ML20006C408

Forwards Draft Proposed NRC Bulletin on Loss of fill-oil in Rosemount Transmitters,For Comments

ML20006C408
Person / Time
Issue date:	01/29/1990
From:	Berlinger C Office of Nuclear Reactor Regulation
To:	Wanek S ROSEMOUNT, INC.
References
NUDOCS 9002070471
Download: ML20006C408 (13)

Text

JANUARY 29,'1990 1-

-Mr. Stephen J. Wanek Vice President Operations Rosemount, Inc.

12001 Technology Drive Eden Prairie, Minnesota 55344

SUBJECT:

PROPOSED NRC BULLETIN ON LOSS OF FILL-OlL IN ROSEMOUNT TRANSMITTERS Enclosed for your information is a draft copy of a proposed NRC bulletin on loss of fill-oil in Rosemount transmitters. Although we are not specifi-cally requesting comments from Rosemount on this proposed bulletin, any comments' developed during your review of this proposed bulletin concerning possible technical inaccuracies may be transmitted to me at your earliest convenience, t

l Sincerely, L

1 Carl H. Berlinger, Chief I'

Generic Communications Branch Division of Operational Events Assessment Office of Nuclear Reactor Regulation

Enclosure:

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~OMB No.:' 3150-0011 NRCB 90-XX 1

UNITED STATES NUCLEAR REGULATORY COMMISSION 0FFICE OF NUCLEAR REACTOR REGULATION hn a r==y WASHINGTON, D.C.

20555 ggg g January xx,1990

/h./uz.pg I l29l9O NRC BULLETIN NO. 90-XX: LOSS OF FILL-0!L IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT 1

Addressees:

t All holders of operating licenses or construction permits for nuclear power L

reactors.

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Purpose:

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This bulletin is being provided to request that addressees take actions to promptly-identify and replace transmitters manufactured by Rosemount that may be leaking fill-oil.-

Description of-Circumstances:

NRC Information Notice No. 89-42 ' Failure of Rosemount Models 1153 and 1154 Transmitters," dated April'21 1989, was' issued to alert industry to a series

-of reported failures of Rosemount Models.1153 and 1154 pressure and differential pressure transmitters.

The reported failures occurred at Northeast Utilities' L

Millstone Unit 3 between March and October 1987. Subsequent-investigation into l

the cause of the failures by Rosemount confirmed that the. failure mode was s' gradual lo'ss of fill-oil from the transmitter's sealed sensing module, r

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Discussion of Safety Sinnificance:

The performance of a transmitter that is leaking fill-oil gradually deterio-l rates and may eventually lead to failure. Although some failed transmitters

-have shown symptoms of loss of fill-oil prior to failure, it has been reported that in:some cases the failure of a transmitter that is leaking fill-oil is not detectable during operation. Loss of_ fill-oil'may result in a transmit-j ter not performing its intended safety function.

Discussion:

Model 1151, 1152, 1153, and 1154 Ros6 mount transmitters are utilized exten-

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sively in nuclear power plants. Model-1153 and 1154 transmitters are supplied by: Rosemount as both seismically and environmentally qualified equipment.

Nodel 1152 transmitters are supplied by Rosemount only as seismically qualified l

equipment. Model 1151 transmitters are supplied by Rosemount as comercial-grade. equipment.

DRUT I

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1e NRCB 90-XX January xx,1990 Page 2 of 10 Rosemount has indicated, to date, that failure of approximately 91 Model 1153 and 1154 transmitters due to loss of fill-oil from a glass to metal seal failure have been confirmed.

Since the sensing module is sealed, loss of fill-oil usually cannot be confirmed without destructive analysis of the sensing module. -NRC staff review of this issue has identified additional failed Model 1153 and 1154 transmitters with symptoms indicative of loss of fill-oil that may not have been brought to Rosemount's attention. Thus, the number of failed Model 1153 and 1154 transmitters that have experienced a loss of fill-oil may be greater than that confirmed by Rosemount.

4 Rosemount has indicated that similar sensing modules are utilized in Model 1151, 1152, 1153, and 1154 transmitters and that failures of both Model 1151-and 1152 transmitters due to loss of fill-oil from a glass to metal seal i

failure have been confirmed. The NRC staff believes that, while Model 1153 and 1154 transmitters have a greater susceptibility to loss of fill-oil, Model 1151 and 1152 transmitters may also be susceptible to loss of fill-oil. Thus, loss of fill-oil may be generically applicable to Rosemount manufactured sensing modules. Accordingly, for the purposes of the actions requested in this bulletin, Model 1151 and 1152 transmitters utilized in safety-related systems should be addressed in a manner comparable to that of Model 1153 and l

1154 transmitters.

In addition, Rosemount has indicated that they have insti-l tuted additional quality control and quality assurance steps in the manufactur-i ing process that they believe will minimize the potential for Model 1153 and I

1154 transmitter failures due to loss of fill-oil. As a result, Rosemount has indicated that Model 1153 and 1154 transmitters manufactured after July 11 1989 are not subject to their May 1989 10 CFR Part 21 notification. The NRC staff has not, to date, received indications that Model 1153 and 1154 transmit-ters manufactured by Rosemount subsequent to July 11, 1989 are susceptible to loss of fill-oil; therefore, the NRC staff concludes that Model 1153 and 1154 transmitters manufactured by Rosemount subsequent to July 11, 1989 are not subject to the actions requested in this bulletin. The NRC staff has not, to date, received sufficient information to address the applicability of these manufacturing process modifications to Model 1151 and 1152 transmitters.

Rosemount had previously indicated that Model 1153 and 1154 transmitters that were experiencing.a loss of fill-oil should fail within approximately 36 months of in-service time. Recent information indicates that the rate'at which fill-oil leaks is application and pressure dependant. Therefore, while transmitters that are experiencing a loss of fill-oil that are subject to continuous high-pressure (e.g. reactor operating pressures) may fail within L

this timeframe, transmitters utilized in low-pressure systems or not subject to

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continuous high-pressure may take longer to fail.

i' Rosemount has indicated that they manufacture both complete transmitters and' transmitter parts (including sensing modules) for other manufacturers. At least -one vendor purchases complete transmitters from Rosemount and then DRAFT L

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NRCB 90-XX January xx,1990 Page 3 of 10 provides these transmitters for use in nuclear. power plants under a different brandname. At least one other instrument manufacturer purchased Rosemount manufactured sensing modules and incorporated these sensing modules into transmitters supplied to nuclear power plants. Thus, equipment supplied for use in nuclear power plants by other manufacturers may also be susceptible to-loss of fill-oil.

In addition, Rosemount has indicated that unauthorized remanufacturers and refurbishers exist for Model 1151 and possibly Model 1152, 1153, and 1154 transmitters.

The symptoms a Model 1153 or 1154 transmitter may exhibit during normal opera-tion if it is leaking fill-oil include:

a slow setpoint drift of 1/4 of 3 percent per month deviation from the normal system signal fluctuation that is consistent in

'k only the increasing or decreasing direction ("one-sided-noise")

. slow response to or inability to follow planned or unplanned plant transients a decrease in noise amplitude an outlut that deviates from that of redundant transmitters The symptoms a Model 1153 or 1154 transmitter may exhibit-during calibration activities if it is leaking fill-oil include:

inability to respond over the entire design range slow response to either an increasing or decreasing test pressure drift of greater than 1 percent from the previous calibration The NRC staff believes these symptoms can also be utilized to detect other transmitter models that may be experiencing a loss of fill-oil.

In addition, addressees may wish to consult References 1, 2, 3, and 4 to obtain additional detailed technical information concerning loss of fill-oil. However, address-ees are cautioned that the NRC staff has reviewed Reference 4 and concludes that, while Rosemount has provided sufficient bases to support their proposed diagnostic procedures (trending calibration data, trending operational data, sluggish transient response, and process noise analysis) for detecting whether a transmitter may be leaking fill-oil, Rosemount has not provided sufficient bases to support their proposed methodology for identifying which transmitters should be put into the enhanced surveillance program (pressure versus time-in-service and only Model 1153 and 1154 transmitters).

DRAFT

NRCB 90-XX January xx, 1990 Page 4 of 10 Certain manufacturing lots of Model 1153 and 1154 transmitters have been previously identified by Rosamount as having had a high failure fraction (on the order of 6%) due to loss of fill-oil. Specific information needed to identify transmitters that are from these suspect lots has been provided to industry by Rosemount. The NRC sttff believes that transmitters from these suspect lots have an unacceptably high susceptibility to failure from loss of fill-oil and should not be utilized in the reactor protection or engineered safety features actuation systems.

General Design Criterion (GDC) 21 " Protection System Reliability and Testabil-ity" of 10 CFR 50, Appendix A requires the protection system to be designed for high functional reliability and with sufficient capability to allow periodic testing of its functioning when the reactor is in operation.in order to readily detect failures of subcomponents and subsystems within the protection system as well as loss of the required protection system redundancy as they occur.

10 CFR 50.55a(h) requires that protection systems meet the Institute of Elec-trical and Electronics Engineers Standard: " Criteria for Protection Systems for Nuclear Power Generating Stations" (IEEE-279).

IEEE-279 states that means shall be provided for checking, with a high degree of confidence, the opera-tional availability of each system input sensor during reactor operation.

Thus, the NRC staff concludes that facilities that utilize transmitters that may be susceptible to loss of fill-oil may not be in full compliance with these regulations because undetected transmitter failure could occur.

Accordingly, the NRC staff requests that addressees take the actions requested below.

Requested Actions:

Operating Reactors 1.

Identify, within 60 days after the receipt of this bulletin, all pressure or differential pressure transmitters, including Model 1151, 1152, 1153, and 1154 transmitters but excluding Model 1153 and 1154 transmitters manufactured by Rosemount subsequent to July 11, 1989, that were manu-factured by Rosemount or that contain Rosemount manufactured sensing modules and are utilized in either safety-related systems or systems installed in accordance with 10 CFR 50.62 (the ATWS rule). Addressees may find it necessary to perform, in addition to document reviews, system walkdowns to complete this action.

In addition, the following information is provided to facilitate addressee's activities in this area.

All Model 1153 and 1154 transmitters, whether obtained directly from Rosemount, obtained through intermediary suppliers, or provided as an integral part of another component (such as an emergency diesel generator), should a) indicate manufacture by Rosemount, b) have a distinctive Rosemount model and serial number, c) have the physical profile characteristics of a Rosemount transmitter, and d) have a blue or stainless steel housing.

Rosemount has indicated that Model 1153 and 1154 transmitters are not provided to other manufacturers for resale under a different brandname.

In addition, a simplified diagram that describes the typical physical characteristics of a Rosemount transmitter is provided by Attachment 1.

j HAFT

P RCB 90-XX

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Page 5 of 10 1

January xx,1990 4

manufacture by Rosemount, b) pt as noted below, should a) indicate Model 1152 transmitters, exce have a distinctive Rosemount model and serial number,_c) have the ph Rosemount transmitter, and d)ysical profile characteristics of a have a blue or stainless steel housing.

Rosemount has indicated that they have supplied Model 1152 transmitter sensing modules to Bailey Controls (formerly Bailey Meter). ~ Bailey manufactured transmitters that contain Rosemount manufactured Model 1152 sensing) modules have gray housings that appear slightly different (more rounded than Rosemount housings.

Model 1151 transmitters, except as noted below, should a) indicate manufacture by Rosemount, b) have a distinctive Rosemount model and serial number, c) have the ph Rosemount transmitter, and d)ysical profile characteristics of a have a blue housing. Model 1151 transmitters manufactured by Rosemount may have been supplied for use in nuclear power plants by othe'r original equipment manufacturers (OEM's).

The OEM's identified in Attachment 2 may offer for resale under their own brandname Model 1151 transmitters purchased from Rosemount. These transmitters should have the physical profile characteristics of a Rosemount transmitter and have a blue housing.

Fisher Controls may also offer for resale under their own brandname Model 1151 transmitters purchased from Rosemount. These transmitters should have the physical profile characteristics of a Rosemount transmitter, but have a green lousing.

In addition, Rosemount has indicated that they have supplied Model 1151 transmitter sensing modules to Bailey Controls. Bailey manufactured transmitters that contain Rosemount manufactured Model 1151 sensing) modules have gray housings that appear slightly different (more rounded than Rosemount housings.

2.

Review, within 90 days.after receipt of this bulletin, plant records (for example,calibrationrecords)associatedwiththetransmittersidentified 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 acce)tance criteria and are not addressed in the technical specifications s1ould be replaced at the earliest appropriate opportunity.

3.

Develop and implement, within 120 days after receipt of this bulletin, 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:

DRAFT l

e HRCB 90-XX January xx,= 1990 '

,l Page 6 of 10 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 excessive transmitter drift;--

c)

Review of transmitter output data following planned or unplanned plant transients or tests to identify sluggish transmitter-response;-

d)

Inclusion of sensor response time testing into routine channel calibration. activities; e)

Development and implementation of a program to detect a decrease in transmitter noise level amplitude; 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.

4.

Determine, within 60_ days after receipt of this bulletin, whether any Model 1153 or 1154 transmitters identified in Item 1 are from the manufacturing-lots that have been identified by Rosemount as having a high failure fraction-due tc loss of fill-oil.

(Informationconcerning these transmitters wac provided to industry by Rosemount concurrent with Reference 4). Addressees are requested not to utilize transmitters from these suspect. lots in the reactor protection or engineered safety features actuation systems;-therefore, transmitters from these suspect lots in use in the reactor protection or engineered safety features actuation systems should be replaced at the earliest appropriate opportunity.

5.

Document, within 60 days after receipt of this bulletin, and maintain in accordance with plant procedures a basis for continued plant operation covering the time period from the present until such time that the Model 1153 and 1154 transmitters from the manufacturing lots that have been DRAFT l

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Page 7 of 10-NRCB 90-XX i

January xx,1990

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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 tb? 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.

Construction permit Holders 1.

A11' construction permit holders are requested to complete Items 1 and 3 of Requested' Actions for Operating Reactors prior to the date scheduled for fuel loading or in accordance with the timeframes specified for Operating Reactors, whichever is later.

2.

All construction permit holders that are completing Items 1 and 3 of Requested Actions for Operating Reactors in accordance with the timeframes specified for Operating Reactors are requested to complete Items 4 and 5 of Requested Actions for 0perating Reactors in accorAnce with the timeframes specified for Operating Reactors.

L 3.

All. construction permit holders that are completing Items 1 and 3 of Requested Actions for Operating Reactors prior to the date scheduled for 1

fuel loading are requested to address the intent of Items 4 and 5 of

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Requested Actions for Operating Reactors by performing the following actions:

a)

Identify and replace, prior to the date scheduled for fuel loading, any Model 1153 or 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil that are installed in the reactor protection or engineered safety features actuation systems; and b)

Document and maintain in accordance with plant procedures a basis il for continued plant operation that addresses transmitters that, subsequent to fuel loading, are identified as 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 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 replacennt of certain suspect transmitters.

DRAFT

-NRCB 90-XX' January xx,1990 '

.Page 8 of 10 Reporting Requirements:

Operating Reactors 1._

. Provide, within 120 days after receipt of this bulletin, a response that:

-a)

Confirms that those Requested Actions for Operating Reactors in Items 1, 2, 3, 4, and 5 that are to be completed within 120 days after receipt of this bulletin have been completed and that programs are in place to perform the remaining requested actions; b)

Identifies the indicated manufacturer; the model nu der; the safety-related system the transmitter was utilized in; the approxi-mate amount of time in service; the corrective actions taken; and the disposition (e.g., returned to vendor for analysis) of transmitters,

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including those identified while performing Item 2 of Requested Actions for Operating Reactors above, that are believed to have exhibited sym) toms indicative of' loss of fill-oil or have been confirmed to aave experienced a loss of fill-oil; and c)

Identifies the safety-related system in which the Model 1153 or 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 provides a schedule for replacement of v

these transmitters which are in use in the reactor protection or engineered safety features actuation systems, h

2.

_ Transmitters that, subsequent to providing the response required by Item 1 a

l above, exhibit symptoms of loss of fill-oil or are confirmed to have l

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 plant proce-dures, information consistent with that requested in Item 1 b) above for.

each suspect transmitter identified.

Construction Permit Holders 1.

All holders of construction permits that perform Items 1 and 3 of Requested Actions for Operating Reactors in accordance with the timeframes specified for Operating Reactors should provide, within 120 days after receipt of this= bulletin, a response that:

L a)'

Confirms that those Requested Actions for Operating Reactors in Items'1, 3, 4, and 5 that are to be completed within 120 days after

]

n receipt of this bulletin have been completed and that programs are p

in place to perform the remaining requested actions; and 1

i b)

' Identifies the safety-related system in which the Model 1153 or 1154 transmitters from the manufacturing lots that have been identified by Rosemount 'is having a high failure fraction due to loss of p

fill-oil are utilized and provides a schedule for replacement of l

these transmitters which are in use in the reactor protection or engineered safety features actuation systems.

DRAFT r

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NRCB 90-XX January xx,1990:

i Page 9 of 10 2.-

All holders of construction permits that perform Items 1 and 3 of Requested Actions for Operating Reactors _ prior to the date scheduled for fuel loading should provide, prior to the date scheduled for fuel loading, a response that:

a)

Confirms that all actions in Items 1 and 3 of Requested Actions for Operating Reactors have been completed; and b)

Confirms that Model 1153 or 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 not utilized in the reactor protection or engineered safety features actuation systems.

3.

Transmitters-.that, subsequent to providing the response required by Item J

1 or 2 above, exhibit symptoms of loss of fill-oil or are confirmed to have experienced a loss of fill-oil should be reviewed for reportability i

i under existing NRC regulations.

If determined not to be reportable, addressees are requested to document and maintain, in accordance with plantprocedures,informationconsistentwiththatrequestedinItem1b) of the Reporting Requirements for Operating Reactors above for each suspect transmitter identified.

The written reports required above shall be addressed to the U.S. Nuclear Regulatory Commission, ATTN: Document Control' Desk, Washington, D.C.

20555, and shall be submitted under oath or. affirmation pursuant to the provisions of Section-182a, Atomic Energy Act of 1954, as amended and 10 CFR 50.54(f).

In addition, a-copy shall be submitted to the appropriate Regional ' Administrator.

Backfit Discussion The objective of the actions requested in this bulletin are to ensure that transmitter failures due to loss of fill-oil-are promptly detected.

Loss of fill-oil may result in a transmitter not performing its intended safety

. function.

i The actions requested in this bulletin represent new staff positions and thus, this request is considered a backfit in accordance with NRC procedures.

Because established regulatory requirements exist but were not satisfied, this backfit is-to bring facilities into compliance with existing requirements.

Therefore, a full backfit analysis was not performed. Ar. evaluation of the type discussed in 10 CFR 50.109(a)(6) was performed, including a statement of the objectives of and reasons for the modification and the basis for invoking the compliance exception.

It will be made available it. the Public Document

' Room with the minutes of the meeting of the Committee to Review Generic Requirements.

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.1 NRCB 90-XX Rh January xx,1990 g

Page 10 of 10

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This request is covered by Office of Management and Budget Clearance Number 3150-0011 which expires January 31, 1991. The estimated average burden hours are 100 person-hours per licensee response, including assessment of the new

. requested actions, searching data sources, gathering and analyzing the data, and preparing the required letters.

These estimated average burden hours pertain only to these identified response-related matters and do not include the time for actual implementation of the requested actions. SenTIomments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch, Division of Information Support Services, Office of.Information Resources Management, U.S. Nuclear Regulatory Connission, Washington, D.C.

20555;andtothePaperworkReductionProject(3150-0011),

Office of Management and Budget, Washington D.C.

20503.

If you have any questions about this matter, please contact one of the techni-cal contacts listed below or the appropriate NRR project manager.

Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts: Jack Ramsey, NRR (301)492-1167 Vince Thomas, NRR (301)492-0786 l

References:

1.

Rosemount Technical Bulletin No. I dated May 10, 1989

2. -Rosemount Technical Bulletin No. 2 dated July 12, 1989 3.

Rosemount Technical Bulletin No. 3 dated October 23, 1989 4.

Rosemount Technical Bulletin No. 4 dated December 22, 1989 : Typical Physical Characteristics of a Rosemount Transmitter :

Original Equipment Manufacturers That May Resell Rosemount Manufactured Model 1151 Transmitters Under Their Own Brandname :

List of Recently Issued NRC Bulletins 1

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NRCB 90-XX

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January xx.1990 f

TYPICAL PHYSICAL CHARACTERISTICS OF A ROSEMOUNT TRANSMITTER ELECTRONIC,8 HOUSING

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DRAFT i

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i NRCB 90-XX 1

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• i January. xx,1990 '

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'b 0RIGINAL EQUIPMENT MANUFACTURERS THAT MAY RESELL i

ROSEMOUNT MANUFACTURED MODEL 1151 TRANSMITTERS-UNDER THEIR OWN BRANDNAME 1

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' 1. :

FISHER CONTROLS 2.

BAILEYCONTROLS(FORMERLYBAILEYMETER)

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DIETRICH STANDARD

4. -

DANIEL INDUSTRIES' p 'e 5.

CLEVELAND CONTROLS

- 6.

F.- B. LEOPOLD 7;

HAYS REPUBLIC 8.-

MOORE PRODUCTS

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NORTH AMERICAN MANUFACTURING

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