested Actions and the associated transmitter criteria in Section 2. The licensee identified a total of two transmitters at Millstone Unit No. 2 and 105 transmitters at Millstone Unit No. 3 that are in the scope of this review. The following sections discuss the licensee response to the Supplement.

3.2.1 Licensee Resoonse to Reauested Actions 1.a and 1.b Unit No. 2 The licensee has 2 Rosemount transmitters, LT-110X and LT-110Y, that monitor the pressurizer level at a nominal pressure of 2250 psig. The licensee includes these transmitters in their enhanced surveillance program.

The licensee monitors these transmitters by trending the accumulative refueh.ig calibration data and computerized comparisons of the redundant signals, using the Offsite Facility Information System. The licensee makes this comparison 3 times in each 60 day period. The licensee allows the timeliness of this schedule to deviate up to 25%. Refueling intervals do not exceed 24 months. Based on the licensee description, we find the enhanced surveillance program for these Unit No. 2 transmitters acceptable.

Unit No. 3 The 28 Rosemount transmitters in these two transmitter classifications participate in the enhanced surveillance program.

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The licensee trends the calibration data from five transmitters. The [

calibration interval does not exceed 24 months. Additionally, the licensee l monitors these transmitters, which have no redundant transmitter, with a t

personal computer program. The program looks for variance from the prior j recorded signals of the nominally constant fic r <te. The monitoring occurs 3 times in each 60 day period. The licensee allu.~ the timeliness of.this j schedule to deviate up to 25%. Rosemount Technical Bulletin No. 4 l

acknowledges that this method is effective in monitoring transmitters where

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the process is relatively constant. 1 i

Four transmitters, 3HVC-PT73A, 3HVC-PT738, 3SIH-FT917, and 3RCS-PT403A, i have an installed service life of greater than 80,000 psi-months. They show no drift indicative of a defect or a loss of fill-oil. The licensee described '

the application and use of these transmitters. The licensee states they will i trend the refueling interval calibration data from these four transmitters. l 3  !

The operations department performs channel checks on 2 Rosemount  !

transmitters in these transmitter classifications. The channel checks compare  :

the signals of redundant channels. The licensee performs these channel checks l

3 times in each 60 day period. The licensee allows the timeliness of this i schedule to deviate up to 25%. Additionally, the licensee trends the l

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, calibration data from these transmitters.  ;

i The licensee incorporated 17 transmitters from these transmitter classifications in a computerized monitoring system that tracks drift and drift rate 3 times in each 60 day period. The licensee allows the timeliness i of this schedule to deviate up to 25% while in Modes 1 and 2, with the reactor coolant system pressurized. With pressurization, the comparison is possible.

This deviation from the strict monitoring frequency required by the Supplement  ;

is acceptable, because operation at pressure is the primary factor driving the j

, failure mechanism. When not in Modes 1 or 2, the failure mechanism is not i 1

. significant. '

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P Based on the licensee description, we find the enhanced surveillance i program for Unit No. 3 transmitters in transmitter classifications 1.a and 1.b l acceptable.

i 3.2.2 Licensee Resnonse to Reauested Action 1.c and 1.d Unit No. 2 The licensee does not have Rosemount transmitters in these transmitter classifications at Unit No. 2 of the Millstone Nuclear Power Station. .

Unit No. 3 '

The licensee lists 22 Rosemount transmitters in these two transmitter.

classifications at Unit No. 3 of the Millstone Nuclear Power Station.  ;

Four transmitters show no drift indicative of a defect or a loss of fill-oil. The licensee described the application and use of these j transmitters. The licensee states they will trend the refueling interval ,j '

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calibration data from these four transmitters.

The licensee incorporated 18 transmitters from these transmitter ,

classifications in a computerized monitoring system that tracks drift and l drift rate 3 times in each 60 day period. The licensee allows the timeliness of this schedule to deviate up to 25% while in Modes 1 and 2, with the reactor coolant system pressurized. With pressurization, the comparison is possible.  ;

This deviation from the strict monitoring frequency required by the Supplement is acceptable, because operation at pressure is the primary factor driving the i failuremehhanism. When not in Modes 1 or 2, the failure mechanism is not significant.

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Based on the licensee description, we find the enhanced surveillance '

program for Unit No. 3 transmitters in transmitter classifications 1.c and 1.d  !

-acceptable.

3.2.3 Licensee Resnonse to Reauested Action 1.e  !

Unit No. 2  :

The licensee does not have Rosemount transmitters in tbis transmitter  !

classification at Unit No. 2 of the Millstone Nuclear Power Station.

Unit No. 3 l l

The licensee states they are not excluding any transmitters in this transmitter classification from the enhanced surveillance program. The  !

licensee states, in Reference 3, that they may exclude these transmitters from f the enhanced surveillance program if warranted in the future by the individual j transmitter situation. If the licensee later excludes eligible transmitters from the enhanced surveillance program, calibration data, taken on a 24-month interval, if outside acceptance limits, triggers a failure analysis. The l failure analysis determines if any trend towards transmitter failure is  :

evident. The licensee states that this will identify any Rosemount  ;

transmitter failing due to loss of fill-oil. This provides the confidence and I capability required by the Supplement.

i 3.2.4 Licensee Resnonse to Reauested Action 1.f l 1

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The licensee does not have Rosemount transmitters in this transmitter  !

classification at Unit No. 2 of the Millstone Nuclear Power Station. t L

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Unit No. 3

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The licensee states that the 55 Rosemount transmitters that make up this transmitter classification will not continue in the enhanced surveillance f program. The Supplement pemits this action. However, the licensee must maintain confidence in the transmitters and in their ability to detect a loss of fill-oil failure. Calibration data, taken on a 24-month interval, if  ;

outside acceptance limits, triggers a failure analysis. The failure analysis -

determines if,any trend towards transmitter failure is evident. The licensee states that this will identify any Rosemount transmitter failing due to loss ,

of fill-oil. This provides the confidence and capability required by the Supplement.

3.2.5 Enhanced Surveillance Monitorina Proaran ,

The licensee states their vnhanced surveillance program provides data accurate enough for comparison to the Rosemount drift data limits. Most of the monitored transmitters provide data to the plant computer system. The (

licensee downloads this data to a PC-based analysis program. The licensee '

trends redundant channels with detailed plots maintained specifically to check I for transmitter drift. If the licensee finds the drift is greater than the l Rosemount guidelines, the licensee initiates further testing of the suspect '

transmitter. For instruments with no redundant transmitters, the licensee i measures the variance of the transmitter on-line signal and trends calibration  ;

data on a refueling basis. Calibration data are accurate to three decimal pl aces. Based on the surveillance programs described by the licensee, the  !

M111 stone-2/-3 enhanced surveillance program is acceptable.

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4. CONCLUSIONS ,

Based on our review, we find the licensee has completed the reporting I requirements of Supplement 1 of NRC Bulletin 90-01. Further, the licensee conforms to the requested actions of Supplement I to NRC Bulletin 90-01.

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5. REFERENCES

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1. NRC Bulletin No. 90-01: ' Loss of Fill-oil in Transmitters Manufactured by Rosemount," March 9, 1990, OMB No. 3150-0011.  !

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2. NRC Bulletin No. 90-01, Supplement 1: " Loss of Fill-oil in Transmitters l Manufactured by Rosemount," December 22, 1992, OMB No. 3150-0011.

3. Letter, Northeast Nuclear Energy Company (J. F. Opeka) to NRC, " Response to NRC Bulletin 90-01, Supplement 1, Loss of Fill-011 in Transmitters Manufactured by Rosemount," March 4, 1993, B14381.

4. Letter, Northeast Nuclear Energy Company (E. J. Mroczka) to NRC, "NRC Bulletin 90-01, Loss of F111-011 in Transmitters Manufactured by Rosemount," July 3, 1990, A08646.

l 5. Letter, Northeast Nuclear Energy Company (E. J. Mroczka) to NRC, "NRC Bulletin 90-01, Loss of F111-011 in Transmitters Manufactured by Rosemount," March 26, 1991, A08646.

6. Memo, Northeast Nuclear Energy Company, S. I. Stricker to R. Joshi, "NRC Request for Information Concerning NNECO's Response to NRC Bulletin No. 90-01, Supplement 1 - Loss of Fill-Oil in Rosemount Transmitters,"

August 12, 1994, MP3-TS-94-614.

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NRC FOR3 336 U.S. NUCLEAR REOULATCf.Y CO%Mi&SION 1. REPOAT NUMBEA (2-89) '*"****""*******'"*"'"'"*d"'-

NRCM 1102, 3201,3202 BIBLIOGRAPHIC DATA SHEET INEL-94/0214 is wm . e. , .,..>

2. TITLE AND SUBTITLE 3. DATE MEPORT PUBLISHED Evalustion of Utility Response to Supplement I to MONm YEAR NRC Bulletin 90-01: Millstone-2/-3 November 1994 _

4. FN OR GRANT NUMBER L1695

6. AUTHOR (S) 6. TYPE OF REPORT Alan C. Udy Technical Evaluation l

7. PERIOD COVERED

8. PERFORM NG ORGANIZATION . NAME AND ADDRESS w s-wen.. u -

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National Nuclear Operations- Analysis Lockheed Idaho Technologies Company P.O. Box 1625 Idaho Falls, ID 83415-3870

9. 8PONSORING ORGANIZATION NAME AND ADDRESS w s . e n ee .. u ,-

Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

10. SUPPLEMENTARY NOTES 11.A8STRACTa. .

This report documents the Lockheed Idaho Technologies Company review of the Northeast Nuclear Energy Company submittals that respond to Supplement 1 to NRC Bulletin 90-01 for the Millstone Nuclear Power Station, Unit Nos. 2 and 3. This NRC bulletin provides information regarding the loss of fill-oil in certain pressure and differential pressure transmitters manufactured by Rosemount, Incorporated. This report finds the licensee conforms to the requested actions and the reporting requirements of the supplement.

12. KEY WOR 05/DESCRIPTOR6 n. .- . 13. AVAILABILITY STATEMENT Rosemount Transmitters Unlimited Distribution

" " '***'" ^" "

B 11 -01, Supplement 1 c~

Unclassified c .-

Unclassified

15. NUMBER OF PAGES

16. PRICE l

NHC FORM 33b (2 88)

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SALP INPUT i

FACILITY NAME: Millstone Nuclear Power Station Units 2 and 3 i

SUMMARY

OF REVIEW The staff completed its review of the licensee's response to Nuclear Regulatory Commission Bulletin 90-01 Supplement 1, submitted by the Northeast Nuclear Energy Company for the Millstone Nuclear Power Station. The staff finds the licensee's response for this item acceptable.

NARRATIVE DISCUSSION OF LICENSEE PERFORMANCE - FUNCTIONAL ARE&

The initial response provided to meet the requested actions was adequate for staff review. '

L Author: D. Spaulding Date: December 1, 1994  ;

I ATTACHMENT 3 J

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