L-94-079, Responds to Request for Addl Info Re NRC Bulletin 90-001, Suppl 1, Loss of Fill-Oil in Transmitters Mfg by Rosemount
| ML17352A537 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/13/1994 |
| From: | Plunkett T FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-90-001, IEB-90-1, L-94-079, L-94-79, NUDOCS 9404200153 | |
| Download: ML17352A537 (7) | |
Text
ACCELERATED DISTRIBUTION DEMONS/RATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9404200153 DOC.DATE: 94/04/13 NOTARIZED: NO FACIL:50-250 Turkey Point Plant, Unit 3; Florida Power and Light C 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C AUTH.NAME AUTHOR AFFILIATION PLUNKETT,T.F.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to request for addi info re NRC Bulletin 90-001, Suppl 1, "Loss of Fill-Oil in Transmitters Mfg by Rosemount."
DISTRIBUTION CODE:
IE39D COPIES RECEIVED'LTR ENCL SIZE:
TITLE: NRC Bulletin 90-001, Loss of Fill Oil in Transmitters Mfg by NOTES DOCKET 05000250 05000251 D
Rosemoun /
A RECIPIENT ID CODE/NAME PD2-2 PD INTERNAL: NRR/DRPW/OGCB
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NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE %VASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 13 ENCL 13 A
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, FPL L-94-079 10 CFR 50.4 U.
S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
Subject:
Turkey Point Units 3 and 4
Docket Nos.
50-250 and 50-251 NRC Bulletin 90-01, Supplement 1
Loss of Fill-Oil in Transmitters Manufactured by Rosemount
Response
to Re uest for Additional Information By letter L-93-41, dated March 3, 1993, Florida Power
& Light Company (FPL) submitted a response to NRC Bulletin 90-01, Supplement 1,
"Loss of Fill-Oil in Transmitters Manufactured by Rosemount",
issued December 22, 1992.
7he purpose of this letter is to provide in the attachment additional information as requested by members of the NRC staffs If you have.any questions regarding this information, please contact us.
Very truly yours, T. F. Plunkett Vice President Turkey Point Plant Attachment TFP/OIH cc:
Stewart D. Ebneter, Regional Administrator, Region II, USNRC T. P. Johnson, Senior Resident Inspector,
- USNRC, Turkey Point Plant
> 806'">>3 9404200153 940413 PDR ADOCK 05000250 9
PDR an FPL Group company rP'99
Attachment to L-94-079 Page 1 of 4
INFORMATION REGARDING NRC BULLETIN 90-01
.SUPPLEMENT 1
As a result of FPL's submittal of March 3, 1993, the NRC staff has identified some additional information that is required to clarify FPL's position related to the Turkey Point Units 3 and 4
Enhanced Surveillance Program.
Re uested Action Item l.a NRC requests the following information regarding Rosemount transmitters which fall under Requested Action Item l.a:
1) 2)
Identify transmitters which have reached "maturity."-
Verify if extended surveillance intervals based on "maturity" is being considered.
Describe the acceptance criteria and justification for extending the surveillance, interval.
Per FPL letter L-93-41, dated March 3,
- 1993, FPL identified all safety related Rosemount Model 1153 Series B, Model 1153 Series D,
and Model 1154,transmitters manufactured before July 11,
- 1989, that have a normal operating pressure greater than 1500 psig and that are installed in reactor protection trip systems, Engineered Safety Features (ESF) actuation systems or Anticipated Transient Without Scram (ATWS) systems.
There are no transmitters in this group that are considered "mature."
Turkey Point does not plan to re-classify any transmitters in this category as "mature."
The transmitters will continue to be monitored on a monthly basis using the enhanced surveillance program until replacement; therefore, justification for other than monthly surveillance is not required.,
Re uested Action Item 1.b NRC requests the following information regarding Rosemount transmitters which fall under Requested Action Item l.b:
Verify if surveillance intervals will be extended for any transmitters which fall under this category, and provide the technical justification and acceptance criteria which will be used.
2.
Provide technical justification for extending the surveillance interval from quarterly to a refueling basis for the two transmitters identified as "mature."
Per FPL letter L-93-41, dated March 3,
- 1993, FPL identified all safety related Rosemount Model 1153 Series B, Model 1153 Series D,
and Model 1154 transmitters manufactured before July 11,
- 1989, that have a normal operating pressure greater than 1500 psig and that are used in safety related applications but are not installed in reactor protection trip systems, ESF actuation
Attachment to L-94-079 Page 2 of 4
systems or ATWS systems.
Turkey Point does not plan to re-classify 'any other transmitters in this category as "matured
The transmitters will continue to be monitored on a quarterly basis using the enhanced. surveillance program until replacement.
Therefore, justification for other than a quarterly surveillance is not required.
FPL identified two transmitters in Action. Category 1.b as having reached time-at-pressure "maturity" per the guidance provided in Supplement 1 of Bulletin 90-01-and Rosemount Technical Bulletin Number 4.
LT-3-462 and LT-4-462, wide range pressurizer level transmitters, measure pressurizer level for wide range indication on the alternate shutdown panel in the event of control room evacuation.
LT-3-462 and LT-4-462 are Rosemount 1153 Series D
units 'of Range Code 5
~
Rosemount Technical Bulletin Number 4
specifies a "maturity" criterion of 60,000 psi-months for all pressure transmitters of Range Codes 3 through 5.
LT-3-462 has accumulated 115,000 psi-months of operation, and LT-4-462 has accumulated 155,000 psi-months.
These times far exceed the criterion of 60,000 psi-months specified by Rosemount Technical Bulletin 4.
Additionally, review of the two transmitters'istorical performance data verified they have not exhibited loss of fill-oil symptoms'ased on the large number of psi-months without loss of fill-oil
- symptoms, LT-3-462 and LT-4-462 will be monitored as part of the enhanced surveillance program at least once every refueling, but not exceeding 24 months.,
Re uired Action 1.e For those transmitters which have a normal operating pressure greater than 500 psig and less than or equal to 1500 psig, have reached the appropriate psi-month threshold criterion recommended by Rosemount, and are excluded from the enhanced surveillance.
- program, address how confidence will be maintained in the ability to detect transmitter failures.
FPL letter L-93-41, dated March 3, 1993, provided FPL's response to NRC Bulletin 90-01; Supplement 1, Required Action Items 1.c and 1.d as it applies to Turkey Point Units 3 and 4.
Required Action Items 1.c and 1.d address Rosemount Model 1153 and Model 1154 transmitters manufactured before July 11, 1989, that have a
normal pressure greater than 500,psig but less than 1500 psig and perform a safety related function.
There are no transmitters in this group that are considered "mature."
Turkey Point does not plan to re-classify any transmitters in this category as "mature."
The transmitters which fall under Required Action Item l.c will continue to be monitored on a monthly basis using the enhanced surveillance program until replacement; therefore, a
high degree of confidence is maintained for detecting loss of fill-oilfailures..
The transmitters which fall under Required Action Item 1.d will continue to be monitored at least once every
III
Attachment to L-94-079 Page 3 of 4
refueling, but not exceeding 24 months, using the enhanced surveillance program until replacement.
Therefore, a high degree of confidence is maintained for detecting loss of fill-oil failures.
Re uired Action 1.f For those transmitters which have a normal operating pressure less than or equal to 500 psig and are excluded from the enhanced surveillance
- program, address how confidence will be maintained in the ability to detect transmitter failures.
Rosemount Technical Bulletin 4 reports an acceptably low risk of transmitter failure for operating pressures below 250 psig.
On this basis, FPL has excluded from the enhanced surveillance program all safety related transmitters that have normal operating pressures less than or equal to 250 psig.
Safety related transmitters that have normal operating pressures greater than 250 psig and less than or equal to 500 psig have been excluded from the enhanced surveillance program based on other bulletin criteria, namely transmitters which are Rosemount Model 1153 Series A, or transmitters which have a sensor modul'e serial number greater than 2182605.
Transmitters which are excluded from the enhanced surveillance program are tested in accordance-with the applicable surveillance procedures.
Transmitters found to be sluggish during standard calibration will be evaluated in accordance with the guidance provided in Rosemount Technical Bulletin 4, Appendix B.
Therefore, a high degree of confidence is maintained for detecting loss of fill-oilfailures.
Re uested Action 2
Provide details of the Turkey Point Units 3 and 4 enhanced surveillance program.
Turkey Point Units 3 and 4 enhanced surveillance program is based on the guidance and recommendations of Rosemount Technical Bulletin 4.
Rosemount has developed diagnostic guidelines that can be used to monitor and identify transmitters suspected of loss of fill-oil. The Turkey Point Units 3 and 4 enhanced surveillance program utilizes the output drift analysis and sluggish response diagnostic guidelines of Rosemount Technical Bulletin 4.
The output drift.'analysis can be divided into two types of analyses:
- 1) normal calibration data analysis which uses the as-found and as-left data to determine cumulative positive or negative drift trends,
- 2) operating data analysis which involves trending and comparison of actual operating data on processes with redundant transmitters to identify loss of fill-oil symptoms.
Attachment to L-94'-079 Page 4 of 4
The enhanced surveillance program for transmitters which fall under the requirements of Requested Actions l.a and 1.b follows the recommendations of Rosemount Technical Bull'etin 4 Appendices A and B.
The surveillance will be performed monthly or quarterly, as -specified in FPL letter L-93-41,
Response
to Requested Actions l.a and 1.b.
The Turkey Point Units 3 and 4
enhanced surveillance program monitors redundant, on-line transmitters simultaneously using the Emergency
Response
Data Acquisition and Display System (ERDADS).
The periodic change observed in the data obtained from the ERDADS will be compared against the drift criteria specified by Rosemount Technical Bulletin 4, Appendix A, Table A1.
Channels which exhibit excessive.drift will be evaluated.
Additionally, transmitters found to be sluggish during standard calibration will be evaluated in accordance with the guidance provided in Rosemount Technical Bulletin 4, Appendix BE The enhanced surveillance program for transmitters which fall under the requirements of Requested Actions 1.c and 1.d follows the recommendations of Rosemount Technical Bulletin 4 Appendices.
A and B.
Using existing plant surveillance procedures, transmitter response will be evaluated during standard calibration on a refueling outage basis with intervals not to exceed 24 months.
Drift data will be collected and trending will be performed by comparing the as-found data with the as-left data'ny transmitter that approaches or reaches the maximum allowable cumulative drift as defined in Rosemount Technical Bulletin 4, Appendix A, Table A1, will be evaluated.
Additionally, transmitters found to be sluggish during standard calibration will be evaluated in accordance with the guidance provided in Rosemount Technical Bulletin 4, Appendix B.