ML17309A747

Technical Evaluation Rept;Evaluation of Util Response to Suppl 1 to NRC Bulletin 90-001:St.Lucie-1/-2

ML17309A747
Person / Time
Site:	Saint Lucie
Issue date:	09/30/1994
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML17228A867	List: ML17228A866 ML17228A868 ML17309A747
References
EGG-DNSP-11487, IEB-90-001, IEB-90-1, NUDOCS 9410040305
Download: ML17309A747 (12)

Text

ATTACHMENT 2 EGG-ONSP-11487 TECHNICAL EVALUATION REPORT Evaluation of Utility Response to Supplement

-1 to NRC Bulletin 90-01:

St. Lucie-I/-2 Docket Nos.

50-335 and 50-389 Alan C.

Udy Published September 1994 EG8G Idaho, Inc.

Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Under OOE Contract No. DE-AC07-761001570 FIN.No.

L1695, Task No.

11a

~AC Nos.

M85446 and M85447

SUHHARY This report documents the EG&G Idaho, Inc., review of the Florida Power and Light Company submittals that respond to Supplement

.1 to NRC Bulletin 90-01 for Unit Nos.

1 and 2 of the St. Lucie Plant.

This NRC Bulletin provides

~ information regarding the loss of fill-oil in certain pressure and differential pressure transmitters manu.actured by Rosemount, Inc.

=This report finds that the licensee complies to the requested actions and the reporting requirements of the Supplemenc.

FIN No. L1695, Task No.

11a B&R No. 320-19-15-05-0 Docket Nos.

50-335 and 50-389 TAC Nos.

H85446 and H85447 11

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 Commission, Office of Nuclear Reactor Regulation, Division. of. Reactor Controls and Human Fact'ors', 'by. EGEG Idaho, Inc.,

DOE/NRC Support Programs Unit.

CONTENTS S UMMARY..............

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NRC SPECIFIED REQUESTED ACTIONS........

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EVALUATION

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3. 1'valuation of Licensee

Response

to Reporting Requirements 7

3.2 Evaluation of Licensee

Response

to Requested Actions......

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CONCLUSIONS...................

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REFERENCES................,...

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Evaluation of Utilit Res onse to Su lement 1 to NRC Bulletin 90-01:

St. Lucie ~ 1.

INTRODUCT ION 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-related 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.ill-oil, the transmitter would not have the long term accuracy, time response, and reliability needed for its intended'afety 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 1 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 conf"."m with the dire".'.io~ "iven.

Finally, the licensee was ir.'ructed to

those submittals.. It also determines whether propo'sed surveillance methods are adequate to determine fill-oil loss-caused degradation of the transmitter..

Finally, this report addresses the int'erval of surveillance proposed by the licensee for 'any transmitters included in the enhanced surveillance monitoring program.

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

't Rosemount improved the manufacturing process for transmitters manufactured after July ll, 1989.

Those improvements included a limit of the torque applied to the flange bolts.

This limits the stress caused in tl;e 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 Rn~emount transmitters manufactured after July ll, l989, are not subject to this review.

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

C.

For boiling water reactors (8WR)--

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 this classification, enhanced surveillance on a refueling (not exceeding 24 months) basis is acceptable.

Under this option, justification must be based no t."~ 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) on 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 (bg Rosemount) nsi-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.

3.

EVALUATION The licensee responded to Supplement 1 of NRC Bulletin '90-01 on March 5, 1993.

The licensee provided additional information on March 9, 1994.

The licensee notified'he NRC that their transmitter replacements were complete on August 18, 1994.

Those responses were compared to the Bulletin

~Re ortin d

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bdb1 Th having Rosemount transmitters that are subject to the Re vested Actions'of the Supplement.

Other Rosemount transmitters are outside the scope of the Supplement due to replacement or refurbishment.

3. 1 Evaluation of Licensee Res onse to Re ortin Re uirements The licensee

states, in Reference 3, that they intend to implement the Re uested Actions detailed in Supplement 1 of NRC Bulletin 90-01.,

Included.'ith that statement is clarification, interpretation, and the limits placed;on that commitment.

The licensee described the specific actions taken to execute the Re uested Actions.

The licensee provided a statement that the Re<euested Actions are complete on August 18, 1994.

The licensee submittals conform to the Re ortin Re uirements of Supplement 1 of NRC Bulletin 90-01.

3.2 Evaluation of Licensee Res onse to Re uested Actions Supplement 1 of NRC Bulletin 90-01 requested licensee action to resolve the issue of fill-oilleakage in Rosemount transmitters.

This Technical Evaluation. Report summarizes the Re uested Actions and the associated transmitter criteria in Section 2.

Ro emount transmit.~

manufactured after July 11, 1989 are not subject to the Supplement requirements or an enhanced surveillance monitoring program.

The licensee response to the Supplement is discussed in the following sections.

quarterly as part of their enhanced surveillance monitoring program.

The licensee states they will not increase the surveillance interval from

-quarterly without providing justification to the NRC.

The licensee actions for transmitters in transmitter. classification 1.b at Unit No.

1 are acceptable.

As noted in Reference 5, the licensee actions for this transmitter classification are complete, and the transmitters replaced as scheduled.

Unit No.

2 The licensee states there are Rosemount transmitters from this transmitter classification at Unit Ho.

2 of the St. Lucie Plant.

The licensee scheduled the subject transmitters for replacement in the fall of 1993.

The 1'~onsee ommitted, in Reference 3, to monitor these tr~nsr.'+ters quarterly as part of the enhanced surveillan=e monitoring program until replaced.

Some of the Unit No.

2 Rosemount transmitters were manufactured after July ll, 1989',

and are exempt from the Supplement requirements.

The licensee actions for transmitters in transmitter classification 1.b at Unit No.

2 are acceptable.

As noted in Reference 5, the licensee actions for this transmitter classification are complete, and the transmitters replaced as scheduled.

3.2.3 Licensee Res onse to Re uested Action 1.c The licensee states there are Rosemount transmitters from this transmitter classification at the St. Lucie Plant.

The licensee states that these transmitters will participate in an enhanced surveillance monitoring program on a refueling basis.

The interval will not exceed 24 months.

Either replacement or successfully achieving the psi-month maturity threshold will remove a transmitter from the enhanced surveillance monitoring program.

Replacement with a transmitter manufactured after July ll, 1989, removes the transmitter from the Supplement requirements.

Successfully achieving maturity transfers the transmitter to transmitter classification l.e.

See Section 3.2.5.

The Supplement requires the licensee to maintain a high degree of confidence that these transmitters remain highly reliable.

The l,icensee states that existing maintenance and surveillance programs can detect future failures due to the loss of fill-oil.

3.2.7 Enhanced Surveillance Monitorin Pro ram The licensee described the monitoring intervals for the different transmitter classifications.

The licensee, in addressing Re uested Action 2 of the Supplement, states their enhanced surveillance monitoring program uses the guidelines of Rosemount Technical Bulletin No. 4.

Following the guidelines of Rosemount Technical Bulletin No.

4 satisfies the requirements of the Supplement and is acceptable.

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5.

REFERENCES NRC Bulletin No. 90-01:

"Loss of Fill-oil in Transmitters Manufactured by Rosemount,"

March 9,

1990, OMB No. 3150-0011.

NRC Bulletin No. 90-01, Supplement 1:

"Loss of Fill-oil in Transmitters Manufactured by Rosemount,"

December 22,

1992, OMB No. 3150-0011.

Letter, Florida Power and Bulletin 90-01 Supplement Letter, Florida Power and Bulletin 90-01 Supplement L-94-061.

Light Company (D. A. Sager) to NRC, "NRC 1 Response,"

Harch 5,

1993, L-93-61.

Light Company (D. A. Sager) to NRC, "NRC 1 Additional Information," March 9,

1994, Letter, Florida Power and Light Company (D. A. Sager) to NRC, "NRC Bulletin 90-01 Supplement 1 Additional Information," August 18,

~994, L-94-210.

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