ML20006G115

Affidavit of Gc Minor Re Rev of Rosemount Transmitters at Seabrook.* Discusses Potential Safety Impact of Rosemount Transmitter Problems & Need for Changing Faulty Transmitters Before Plant Proceeds W/Power Ascension & Operation

ML20006G115
Person / Time
Site:	Seabrook
Issue date:	02/26/1990
From:	George Minor MHB TECHNICAL ASSOCIATES
To:
Shared Package
ML20006G104	List: ML20006G103 ML20006G108 ML20006G115
References
IEIN-89-042, OL-1, NUDOCS 9003050068
Download: ML20006G115 (38)

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l UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION  !

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD i

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket No. 50-443 OL NEW HAMPSHIRE, ET AL )

) February 26,1990 (Seabrook Station Unit 1) )

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AFFIDAVIT OF GREGORY C. MINOR REGARDING REVISION OF ROSEMOUNT TRANSMITTERS AT SEABROOK i

I, Gregory C. Minor, do make oath and say:

1. My name is Gregory C. Minor. I am a Vice President of MHB Technical Associates. My business address is 1723 Hamilton Avenue, Suite K, San Jose, California 95125. I received a B.S. in Electrical Engineering from the University of California, Berkeley, in 1960 and 'a M.S. in Electrical Engineering from Stanford University in 1966.

2. - I have thirty years experience in the design, development, research, start up testing, and management of nuclear reactor systems. From 19601976, I worked for General Electric Company in the design, development, and testing of safety and control .

systems for nuclear power plants. My responsibilities included equipment and systems design, as well as management of a large engineering group responsible for new control room design.

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3. For the past fourteen years,I have been an independent technical consultant.

In that capacity, I have participated in a variety of studies addressing nuclear facility i economic, management, and safety issues for various ' organizations, including the H I

Department of Energy /Sandia National Laboratories, the Swedish Government, and the offices of several states' Attorneys General. I am currently a consultant on several nuclear  !

plant cases in which design, management, and compliance with existing regulations are being investigated.

4. I am a member of the Nuclear Power Plant Standards Committee for the Instrument Society of America. Also, I participated in a Peer Review Group of the Nuclear Regulatory Commission's Three Mile Island Special Inquiry Group. Further ,

- ' details of my qualifications and professional experience are summarized in my Statement l of Professional Oualifications which is appended to this affidavit at Attachment 1.

5. The purpose of this affidavit is to discuss the potential safety impact of Rosemount transmitter problems and the need for changing out any potentially faulty transmitters utilized at Seabrook, before the plant proceeds with power ascension and  ;

operation.

DISCUSSION OF THE PROBLEM

6. The nature of the Rosemount transmitter problems is summarized in Rosemount's February 9,1989, Notification to the NRC under 10CFR21 of a potentially significant safety issue. See Attachment 2. j I

Thefailure mode is a loss offillfluidfrom the transmitter sensing module due to internalleak (no oil is lost into the process fluid). When this condition occurs, the transmitter may exhibit reduced performance prior to a detectable failure.

This reduced performance may manifest itself as an output shift, lack of

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response over it'sfull range, and/or an increase in time response. The loss of .

- time response may be um directional. At this time, we have not been able to determme the limits of this potentialperformance reduction.

Based on existing confirmed information, all reponedfailures to date occurred

, during the first 30 months of service and eventually resulted in a detectable condition during that 30 month time span. In these situations, the transmitter would show an mcreasing output shift, typicallyfollowed by a significant output '

shift, and then possibly resulting in a high or low offscals reading. Other symptoms that may ident loss of oilinclude inability to calibrate (slugish response orpanial response and reduced noise in a signal that normally would show noise. ' Data avail ble also sugests but does not yet confirm that transmitters which have been in servicefor more than 36 months are not going to ,

failin this way.

Recent information indicates that prior to detectable failure, Ihe transmitter may  ;

continue to provide a signal but not respond over 'it's full range and/or time response may be sigmficantly degraded. Tiis t may i.e a safety concern at your plant.

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7. The Rosemount design problems are spread over several of its transmitter models (Models 1151,1152,1153, and 1154).1/ Rosemount parts may also be utilized as internal parts of other manufacturers' models. These transmitters are utilized in numerous systems in nuclear power plants such as Seabrook in a variety of safety and non-safety _

-applications to measure pressure or differential pressure. Some of these applications are safety related and some are important to safety. 2/ Rosemount projects that transmitters which are picne to fail are most likely to fail within 30 monihs of their in-service date, j 1/ Models 1153 and 1154 were identified in the Part 21 Notice (Attachment 2) and in NRC IN #89-42, April 21,1989, (see Attachment 3) as models with the potential for failing in an unsafe mode. More recently a draft NRC Information Notice released in draft January 29,1990 (see Attachment 4) identified models 1151 and 1152 as 1 '

also being suspect because they utilize the same design of sensing unit. Reportedly, NRC has now decided to exemp"t Models 1151 and 1152 from its'" enhanced w surveillance" requirements. Ssa, NRC Bulletin on Replacement of Rosemount Transmitters Due Soon," Inside N"1C, February 26,1990. (Attachment 5)

( 2/ in its February 8,1990 draft responses to the The Draft BWR' Owners' NRC Bulletin Group (BWROG) Transmitters, from S. D. Floyd (Chairm on Rosemount -l 7J BWROG) to C. E. Rossi (NRC), states that "[o]ne utilitypresently has approximately 550 Rosemount Transmitters installed in safety-related and imponant to safety applications, of which 54 are from the suspect manufacturing lots identified by l Rosemount." (This is undoubtedly a utility with multiple nuclear plants, but it gives I an idea of the pervasiveness of the problem.) l 3-l

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a However, on individual units this time interval may vary due to the operating conditions of the unit. The failure mechanism appears to exhibit a sensitivity to the operating pressure ,

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of the transmitter. 3/

8. A year ago the NRC asked licensees to review their systems to identify the uses of models 1153 and 1154 and assure that they are not utilized in reactor protection i

systems or engineered safety features actuation systems. A/ No response to the Information Notice was required. Recently, the Nuclear Regulatory Commission prepared a draft NRC Bulletin that would order licensees tp identify and monitor the performance of Rosemount transmitters and replace them as soon as possible (Draft NRC Bulletin 90-XX,  ;

January 29,1990; provided as Attachment 4). Even though Rosemount has outlined a plan for monitoring suspect transmitters, it is possible that the units could fail without detection l t

of the trends identified by Rosemount. It also is difficult, if not impossible in some cases, to detect a failure during operation (e.g., a zero shift of the reading or a limitation of the full scale range), t SEABROOK SITUATION

?. . At Seabrook, as in all nuclear plants, there is a need to monitor certain pressures and differential pressures as inputs to the protection systems and plant control systems. Many of the devices used in these applications are of Rosemount design. 5/ To.

3/ Apparently a transmitter operating in a high pressure environment is likely to fail in a different time interval due to fill-ois leakage than one in a low pressure environment. t

{ f/ See Attachment 3.

5/ informed the NRC New Hampshire on October 9,1986Yankee (which in a letter operates from George the Seabrook Thomas to V.S. Plant)Noonan, that it was l:

replacing faulty transmitters designed by Veritrak/Tobar with Rosemount i transmitters. In a May 27,1988 letter to the NRC, NHY/PSNH provided the NRC l

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e i the best of my knowledge, New Hampshire Yankee has not produced a publicly available list of each Rosemount application and the safety significance of possible failure modes.

10. Seabrook. is required to comply with the same requirements as other licensees ~of op'erating reactors. These requirements include compliance with its FSAR ~

commitments and its Technical Specifications. Under NRC regulations and regulatory guidance, Seabrook must meet requirements for adequate levels of reliability, redundancy  !

and qualification of structures, systems and components important to safety. The potential y for Rosemount transmitter failures undermines confidence in Seabrook's ability to comply with these requirements. ,.

11. The draft NRC Bulletin would allow interim operation with Rosemount -

transmitters in place, provided that the transmitters are identified and monitored. This is not an ndequate means of assuring safe operation of the Seabrook reactor, given its unique operational status.

12. Eini, the plant is about to enter its power ascension phase where it will be subjecting its monitoring and safety systems to numerous tests. These tests include large

' load rejection tests, station blackout tests, and scrams from full power. 6/ Under these .

. predictable stresses and tests of the plant equipment and safety systems, fully operational, reliable, and qualified equipment should be available for important to-safety applications.

with its analysis of the changes required in its Technical Specifications, set points, l etc. as a result of the re

,-- transmitter applications. placement of Veritrak with Rosemount in safety rela 1 L generator level, pressurizer level, and pressurizer pressure, ,

f/ Other tests include steam dump control test, MSIV closure tests, shutdown from outside control room, RCS trip and flow coastdown, and natural circulation tests.

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13. Second. the plant has had only a brief history of operation, and all of that was at low power levels. 2/ This reduces the chances of discovering potential failures in transmitters by monitoring and calibrating. Rosemount failure data show that 'some

- transmitter elements may crperience early mortality and fall early in their operating life -

while others require many months of operation at normal power operating conditions

- before they begin to disclose their weaknesses.

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~14. Third, Rosemount has indicated that the suspect sensing unit may have been -

sold 'to other manufacturers for inclusion in transmitters sold under their label. The f problem is already of safety significance (as shown by the Part 21 notice) 8/ but it could be even more extensive. The possibility of other transmitters or components having the same or related Rosemount elements incorporated in their equipment could make this problem more pervasive than it is presently considered based on only Rosemount transmitters being involved. ,

i RECOMMENDATIONS

15. Because of the unique conditions of the Seabrook reactor, its non-operating status, and its systems which are barely broken in (and in some cases not fully tested), and  ;

its plan to challenge the safety systems in power testing, Seabrook transmitter units should '

be subjected to the following revisions and analyses:

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7/ License for Seabrook is limited to low 3ower conditions (i.e., no l The more Operatinfo taan 5 of full power) and only for a duration of 0.75 effective full pow '

hours.

H/ See Attachment 2.

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1. All potentially suspect transmitters should be identi6ed and their importance to safety . status noted, as well as the implications of '

failures at various power levels. "

2. All suspect transmitters which are either safety related or important-to-safety should be changed out before power ascension.  !

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, Signed under the pains and penalties of perjury this 26th day of February 1990.

~t Gref,ory C Minor i

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On this the2 fit;h day of Pnh. 199.0 .betore me, Statebl Onlifornia f ss. '

s Laurita Castro

~ County of . Santa Clara , ,

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the undersigned Notary Public, personally appeared ,

b Gregory C. Minor Q'.

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O proved to me on the basis of satisf actory evidence j }

to be the person (s)whose name(s) 4m subscribed to the 8 within instrument, and acknowledged that he executed it.

fI y WITNESS my ha d off' lal seal.  ;

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, t ATTACHMENT 1-Statement of Professional Qualifications Gregory C. Minor "

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, PROFFMIONAL QUAL IFICATIONS OEGREGORY C. MINOR '

GREGORY C. MINOR l MHB Technical Associates.

1723 Ilamilton Avenue - '

.. Suite K San Jose, California 95125  :

(408) 266-2716  ;

EXPERIENCE:

i p - 1976 to PRESENT Vice President - MHB Technical Associates. San Jose. California '

Engineering and energy consultant to state, federal, and private organizations and individuals. Major activitics .

include studies of safety and risk involved in energy generation, providing technical consulting to legislative, regulatory, public and private groups and expert witness in behalf of state organizations and citizens' groups. ,

Was co editor of a critique of the Reactor Safety S?udy (WASH-14(YJ) for the Union of Concerned Scientists and co author of a risk analysis of Swedish reactors for the Swedish Energy Commission. Served on the Peer

, Review Group of the NRC/TMI SpecialInquiry Group (Rogovin Committee). Actively involved in the Nuclear . 3 Power Plant Standar(is Committee. work for the lastrument Society of America (ISA).

L' 1972 1976- P Manneer. Advanead Control and instrumentation Fnaineerina. General Electric Comnany. Nuclear Encrev Division. San Jose. California Managed a design and development group of thirty-four engineers and support personnel designing systems for use in the measurement, control and operation of nuclear reactors. Involved coordination with other reactor s

design 1 organizations, the Nuclear Regulatory Commission, and ~ customers, both overseas and domestic. i Responsibilities included coordinating and managing and design and development of control systems, safety - l systems, and new control concepts for use on the next generation of reactors. The position included "

. responsibility for standards applicable to control and instrumentation, as well as the design of short term  :

solutions to field problems. The disciplines involved included electrical and mechanical engineering,~scismic ,

design and process computer control / programming, and equipment qualification.

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f Mannocr. Re.setor Control Svstems Declan General Electric Company. Nudcar Enerny Division. San Jose.

Cahfornia 1 Managed a group of seven engineers and two support personnel in the design and preparation of the detailed I system drawings and control documents relating to safety and ~ emergency- systems for nuclear reactors. -

Responsibility required coordination with other design organizations and interaction with the customer's

? engineering personnel, as well as regulatory personnel.

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m 1963 1970 Detion F'naineer. General Electric Comnanv. Nuclear Encrev Division. San Jose. California Responsible for the design of specific control and instrumentation systems for nuclear reactors.- Lead design responsibility for various subsystems of instrumentation used to measure neutron flux in the reactor during startup and intermediate power operation. Performed lead system design function in the design of a major.

system for measuring the power generated in nuclear reactors. Other responsibilities included onsite checkout and testing of a complete reactor control system at an experimental reactor in the Southwest. Received patent for Nuclear Power Monitoring System.

1960 1963 Advanced Ennineerina Program. General Electric Comoany Atalanments in Washincton. California. and Ari7ona Rotating assignments in a variety of disciplines:

Engineer,Lreactor maintenance and instrument design, KE and D reactors, Hanford, Washington, circuit design and equipment maintenance coordination.

Design engineer, Microwave Department, Palo Alto, California. Work on design of cavity couplers for Microwave Traveling Wave Tubes (T%T).  !

Design engineer, Computer Department, Phoenix, Arizona. Design of core driving circuitry, i Design engineer, Atomic Power Equipment Department, San Jose, California. Circuit design and analysis.

Design engineer, Space Systems Department, Santa Barbara, California. Prepared control portion of satellite proposal.

Technical Staff - Technical Military Planning Operation. (TEMPO), Santa Barbara, California.

i Prepare analyses of missile exchanges.

y During this period, completed three-year General Electric program of extensive education in advanced engineering principles of higher mathematics, probability and analysis. Also completed courses in Kepner.

Tregoe, Effective Presentation, Management Training Program, and various technical beminars.

EDUCATION University of California at Berkeley, BSEE,1960.

1 Advanced Course in Engineering three-year curriculum, General Electric Company,1963.

Stanford University, MSEE,1966.

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IlONORS AND' ASSOCIATIONS Tau Beta Pi Engineering Honorary Society -

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Co. holder of U.S. Patent No. 3,565-760, *Nuc1 car Reactor Power Monitoring System,' February,1971.

Member: American Association for the Advancement of Science.

P Member: Nuclear Power Plant Standards Committee, Instrument Society of America. ,

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PUBLICATIONS AND TESTIMONY j l

1.' G. C. Minor, S. E. Moore, ' Control Rod Signal Multiplexing," IEEE Transactions on Nuclear Science. Vol. NS- j 19, February 1972.

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2. G. C. Minor, W. G. Milam, "An Integrated Control Room System for a Nuclear Power Plant," NEDO-10658,  !

presented at International Nuclear Industries Fair and Technical Meetings, October,1972, Basic, Switzerland.  !

3. The above article was also published in the German Technical Magazine, NT, March,1973.

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4. Testimony of G.' C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the Joint Committee on Atomic j 1

Energy, Hearing held February 18, 1976, and published by the Union of Concerned Scientists, Cambridge, '

Massachusetts.

5. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard before the California State Assembly Committee on Resources, Land Use, and Energy, March 8,1976.

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6. Testimony of G. C. Minor and R. B. Hut, bard before the California State Senate Committee on Public Utilitics,  !

Transit, and Energy, March 23,1976.  !

7. Testimony of G. C. Minor regarding the Grafentheinfeld Nuclear Plant, March 16-17, 1977, Wurzbuerg, '!

Germany. j

8. Testimony of G. C. Minor before the Cluff Lake Board of Inquiry, Regina, Saskatchewan, Canada, September 21, 1977. i j

9. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH.1400 (NUREG. i 75/014), H. Kendall, et al, edited by G. C. Minor and R. B. Hubbard for the Union of Concerned Scientists, q August,1977.  ;

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10. Swedish Reactor Safety Study- Barseback Risk Aurument. MHB Technical Associates, January,1978.

(Published by Swedish Department of Industry as Document Dsl 1978:1)

11. Testimony by G. C. Minor before the Wisconsin Public Service Commission, February 13,1978, Loss of Coolan1 Accidents: Their Probability and Conscauence. f

12. i Testimony by G. C. Minor before the California Legislature Assembly Committee on Resources, Land Use, and Energy, AB 3108, April 26,1978, Sacramento, California.

13. Presentation by G. C. Minor before the Federal Ministry for Research and Technology (BMFT), Meeting on j Reactor Safety Research, Man / Machine Interface in Nuclear Reactors, August 21, and September 1,1978, Bonn, '

Germany.

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14. Testimony of G. C. Minor, D. G. Bridenbaugh, and R. B. Hubbard, before the Atomic Safety and Licensing -

Board, September 25,1978, in the matter of Black Fox Nuclear Power Station Construction Permit Hearings, Tulsa, Oklahoma.

15. Testimony of G. C. Minor, ASLB Hearings Related to TMI.2 Accident, Rancho Seco Power Plant, on behalf of

, Friends of the Earth, September 13,1979. ,

16. Testimony of G. C. Minor before the Michigan State Legislature, Special Joint Committee on Nuclear Energy, .  !

Implications of Three Mile Islanti Accident for Nuclear Power Plants in Michinan, October 15,1979.

17. A Critical View of Reactor Safety, by G. C. Minor, paper presented to the American Association for the Advancement of Science, Symposium on Nuclear Reactor Safety, January 7,1980, San Francisco, California.

18. The Effects of Aoino on Safety of Nuclear Power Plann- paper presented at Forum on Swedish Nuclear Referendum, Stockholm, Sweden, March 1,1980.

19. Minnesota Nuclear Plants Gaseous Emiulons Study. MHB Technical Associates, September 1980, prepared for the Minnesota Pollution Control Agency, Roseville, MN. <

20. Testimony of G. C. Minor and D. G. Bridenbaugh before the New York State Public Service Commission, Shoreham Nuclear Plant Construction Schettolt in the matter of Long Island Lighting Company Temporary Rate Case, case # 27774 September 22,1980.

21. Direct testimony of Dale G. Bridenbaugh and Gregory C. Minor before the New York State Public Senice Commission, Kaiser Engineers Power Corporation Review, Shoreham Nuclear Power Station costs and Schedule. in the matter of Long Island Lighting Company Temporary Rate Case, Case Number 27774, September 29,1980.

22. Systems Interaction and Sinnie Failure criterion. MHB Technical Associates, January,1981, prepared for and '

available from the Swedir.h Nuclear Power Inspectorate, Stockholm, Sweden.  !

23. Testimony of G. C. Minor and D. G. Bridenbaugh before the New Jersey Board of Public Utilities, Ovster Creek' j 1980 Refuelinn Outane Invectioation, in the matter of the Petition of Jersey Central Power and Light Company for approval of an increase in the rates for electrical service and ;.djustment clause and factor for such senice, OAL Docket No. PUC 3518 80, BPU Docket Nos. 804-285,807 488, February 19,1981.

24. Testimony of G. C. Minor and D. G. Bridenbaugh on PORV's and Pressurizer Heaters. Diablo Canyon Operating License hearing before ASLB, in the matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), Docket Nos. 50-275-OL,50-323-OL, January 11,1982.

25. Testimony of G. C. Minor and R. B. Hubbard on Emernenev Response Plannino Diablo Canyon Operating License hearing before ASLB, Docket Nos. 50 275-OL,50 323-OL, January 11,1982.

26. Systems Interaction anri Sinnie Failure Criterion Phase II Reoort. MHB Technical Associates, February 1982, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.

27. Testimony of G. C. Minor, R. B. Hubbard, M. W. Goldsmith, S. J. Harwtxx! on behalf of Suffolk County, before j

. the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear '

Power Station, Unit 1, regarding Contention 7B, Safety Classification and Systems Interaction. Docket No. 50-l

,- 322 OL, April 13,1982.

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28. Testimony of G. C. Minor and D. G. Bridenbaugh on. behalf of Suffolk County, before the Atomic Safety and  !

Licensing Board, in the matter of lang Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 11. Passive Mechanical Valve Failure. Docket no. 50-322-OL, April 13, 1982.

29. Testimony of G. C. Minor and R. B. Hubbard on behalf of Suffolk County, before the Atomic Safety and ,

Licensing Board, in the matter of long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1,

• regarding Suffolk County Contention 27 and SOC Contention 3. Post. Accident Monitoring. Docket No. 50-322 OL, May 25,1982.

~ 30. ' Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 22. SRV Test Pronram, Docket No. 50-322-OL, May 25,1982.

31. Testimony of G. C. Minor and D. G. Bridenbaugh on behalf of Suffolk County, hfore the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Reduction of SRV Challences, Docket No. 50-322-OL, Juni 14,1982.

32. Testimony of G. C. Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Pover Station Unit 1, regarding Environmental Onalmention. Docket No. 50 322-OL, January 18,1983.

L 33. Testimony of G. C. Minor and D. G. Bridenbaugh before the ' ennsylvania Public Utility Commission, on behalf of the Office of Consumer Advocate, Renarmaa the Cost of Constructino the Susauchanna Steam Electric i' Statlon: Unit I. Re: Pennsylvania Power and Light, Docket No R 822189, March 18,1983.

lI 34. Supplemental testimony of G. C. Minor, R. B. Hubbard, and M. W. Goldsmith on behalf of Suffolk County, l before the Atomic Safety and Licensing Board, la the matter of Long Island Lighting Company, Shoreham '

l Nuclear Power Station, Unit 1, regarding Safety Cla4 cation and Systems Interaction (Contention 7B1. Docket No. 50-322, March 23,1983.

35. Verbal testimony before the District Court Judge in the case of Sierra Club et. al. vs. DOE regarding the Cleanup I of Uranium Mill Tailings, June 20,1983.

36. Systems Interaction and Sinnle Failure Criterion: Phase 3 Renort. MHB Technical Associates, June,1983, prepared for and available from the Swedish Nuclear Power inspectorate, Stockholm, Sweden.

37. Systematic Evaluation Prouram: Status Renort and Initial Evaluation. MHB Technical Associates, June,1983, i prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.

L 38. Testimony of G. C. Minor, F. C. Finlayson, and E. P. Radford before the Atomic Safety and Licensing Board, in the Matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Emercency

[ Plannina Evacuation Times and Doses (Contentions 65. 23.D and 23.H), Docket No. 50 322 OL 3, November 18,1983.

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39 Testimony of G. C. Minor, Sizewell'B' Power Station Public Inquiry, Proof of Evidence Recardina Safety Issues.

December,1983.

n 40. Testimony of D. G. Bridenbaugh, L M. Danielson, R. B. Hubbard and G. C. Minor before the State of New York Public Service Commission, PSC Case No. 27563, in the matter of Long Island Lighting Company Proceeding to Investiaate the Cost of the Shoreham Nuclear Gen ratina Facility -- Phase II, on behalf of County L of Suffolk, February 10,1984.

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- 41. Testimony of Pred C. Finlayson, Gregory C. Minor and Edward P, Radford before the Atomic Safety and Licensing Board, in the Matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, on ~

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behalf of Suffolk County Regarding F=ernency Plaaaina - Shcherina (Contention 61). Docket No. 50-322 OL, 1 March 21,1984.

42. Testimony of G. Dennis Eley, C. John Smith, Gregory C. Minor and Dale G. Bridenbaugh before the Atomic I Safety and Licensing Board, in the matter of Long Island Lighting company, Shoreham Nuclear Power Station Unit 1, regarding EMD Diesel Generators and 20 MW Gas Turbine. Docket No. 50-322 OL, March 21,1984.

43. Revised Testimony of Gregory C. Minor before the Atomic Safety and Licensing Board, in the matter of Loog Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County regarding i Emernency Plannino - Recovery and Reentry (Contentions 85 and 88). Docket No. 50-322-OL, July 30,1984.

44. Testimony of Dr. Christian Meyer, Dr. Jose Roesset, and Gregory C. Minor before the Atomic Safety and '

Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, on behalf of Suffolk County, regarding Low Power Hearince - Seismic Capabilities of AC Power Sources. Docket No. 50-322 0L, July 1984.

45. Surrebuttal Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, Richard B. Hubbard, and Gregory C. Minor, -

Before the New York State Public Service Commission, PSC Case No. 27563, Shoreham Nuclear Station, Long Island Lighting Company, on behalf of Suffolk County and New York State Consumer Protection Board, regarding Inystiontion of the Cost of the Shoreham Nuclear Generatino Facility. October 4,1984.

46. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on behalf of Massachusetts Attorney General, DPU 84-145, before the Massachusetts Department of Public Utilities, regarding Prudence of Ernenditures by Fitchburn Gas and Electric I loht Company for Seabrook Unit 2. November 23,1984,84 pgs.

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47. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson and Gregory C. Minor on behalf of Maine Public Utilities Commission Staff regarding Prudence of Costs of Seabrook Unit 2. Docket No.84-113, December 21, 1984.

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48. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Suffolk County regarding Shoreham Emernency Diesel Generator Loads, Docket No. 50-322 OL, January 25,1985.

49. Direct Testimony of Dale G. Bridenbaugh, Lynn M. Danielson, and Gregory C. Minor on behalf of the Vermont Department of Public Service, PSB Docket No. 5030, regarding Prudence of Central Vermont Public Service Corporations costs for Seabrook 2. November 11,1985.

50. Surrebuttal testimony of Gregory C. Minor on behalf of the Vermont Department of Public Service, PSB Docket No. 5030, Prudence of Central Vermont Public Service Coroorations Costs for Seabrook 2. December 13,1985.

L 51. ' Direct Testimony of Dale G. Brideabaugh, Gregory C. Minor, Lynn K. Price, and Steven C. Sholly on b half of I State of Connecticut Department of Public Utility Control Prosecutorial Division and Division of Consumer Counsel regarding the Prudence of Exnenditures on Millstone Unit 3. Docket No. 83 07 03, February 18,1986.

52. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General regarding the Prudence of Exnenditures by New Fnoland Power Co. for Seabrook Unit 2. Docket Nos. ER 85-646-000, ER 85-647 000, February 21,1986.

53. Direct Testimony of Gregory C. Minor on behalf of the Prosecutorial Division of CDPUC regarding CL&P Construction Prudence for Millstone Unit 3. Docket No. ER 85 720-001 March 19,1986.

54. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General I regarding WMECo Construction Prudence for Millstone Unit 3. Docket No.85-270, March 19,1986.

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55. Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of Massachusetts Attorney General I regarding WMECo's Commercial Oneratina Dates and Deferred Canital Additions on Millstone Unit 3. Docket 4

No. 85 270, March 19,1986.

56. Rebuttal Testimony of Dale G. Bridenbaugh and Gregory C Minor on behalf of Massachusetts Attorney General ,

regarding Rebuttal to New Paoland Power Company's Seabrook 2, Docket Nos. ER-85-646-001, ER 85-647-001, April 2,1986.

57. . Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor on behalf of State of Maine Staff of Public ,

Utilities Commission regarding Cnnstructinn Prudence of Millstone Unit 3. in the inatter of Maine Power Company Proposed lacrease in Rates, Docket No.85-212, April 21,1986.

53. Implications of the Chernobyl-4 Accident for Nuclear Emernency Plannina for the State of New York. prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.

59. Direct Testimony of Dale G. Bridenbaugh and Gregory C Minor on behalf of the Vermont Department of Public Service, regarding Prudence of Costs by Central Vermont Public Service Corocration for Millstone 3.

Docket No. 5132, August 25,1986.

60. Surrebuttal Testimony of Gregory C Minor in the matter of Jersey Central Power and Light Company, regarding .

TMI Restart and Performance incentives. (Oral testimony), OAL Docket No. PUC 7939-85, BPU Docket No. l ER851116, September 11,1986.

.6L Surrebuttal Testimony of Gregory C. Minor on behalf of State of Vermont Department of Public Service, .

regarding CVPS/NU Construction Prudsats related to Millstone Unit 3. Docket No. 5132, November 6,1986.

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r 2. Direct Testimony of Gregory C. Minor and Lynn K. Price on behalf of State of Vermont Department of Public Service, regarding Prudence of Exnenditures for Seabrook 1. Docket No. 5132, December 31,1986.  !

63. Direct Testimony of Gregory C Minor on behalf of Suffolk County, before the Atomic Safety and Licensing Board, concerning Shorehnm - Protective Action Recommendations (Con'ention EX 36L in the matter of Long j island Lighting Company, Shoreham Nuclear Power Station, Unit 1, Docket No. 50-322 0L-5, February 27,1987. 4 1

64. Direct Testimony of Gregory C. Minor et. al. on behalf of the State of New York and St ffolk County, before the i Atomic Safety and Licensing Board, regarding The Scone of the Rmeraency Plannino Exercise (ContentionLE(

15 and 16L in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1,' Docket

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No. 50-322 OL 5, April 6,1987. '

65. Direct Testimony of Gregory C Minor regarding Fmernency Plannina Recention Centers - Monitorine and J Decontamination. Shoreham Docket 50-322-OL 3 (Emergency Planning)' April 13,1987.

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66. Testimony of Gregory C Minor, Steven C. Sholly et. al. on behalf of Suffolk County, regarding LILCO's i Recention Centers - Plannino Basis. before the Atomic Safety and Licensing Board, in the matter of Long Island l Lighting Company, Shoreham Nuclear Power Station Unit 1, Docket No. 50-322-OL-3, April 13,1987.

67. Rebuttal Testimony of Gregory C Minor and Steven C Sholly on behalf of Suffolk County regarding LILCO's Reception Centers (Rebuttal to Testimony of Lewis G. Hulmant in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, Docket No. 50-322 OL 3, May 27,1987.

68. Direct Testimony of Dale G. Bridenbaugh and Gregory C Minor on behalf of Massachusetts Attorney General I before the Federal Energy Regulatory Commission, regarding Canal Electric Comnany Prudence Related to Scabrook Unit 2 Construction Exnenditures. Docket No. ER86-704-001, July 31,1987.

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69. - Direct Testimony of Dale G. Bridenbaugh and Gregory C. Minor before the Pennsylvania Public Utility Commission, Regarding Beaver Vallev Unit 11979 Oulagt, Docket No. 1 79070318, OCA Statement No. 2,

. August 31,1987.'

, - 70. Oral testircony of Gregory C, Minor Before the Illinois Pollution Control Board on behalf of Reed Custer .

Community Unit School District No. 255 U, re: Braidwood Coolina Pond September 8,1988, Case PCB 87-209,

71. Testimony of Gregory C. Minor in the U. S. District Court, Brooklyn, New York, September 31,1988, re: County of Suffolk vs. LILCO et. al Case CV 87-646.

72. GE Reed Reoort Safety Issue Reviews. Issues 5,10, and 24, prepared by MHB Technical Associates for The Ohio State University Nuclear Engineering Program Expert Review Panel, Public Utility Commission of Ohio, October 1988.

73. Direct Testimony and Exhibits of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of -

Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, Investination of Piierim Outage, DPU 88 28, November 30,1988, PROTECTED INFORMATION.

74. Supplemental Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of i Massachusetts Department of the Attorney Gerieral, Re: Pilgrim Nuclear Power Station, Investination of Pilcrim Outage, DPU 88-28, January 20,1989, Exhibit AG 2.

75. Testimony of Gregory C. Minor, U. S. District Coust, Brooklyn, New York, February 3,1989, re: County of Suffolk vs. LILCO et. al Case 87 CIV. 646 (JBW).

76. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C, Sholly on Behalf of--

M2ssachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, Investiention of Pilcrim Outage. DPU 88-28, February 13,1989, Exhibit AG 74.

77. Surrebuttal Testimony of Dale G. Bridenbaugh, Gregory C. Minor and Steven C. Sholly on Behalf of Massachusetts Department of the Attorney General, Re: Pilgrim Nuclear Power Station, Investication of Pilgtim Outage, DPU 88-28, February 17,1989, Exhibit AG-93.

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i ATTACHMENT 2 February 9,1989 Notification Under 10CFR21 v

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RET Notification Under 10CTR21 Rosemount places the highest commitment on product reliabi)ity are se:vice to the Nuclear Power Industry.

IA a letter dated December 12, Dbs, we natitj;ed the Ineastry;of a potential failure that oonid occur in our

-model 1153 and 1154 transmitters. Rosemount has dotarained that a furt.hcr notification to you, our customer, le required undu the regulatione called out in 10 CFR Part 21.-  ;

The intent of this letter is to further describe the potential f ailure and identify which transmittore in your  ;

plant or' plant aites mey be affocted. 7 1

The f a11ure mode is e. loss of fill fluid from the transmittar sensing meAule due to internal leak (no oil is 1

'l s lost'into the proc *as tiuid), when thic condition occurs, L

the transmittar u.ay exhibit reduced performanoa prior to a D detectable failure. This twduced performance may manifest itself as an output shift, lack. of response over it's full

. range, and/or an incrosse in time response. The loss-of j time response any be uni-directional. At'this time, we have l not bean-able to determine the limits of this potential  ;

L i partormance reduction'.

1 named on suisting confirmed infornation, all reported 1 I

failures to date occurred during the first 30 months-o*

' servios and eventually resulted in a detectable condition I i during that 30 month time span. . In these situations, the transmitter would show an increasing outpot shift, typically followed try a significant output phift, and then possibly Other.. symptoms.

l D resulting sa a high or low offacale read .

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' that any teentify less of cil include inah lity to calibrate

[ (aluggish response or partial responne) and reduced noise in a signal that.moraally would show noise. Osta av3tlable

-also suggests but does not yet confirm that-transmitters which have been in uervios for mors than 36 months are not go1.ng to fail in this way.

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i re.bruary 9,-1989-Page . 2-Recent information indicates that prior to detectable .

failure, the trinamitter.may continue to provide a signal but not' respone over it's full range ana/or time response may be significantly degraded. This may be a safety concern ,

at your plasnt..

At this time we do not have details as to the seguanoe of symptoms- or to the magnitude of this perfo:nnanos reduction.

testim is currently underway to determine limits for this J

conditaon and a possible method by which te detect affected

,m trannaittars.. Testing will not be coupleta until'at least l sid-April' and upon completion, we will again notify .the Inoustry.

me haye found that t.his fa11ure mode haa occurred in certain ,

groups of transmitterc. Transmitters f rom these groups, .

which have been shipped to your plant or plant sites by Rosamount are listad on the attachment to this letter. ,

While these transmittare may centinoe to-perfotin in a  !

satisf actory manner, they are part of. a segregated group which has shown a susceptibility to fail.

Rosemount has taken action to correct the source of this probles by improving the manufacturing process and intensifying tsst criteria, those actions . assure that the potential'for failures of this nature in transa.itters currently being produced has essentially been eliminated. -l Rosemount; recommends that you -identify the location of these ,

transmitters in your_ plant and detaraine the ef f ect which this reduced performance may have in each situation. We stand _ ready'to as,sist your efforts to correct any situation which.may arise from-your review.

Rosamount will continue to monitor the situation and you i will'be kept informed of any new information that becomes available, Please contact us directly if you have sean these symptoms cr.if you have any questions. Call Tim Iayer-(612) 828-3540, Neil 1.ien (612) 829-3100, or Jane Sandstrom (612) a28- I 3286.

J Sinoarely, ROSDOUNT INC.  ;

1 Steve Wansk V.P. Operations

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ATTACHMENT 3 IN 89 42 April 21,1989 .

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x UNITED STATES NUCLEAR REGULATORY COMMISSION d 0FFICE OF NUCLEAR REACTOR REGULATION A WASHINGTON, D.C. 20555 g

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April 21,1989 E G J

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NRC INFORPATION NOTICE NO. 89-42: FAILURE OF ROSEMOUNT MODELS 1153 AN M 154 1 TPANSMITTERS

• I Addressees:

All: holders of operating licenses or construction pernits for nuclear power reactors.

Purpose:

This information notice is being provided to alert addressees about recent f ailures of Rosemount models 1153 and 1154 pressure' and differential pressure transmitters. It is expected that recipients will review the information for applicability tc their facilities and consider actions, as appropriate, to -)

avoid similar prchlems. However, suggestions contained in this information 1 notice do not constitute NRC requirements; therefore, no specific action or '

written response is required. ,

Description of Circumstances: ,

During 1986 and 1987, five Rosemount model 1153 HDSPC differential pressure transmitters malfunctioned at Northeast Utilities'- (NU) Millstone Nuclear Fower Station, Unit 3. During power operation, the Millstone operators noted Lthat the signals from the Rosemcunt 1153 transmitters were deviating from .

redundant channel signals and'that the transmitters were indicating reduced levels of process noise. The transmitters were declared out of service by NU personnel, and the affected channels were placed in the tripped condition.

After attempts to calibrate the transmitters failed, NU returned >the trans-mitters to Rosemount and informed them that the malfunctions had occurred with transmitters of the sare model and related serial numbers. Destructive ,

testing performed by Rosemount determined that the feilures were caused by the '

loss of oil from the transmitter's sealed sensing module. However, Rosemount indicated that the failures appeared to be. random and not related to any generic problem with Rosemount.1153 pressure transmitters. NU submitted a 10 CFR Part 21 nctification to the NRC on this issue on March 25, 1988, and provided adcitional  ;

informatien on the failures via a letter dateo April 13, 1989. n

' Ci scussior.: '

Af ter additional evaluations by NU and Roser.our.t, Rosemount issued a letter

'.o its custwers on December 12, 1988, regardirg the potential malfunction of models 1153 and 1154 tressure and differential pressure transmitters. The 8904100193

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g IN 89 a2 April'21, 1989 Page 2 of 3 RosercLnt letter was supplemented with a letter dated 'ebruary 7, 1989, to=

customers who had purchased transmitters from specific lots that were identi- -)

i fied by Rosemount as being potentially defective. Rosemount issued a separate l letter dated February 16, 1989, to customers who had purchased model 1153 and

1. A transmitters from lots that were not considered suspect. Rosemount indi- .l' p cated that transmitters from the suspect lots were susceptible to a loss of silicone oil, from the transmitter sealed sensing module and to possible fail-ure. According to Rosemount, as the oil leaks cut of the sensing module the transmitter's performance gradually deteriorates and may eventually lead to a oetectable failure.

' Some of the symptoms that lave been observed during operation and before failure include slow drift in either direction of about 1/4 percent or more per month, lack of response over the transmitter's full range, increase in t

the transmitter's time response, deviation from the normal signal fluctuations, decrease in the detectable noise level, deviation of signals from one channel compared with redundant channels, "one sided" signal noise, and slow response to a transient or inability to follow a transient. Some of the symptoms observed by NU personnel during calibration include the inability to respond- 'I over the transmitter's entire range, slow response-to either increasing or _j decreasing hydraulic test pressure, and drif t of greater than 1*. from the j' previous calibration.

• Although some of the defective transmitters have shown certain symptoms before their failure, it has been reported that in some cases the failure of a trans-mitter may not be detectable during operation. .In addition, Rosemount now .

indicates that the potential for malfunction may not be limited to the speci- j

'fied manufacturing lots previously identifico in the February 1989 letter.  !

4 It is important for addressees to determine whethor any Rosemount models l3 and 115a pressure and differential: pressure transmitters, regardless of their - l 1

1 manufacturing date, are installed.in their facilities and to take whatever j actions 'are deemed necessary to ensure that any potentiel failures of these _i transmitters are identified.- Although it may not be possible to detect the {

onset of failure in all ir. stances, scme transmitters have exhibited scme of l y the aforementioneo symptoms before failure. It is important for potential i failure modes to be identified and that operators be prepared for handling i potential malfunctions. In addition, careful examination of plant data,

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' calibration records, and operating experience may yield clues that identify l potentially defective transmitters, Adoressees may wish to contact Rosemount j for~assistar.ce in determining appropriate corrective actions whenever any of- l the aforementioned symptoms are observed er if failures are identified, i On April 13,19ES, the NRC staf f met and discussed this matter with Rosemount I and several industry groups. Rosemount has launched a program to identify the i p root cause of the loss of oil from the sensing module and to determine recom- ,

p mendations for its customers to address poter.tially oefective transmitters. i i

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IN 89-42 April 21,1989 Page 3 of 3 No specific action or written response is required by this information notice. l If you:have any questions regarding this matter, please contact one of the technic 61 contacts listed below or the Regional Administrator of_the appro-J priate regional office, arl , cto[

Division of Operational Events Assessment

p. Office of Nuclear Reactor Regulation Technical Contacts: Kamal Naidu, NRR '

(301)492-0980~

Jaime Guillen. NRR  !

(301) 492'1170 l

Attachment:

List of Recently Issued NRC Information Notices 1

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i9-ATTACHMENT 4 '

Draft NRC Bulletin Released 1/29/90 -

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OMB No.: 3150-0011 '

. , N'tCB 90-XX

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UNITED STATES l NUCLEAR REGULATORY COMMIS$10N .t Off!CE Of NUCLEAR REACTOR REGULATION I)fB M peep WASHINGTON, D.C. 20555 ggg g  !

January xx,1990 /24a oc/ 7 8 /2d90  ;

KRC BULLETIN NO. 90-XX: LOSS Of FILL-0!L IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT Addressees:

All holders of operating licenses or construction permits for nuclear power reactors.

Purpose:

This bulletin is being provided to request that addressees take actions to

"' promptly identify and replace transmitters manufactured by Rosemount that may

~ 1 bt 1ea king .fiii-cili ~~ l Description of Circumstances:

HRC 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 f ailures of: Rosemount Models 1153 arid 11:,4 pressure and differential pressure transmitters. The reported failures occurred at Northeact Utilities' Hillstone Unit 3.between March and October 1987._ Subsequent investiga?lon into

_ the cause of the failures by Roserount confirrned that the failure mode was a gradual loss of- fill-oil from the transmitter's sealed sensing rnodule. *

,04scussion of Safety Significance:

L 'The performance of a transmitter that is leaking fill-oil gradually deterio- -J 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 tnat 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. i i

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,D y ussion:

Model 1151, 1152, 1153, and 1154 Resemount transmitters are utilized exten-l sively in nuclear power plants. Model 1153 and 1154 transmitters are supplied i- by Rosec.ount as both seismically and environmentally qualified equipment.

L Fedel 115. transtnitters are supplied by Rosemount only as seismically qualified

' equ ipre tat . Model 1151 transmitters are supplied by Rosemount as comer.lal-grace equiptrent.

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NRCB 90-XX January xx, 1990 page 2 of 10 Rosemount has indicated, to d.te, that failure of approximataly 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 modu'e i' seoled, loss of-fill-oil usually cannot be confirmed without destructive analysis of the sensing trodule. hRC staff review of this issue has identified additional failed Model 1153 anc' 1154 transmitters with symptoms indicative of loss of fill-oil that may not have been brought to Rosemount's attention. Thus,.the number of f athd Model 1153 and 1154 transmitters that have experienced a loss of fill-oil may be greater than that confirmed by Rosei.ount.

Rosemount has indicated that similar sensing modules are utilized in Model 1151,115?,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 '

failure have been confirmed. The NRC staf f believes that, while Model 1153 and 1154 transmitters have a greater susceptibility to loss of ' fill-oil, Model 1151 and 1152 trans.aitters may .15o be susceptible to loss of fill ot1. Thus, loss of fill-oil may be generically applicable to Rosemount manufactured sensing modules. Accordingly, for the purposes of the actions requested in this-bu-iletinrttodet 1151 and 1162 transmittW5 Utilized ~1n safety-related systems'should be addressed in a manner comparable to thit of Model 1153 and 1154 transmitters, in addition, Rosamnunt has indicated that they have insti-tuted additional quality control and quality assurance steps in the manufactur-ing process that they believe will minimize the potential for Model 1153, and 1154 transmitter failures due to loss of fill-oil. As o result, Rosemount has indicated that Model 1153 and 1154 transmitters manufactured of ter July 11 1989 are not subject .to their May 19M 10 CIR Part '.'l notification. The FGC staf f has not, to date, received indicot tons that Model 1153 and 1154 transmit-ters manufactured by Rose.nount subsequent to July 11,1989 are susceptible to loss of fill-oilt therefore, the tGC staf f 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 .iot, to date, received sufficient information to address the applicability of these

! manuf acturing process modifications to Model 1151 and 1152 transmitters.

Rosemount had previously indicatec' that Model 1153 and 1154 transmitters that wer. experiencing a loss of fill-r il should fail within approximately 36 rnenths l of in-service time. Recent information indicates that the ra'e at which  !

till oil leaks is application and pressure dependant, ihtrefore, while trarismitters that are experiencing a loss of fill-oil that are subject to cuntir,uous high-pressure (e.g. reactor operating pressures) may f oil within this timef rame, transtnitters utilized in low-pressure systems or not subject 19 cu.tinuous high-pre sure may take langer to fail.

Posemount has indicated that they manufacture both complete transmitters and

• transnitter parts (including sensing modules) for other mar.ufacturers. At 1(as t ore sendor purchases complete transn.itters frorr. Fosetr.ount and then -

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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 dif ferent -

brandname. At least one other. instrunent 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-cil. In additinn, Rosemount has indicated that unauthorized g

~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 nomal opera-tion if it is leaking fill-cil include: <(

• i a slow setpoint diif t of 1/4 of 1 percent per month deviation from the normal system signal fluctuation that is consistent in only the. increasing or decreasing direction ("one-sided-noise") .

slow respense to or insbility to follow planned or unplanned plant transients - i c -

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a , decrease in noise _applitude . . l an output that deviates from that nf redundant transmitters '

The symptoms a Model 1153 or 1154 transmitter may cxhibit during calicration activities if it is leating fill-oil intlude: l I

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inability tn respond 'over t he ent ire des ign r ange j slow response to either an increasing nr decreasing test pressure

.drif t of greater than 1 percent from the previous calibration i

l The NRC staff believes these symptoms can also be utilized to detect other '

y transmitter h.odels 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 tr:.05mitters L should be put into the enhanced surveillance program (pr qsure versus o time-in-service and only Model 1153 and 1154 transmitters). -

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NRCD 90-XX -

January xx, 1990 l

• " Page 4 of 10 '

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Certain manufacturing lots of Model 1153 and 1154 transmitters have been previously identified by Rosemount as having had a high failure fraction (on ' I the order of 61) 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 staff believes that transmitte 3 from these suspect lots have an unacceptably high susceptibility to f ailure f rom loss of fill-oil and should not be utilized in the re.: tor 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 suf ficient capability to allow periodic testi.ig of its functioning when the reactor is in operation 1.1 order to readily detect failures of subcon.ponents and subsystems.within the protection system as well as loss of the required protection system redund6. icy a they occur.

10 CFR 50.55a(h) requires that protection systems meet the Institute of Elec- '

,trical and Electrcnies Engineers Standard: " Criteria for Protection Systems ' for ,

1 Nuclear Power Generating Stations" (IEEE-279). lEEE-279 states that means l shall be provided for checking, with a high degree of confidence, the. opera- ,

i.ici>61-avaHabtlity ef eachwytteinput sensnr -duririg reactor operation. -

Thus, the NRC staff concludes that faillittis that utilize transmitters that snay be susceptible to loss of fill-oil me ont be in tull compliance with .

.these regulations because undetected trateanitter f ailure could occur. '

Accordingly, the NRC stof f renuests that oddreswe'. tali the actions requested below.

Requested Actions:

Operating Reactors l' . Identify, within 60 days af ter t!.e receipt uf this bulletin, all pressure

.or differential pressure transmitters, including Model 1151, 1152, 1153, and 1J54 transmitters but excluding Hodel 1153 and 1154 transmitters -

manufactured by Rosemousit subsequent to iluly 11, 1989, that were manu-factured by Roserount or that contain Rosemount manufactured sensing modules and are utilized in either safety-related systems or systems l installed in accordance with 10 CFR 50.62 (the ATUS rule). Addressees .l may find it necessary to perfostr, in addition to document reviews, system waladowns to complete this action. In addition, the following information .

is provided to f acilitate addressee's activities in this area.

All Model 1153 and 1154 transmitters, whether obtained directly from l

Rosemount, obtained through intermediary suppliers, or prov.ded as an integral part of another component (such as an emergency diesel '

generator), should a) indicate manufacture by Posemount, b) have a distinctive Rosr.nount model and serial number, c) have the physical profile charac! eristics of a Rosemouat transmitter, and d) have a blue or  !

E stainless steel housing. Rosemount has indicated that Model 1153 anil

! llM transmitters are not provided to other manuf acturers for resole l l_

u t.c e , a different bras.Jname, in addition, a simplified diagram that l l

t descrit,es the typical physical characteristics of a Rosenount trarsmitter l l

is g rovided by Attachkent !. [ i i DWT  :

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'l Model 1152 tr.insmitters, except 45 noted belew, should a) indicate.

soanufacture by Rosemount, b) have'a distinctive Rosemount model and 1 seria'. number, c) have the physical profile characteristics of a ;I 3

Roseracunt transtrittle, and d) have a blue or stainless steel housing.  !

Rosecount has indicated ti.ot they have supplied Model 1152 transmitter sensing modules to Dalley Controls (formerly Poiley Peter). Belley ,

.rnaqufactured transmitters that contain Rosemount nanuf acturtd Hocel 115? )

sensing) modules rounded -than have gray Rosemount housings that appear slightly diffarent (more housirigs.

. I Model !!51 transmitters, except as noted below, should a) indicate ,

, renufacture by Rosemount, b) hcve a distifictive Rosemount enodel and l serial nurrber, c) have the ph Rosemount transmitter, and d)ysical profile have a blue characteristics housing. Model 1151 of a 1 l

transmitters manuf actured by Rosemount may have been supplied for use in nuclear power plants by other original equipment manufacturers (OEM's).

The OEM's identified in Attachrent ? may of fer for resalt- under their own .i brandname Mocel 1151 transnitters purchased from Rosemount. These ,-

Lj transmitters should have the physical profile characteristics of a i Rosemount transmitter and have a blue housino, fisher Controls may also ,

I of flir76r"fR&TE 6~nder ~thcTr~owW tWndnaFHodel 1151 transmitters e a

purchased from Rosemount. These transmitters should have the physical profile characteristics of a Rosemount transmitter, but have a green *

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' housing. 'In addition, Posemount has indicated that they have supplied Model 1151 transmitt'er sensing modu:es to Halley Controls. Dailey manufactured transmitters that contain Rn'.crount manuf actured Model 1151 sensing) modules have housings.

grey hnusing ' hat appear ' light ly dif f erent (more rounded than Roseraount

2. Review, within 90 days af ter receipt of this bulletin, plant records (for example, calibration records) associated with the transmitters identif, led .

.in item 1 above to determine whether any of these transmitters ma'y hdvs-

)

already exhibited 'vmptoms indicative of Inss of fill-oll. Appropriate ,

operability acceptance criteria shoul.d be developed and applied to 'l transniitters identified as having exhibited symptoms indicative of loss -

of fill-oil from this plant record review. Transmitters identified as c ,

having exhibited symptoms indic'ative of loss of fill-oil that do not conform to the operability acceptance criteria should be addressed in eccordance with the applicable technical specification. Transmitters- 1 identified d*, having exhibited symptoms indicative. of loss of fill-oil that do not conform to'the operability acceptance criteria and are .not addressed in the technic al !". :ifications should be replaced at the earliest appropriate opportunity.

3.. ' Develop and implernent, within 120 days af ter receipt of this- bulletin, an enhanced surveillance program to monitor trar .it ters identified in item l l for symptoms of loss of fill-oil. This enhanced surveillonce program  ;

l

[ should consider the following or equally effective actions:

(

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• i l: NRCB 90-KK January xx,1990 -

Page 6 of 10-a) Ensuring appropriate licensee personnel are aware of the symptoms i that a transmitter, both during operation and during calibration  ;

activities, may exhibit if it is experiencing a loss of Till oil and i the need for prompt identification of transtritters that may exhibit these symptoms; P

b) Enhanced transmitter monitoring to identify excessive transmitter drift;

• c) Review of transmitter output data following planned or unplanned .

plant transienti or tests to identify sluggish transmitter response; '

u d) Inclusion of sensor response time testing into routine channel calibration activities; e) Development and implementation of a program to detect a decreast in -

transmitter noise it.'el ampIttude; and f) Development and application in tronsmitters identifico as having exhit>4ted symptoms- indicn ive of loss-of fill-oil of an appropriate

• operability a*(eptance c'iterto. Transo.itter s identified as having.

exhibited syrnptorns indicalive of lou of fill-nil that do not conform ,

to the operability acceptoue is tter to should be addressed in -

accordance Hth the applitchle t ec hn t<.41 spei t t t ration. Transmitters

, identified as bovin9 erh bited sympti,ms indicative of loss of fill oil that do not cot;tmm to the operehtlity acceptance criteria and are not addressed in the technical specifications should be s eplaced at the earliest appropt tote opportunity.

1

4. petermine, within 60 days after re r tpt of thi', bullettie, whether any Hodel 1153 or 1101 transmitters ident if ied in item I are f rom the .

manuf acturing lots that have b'.n identified by Rosemount as having a high failure fraction due to loss of fill-oil. (Inf ornation concerning I these transmitters was provided to industry by Rosemount concurrent'with .

I Reference 4). Aodressees are requested not to utilize transmitters from these suspect lots in the reactor pintection or engineered safety '

featurn actuation systems; therefore, transmitters from these suspect "

lots in use in the reactor protection or engineered safety features actuation systerrs should be replaced at the earliest approptlate -

opportunity.

5. Document, within 60 days af ter receipt of this bulletin, a .d :intain in . I accordance with plant procedures a basis for continued plar,t operation

• covering the time period from the present until such time that the Model

• j 1153 and 1154 transmitters from the manufacturir.g lots that have been l

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DQ"'j";gg?anuary us,1990 page 7 of 10

,*. i 9

identified by Rosemount as having a higli failure fraction due to loss of fill oil in use in the reactor protection or engineered safety feature, ,

actuation systems can be replaced, in addition, while performing the ,

i actions requested above, addressees may identify transmitters exhibiting symptoms indicative of loss of fill. oil that Jo not conform to the 1 established operability accepta' ice 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 I transmitters covering the time period from the time these transmitters ,

are identified until such time that these transmitters can be reul.'ced.  !

When developing and updating this basis for contitucd p1' ant oper tion, 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) imediate replacement of certain suspect transmitters. '

Construction permit Hniders.

1. All construction permit holders are requested to complete I* ems 1 and 3 '

of Requested Actions for Operating Reactors prior to the date scheduled

• i for fuel loading or in accordance with the timeframes specified for  !

Operat,ing React _ ors, whichev,er is,, late,r.. ,

2. All construction permit holders that are completing items 1 and 3  ;

of Requested Actions fc. Operating Peactors in accordanc' e with the '

timefranes specified for Operating peactors are requested to complete items 4 and 5 of Requested Actions for Operating Reactors in accordance with the tirefrAmes specified for Operating Reactors. ,

3. All construction permit holders that are completing item 1 and 3 of '

Requested Actions for Operating Reactors prior to the date schedu'ad for '

3 '1 fuel loading are .equested to address the intent of items 4 end 5 of Reque.ted Actions for Operating Reactors by performtre the following' -

actions:

e, 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 idertified by Rosemount es having a high failure fraction due to loss of fill-oil tha. are installed in the reactor protection or engince ed safety 'catures actuation systems; and b) Docunent and matiit61n in accordance with plant procedure's a basis f or 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 cceptance criteria and are not addressed.in the technical specifications covering the time period from the tihe' these transmitters are identified until suCh time that these transmitters Can be replaced.

s When developing and updating this basis for continued plant operattor , ,

ddditssPe$ m1y Oish to Consider trJrsmit ter diverbity and redundancy.

F l, div rse trip functions (a separate trip function that stay also prosice -

i a coi responding trip. signal). special system and/or cocponent tests, or (if necessary) ir.n.ediate replacement of certain suspect trarsn.itters. )

! DRAFT J I

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NRCB 90 KK ghr4 D *v January <*,1990

• g l' age 8 of 10 t

Peporting Regt:irements:  !

_0peratino Reactors  !

t

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

a) Confirms that those Requested Actions for Operating Reactors in l g items 1, 2, 3, 4, and 5 that are to be completed within 120 days t e

after receipt of this bulletin have been completed and that programs l are in place to perform the remaining requested actions; b) Identifies the indicated manufacturer; the model nuntser; the I safety related system the transmitter was utiliped in; the approxi. l mate amount of time la service; the corrective actions talen; and the '

' disposition (e.g., returned to vendor for analysis) of transmitters, including those identified while_ performing item 2 of kequested i Actions for Operating Reactors atiove, 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; and ,

' n .

c.  : .. .a W

'" 4dentifiss.-4,t4-46f+t.welated-systemin.which the Model !!$3 or 1164, 0s transmitters from the manufacturir.g Ic, that have been identified

• by Rosemount as having at hi, f silure fraction due to loss of fill oil are utilized and provides a schedule for replacement of these transmitters which are in use in the reactor protection or engineered safety features actuation systems.

'2. Transmitters that, subsequent to providing the response required by item 1 above, exhibit syrnptoms 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 so be reportable, addressees are requested to document and maintain, in accordance with plant proce-dures, information consistent with that requested in Item I b) above for each suspect transhtitter identified.

Constr'ation permit lioiders

1. All holders of construction permits that perform items 1 and 3 of j Requested Actions for Operating Reactors in accordance with the timeframes i specified for Operating Reactors should provide, within 120 days of ter '

f receipt of this bulletin, a response that: ,

a) Confirms that those Requested Actions for Operating Reactors in items 1, 3, 4, and 5 that are to be comp 10ted within 120 days af ter I receipt of this bulletin have been completed and that programs are l in place to perform the remaining requestert actions; and '

I i b) Identifies the safety related system in which the Model 1153 or 11!4 transmitters from the tr.anuf acturing lots that have been identified by Posemount as having a high failure fraction due, to loss of  ;

[ fill oil are utilized and provides a schedule for replacer.ent of i i .

these transmitters which are in use in the rN rter protect 10f. er

engineered safety features actuation systeris, y

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NRtB 90 IX January xx,1990

. Page 9 of 10 l

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: '

1 a) Confirms that all actions in items 1 and 3 of Requested Actions for OperatingReactorshavebeencomplete{;and l b) Confirms that Model 1153 or 1154 trendinitters from the manufacturing -

lots that have been identified by Rosemount as having a high failure fractior, due to loss of fill-oil are n'ot utilized in the reactor protection or engineered safety features actuation systems.

3. Transmit'ers that, subsequent to providing the response required by item '!

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 under existing NRC regulations. If determined not to be reportable, addressecs are requested to document and maintain, in accordance with plant procedures, information consistent w'ith that requested in item I b) -

Of th prth; ":q,;h;;ts for-OperetiftF eetters P ebove-for esch-suspect transmitter identified.

The written reports required above shall be addressed to the U.S. Nuclear Regulatory Commission, ATTN: Docunent Control 0'esk, Washtr aton, D.C. 20555, and shall be submitted under oath or affirr.ation; pursuant to the provisions of  ;

Section IB2a, Atomic Energy Act of 1954, as anented and 10 CFR 50.54(f). In addition, a copy shall be sutimitted to the appropriate regional Administrator, ,

Backfit Discussion I The objective of the actions requested in this b'ulletin are to ensure that transmitter f ailures due tu loss of fill-oil are' promptly detected. Loss of. <

fill-oil may result in a transmitter nst perform _ing its intended safety l function. '

, 1 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, l

Therefore, a full t>acifit analysis was not performed. An evaluation of the type discussed in 10 CFR 50.109(a)(6) was performed, including a staterent of the objectives of and reasons for the modification and the basis for invoktrg the compliance exception, it will be rade availible in the Nt hc Docu ent

Room with the rinutes of the meeting of thf Comittee to Fe te. Cerern 3

Requ eer-e n t s. T;

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9 i-NRCB 90-XX p January an.1990

. te Page 10 of 10 L D This request is covered by Office of Management and Budget Clearance Nurber L

3150 0011 which empires January 31,1W1. The estimated average burden hours

are 100 person-hours per licensee response, including assessment of the new requi'sTed s actions, searching data sources, gathering and analyzing the data, i i

l and preparing the required letters. These estimated average burden hours t pertain only to these identified response related matters and do not include the time for actual implementation of the requested actions. SenTTorsnents I'

• 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 Panagement. U.S. Nuclear Regulatory Comission, Washington, D.C. 20555: and t,, 6ne Paperwork Peduction Project (3150 0011),  ;

Office of Management ena Budget, Was5tngton D.C. 20503. I

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

l

_ _ . _ . . . . . . . . . . . . . - - . - --- - - -- - - ~ - -

Ct. rles [. Posai, Director ,.

Livision of Operational Events Assessment Office of Nuclear Reactor Pegulatio'n Technical Contacts: J.i c 6 F e r *.ey , h u l (301) at?. llc, e

l i l_ '.' int e ino-a s , M i o (301) 492 C:'EC

References:

1. Roserour.t Technical Bulletin ho. I dated Fay 10, 1929

2. Roseacunt Technical Bulletin ho. 2 dated July !?,1969 3.

a.

Posemount Technical Bulletin No. 3 dated October 23. 1989 Rosemount Technical Bulletin No. 4 dated Decerter 22, 1969 f

i Attachrent 1: Typical Physical Characteristics of a F

Rosemount Transmitter

! Attactr:ent 0: Original Equipw nt P.anufacturers that F.ay i

g Fesell Rosereunt Manuf actured Model !!!!

Transe.itters Under Treir Own Erardrare

-{ A t t a c t.r e t t 3 : List of Secently Issued hRC Eulletics , ,

f L  !

(i 1 DRUT L a l

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'i__-.__._____________._______._, , . _ . . - . . . _ . . . _ . . _ . . . . _ , . _ . . _ . _ , _ . . . , _ . . . - , . . _ _ . _ . , - . ,

Attachment 1 NRCB 90 11 i January sa,1990 TYPICAL PHYSICAL CHARACitR15 TIC $ Or A ROSIMOUNT TRANSMITTER  !

\ n ELECTRONICS HOUSING i 18 8 , 4pf CIRCulf 80ARDS '

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_ _ _ . _ _ _ - _ . - - - - - - - - - - - - ~ - - - - - - - - -

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? i Attachment ?

hRCB 90.!! l

,, January an ,1990 5

ORIGINAL ECU!RFINT P.ANurACTL'RIR5 THAT P.AY RESCLt  ;

R0$lP0t'NT P.ANUTACTURCD PODIL 1151 TRAN5MITTERS j UNDER THi!R OWN BRANONAMC

'l

1. Fl$HER CONTROLS '

i

2. BAILLY CONTROLS (FORMIRLY BAltiY MtitR)  !

3. OltTRICH STANDAF.D 4 '

DAhlEL liiDUSTRIES

5. CLEVIL AND CONTROLS i

.gy. 6. f. h.;tt0 POLO .  :

. i '. .

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l. 7 ~ NXYfitTFtI6Cc. ~~ ' I l E. MOORE pre::C

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9. N O U l: M .

" Ald'F ACTURINC l

10. 0* D ' ' s " '- -

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'. j A1TACHMENT 5  :

Inside NRC, February 26,1990 "NRC Bulletin on Replacement of -

t Rosemount Transmitters Due Soon" ,

i.

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w i r.:5 '4 0 inu Inside N R C Mi  !

An osolusive report on the U.S. Nuclear Regulatory Counsalaston

m. :. No.s r bm,7 2s,im j

\

i NRC BULLETIN ON REPLACEMENT OF ROSEMOUNT TRANSMITTERS DUE SOON j An NRC bulletin requiring all holders of operaung and construction licenses to " identify and 3 replace" as soon as possible some models of pressure transmitters in safety systems manufactured by 7 f Rosemount Inc. before July 11,1989 will be made 6ral and issued early this week with few changes, L according to the agency's Of6ce of Nuclear Reactor Reguladon (NRR). .

A draft version of the bulletin (Nucleoni;s Week,5 Feb.,1), sent for comment late last month to (

Rosemount and the Nuclear Management & Resources Council (Numart), proposed a strenuous sear $

program to pinpoint failure prone pressure transmitters, including " document reviews" and "syr'm I walkdowns,"if necessary.The draft bulletin asserted that there may have been more failures of the ,

Rosemount instruments than the 90-odd cases on record, and that potential failures "of safety signi6 ,

cance"in the oil filled pressure transmitters are not always vetectab!c during operation.

The draft bulletin would have required licensees to monitor the performance of thousands of pres. ^

sure sensing instruments-not only Rosemount's pre July 1989 models 1153 and 1154 transmitters, which have been the focus of a long controversy over some 90 odd reported failures, but also Rosemount's models 1151 and 1152, which are less environmentally qualified.

At Rosemount's request, models 1151 and 1152 will be exempted from the bulletin's " enhanced surveillance" requircrants, In its response to the draft proposal. Rosemount said it had found only one failure of Model !!$2 in "a populauon of over 18,000 shipments w1rldwide " Numare and the BWR Owners Group agreed in scparate comments. }-  !

Also exempt will be Rosemount transmitters made after last July, shen the manufacturer changed L-produedon procedurcs to fix " loss of fill oil" leaks at a glass to metal sealinside the instruments, They =

measure and display critical pressure changes in safety systems. 4....

NRC's 6rst information notice mentioning Rosemwnt ll53s (Series B) transmitters was dated -!

December 31,1985. Another notice, directly pointing to the suspect transmitters' leakage of silicon oil, -

' came last April following five con 6rmed transmitter failures at Northeast Utilities Millstone 3.The next month Rosemt & noti 6cd customers of"the potential for failure"in models 1153 and 1154 pressure transmitters.--ben A. Franklin, Washington i

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{

y INSIDE N.R.C.- Febmn :6,1W

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