ML13331A461
| ML13331A461 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/19/1990 |
| From: | Nandy F SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-PT21-90 IEB-90-001, IEB-90-1, NUDOCS 9007230070 | |
| Download: ML13331A461 (11) | |
Text
0 Southern California Edison Company 23 PARKER STREET IRVINE, CALIFORNIA 92718 F. R. NANDY July 19, 1990 TELEPHONE MANAGER. NUCLEAR LICENSING (714) 587-5400 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket Nos. 50-206, 50-361 and 50-362 NRC Bulletin 90-01: "Loss of Fill-Oil in Transmitters Manufactured by Rosemount" San Onofre Nuclear Generating Station Units 1, 2 and 3 This letter provides Southern California Edison's (SCE's) response to NRC Bulletin 90-01: "Loss of Fill-Oil in Transmitters Manufactured by Rosemount,"
for San Onofre Units 1, 2 and 3. The details of the response to the bulletin are documented in the enclosure to this letter and are summarized below.
SCE complies with the staff's requests in NRC Bulletin 90-01.
SCE has identified all Rosemount models 1153 Series B, 1153 Series D, and 1154 transmitters manufactured prior to July 11, 1989, that are in use at San Onofre Nuclear Generating Station (SONGS).
SCE has ensured that Rosemount transmitters from the manufacturing lots having a high failure fraction are not in use at SONGS in either safety-related systems or systems installed in accordance with 10 CFR 50.62 (the Anticipated Transient Without Scram (ATWS) rule).
SCE has replaced the only transmitter of a suspect lot found at SONGS Unit 2. This transmitter was used for the non-safety related condensate storage tank level indication on the remote shutdown panel which does not provide any automatic control or protective function. An evaluation as described in the enclosure has confirmed that none of the currently installed transmitters exhibited symptoms of loss of fill-oil.
The enhanced monitoring program, detailed in the enclosure, is in effect for the Rosemount transmitter models used in safety related or ATWS applications at Units 2 and 3. There are no Rosemount transmitters installed at Unit 1 used for safety related or ATWS applications.
SCE bases the justification for continued operation on the determination that there are no suspect transmitters in service at SONGS and the transmitters in service, identified in Attachment 1, are not presently exhibiting symptoms of loss of fill-oil.
An operability analysis of any transmitters which are suspected in the future of loss of fill-oil will include a justification for continued operation.
F F:R T F0 Fi:
+/-
Document Control Desk
-2 The information requested on transmitters that have experienced loss of fill oil is provided in the enclosure. However, since there are no Rosemount transmitters in the suspect lots installed at SONGS, a replacement schedule is not necessary. Reportablity requirements will be evaluated for any Rosemount transmitter Model 1153 Series B or D and Model 1154 that exhibit symptoms of loss of fill-oil in the future.
If you have any questions or comments, please contact me.
Respectfully submitted, F. R. Nandy J
Manager, Nuclear Licensing Subscribed and sworn t before me this
/ 9 day of <
j OFFICAL SEAL
/
/
YOMAR V. CLEARY Noar Pubi Fmla ORANGE COUNTY ZL My Comm. Exp. May 8.1992 Notary -ublic in the State 4/
of Ca fornia Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V C. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3 James E. Tatum, US NRC SONGS, Project Manager
Enclosure RESPONSE TO BULLETIN 90-01 San Onofre Units 1, 2 and 3 la) REQUESTED ACTIONS 1, 2, 3, 4 AND 5.
SCE has completed Requested Actions 1, 2, 3, 4 and 5. A summary of each action taken is provided below:
NRC Requested Action 1.
Identify Model 1153 Series B, 1153 Series D, and Model 1154 pressure or differential pressure transmitters, excluding Model 1153 Series B, 1153 Series D, and Model 1154 transmitters manufactured by Rosemount subsequent to July 11, 1989, that are currently utilized in either safety-related systems or systems installed in accordance with 10 CFR 50.62 (the ATWS rule).
SCE Response identifies the Rosemount Model 1153 Series B, 1153 Series D, and Model 1154 pressure transmitters manufactured by Rosemount prior to July 11, 1989, that are currently utilized in either safety-related systems or systems installed in accordance with 10 CFR 50.62 (the ATWS rule) at Units 2 and 3. There are no Rosemount transmitters installed at Unit 1 used for safety-related or ATWS applications. Review of plant design documentation confirmed there is no pressure or differential pressure transmitter installed at SONGS Unit 1, 2 or 3 using the Rosemount sensing cells which has been supplied by another manufacturer.
NRC Requested Action 2.
Determine whether any transmitters identified in Item 1 are from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil.
Addressees are requested not to utilize transmitters from these suspect lots in the reactor protection or engineered safety features actuation systems; therefore, addressees are requested to develop and implement a program to replace, at the earliest appropriate opportunity, transmitters from these suspect lots in use in the reactor protection or engineered safety features actuation systems.
1
SCE Response SCE reviewed all instrument calibration records for Rosemount transmitters on Units 1, 2, and 3, and only one transmitter was found installed from the suspect lots. This transmitter, 2LT4356, provided condensate storage tank level indication on the remote shutdown panel.
This transmitter was classified safety related for pressure boundary only. Even though no symptoms of loss of fill-oil were exhibited, and the transmitter did not perform a safety-related function, it was replaced to eliminate any suspect lot transmitter from use at SONGS.
SCE has verified all spare transmitter serial numbers in the warehouse and found no transmitters from the suspect lots. Spare Rosemount transmitters, designated for use in safety related or ATWS systems are being returned to Rosemount for exchange with transmitters manufactured after July 11, 1989.
In addition to the serial numbers obtained from instrument calibration data records, a walk down of the Attachment 1 Rosemount transmitter serial numbers was completed at Unit 3 during the Cycle 5 refueling outage, and no discrepancies were found. A similar walk down is planned for Unit 2 at the next outage of sufficient duration.
NRC Requested Action 3.
Review plant records (for example, the three most recent calibration records) associated with the transmitters identified in Item 1 above to determine whether any of these transmitters may have already exhibited symptoms indicative of loss of fill-oil.
Appropriate operability acceptance criteria should be developed and applied to transmitters identified as having exhibited symptoms indicative of loss of fill-oil from this plant record review. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria should be addressed in accordance with the applicable technical specification. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria and are not addressed in the technical specifications should be replaced at the earliest appropriate opportunity.
SCE Response Plant calibration records for all safety related and non-safety related Rosemount transmitters were reviewed to determine whether any transmitters may have already exhibited symptoms indicative of loss of fill-oil.
The Rosemount Technical Bulletin No. 4 dated December 22, 1989 Appendix A "Drift Analysis Guideline" was utilized for guidance in this evaluation. This evaluation, a review of post trip review packages for the past two years, and concurrent testing confirmed that none of the currently installed transmitters exhibited symptoms of loss of fill-oil.
2
NRC Requested Action 4.
Develop and implement an enhanced surveillance program to monitor transmitters identified in Item 1 for symptoms of loss of fill-oil.
This enhanced surveillance program should consider the following or equally effective actions:
a) Ensuring appropriate licensee personnel are aware of the symptoms that a transmitter, both during operation and during calibration activities, may exhibit if it is experiencing a loss of fill-oil and the need for prompt identification of transmitters that may exhibit these symptoms; b) Enhanced transmitter monitoring to identify sustained transmitter drift; c) Review of transmitter performance following planned or unplanned plant transients or tests to identify sluggish transmitter response; d) Enhanced awareness of sluggish transmitter response to either increasing or decreasing test pressures during calibration activities; e) Development and implementation of a program to detect changes in process noise; and f) Development and application to transmitters identified as having exhibited symptoms indicative of loss of fill-oil of an appropriate operability acceptance criteria. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria should be addressed in accordance with the applicable technical specification. Transmitters identified as having exhibited symptoms indicative of loss of fill oil that do not conform to the operability acceptance criteria and are not addressed in the technical specifications should be replaced at the earliest appropriate opportunity.
SCE Response SCE has instituted an enhanced surveillance program for the Attachment 1 Rosemount transmitters. Elements of the program include:
a) Training of Units 2 and 3 Licensed Operators and I&C personnel includes 1) symptoms that a transmitter, both during operation and calibration activities, may exhibit if it is experiencing a loss of fill-oil and 2) the need for prompt identification of transmitters that exhibit these symptoms. All I&C personnel have been trained.
Training for Units 2 and 3 Operations personnel will be completed by August 31, 1990, consistent with the current operator requalification training schedule.
3
b) Enhanced transmitter monitoring to identify sustained transmitter drift has been implemented as follows:
Transmitter data for Attachment 1 transmitters will be reviewed on a quarterly basis to identify sustained drift and other operational anomalies associated with these transmitters. The monitoring program will be accomplished through a combination of monitoring techniques based upon the plant's data retrieval capabilities.
Transmitters will be monitored quarterly through analysis of both manual data acquisition and continuously recorded data. Attachment 1 indicates which of the above techniques is used for each transmitter.
Follow-up actions will be implemented as potentially defective transmitters are identified, in accordance with item (f) below. After one year of monitoring, starting July 1991, transmitters that have performed satisfactorily for 60,000 psi-months will be deleted from the quarterly monitoring program as recommended in Rosemount Technical Bulletin 4.
Instrument and Control (I&C) calibration data for Attachment 1 transmitters obtained during future calibrations, while the quarterly monitoring program is in effect, will be reviewed for excessive drift.
c) Transmitter performance following planned or unplanned plant transients or tests will be reviewed to identify sluggish transmitter response for those presently connected to the plant process computer.
Certain Attachment 1 transmitters (2(3)POT0978-1,2,3,4; 2(3)POT0979 1,2,3,4; 2(3)LT1115-2; 2(3)1125-2) are not monitored by our plant process computer. SCE is confident that a potentially defective transmitter in this group could be identified prior to significantly impaired transmitter performance since: 1) These transmitters are Range Code 5 and 6 transmitters, which, from Rosemount Technical Bulletin No. 4, would provide an indication of impending failure via drift analysis per item b) above, 2) Appropriate personnel have been trained to identify suspect transmitter behavior as described in item a) above, and 3) Approximately sixty percent of these transmitters have well in excess of 60,000 psi-months of operating history, indicating a decreased probability of failure based on Rosemount Technical Bulletin 4.
d) As identified in item a), all I&C personnel have been trained to identify symptoms of loss of fill oil exhibited by Rosemount transmitters, including sluggish response to increasing or decreasing test pressures during calibration activities. Also, calibration procedures have been revised to provide guidance for identifying "sluggish" transmitter behavior.
e) Rosemount has not provided guidance on use of noise analysis; they have said in Rosemount Technical Bulletin 4, Appendix C, that "noise data is difficult to analyze and interpret."
Neither Rosemount, NUMARC, nor the nuclear industry has published general guidelines to 4
assist in development of a program. Therefore, noise analysis is not part of SCE's enhanced surveillance program as no clear, definitive program can be established. As more industry information or guidelines for process noise becomes available SCE will consider using process noise analysis in the enhanced surveillance program.
f) The drift limits given in Rosemount Technical Bulletin 4, Table A-1, are used to "flag" transmitters in Attachment 1 as having exhibited symptoms indicative of loss of fill-oil for further assessment of transmitter operability. This further assessment will include a confirmatory test or analysis to verify the transmitter's capability to perform its safety function (e.g. verification of response time).
Any transmitter that is determined inoperable will be assessed against the applicable technical specification requirements.
Inoperable transmitters not described in the technical specifications will be replaced in accordance with the Justification for Continued Operation.
NRC Requested Action 5.
Document and maintain in accordance with existing plant procedures a basis for continued plant operation covering the time period from the present until such time that the Model 1153 Series B, 1153 Series D, and Model 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil in use in the reactor protection or engineered safety features actuation systems can be replaced. In addition, while performing the actions requested above, addressees may identify transmitters exhibiting symptoms indicative of loss of fill-oil that do not conform to the established operability acceptance criteria and are not addressed in the technical specifications.
As these transmitters are identified, this basis for continued plant operation should be updated to address these transmitters covering the time period from the time these transmitters are identified until such time that these transmitters can be replaced. When developing and updating this basis for continued plant operation, addressees may wish to consider transmitter diversity and redundancy, diverse trip functions (a separate trip function that may also provide a corresponding trip signal),
special system and/or component tests, or (if necessary) immediate replacement of certain suspect transmitters.
SCE Response SCE's evaluation determined that no Rosemount transmitters from the suspect lots are installed in safety-related or ATWS applications. This evaluation, as described in our responses to NRC Requested Actions 1, 2, and 3, of presently installed SONGS Model 1153 Series B and D and 1154 Rosemount transmitters determined none are presently exhibiting symptoms indicative of loss of fill-oil.
5
0 The operability analysis of any transmitters which are suspected in the future of loss of fill-oil will include a justification for continued operation.
1b) ROSEMOUNT TRANSMITTER DATA FOR MODEL 1153 SERIES B, MODEL 1153 SERIES D AND MODEL 1154.
Identify the indicated manufacturer; the model number; the system the transmitter was utilized in; the approximate amount of time at pressure; the corrective actions taken; and the disposition (e.g., returned to vendor for analysis) of Rosemount Model 1153 Series B, Model 1153 Series D, and Model 1154 transmitters that are believed to have exhibited symptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil.
This should include Model 1153 Series B, Model 1153 Series D, and Model 1154 transmitters manufactured after July 11, 1989.
SCE Response SCE recognized the significance of loss of fill-oil and implemented corrective actions prior to the issuance of Bulletin 90-01. No transmitters are presently exhibiting symptoms of loss of fill-oil.
The following are the only two transmitters which were suspected and confirmed to have experienced loss of fill-oil, as determined by Rosemount, and have been replaced. Both transmitters were discovered and replaced prior to issuance of Bulletin 90-01.
- 1) Plant ID:
3LT0342 Quality Class: Non-Safety Related Indicated Manufacturer:
Rosemount Model No:
1154HP4RB Sensing Cell Serial Number:
1836634 System:
Safety Injection (Safety Injection Tank Level)
Static Pressure:
600 psia Approximate Time at Pressure:
18 Months Corrective Action:
Replaced 10/89 Disposition: Loss of fill-oil confirmed by Rosemount
- 2) Plant ID:
3LT1115-2 Quality Class: Safety Related Indicated Manufacturer: Rosemount Model:
1153HD5 Transmitter Serial Number:
413664 System:
Main Steam System (Steam Generator Wide Range Level)
Static Pressure:
1,000 psia Approximate Time at Pressure:
18 Months Corrective Action: Replaced 7/87 Disposition:
Loss of fill-oil confirmed by Rosemount 6
Ic) SYSTEM IDENTIFICATION AND REPLACEMENT SCHEDULE Identify the system in which the Model 1153 Series B, 1153 Series D, and Model 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil are utilized and provide a schedule for replacement of these transmitters which are in use in the reactor protection or engineered safety features actuation systems.
SCE Response Rosemount transmitters from the manufacturing lots identified as having a high failure fraction are not used in SONGS Reactor Protection or Engineered Safety Features Actuation systems and they are also not used in any system at SONGS. Only one transmitter from this manufacturing lot was identified, Plant I.D. 2LT4356; it was used for non-safety related condensate storage tank level indication and was replaced. Since there are no Rosemount transmitters in the suspect lots installed at SONGS, a replacement schedule is not necessary.
- 2. DETERMINATION OF REPORTABILITY FOR LOSS OF FILL-OIL IN TRANSMITTERS Model 1153 Series B, Model 1153 Series D and Model 1154 transmitters that, subsequent to providing the response required by Item 1 above, exhibit symptoms of loss of fill-oil or are confirmed to have experienced a loss of fill-oil should be reviewed for reportability under existing NRC regulations. If determined not to be reportable, addressees are requested to document and maintain, in accordance with existing plant procedures, information consistent with that requested in Item lb) above for each transmitter identified.
SCE Response SCE will evaluate reportability requirements for any subsequent determination of Rosemount Model 1153 Series B-and D and Model 1154 transmitters exhibiting symptoms or are confirmed to have experienced a loss of fill oil.
If not determined reportable SCE will document and maintain, in accordance with existing plant procedures, information consistent with item 1b) above for each transmitter identified.
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ATTACHMENT 1 (Page 1 of 2)
SONGS Unit 2 Models 1153 Series B, 1153 Series D or Model 1154 Pressure or Differential Pressure Transmitters (manufactured prior to 7/11/89) used in Safety Related or ATWS Applications Transmitter Function Model No.
2PT0102-1 Pressurizer Pressure - Wide Range 1153GD9*
2PT0102-2 Pressurizer Pressure - Wide Range 1153G09*
2PT0102-3 Pressurizer Pressure - Wide Range 1153GD9*
2PT0102-4 Pressurizer Pressure - Wide Range 1153GD9*
2PT0104-2 Pressurizer Pressure - Low Range 1153GD9*
2PT0106-4 Pressurizer Pressure - Low Range 1153GD9*
2PT0114A Pressurizer Pressure - (ATWS) 1154GP9RA*
2PT0114B Pressurizer Pressure - (ATWS) 1154GP9RA*
2PT0114C Pressurizer Pressure - (ATWS) 1154GP9RA*
2PT0114D Pressurizer Pressure - (ATWS) 1154GP9RA*
2PDT0978-1 SG E089 Primary Flow D.P.
1153HD6**
2PDT0978-2 SG E089 Primary Flow D.P.
1153HD6**
2PDT0978-3 SG E089 Primary Flow D.P.
1153HD6**
2PDT0978-4 SG E089 Primary Flow D.P.
1153HD6**
2PDT0979-1 SG E088 Primary Flow D.P.
1153HD6**
2PDT0979-2 SG E088 Primary Flow D.P.
1153HD6**
2PDT0979-3 SG E088 Primary Flow D.P.
1153HD6**
2PDT0979-4 SG E088 Primary Flow D.P.
1153HD6**
2LT1115-1 Steam Generator E089 Level - Wide Range 1153HD5*
2LT1115-2 Steam Generator E089 Level - Wide Range 1153HD5**
2LT1125-1 Steam Generator E088 Level - Wide Range 1153HD5*
2LT1125-2 Steam Generator E088 Level - Wide Range 1153HD5**
2LT4355 Condens Storage Tk Level - Narrow Range 1153DD3PB***
2LT4356 Condens Storage Tk Level - Wide Range 1153DD5PB***
Enhanced Monitoring Transmitter data is continuously scanned and stored. Data will be analyzed on a quarterly basis.
Transmitter Data can only be manually recorded and stored due to current plant design. Data will be recorded and analyzed on a quarterly basis.
2LT4355 and 2LT4356 are SR for pressure boundary purposes only and do not perform any safety related function.
No enhanced monitoring is thus necessary.
ATTACHMENT 1 (Page 2 of 2)
SONGS Unit 3 Models 1153 Series B, 1153 Series D or Model 1154 Pressure or Differential Pressure Transmitters (manufactured prior to 7/11/89) used in Safety Related or ATWS Applications Transmitter Function Model No.
3PT0102-1 Pressurizer Pressure - Wide Range 1153G09*
3PT0102-2 Pressurizer Pressure - Wide Range 1153GD9*
3PT0102-3 Pressurizer Pressure - Wide Range 1153G09*
3PT0102-4 Pressurizer Pressure - Wide Range 1153GD9*
3PT0104-2 Pressurizer Pressure - Wide Range 1153GD9*
3PT0106-4 Pressurizer Pressure - Wide Range 1153G09*
3PT0114A Pressurizer Pressure (AIWS) 1I54GP9RA*
3PT0114B Pressurizer Pressure (AIWS) 1154GP9RA*
3PT0114C Pressurizer Pressure (AIWS) 1154GP9RA*
3PT0114D Pressurizer Pressure (AIWS) 1154GP9RA*
3PDT0978-1 SG E089 Primary Flow D.P.
1153HD6**
3PDT0978-2 SG E089 Primary Flow D.P.
1153HD6**
3PDT0978-3 SG E089 Primary Flow D.P.
1153HD6**
3PDT0978-4 SG E089 Primary Flow D.P.
1153HD6**
3PDT0979-1 SG E088 Primary Flow D.P.
1153HD6**
3PDT0979-2 SG E088 Primary Flow D.P.
1153HD6**
3PDT0979-3 SG E088 Primary Flow D.P.
1153H06**
3PDT0979-4 SG E088 Primary Flow D.P.
1153H06**
3LT1115-1 Steam Generator E089 Level - Wide Range 1153HD5*
3LT1115-2 Steam Generator E089 Level - Wide Range 1153HD5**
3LT1125-1 Steam Generator E088 Level - Wide Range 1153HD5*
3LT1125-2 Steam Generator E088 Level - Wide Range 1153HD5**
3LT4355 Condens Storage Tk Level - Narrow Range 11530D3PB***
3LT4356 Condens Storage Tk Level - Wide Range 11531D5PB***
Enhanced Monitorin-g
- Transmitter data is continuously scanned and stored.
Data will be analyzed on a quarterly basis.
Transmitter Data can only be manually recorded and stored due to current plant design.
Data will be recorded and analyzed on a quarterly basis.
S3LT4355 and 3LT4356 are SR for pressure boundary purposes only and do not perform any safety related function. No enhanced monitoring is thus necessary.
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