ML18101A375

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Evaluation of Util Response to Suppl 1 to NRC Bulletin 90-001:Hope Creek & Salem-1/2.
ML18101A375
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 11/30/1994
From: Udy A
EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:
NRC
Shared Package
ML18101A373 List:
References
IEB-90-001, IEB-90-1, INEL-94-0168, INEL-94-168, NUDOCS 9412080259
Download: ML18101A375 (14)
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Text

  • INEL-94/0168 TECHNICAL EVALUATION REPORT Evaluation of Utility Response to Supplement 1 to NRC Bulletin 90-01: Hope Creek and Salem-1/-2 Docket Nos. 50-354, 50-272, and 50-311 Alan C. Udy Published November 1994 Lockheed Idaho Techncrlogies Company Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 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-AC07-941Dl3223 FIN No. Ll695, Task No. Ila TAC Nos. M85397, M85436, and M85437 941~080259 941202

~R ADOCK 0500~5~2

SUMMARY

This report documents the Lockheed Idaho Technologies Company review of the Public Service Electric and Gas Company submittals that respond to Supplement 1 to NRC Bulletin 90-01 for the Hope Creek and Salem Generating Stations. 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 that the licensee conforms to the requested actions and the reporting requirements of the Supplement.

FIN No. Ll695, Task No. Ila B&R No .. 320-19-15-05-0 Docket Nos. 50-354, 50-272, and 50-311 TAC Nos. M85397, M85436, and M85437 ii

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 Factors, by Lockheed Idaho Technologies Company, National Nuclear Operations Analysis Department.

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CONTENTS

SUMMARY

................................................................. ii PREFACE . . . . . * . * . * * . . . . . . * * . . . . . . . . . . . . . . . . . . . . . . . * . . . . . . . * . . . * . . . . . . . . . . iii

1. INTRODUCTION ....*............*....*........*..........*..*.......* 1
2. NRC SPECIFIED REQUESTED ACTIONS ....*...................*.**........ 4
3. EVALUATION FOR THE HOPE CREEK GENERATING STATION .........*.*...*.** 7 3.1 Evaluation of Licensee Response to Reporting Requirements ..* 7 3.2 Evaluation of Licensee Response to Requested Actions *....... 7
4. EVALUATION FOR THE SALEM GENERATING STATION........................ 12 4.1 Evaluation of Licensee Response to Reporting Requirements *.* 12 4.2 Evaluation of Licensee Response to Requested Actions ..*..... 12
5. CONCLUSIONS . . . . . . . . . . . . . . . . . . . * . . . . . . * . * * * . * . . * * * . . * * * * . * * . . * * . . *
  • 16
6. REFERENCES . . * . . . . . . . . . . . . . . . . . . * . * . . . . * * . * . . . . . . . . . * . * . * * * * . * * . * * . 17 iv

Evaluation of Utility Response to Supplement 1 to NRC Bulletin 90-01: Hope Creek and Salem-1/-2

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-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 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 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 conform with the direction given. Finally, the licensee was instructed to 1

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 "O"-rings between the sensing module and the process flanges.

Rosemount improved the manufacturing process for transmitters manufactured after July 11, 1989. Those improvements inciuded a limit of the torque applied to the flange bolts. This limits the stress caused in the sensing module by the 11 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 1 of NRC Bulletin 90-01, those Rosemount transmitters manufactured after July 11, 1989, are not subject to this review.

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justification can be based on high functional reliability provided by redundancy 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 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 ~s 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 (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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3. EVALUATION FOR THE HOPE CREEK GENERATING STATION The licensee responded to Supplement 1 of NRC Bulletin 90-01 on March 5, 1993. That response was compared to the Bulletin Reporting Requirements and Requested Actions as described below. The licensee reports they have 182 Rosemount transmitters at Hope Creek Generating Station that are subject to the Requested Actions of the Supplement. Other Rosemount t~ansmitters are outside the scope of the Supplement due to replacement, refurbishment, or use in non-safety applications. The licensee tagged spare transmitters manufactured before July 11, 1989, for non-conformance. The licensee infers that each non-conforming spare transmitter was refurbished.

3.1 Evaluation of Licensee Response to Reporting Requirements The licensee states they have ta~en the Requested Actions detailed in Supplement 1 of NRC Bulletin 90-01. Included with that statement is clarification, interpretation, and the limits placed on that corrmitment. The licensee described the specif~c actions taken to implement. the Requested Actions.

The licensee submitted a statement that the Requested Actions are complete on April 27, 1994.

The licensee submittals conform to the Reporting Requirements of Supplement 1 of NRC Bulletin 90-01.

3.2 Evaluation of Licensee Response to Requested 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 Requested Actions and the associated transmitter criteria in Section 2. The licensee identified a total of 182 Rosemount type 1153, series B, transmitters at the Hope Creek Generating 7

  • lBGFT-114790 receives daily channel checks and an 18 month interval calibration drift trending.
  • 1SBPT-N052A-C71 receives a weekly functional test of the turbine stop valve closure (including transmitter channel checks) and an 18 month response time check.
  • 1SBPT-N052B-C71 receives a weekly functional test of the turbine stop valve closure (including transmitter channel checks) and an 18 month response time check.
  • 1SBPT-N052C-C71 receives a weekly functional test of the turbine stop valve closure (including transmitter channel checks) and an 18 month response time check.
  • 1SBPT-N052D-C71 receives a weekly functional test of the turbine stop valve closure (including transmitter channel checks) and an 18 month response time check.

The licensee described, for the above transmitters, the function of the transmitters, the enhanced surveillance monitoring program for the transmitters, the failure modes of the transmitters, any alternative parameters available to back *up the transmitters, and the operational history of the transmitters. Based on the described surveillance and justification, we find the enhanced surveillance monitoring program for these transmitters acceptable.

3.2.4 Licensee Response to Requested Action 1.d The licensee states there are ten Rosemount transmitters from this classification at the Hope Creek Generating Station. The licensee monitors seven of the ten transmitters using calibration drift trending at least once per 23 months (nominally 18 months). Three transmitters have monthly channel checks with an 18 month (maximum of 23 months) calibration check for sluggish response *. Drift trending alone for these three transmitters is not acceptable due to transmitter range code 9. This program, as described, meets the requirements of the Supplement and is acceptable.

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The enhanced surveillance monitoring program for Rosemount transmitters consists of four parts. First, the licensee trends the zero drift of all transmitter calibration data at a nominal 18 month interval. Second, transmitter calibration includes observation of the transmitter response, specifically looking for a sluggish response to transients. Third, the licensee performs channel checks against a redundant transmitter on certain transmitters in accordance with Technical Specifications. Deviations between redundant channels are noted, investigated, and resolved. Fourth, process noise analysis is available to monitor questionable transmitters while in service.

Three range code 9 transmitters from transmitter classification l.d use this last method for quarterly trending of spectrum power density data and comparison to the established baseline data. Those transmitters also have monthly channel checks against redundant transmitters. 1BEPT-N090N-B21, a range code 9 transmitter in transmitter classification l.c, has channel checks daily against redundant transmitters, quarterly noise analysis and refueling interval checks for response time. The licensee's extra efforts for range code 9 transmitters shows the licensee is cognizant of and knowledgeable concerning Rosemount Technical Bulletin No. 4. Rosemount Technical Bulletin No. 4 states that channel checks against redundant transmitters provide the earliest detection of failure of a range code 9 transmitter.

Based on the program elements described by the licensee, the enhanced surveillance monitoring program at the Hope Creek Generating Station is acceptable.

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Station that are in the scope of this review. The following sections discuss the licensee response to the Supplement.

4.2.1 Licensee Response to Requested Action I.a The licensee states they had 14 Rosemount transmitters from this transmitter classification at Unit I of the Salem Generating Station. Unit 1 had none. The licensee replaced all transmitters in this transmitter classification with Rosemount transmitters manufactured after July 11, 1989.

The licensee verified that this replacement was complete in their April 27, 1994, submittal.

4.2.2 Licensee Response to Requested Action l.b The licensee states there are six Rosemount transmitters from this classification at the Salem Generating Station. Each unit has three installed. All exceed the psi-month maturity threshold established by Rosemount and endorsed by the NRC. The licensee provided justification for*

extending the quarterly test interval to once per 18 months in the enhanced surveillance monitoring program. The Supplement permits monitoring mat~re transmitters in this transmitter classification at up to a 24 month interval, provided the licensee provides adequate justification. The licensee discussed the maturity of the transmitters, the transmitter time in service, the specific safety function of each transmitter, and noted none had any indication of fill-ail loss. Based on the provided licensee justification, the nominal 18 month surveillance interval is acceptable.

4.2.3 Licensee Response to Requested Action l.c The licensee identified a total of 20 transmitters in this transmitter classification. The licensee scheduled all of these transmitters for replacement. The licensee scheduled two transmitters on Unit 2 for 13

calibration data trended every refueling cycle. This allows the licensee to maintain a high degree of confidence that these transmitters remain highly reliable.

4.2.7 Enhanced Surveillance Monitoring Program The licensee states their enhanced surveillance monitoring program follows the Rosemount recommendations in the published Technical Bulletins.

Further, the licensee states their enhanced surveillance monitoring program provides the necessary data and a high degree of confidence for detection of loss of fill-oil caused transmitter degradation.

The enhanced surveillance monitoring program for Rosemount transmitters consists of four parts. First, the licensee trends the zero drift of all transmitters calibration data at a nominal 18 month interval. Second, transmitter calibration includes observation of the transmitter response, specifically looking for a sluggish response to transients. Third, the licensee performs channel checks against redundant transmitters on certain transmitters in accordance with Technical Specifications. Deviations between redundant channels are noted, investigated, and resolved. Fourth, process noise analysis is available to monitor questionable transmitters while in service.

Certain range code 9 transmitters use the last two methods in addition to trending refueling calibration 9ata. Those range code 9 transmitters that do not use process noise analysis have a fail state that does not impact the operation of a safety system. These distinctions for range code 9 transmitters show the licensee is cognizant of and knowledgeable concerning Rosemount Technical Bulletin No. 4. Rosemount Technical Bulletin No. 4 states that channel checks against redundant transmitters provide the earliest detection of failure of a range code 9 transmitter.

Based on the program elements described by the licensee, the enhanced surveillance monitoring program at the Salem Generating Station is acceptable.

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  • 6. REFERENCES
1. NRC Bulletin No. 90-01: "Loss of Fill-oil in Transmitters Manufactured by Rosemount," March 9, 1990, OMB No. 3150-0011.
2. NRC Bulletin No. 90-01, Supplement 1: "Loss of Fill-oil in Transmitters Manufactured by Rosemount," December 22, 1992, OMB No. 3150-0011.
3. Letter, Public Service Electric and Gas Company (J. J. Hagan) to NRC, "Response to NRC Bulletin 90-01, Supplement l," March 5, 1993, NLR-N93032.
4. Letter, Public Service Electric and Gas Company (J. J. Hagan) to NRC, "NRC Bulletin_90-0l, Supplement 1, Requested Actions for Operating Reactors - Items 1 and 2," April 27, 1994, NLR-N94074.

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J NRC FORM 336 12-891
  • U.S. NUCLEAR REGULATORY COMMI-* 1. REPORT NUMBER

<"-'-' ~ P-mC. AM v-., ...,_, 1-., _. ......._ ........_, ~ -..J NRCM 1102, 3201,3202 BIBLIOGRAPHIC DATA SHEET INEL-94/0168 (See instructions on the revensel

2. TfilE AND SUBTITLE 3. DATE REPORT f'UBUSHED Evaluation of Utility Response to Supplement 1 to MONTH YEAR NRC Bulletin 90-01: Hope Creek and Salem-1/-2 November 1994
4. FIN OR GRANT NUMBER Ll695
5. AUTHORISI 6. TYPE OF REPORT Alan C. Udy Technical Evaluation
7. PERIOD COVERED<....... - .
8. PERFORMING ORGANIZATION* NAME AND ADDRESS <"_,,,_._ ........_u.L ...... 1-----. .. - - * -...--... - - ,

National Nuclear Operations Analysis Lockheed Idaho Technologies Company P.O. Box 1625 Idaho Falls, ID 83415-3870 Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

10. SUPPLEMENTARY NOTES
11. ABSTRACT (>1111_.*~

This report documents the Lockheed Idaho Technologies Company review of the Public Service Electric and Gas Company submittals that respond to Supplement 1 to NRC Bulletin 90-01 for the Hope Creek Generating Station and the Salem Generating Station, Unit Nos. 1 and 2. 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 1icensee conforms to the requested actions and the reporting requirements of the supplement.

12. KEY WORDS/DESCRIPTORS <U0_. _ _ ,.._. _ _ ~._.... - .

1 13. AVAILABILITY STATEMENT Rosemount Transmitters Unlimited Distribution Loss of Fill-Oil 14. SECURITY CLASSIFICATION NRC Bulletin 90-01, Supplement 1

-- Unclassified

-*- Unclassified

15. NUMBER OF PAGES
16. PRICE NRC FORM 335 12*891
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