ML20012C683
| ML20012C683 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/14/1990 |
| From: | Mauck J Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML20012C677 | List: |
| References | |
| OL, NUDOCS 9003230051 | |
| Download: ML20012C683 (62) | |
Text
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UNITED STATES OF AMERICA l
i NUCLEAR REGULATORY COMMISSION I-j BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD i
-In the Matter of
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PUBLIC SERVICE COMPANY COMPANY
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Docket Nos. 50-443 I
0F NEW HAMPSHIRE, g al,,
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and 50-444 i
(SEABROOKSTATION,UNITSIand2)
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AFFIDAVIT OF JERRY L. MAUCK ROSEMOUNT TRANSMITTERS AT SEABROOK 1, derry L. Buck, depose and say:
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I am a Section Chief within the Instrumentation and Control Sy;.tema Branch,
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- Division of Systems To hnoingy, Off tce of ?!vc1 car Reactor Rtgulction, United j
Staten Nuclear Regulatory Comission, % Frofessional Qualifications cre
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V attached. TMs Affidavit is submitted in response to Intervanor's request
-to the Appeal Board to reopen the record and admit a late filed contention regarding Rosemount transmitters at the Seabrook plant.
1
-Rosemount transmitters are widely used in commercial nuclear power plants
.l in both safety and non-safety systems. Transmitters monitor selected process parameters such as flow, pressure, and water level throughout a nuclear plant.
1 Basically, the transmitter is connected to the process to be measured and senses the process fluid in such a way that any change in the process fluid 9003230051 900314 PDR ADOCK ObOOO443 O
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2 pressure is then converted to a proportional electrical signal which is transmitted to either a trip unit which will initiate proper system actions and/or an indicator for use by the operators located in the control room.
For these applications, the Rosemount type transmitter is considered to be reliable and suitable.
In early 1989 Rosemount issued a notification pursuant to 10 CFR Part 21 to the nuclear industry concerning a series of reported failures of Rosemount Models 1153 Series B,1153 Series D and Model 1154 pressure and differential pressure transmitters manufactured prior to July 11, 1989. Subsequent investigation by j
Rosemount into the cause of the failures revealed that the failure mode was a gradual loss of fill oil from the transmitter's sealed sensing mocule. The fill-oil is used to convert ti;e sensed process pressure into the proportional electrical signal. The performance of a transmitter that is leaking fill-oil gradually deteriorates and may eventually lead to failure of the unit to function as intended.
Some failed transmitters have shown symptoms of loss of fill-oil prior to failure and in other cases it has been difficult to detect a failing unit during normal plant operation. The concern about this loss of fill-oil issue is that transmitter failures that are not readily detectable by observing instrument readouts or during periodic tests increase the potential for common mode failure which could result in the affectet safety system not performing its intended safety function. The Rosemount Models 1153 Series B and 1153 Series 0 and Model 1154 transmitters appear to be particularly susceptible to 1,oss cf fill-oil because their construction includes the tne of
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a metallic *0" ring (for environmental qualification), whereas Modcis 11F1, 1152 and liS3 Seriet A transmitters employ an elastomeric "O*41ng.
Rosemount has indicated that out of the approximately 14,000 Model 1153 and 1154 transmitters manufactured, 91 failures due to loss of fill-oil have been confirmed. Rosemount has also determined that certain manufccturing lots of Model 1153 Series B and 1153 Series D and Model 1154 transmitters, involving approximately 1000 units, have been identified as the lots from which the overwhelming majority of confirmed failed transmitters originated. These manufacturing lots are referred to as suspect lots.
Information needed to identify these transmitters has been provided to all nuclear power plants by Rosemount.
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AnNRCbulletin90-01wasissuedonMarch9,1990(attached). This Bulletin requests utilities with nuclear power plants licensed for operation, within 120 days from receipt of the request, to take specific actions incluaing:
(1) Identify certain specific models of Rosemount transmitters currently used in plant safety systems or systems that the NRC has required utilities to install to reduce the potential of anticipated transients without scram (an off-normal operating event where an automatic reactor shutdown should occur, but doesn't).
(2) Review plant records associated with the specified models of Rosemount transmitters to determine if any of the transmitters have already exhibited symptoms indicative of loss of oil.
(3) Develop and implement an enhanced surveillance program to identify and take appropriate corrective actions for any of the specified models of Rosemount transmitters that may be leaking oil.
(4) Ensure that transmtters from manufacturing lots identified by Rosemount is having a high failure rate due to loss of oil are not used in the reactor protection or the engineered safety features actuation systtas.
(S) Document end enintain a bssis for contir.ued plant operation with the suspect treasmitters already installed in the reactor protection or engineered safety features actuation systems l
until such time as all suspect transmitters can be replaced.
The replacement program is limited only to suspect lots because of the estimated lower reliability of these lots. The remaining lots (non-suspect I
lots),todate,havenotdemonstratedafailureratethatisoutofrangefrom other components throughout a nuclear power plant. Therefore, they are not addressed as part of the replacement program but are part of the enhanced surveillance program. The enhanced surveillance program is to be implemented to improve the capability to detect transmitter degradation prior to failure.
4-The staff queried the licensee as to the present use of Rosemount transmitters t
at-Seabrook and as to the licensee's present identification and surveillance program. The licensee responded by letters dated March 8, 12, 13 and 14, 1990, from Ted C. Feigenbaum to United States Nuclear Regulatory Comission, copies of which ne attached hereto. The licensee of Seabrook Station reports that 61 Model 11 0 and 1154 Rosemount transmitters are installed in safety related applications (38Model1153and23Model1154). Ofthose,one(1)isfroma suspect lot and it is used to monitor condensate storage tank level for accident monitoring. This transmitter has been installed for over 36 years. The transmitter was Itst calibrated in December 1989 ano determined to be operating satisfactorily.
By the letter dated March 1?,1990, the licensee has stated that this suspect lot transmitter is to be replaced before the close of business on March 14, 1990. The licensee also reports all installed Model 1153 and 1154 transmitters were recalibrated during the period between November 1989, and January 1990 with no transmitter failures identified.
There are presently 23 spare Model 1153 Series B and 1153 Series D and Model i
1154 transmitters on site which are from the suspect lots. These spare transmitters are being replaced with new transmitters as they become available f rom the vendor. There are no 1151 or 1152 transmitters utilized in any safety or anticipated transient without scram (ATWS) system at the Seabrook site.
Furthermors, there are no transmitters with sensing cells manufactured by Rosemount and the body supplied f rom another manufacturing source utilized in any safety or ATWC system at the Seabrook site.
According to the subject bulletin, all Mooel 1153 Series B and 1153 Series D and Model 1154 transmitters in safety systems will be rub. ject to the er.htnced surveillance program.
The licensee for Seabrook has placed all of the 1153 and 1154 transmitters in an enhanced surveillance program. NRC reviewed the enhanced surveillance program proposed by the 1.icensee in their March 8, 12, 13 and 14, 1990 letters.
The staff review of this program has led to the conclusion that it provides an acceptable means of detecting an 1153 or 1154 Rosemount transmitter that is leaking fill-oil. The Seabrook enhanced surveillance program addresses the following points:
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a) 1&C personnel have been made aware of the symptcas associated with a transmitter that is experiencing a loss of fill-oil.
b) 1153 and 1154 transmitters that provide an input to the RPS and ESFAS will be checked on a weekly basis along with transmitters
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that have more than one input to the Main Plant Computer system (MPCS). The remaining 1153 and 1154 transmitters will be I
checked on a monthly basis. This channel check data and the calibration data will be trended for drift to determine if any i
o data is indicating a possible loss of fill-oil transmitter.
c)
Data will be reviewed following any plant transient (e.g.
planned power ascension test program, unplanned transients).
The planned transient data will include transmitters with inputs to the MPCS and the unplanned transient data will include transmitters that input to the MPCS post mortem report.
d)
During calibrations, the instrument technician will observe the qu611tative time response performence of the Rotenount transmitter due to a tapid change in the input.
Seabrook has adequately eddressed the other recommendations of the subject Dulletin. As a result, with regard to the Rosemount transmitter issue, NRC ccncludes that there is no remaining question regaroing the Seabrook plant meeting the recomendations specified in NRC Balletit. 99-01 l 3 datto Mnch 9,1990. After March 14, there will be no transmitters from
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suspect lots installed in any Seabrook system. All remaining Rusemount 1153 And 1154 transmitters will be monitored so that failures can be detected should they occur.
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l In summary, the staff has reviewed the licensee's response and has determined that they have implemented the staff recommendations which were provided in l
Bulletin 90-01. With regard to the Rosemount transmitter issue, the staff concludes that the licensee is in compliance with General Design Criterion (GDC) 21 " Protection System Reliability and Testability" of 10 CFR 50, Appendix A and 10 CFR 50.55a(h) which requires that protection systems l
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6-I meet the Institute of Electrical and Electronics En91neers Standard: " Criteria for Protection Systems for Nuclear Power Generatin9 Stations" (IEEE-279). The l
measures taken by the licensee provide reasonable assurance of an adequate level of protection for the public health and safety.
N 9[L.Mauck
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Jerr
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March 14, 1990 Sworn and subscribed to before ne this 14th day of 11 arch,1990, b
//fb, Jgf aro L. Aurjustino CAROL l. AUGUSTINO NOTARY PUBitO $1 ATE OF MARYLAND My Comminion Empires janvory 17,1994 4
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ATTACHMENT 1 JERRY L. MAUCK DIVISION OF SYSTEMS TECHNOLOGY i
U.S. NUCLEAR REGULATORY COMMISSION
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PROFESSIONAL QUALIFICATIONS i
I have been with the U.S. Nuclear Regulatory Consnission since Septenber 1980.
i I am a Section Chief in the Instrumentation and Control Systems Branch, Division of Systems Technology, Office of Nuclear Reactor Regulation.
I serve as a Section Chief in the area of nuclear power plant instrumentation and control systems in performing and coordinating reviews and evaluations of those portions of the applications for Construction Permits and Operating Licenses and submittals regarding proposed modifications in licensed nuclear i
power plants for which the branch has responsibility to assure public health and safety and protection of the environment.
I serve as project leader and coordinator of other reviewers for the resolution of highly complex technical issues and licensing problems and provide technical assistance and
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authoritative advice in the areas relating to the safety aspects of reactor plant instrumentation and control systems and components.
I received a Bachelor of Science degree in Electrical Engineering from Virginia Tech University in 1967. Additional graduate studies were subse-quently performed at George Washington University where I received a Masters of Science degree in Engineering Administration. Other educational background includes: CFC Instrumentation School,1968; Pressure fieasurement - George Washington University, 1971; Interdata Computer School, 1972; Hewlett Packard Computer School,1978; Micro-Measurements Strain Gage Workshop-1979, Boiling Water Reactor Technology - NRC sponsored - 1980; Boiling Water Reactor Simulator School - NRC sponsored - 1981; Pressurized Water Reactor Technology - NRC j
i ;
sponsored - 1982; Instrumentation Technology and Codes Course - NRC sponsored -
1984; BWR Technology Course - NRC sponsorea - 1984; HTGR Technology Course - NRC sponsored - 1987; and Site Access Training - NRC sponsored - 1988.
In addition, I have been a senior member of the Instrument Society of America since 1986 and actively serve on two of their Standard Comittees; ISA 67.04 and !$A 67.14.
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NRCB 90 01 i
UNITED STATES l
NUCLEAR REGULATORY COMMIS$10N CFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555 March 9, 1990 NRC EULLETIN NO. 90-01: LOSS OF FILL-0!L IN TRANSMITTERS PANUFACTURED BY ROSEMOUNT i
' Addressees:
All holders of operating licenses or construction permits for nuclear power reactors.
greese:
This bulletin requests that addressees promptly identify and take appropriate corrective actions for Model 1153 Series B, Model 1153 Series D and Model 1154 transmitters manufactured by Rosemount that may be leaking fillIcil.
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 differen-tial pressure transmitters.
The reported failures occurred at Northeast Utilities' Millstone Unit 3 between March and October 1987 Subsequent inves-tigation into the cause of the failures by Rosemount confirmed that the failure mode was a gradual loss of fill-oil from the transmitter's sealed sensing module.
Discussion of Safety Significance:
The performance of a transmitter that is leaking fill-oil gradually deterio-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 Ieaking fill. oil may be difficult to detect during operation. An undetected transmitter failure has a greater adverse effect on safety system reliability than a failure that would be readily detectable during normal operation.
For example, electronic circuit malfunctions are routinely detected either by observing instrument channel readout or during periodic surveillance tests.
Transmitter failures that are not readily detectable increase the potential for connon mode failure L
and may result in the affected safety system not performing its intended safety l
function. This corrnon mode failure potential is of increased concern when transmitter designs are particularly susceptible to loss of fill-oil.
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9003050148 i
A
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r V tiRtB 90-01 March 9, 1990 Page 2 of 11 s
Discussion:
Model 1151 1152 1153 and 1154 Rosemount transmitters are utilized ex-tensivelyInnuclearpo,werplants. Modr. 1153 and 1154 transmitters are supplied by Rosemount as both seismically and environmentally qualified equipment. Model 1152 transmitters are scpplied by Rosemount only as seismically qualified ecuipment.
Model 1151 transmitters are supplied by Rosemount as commercial-grade equipment.
Rosemount has indicated, to date, that failure of approximately 91 Model 1153 Series B Fodel 1153 Series D and Model 1154 transmitters due to loss of fill-oil,fromaglasstometalsealfailurehavebeenconfirmed.
Since the sensing moeule is sealed, loss of fill-oil cannot be visually confirmed without cestructive analysis of the sensing module.
NRC staff review of this issue has identified additional Model 1153 and 1154 transmitters with symptoms indicative of loss of fill oil that may not have been brought to Rosemount 5 attention.
Thus, the nurter of Model 1153 and 1154 transmitters that have experienced a loss of fill-oil may be even greater than that confirmed by Rosemount.
Model 1153 Series B. Model 1153 Series D,f a metal o-ring, appear to be par.
and Model 1154 transmitters, because their construction incorporates the use o ticularly susceptible to loss of fill-oil due to a glass to metal seal failure.
Acccrdingly, the NRC staff believes that the degree of susceptibility of these transmitters to loss of fill oil warrants their being subjected to an enhanced surveillance program.
In addition, certain manufacturing lots of Model 1153 Series B, Model 1153 Series D, and Model 1154 transmitters have been identified by Rosemount as having had a high failure fraction 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 concurrent with Reference 4 Ac-cordingly, the NRC staff believes that this additional degree of susceptibility warrantsnotutilizingthesesuspectlottransmittersinthereactorprotection or engineered safety ' estures actuation systems.
Rosemount has indicated that failures of Model 1151 and 1152 transmitters due to loss of fill-oil have also been confirmed.
The construction of Model 1151 1152 and 1153 Series A transmitters is similar to that of Model 1153 Series I, Model1153SeriesD,andModel1154 transmitters (i.e.,theutilizationofa glass to metal seal) except the construction of Model 1151, 1152, and 1153 Series A transmitters incorporates an elastomeric o-ring instead of a metal o-ring. The NRC staff does not, at present, have sufficient information to effectively address the susceptibility of Model 1151, 1152, and 1153 Series A transmitters to loss of fill-oil.
Therefore, in order to cbtain relevant operational experience data, addressees are encouraged to report Model 1151, 1152, and 1153 Series A, as well as Model 1153 Series B Model 1153 Series D and Model 1154 transmitters that may have exhibited symptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil to the Nuclear Plant Reliability Data System (NPRDS).
In addition, while enhanced surveillance of Model 1151 1152 and 1153 Series A transmitters is not specifically requested by thIs bulletin, addressees are encouraged to u m ta b such efforts on Model 1151, 1152, and 1153 Series A transmitters utilized in either safety-related systems or systems installed in accordance with10CFR50.62(theATWSrule).
Hadh9,f11h90 i
Page 3 o k
Rosemount has indicated that they have instituted additional quality control and quality assurance steps in the manufacturing process and modified specifi.
l cations on bolt torque to reduce stress levels.
These chan the potential for Model 1153 Series B ll oil.Model 1153 Series D,ge and Model 1154 t
transmitter failures due to loss of fi As a result, Rosemount has i
indicated that transmitters of these ty>es manufactured after July 11, 1989 i
are not subject to their May 1989 10 CfR Part 21 notification.
The NRC staff has not, to date, received operational experience data that indicates that Model 1153 Series B. Model 1153 Series D and Model 1154 transmitters manu.
1 f actured af ter July 11, 1989 are as susceptible to loss of fill-oil as those i
manufactured prior to July 11, 1989.
Accordingly while enhanced surveillance of transmitters of these types manufactured after duly 11, 1989 is not spect-t i
i fically requested by this bulletin, addressees are encouraged to undertake such efforts on these transmitters if they are utilized in either safety-related systems or systems installed in accordance with 10 CFR 50.62 (the ATWS rule).
In addition, Podel 1153 Series B. Model 1153 Series D and Model 1154 trans-mitters n.anufactured efter July ll,1989 that exhibit symptoms indicative of i
loss of fill-oil or are confirmed to have experienced a loss of fill-oil should be reported in accordance with the report requirements of this bulletin.
The NRC staff encourages utilities to work collectively under the guidance of a technical industry organization to develop and analyze an operational ex-perience database concerning all models of Rosemount transmitters.
The NRC staff will continue to obtain and analyze operational experience data pertaining to Model 1151, 1152, 1153, and 1154 transmitters.
Further regulatory action, such as requesting expansion of enhanced surveillance activities to include Nodel 1151, Model 1152, and Model 1153 Series A transmitters and Model 1153 Series 8 Podel 1153 Series D and Model 1154 transmitters manufactured by Rosemount af ter July 11, 1989 or requesting replacen,ent of addithnal suspect lot transmitters, may be taken if warranted.
l Addressees may have obtained transmitters that were manufactured by Rosemount or that contain Rosemount manufactured sensing medules from a number of different sources.
The following information is provided to facilitate addressee's ider.ti-fication of transmitters that were manufactured by Rosemount or that contain Rosemount manufactured sensing modules:
Rosemount has indicated that unauthorized remanufacturers and refurbishers exist for Model 1151 transmitters. Unauthorized remanufacturers and re-furbishers may also exist for Model 1152, 1153, and 1154 transmitters.
All Model 1153 and 1154 transmitters, whether obtained directly from Rosemount, obtained through intermediar an integral part of another component (y suppliers, or provided as such as cn emergency diesel generator), should a) indicate manufacture by Rosemount, b) have a distinctive Rosemount model and serial number, c) have the physical
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profile characteristics of a Rosemount transmitter, and d) have a blue or stainless steel housiog.
Rosemount has incicated that Model 1153 and 1154
~i 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.
Model 1152 transmitters, except as noted below, should a) indicate manu-facture 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 they have supplied Model 1152 trammitter sensing modules to 2ailey Controls (formerly Bailey Meter).
Bailey manufactured transmitters that centain Rosemount manufactured Model 1152 sensing modules have gray housings that appear slightly different than Rosemount
- housings, r
Model 1151 transmitters, except as noted below, should a) indicete manu-facture by Rosemount, b) have a distinctive Rosemount model and serial number, c) have the physical prefile characteristics of a Rosemount transmitter, and d) have a blue housing. Model 1151 transmitters manu-factured by Rosemount may have been supplied for use in nuclear power plants by other original equipment manufacturers.
These transmitters should have the physical profile characteristics of a Rosemount trans-mitter 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 )rofile characteristics of a Rosemount transmitter, out have a green aousing.
The earliest symptom a Model 1153 Series B, Model 1153 Series D, w Model 1154 transmitter may exhibit during normal operation prior to failure if it is l:
leaking fill-oil is:
a sustained drift The symptoms a Model 1153 Series B, Model 1153 Series D, or Model 1154 trans.
mitter may exhibit dering normal operation subsequent or immediately prior to failure if it is leaking fill-oil include:
a sustained drift an abrupt decreasing drif t (for high range gauge or absolute transmitters) a change in process noise including amplitude variations, "one sided-nof se," or asymetric noise distributions slow response to or inability to follow planned or unplanned plant transients
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The symptoms a Podel 1153 Series B. Model 1153 Series D, or Model 1154 trans-mitter may exhibit during calibration activities if it is leaking fill oil include:
l inability to respond over the entire design range slow response to either an increasing or decreasing test pressure t
a sustained zero or span shift The NRC staff believes these symptoms can also be utilized to detect Model I
1151 1152 of fill-oil.and 1153 Series A transmitters that may be experiencing a loss
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The NRC staff has reviewed the information which has been provided by Rosemount, including References 1 2, 3, and 4, to assist industry in detecting transmitters that may be leaking fill oil.
The NRC staff has concluded that 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. Accordingly, the actions requested in this bulletin are intended to reflect these diagnostic procedures.
However, the NRC staff has concluded that Rosemount has not provided sufficient bases to support their proposed methodology (pressure versus time-in service) for identifying which transmitters should be subject to an enhanced surveillance program.
Specifi-cally, the NRC staff believes that the methodology utilized by Rosemount to support their proposed pressure versus time-in-service criteria for identifying which transmitters should be subject to an enhanced surveillance program does r.ut provide the necessary high cegree of confidence that this failure mode will not occur.
Rosemount had initially indicated that Model 1153 Geries 8. Model 1153 Series D, and Model 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 of loss of fill-oil is application and pressure dependent. Al-though transmitters subject to continuous high pressure (e.g. reactor operating l
pressures) may fail within this-timeframe, transmitters utilized in low-pressure systems or not subject to continuous high-pressure may take longer to fail.
GeneralDesignCriterion(GDC)21"ProtectionSystemReliabilityandTestability" 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.
10CFR50.55a(h) requires that protection systems meet the Institute of Electrical and Electronics Engineers Standard: " Criteria for Protection Systems for Nuclear Power Generating
1990 ia.
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. Stations"(IEEE279).
IEEE-279 states that means shall be provided for checking, with a high degree of confidence, the operational availability of each system input sensor during reactor operation.
Thus, the NRC staff concludes that faci-lities that utilize transmitters that may be particularly susceptible to loss of fill-oil may not be in full compliance with these regulations because undetected i
transmitter failure could occur. Accordingly addressevs take the actions requested below., the NRC staff requests that feouestedActions:
Operatire Reactors All holders of operating licenses for nuclear power reactors are, within 120 days af ter receipt of this bulletin, requested to:
Identify Model 1153 Series B,1153 Series D, and Model 1154 pressure or 1.
ciff erential pressure transmitters, er.cluding Model 1153 Series B 1153 Series D, and Model 1154 transmitters manufactured by Rosemount subsequent to July 11, 1989, that are currently utilized in either safety (the ATWS rule)
-related systems or systems installed in accordance with 10 CFR 50.62 2.
Determine whether any transmitters identified in Item ! are from the manufecturing lots that have been identified by Rcsemount as having a high failure fracticn due to loss of fill-oil.
Addressees are requested not to utilize transmitters from these suspect lots in the reactor pro-tection or engineered safety features actuation systesti therefore addrestees are requested to develop and implemt,t a program to replace, at the earliest appropriate opporwnity, trahamitters from these suspect lots in use in the reactor protection or engineered safety features actuation systems.
3.
Review plert records (for example, the three most recent calibration records) assoc?ated with the trentmiti;ers identified in Item 1 above to cetermine whether any of these transmitters may have already ex-hibited 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 ex-hibited symptoms indicative of loss of fill-cil that do not conform to i
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 appro-priate opportunity.
4 Develop and implement an enhanced surveillance program to monitor trans-mitters identified in Item 1 for symptoms of loss of fill-oil.
This enhanced surveillance program should consider the following or equally effective actions:
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Ensuring appropriate licensee personnel are aware of the symptoms j
that a transmitter, both during operation and during calibration activities, may exhibit if it is experiencing a loss of fill-oil and the need for prompt identification of transmitters that may exhibit these symptoms; b)
Enhanced transmitter monitoring to identify sustained transmitter drift; c)
Review of transmitter performance following planned or unplanned plant transients or tests to identify sluggish transmitter response; d)
Enhanced awareness of sluggish transmitter response to either in-l creasing or decreasing test pressures during calibration activities; e)
Developmer.t and implementation of a program to detect changes in process noise; and 1
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 i
exhibited symptoms indicative of loss of fill oil that do not con-form 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.
5.
Document and maintain in accordance with existing plant precedures a basis for continued plant operation covering the tima period from the present until such time that the Medel 1153 Series 8,11N Series D and Model 1154 i
transmitters from the manufacturing lots that have been ider,tified by L
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 t
can be replaced.
In addition, while performing the actions requested above, addressees may identify transmitters exhibiting symptoms indicative of loss of fill-oil that do not conform to the established operability acceptance criteria and are not addressed in the technical specifications.
As these transmitters are identified, this basis for continued plant operation should be updated to address these transmitters covering the time period from the time these transmitters are identified until such time that these transmitters can be replaced. When developing and updating this basis for continued plant operation, addressees may wish to consider transmitter diversity and redundancy, diverse trip functions (a separate trip function that may aire provide a corresponding trip signal), special system and/or component tests, or (if necessary) immediate replacement of certain suspect transmitters.
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n-March 9, 1990 i
Page 8 of 11 Ccostruction Permit Holders 1.
Ali construction permit holders that anticipate receiving an operating license within 120 days after receipt of this bulletin are requested to perform items 1, 2, 4, and 5 of Requested Actions for Operating Reactors within 120 6ays after receipt of this bulletin.
1 2.
All construction permit holders that do not anticipate receiving an operating license within 120 days af ter receipt of this bulletin are requested to, prior to the date scheduled for fuel loading, complete Itees 1 and 4 of Requested Actions for Operating Reactors and to address the intent of items 2 and 5 of Requested Actions for Operating Reactors by:
a)
Identifying and repit.cing Model 1153 Series B,1153 Series D, and Model 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to
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loss of fill-oil that are installed in the reactor protection or engineered safety features actuation systems; and b)
Documenting and maintaining in accordance with existing plant procedures a basis for continued plant operation that addrecses transmitters that, subsequent to fuel loading are identified as exhibiting symptoms indicative of loss of fil}-cil that do not conform to the estabitshed o)erabilltv acceptanco critsria and are not addressad in the tec5Pical sp,ecif tettions covering the time perio2 from the time these tr6nsmitters are identified until such time that these transmittert can be replaced.
Reporting Recuirements:
Operating React 5r?
1.
Provide, within 120 days af ter receipt of this bulletin, a response that:
a)
Confirms that items 1, 2, 3, 4, and 5 of Requested Actions for Operating Reactors have been completed.
b)
Identifies the indicated manufacturer; the model number; the system the transmitter was utilized in; the approximate amount of time at pressure; the corrective actions taken; and the disposition (e.g., returned to vendor for analysis) of Rosemount Model 1153 Series'B Model 1153 Series 0, and Model 1154 trans-mitters that are believed to have exhibited symptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil.
This should include Model 1153 Series B, Model 1153 Series D and Model 1154 transmitters manufactured af ter July 11, 1989.
c)
Identifies the system in which the Model 1153 Series B,1153 Series D, and Model 1154 transmitters from the manufacturing
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Page 9 of 11 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 these transmitters which are in use in the reactor protection or engineered safety features actuation systems.
2.
Model 1153 Series B, Model 1153 Series D and Model 1154 transmitters that, subsequent to providing the response required by Item 1 above, exhibit symptoms of loss of fill-oil or are confirmed to have experienced a loss of fill-oil should be reviewed for reportability under existing NRC regu-lations.
If determined not to be reportable, addressees are requested to document and reintain, in accordance with existing plant arocedures, informatica consistent with that requested in Item 1 b) a>ove for each transmitter identified.
Although not required by this bulletin, addressees are encouraged to re> ort informatico consistent with that requested in item 1 b) above through tie Nuclear Plant Reliability Data System (NPRDS) for all Rosemount Model 1151, 1152,1153 and 1154 transmitters that exhibit symptoms indicative of a loss of fill-oil or are confirmed to have experienced a loss of fill-oil.
Construction Permit Holders 1.
All holders of construction permits that &nticipate receivirg an operating license within 120 days after receipt of this bulletin dre required to, within 120 days after receipt of this bu11stin, provide a respongc thatt a)
Confirtas that Itas 1. E, 4. sn) 5 of Requested Actt0ns for Operating Reactors have b9en completed; and b)
Identifies the system in which the Model 1153 Series 6, 1153 Serins D, I
and Model 1154 transmitters fron the ennufacturing lots that have been identified by Rosemour.t as having a high fsilure fraction due to less of fill-oil are utilized and provides a schedule for replacement of these transmitt as which are in use in the reactor protection er engineered safety features actuation systems.
2.
All holders of construction permits that do not anticipate receiving an
(
operating license within 120 days after receipt of this bulletin are required to, prior to the date scheduled for fuel loading, provide a response that confirms that Item 2 of Requested Actions for Construction Permit Holders has been completed.
3.
Model 1153 Series B. Model 1153 Series D and Model 1154 transmitters 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, addressees are requested to document
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March 9, 1990
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Page 10 of 11 i
and maintain, in acccrdance with existing plant procedures, information consistent with that requested in Item 1 b) of the Reporting Requirements for Operating Reactors above for each transmitter identified.
d Although not required by this bulletin, addressees are encouraged to report information consistent with that requested in item 1 b) of the Reporting Recuirement for Operating Reactors through the NPRDS for all Rosemount Model i
1151, 1152 1153 and 1154 transmitters that exhibit symptoms indicative of loss of fill-cil or are confirmed to have experienced a loss of fill-oil.
As has been previously indicated, the NRC staff believes that the methodology utilized by Rosemount to support their proposed pressure versus time-in-service criteria for identifying which transmitters should be subject to an enhanced surveillerce program does not provide the necessary high degree of corfidence that'this failure mode will not occur. Additional operational experience data, 1
such as that to be generated in response to this bulletin, could be utilized by Inoustry either to provide aeditional insight as to the appropriateness of Rosemount's pressure versus time-in-service criteria or to develop bases for staff consideration of an a'nendment to or termination of the actions requested by this bulletin.
Accordingly, the NRC staff encourages utilities to work collectively under the guidance of a techaf eel industry organtastion to develop an operational awerit:nco e tabase concerning all models of Rosemount trsnsmitters.
The-written r> ports required above shall be addressed to the 0.5. Nuclear Regulatnry Corvuinica, ATTN: Document Control Desk Washington, D.C.
- 20555, and shall he subaitted ur. der cath or affirmation pur,suant to the provisions of Section 1%e, Ato:nic Energy Act of 1954, as amended and 10 09 50.54(f).
In additica, e copy shall be submia.ted to tne appropriate Regiona) Adelnistrator.
Backfit Discussica l
The objective of the actions requested in this bulletin is to ensure that trans-i mitter failures due to loss of fill-oil are promptly detected, l.oss of fill-oil may result in a transmitter not performing ite intended safety function.
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 bac(fit analy(6) was performed sis was not performed. An evaluation of the type discussed in10CFR50.109(a) including a statement of the objectives of and reasons for the actions reques,ted and the basis for invoking the com-pliance exception.
It will be made available in the Public Document Room with the minutes of the 179th meeting of the Comittee to Review Generic Requirements.
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 6 person-hours per transmitter per licensee.
This includes assessing the requested actions, gathering and reviewing plant records, analyzing the data 1
5
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MaNh9,'$990 Page 11 of 11 obtained from the plant records, and preparing the required response. This does not include developing and implementing the requested enhanced surveil-lance program or replacing 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 utilized in the reactor protection or engineered safety features actuation systems.
Send comments 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 Commission, Washington. 0.C.
20555; and to the Paperwork Reduction Project (3150-0011), Office of Management and Budget. Washington, D.C.
20503.
If ycu have any questions about this matter, please contact one of the technical contacts listed below or the appropriate NRR project manager.
Y k <[ i Director h
Charles E. Ross Dhiston cf Operational Events Assess.wnt Office of Nuclear Reactor Regulation Technical Centacts: Jack Rarsey, NRR (301)492-1167 Vince Thomas, NRR (301) 492 0786
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 Attachments:
1.
Typical Physical Characteristics of a Rosemount Transmitter 2.
List of Recently Issued NRC Bulletins
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March 9, 1990 Page 1 of 1 i
l TYPICAL PHYSICAL CHARACTERISTICS OF A ROSEMOUNT TRANSMITTER I
ELECTRONICS HOUSING CIRCUlf 50ARDS
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SENSING MODULE PROCESS FLANGE
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4 NRCB 90-01 March 9,f 1 1990 Page 1 o LIST OF RECENTLY ISSUED NRC BULLETINS i
Bulletin Date of
[
No.
Subject Issuance Issued to 89-03 Potential loss of Required 11/21/89 All holders of OLs Shutdown Margin During or cps for PWRs.
Refueling Operations 88-10, Nonconforming Molded-Case 8/3/89 All holders of OLs L
Supplement 1 Circuit Breakers or cps for nuclear power reactors.
89-02 Stress Corrosion Cracking 7/19/89 All holders of OLs cf High-Herdness Type 410 or cps for nuclear, Stainless Steel Internal power reactors.
Preloaded Bolting in Anchor Darling Hotel 5350W Swing Deck Valves or Yalves od L
Similar Cesign b
89-01 Failure of Westinghouse 5/15/89 All holders of OLs E
Steam Generator Tube or cps for PWRs.
p Mechanical Plugs Ph 68 08, Thermal Stresses in Piping 4/11/89 All holders of OLs Supplement 3 Connected to Reactor Coolant or cps for light-
- E Systems water-cooled nuclear r
power reactors.
88 07, Power Oscillations in 12/30/88 All holders of OLs Supple;.ent 1 Boiling Water Reactors or cps for BWRs.
88-11 Pressurizer Surge Line 12/20/88 All holders of OLs Thermal Stratification or cps for PWRs.
88-10 Nonconforming Molded Case 11/22/88 All holders of OLs 4
Circuit Breakers or cps for nuclear power reactors.
88-05, Nonconforming Paterials 8/3/88 All holders of OLs Supplement 2 Supplied by Piping Supplies, or cps for nuclear Inc. at Folsom, New Jersey power reactors.
and West Jersey Manufacturing Company at Williamstown, New Jersey OL = Operating License CP = Construction Permit
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New Homoshire Teel C. Feigenbeum i
SeMer Vice Prussiee ord
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Chief Oproting Oker NYN.900$6 March 6. 1990
'Jnited States Nuclear Regulatory Commission Washingsca. DC 20333 Attenticn Document Control Desk
.[
References:
(a)
Tacility Operating License Hc. NPF.67. Decket No. 50.a&3 (b)
U$nc Letter dated January 29. 1990 'Preposed NRC Bulletin i
on Loss of T111 011 1n Rosesount *'ransmitters*, C.H.
Berlinger te NUKA*AC h
fubjects Respenst to Propesed Drakt RC Bullstar t.n Less of Fill Oil in Rosenount fransmitters Gentlemeni Durits recent discursions with the n:: Staff. New Wampshire u nke9 (NNY) was requested *.e prwide a ressor.se to the proposed draf t bulletin en lo7s cf fill.
oil in Resemount transmittest. Accordingly encicted please find NEY's response to the Requested Actions and Reporting Requirements for Operating Reacts,rs (Enclesures 1 and 2 respectively) of the proposed draft bulletin transmitted via Reference (b). It is NEY's understanding that the NRC intends to formally issue a bulletin concerning the lose ci fill. oil in Rosemounts transmitters in the near future. N n that bulletin is issued. NNY will respond to it in full. It will incer;erate where applicable, the enclosed information.
Few Ear.pshire Yankee has been following the F,osemount transmitter fill oil loss issue cicsely and has taken a proactive roll in dealing with the issue. FIY has perforr.ed an extensive review of identified Rosemount and identified original equipment manufacturers (CIM) transmitters in addressing the concerns of the propcsed draft bulletin. As a result of this review. NNY has concluded that there are u Rosemount 1152 transmitterst there are g Rosescunt Model 1151 transmitter performing safety.related or ATVS related functions and that there are u CEM transmitters, containing Rosemount sensing modules of concern.
peric:uing safety.related or ATW6 related functions. NNY has identified 61 Model 1153 anc 1156 Rosessount transmitters whien are installed in safety.related applicattent NNY has determined that there is only one transmitter installed at Seatreck Station from the Model 1153 and 1154 manufacturing lots identified by Rosemount as having a high failure fraction. This transmitter is not utilised in the reactor protection system (RPS) or engineered safety actuation featurte systese (!$FAS). This transmitter has been installed and in. service for ever 5 1/2 years. It has been operating satisfactorily and has not exhibited any syeptoms of potential fill. oil loss. Although not required to be addressed by the draft bulletin, the spare transmitters which were from the lots with a high failure fraction have been returned to Rosemount for the replacement of the sensing module.
New kcmpaire Yonkee 0; vision of Pv' otic Service Corrper y of New HampsYre o A em., inn a t..L,
.'. Liu M 094. t.l..L...IsnY s9s arm
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. u 4.bitaticro D3cument Centrol beak Fase 2 As indicated in the enclosure the calibration data reviews are being performed for til the identified transmitters. The reviews for all transmitters utilised in the KPs er 25FAS have been coEpleted. The conclustone from these i
reviews are that there are no transmitters identified which have a confirmed fall. oil loss et failure er aid net meet the established operability acceptance l
c rit a tie. As indicated in the enc 1csures. one transmitter has emhibited early symptces cf potential fill. oil loss and is being evaluated in accordance with our program.
New Hampshire Yankee, based on Rosemount's technical bulletins. has developee and implemented a program for detecting the onset of fill.cil loss in Rosemount traner.itters before they could lose the ability to perfers their safety functicas. The elements of this program include enhanced monitoring of the identified transmitters trending ef transmitter performance, and thv oction to-be taken f or a potential fill.cil ices condition.
Should you have any stuettiens rest.rding the err.losed pleseg contact Mr.
Terry L. Harpeter at (603) 474 9D21. est0neton 1763 Very tnily yo.trs.
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aui r.c Mt. Villina T. Russell P e t ter.a Aa:ritistrator Vnitte States Mcitar Peg 41 story Concission Region !
475 Allendale Road King of Prussia. PA 19406 Mr. Victor Nerses. Project Manager Project Directorate I.3 United States Huclear Regulatory Cesmistica
. Division ef Reactor Projects Vashingten. D0 10555 Mr. Noel Dudley NRC Senior Resident Inspector a
F.O. Box 1149 Seabrook. N11 03874 Atomic Safety and Licensing Board Service List t
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Pronomed Draf t-Bullatin on 1.oan of Fil,1-011 in Rosa-aunt Tran==i
- c tters Resectaa to tenuested Actionai Oneratina teactors NRC Reauested Actica #1 Identify, within 60 days after the receipt of this bulletin. all pressure or differential pressure transmitters. including Model 1151. 1152. 1153, and 1156 transmitters but excluding Model 1153 and 1154 transmitters manufactured by Rosemount subsequent to July 11. 1989 that were manufactured by Rosemount or that contain Rosemount manufactured sensing modules and are utilised in either safety-related systems or systems inetslied in accordance with 10 Crt 30.62 (the ATVS rule).. Addressess may find it necessary to perform. in addition to document reviews, system walkdowns to completr this action.
(Note In addition to the above. the proposed draf t bulletit. provided additional information to facilitate addressing the above. This additional infermation has not been repeated herein.)
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NRY Reanonna In regards to Rosemount Model 1151 and 1152 transmitters. there are AA Model 1151 transmitters installed at Seabrook Station and there are ng Kodel 1151 transmitters at seabrook Station which perform a safety-related or ATWS related functions. There are Rosemount Model 1153 and 1154 tranesitters at Seabrook Station which. perform safety related functions. These transmitters ara identified on Table 1.
A review was undertaken to determine if the original equipment manufacturer's (CEK's). identified in the proposed draft bulletin, had provided transmitters to Seabrook Station which, as described in the draf t bulletin. may have been manuf actured by Rosemount or contained a sensing modcle manuf actured by Rosemount. The review concluded that only Bailey Controls had supplied transmitters to Seabrook Station which utilised a Model 1151 transmitter sensing module. These transmitters do not perform a safety-related or ATW5 related function.
KRC Remuestad _ Action J2_
Review within 90 days after receipt of this bulletin.. plant records (for example.
calibration records) associated with the transmitters identified in Item 1 above to determine whether any of these transmitters may have already exhibited symptoms indicative of loss of fill-oil. Appropriate operability acceptance i
criteria should be developed and applied to transmitters identified as having exhibited symptoms indicative of lose of fill-oil from this plant record review.
Transmitters identified as having exhibited symptome 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 Ices of fill-oil and are not addressed in the technical specifications should be replaced at the earliest appropriate opportunity.
NHY 7esponse As indicated in NEY's response to Action il above, the response to this action item need only address the Model 1153 and 1154 Rosemount transmitters identified in Table 1.
The review cf plant records (calibration records) associated with the identified model 1153 and 1154 transmitters is presently underwsy to
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i nGLResnonse determine if_they are exhibiting the symptoms of oil leakage. A review has been perf ormed f or the calibestions of the Rosesount model 1153 and 1154 transsdttore performed between January 1907 to March 1. 1990. This review included all transmitters utilised in the reactor protection system (RPS) and engineered safety features actuation system (ESFAS) as identified in the Technical specificaticas. The results of this review are provided in Enclosure 2, Requirement 1(b). For calibratione performed between March 1,1990 and March 9. 1990, the reviews are expected to be completed by March 14, 1990. This
'l vill cocpivte calibrations and associated reviews of all the safety-related Model 1153 and 1134 transmitters installed at Seabrook Station.
The method of review utilises the guidelines of Rosemount Technical Sulletin #4 Appendix A section 3.
This technical bulletin and its guidance wse developed from the extensive testing and evaluation performed by Rosesount in regards to the fill. oil icekage issue. This guidance is utilised to determine if there is a possible fill. oil leak. If this condition potentially esists then the guidance is used to determine leakage rates and the amount of time in service before significantly degraded performance could be expected. If this review indicates a trend in performance which may be indicative of loss of fill-oil condition then the transmitter will be identified as requirin5 8Pecial attention..A transmitter requiring special attention will be recalibrated before the calculated time in service, based on Rosemount Technical Bulletin #4, that the transmitter response could become degraded. If that calibretion confirms a negative performance trend i
is continuing, the transmitter will be tested against the operability acceptance criteria.
For example if the review indicates that the transmitter potential leakage rate is such that there shculd be nine months before the response time might be degraded, the transmitter vill be recalibrated in 6 months. The operability acceptance criteria that will be used for any transmitter exhibiting the symptoms
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indicative of loss of fill oil, is taken from Technical Bulletin f4 Appendix 8 Section 2 and 3. and is as follows:
1 Apply a pressure transient of the full range of the transmitter to test the time. response of the side of the DP cell which is suspected of leaking. For h
range Code 5-9 the transmitter should respond (or follow since_the pressure change r.ay be a fast ramp) to this pressure change within 1 second. Range code 3 should respcnd within 35 seconds and range code 4 should respond within 6 seconds.
Transmitters identified as having exhibited symptoms indicative of loss of fill-L.
oil will be addressed in accordance with the applicable Technical Specification.
Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not confem to the operability acceptance criteria and are not addressed in the Technical Specifications will be replaced at the earliest appropriate opportunity.
NRC Recuested Action #3 Develop and implement, within 120 days after receipt of this bulletin, an enhanced surveillance program to monitor transmitters identified in itsm 1 for symptorts of loss-of fill-oil. This enhanced surveillance program should consider the following or equally effective actiones b
1
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NRC Renuteted Action #3 a)
Ensuring apprcpriate licensee personnel are aware of the symptoms that a 1
transmitter, both during operation and during calibration activities, may 1
ethibit if it is experiencing a loss of fill. oil and the need for prompt idantification of transmitters that may eshibit these symptoms:
b)
Enhanced transmitter monitoring to identify excessive transmitter drif t c)
Review cf transmitter cutput data following planned er unplanned plant transients or toets to identify sluggish transmitter response d)
Inclusien of senect response time testing into routine channel calibration activities; L
e)
Development and implamentation of a program to detect a decrease in transmitter noiss level amplitudes and f)-
Development and application to traner.itters identified as having exhibited symptoms indicative of loss of fill.cil of an appropriate operability l
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 I
tecnnical specification. Transmitters identified as having exhibited symptoms indicative of loss of fill-cil that do not conform to the operability acceptance criteria and are not addressed in the technical specifications should be replaced at the earliest appropriate oppertunity.
NEY lascense The enhanced surveillance program for the installed Rosescunt transmitters is presently being implemented. This program addresses the considerations of the draft NRC Bulletin as follows:
a)
IEC personnel are aware of the symptoms that a transmitter, both during operation and during calibration activities, may exhibit if it is y
i experiencin5 a loss cf fill. oil. IEC Department personnel.have been on l
distribution for all pertinent information pertaining to Rosemount Technical Bulletins and this information has been included inta the required reading program an the IEC Department. In addition, the training department will be scheduling formalized training of operations and IEC personnel regarding the above over the next 4 months.
L.
.b)
Tne enhanced monitoring program consists of monthly channel checks oof the
-transmitters identified in Table 1. performed by IEC personnel, and the scheduling of additional' calibrations for a transmitter identified as requiring special attention, as discussed in Action #2 above. Channel checks are performed on a monthly basis to determine if any of these transmitters are experiencing a sere er span shift which is the first L
indication of a possible fill-oil loss. In the performance of these channel enecke readings will be taken using either the main plant computer or test equipment to achieve a higher accuracy than can be achieved using panel meters.
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'i NHY Resnonae c)
Based on_the information from Rosemount. monitoring for drift should give the first indication of failure long befcre the sluggish response due to a transient would be identified. In addition. the main plant computer system does not have the capability to provide a fast enough scan rate to give meaningful data following unplanned transients to identify the early onset of respense time degradation due to fill-oil-leakage. Therefore this method has not been included in the Station's trending program.
d)
The I&C technicians have been made aware to observe for sluggish response when calibrating Rosemount transmitters. The information from Rosemount indicates that the response will be degraded to such an extent that a formal response time test on a routine basis will not be required. However. a time response test will be performed to verify operability of any transmitter identified by the trending program to have a potential fill. oil loss.
e)
The primary method of detection of a potential loss of oil in a sensing module will be the trending of the performance of the instrument channel that is the sero and span shif t observed during the monthly channel checks and the calibrations. Based on the information from Rosemount, monitoring for zero and span shift should give the first indication of failure before a decrease in transmitter noise level of amplitude would be identified.
Therefore the noise level amplitude method has not be included in the station's trending program.
f)
The operability acceptance criteria is as identified in the response to Action #2 above. For the actions to be taken for transmitters which do not
[
meet the acceptance criteria see the response to Action f2 above.
NRC Reeuested Action #4 Determine. within 60 days after receipt of this bulletin, whether any Model 115) and 1156 transmitters identified in Item 1 are from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to lose of fill-oil.
(Information concerning these transmitters was provided to industry by Rosemount concurrent with Reference 4).
Addressees are requested not to utilize transmittore from these suspect lots in the reactor protection or engineered safety features actuation systenst therefore, transmitters from these suspect lots in use in the reacter protection or engineered safety features
+
actuation systems should be repisced at the earliest appropriate opportunity.
HEY _Ita smriee There is only one installed 1153 or 1154 transmitter from one of the high failure I
fraction lott identitled by Rosemount at Seabrook Station. This transmitter monitors EFW suction pressure transmitter which is used in a RC 1.97 Category 1 indicating loop to monitor condensate storale Tank 1.evel. It is not used for Reactor Protection System (RPS) or Engineered Safety Features Actuation System (ESFAS). This transmitter is in a low pressure application and has been in service for over Sly years. After the issuance of the 10CFR21 notification. it was calibrated in May 1989 and again in Dec 1989 and was determined to be operating satisfactorily and has not exhibited any symptoms of potential fill. oil loss.
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Ele Resuested Aetle.n A5 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 f rom the present until such tLas that the Model 1133 and 1154
- transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to less of fill-oil in use in the reactor prote: tion or engineered safety features actuation systems can be replaced.
In addition. while performing the actions requested abcve, addressess may identify transmitters exhibiting symptoms indicative of loss of fill-oil that do not confors to the established operability acceptance criteria and are not addressed-in the technical specifications. As those transmitters are identified, this basis for continued plant operation should be updated to address these transmitters covering the time period from the time these transmitters are identified until such time that these transmitters can be repisced. When developing and updating this basis for continued plant operation, addressees may
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which to consider transmitter diversity and redundancy, diverse trip functions (a separate trip function that any also provide a corresponding trip signal)..
special system and/or component tests, or (if necessary) immediate replacement of certain suspect transmitters.
NifY Respones As provided in paragraph 4 above there are no 1153 or 1154 transmitters from the manufseturing lots that have been identified by Rosemount as having a high failure fraction due to less of fill oil used in the 178 or 38FAS. As also indicated in Enclosure 2 in the Response to Requirement $1(b), there are no transmitters identified which have a confirmed fill-oil loss failure or do not mest the established operability acceptance criteria. Calibration of all the Rosemount 1153 and 1154 transmitters identified on Table 1 was begun in November.
-1989 and is expected to be completed by Harch 10. 1990 (i.e. an appresiastely 6 1/2 month period). Therefore, basis for continued plant operation at Seabrook Station is not required at this time.
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O-mrca e, um TABLE 1 FAFEff-RELATED RDFIplENT TRANSKITTElRB TRAE$MITTER M
M i
'CC-FT-2091
- RCP Coolers Outlet Flow Loop A 1153DD3 (Pamp coastdown Protection) 1 CC TT 2091-2 R0P Coolers Outlet Flow Loop A 1153DD3 (Pump Coastdown Protection) l CC FT-2291 1 RCP Coelers outlet Flow Loop B 1153DD3 (Pump Ccastdown Protection)
CC FT-2291-2 RCP Coolers outlet Flow Loop 3 1153DD3 (Pump Coastdown Protection)
L,
CC-FT-1175A RCP TB Cutlet FR P-321A & 3 1153DCS Thermal Barrier Cooling (Pump $ tart it 4
Interface)
CC TT-2175B RCP TB outlet FR P-32tA & 5 1153DD5 Thermal Barrier Cooling (Pump Start 1E Interface) i l-CC.LT 2172-1 PCCW Head Tank 19A Level (NNS Header 1153DBA l
Isolation signal) l-CC.LT-2172 2 PCCW Head Tank 19A Level (NN$ Header 1153Dl4 L
Isolation signal)
CC-LT-2172-3 PCCW Need Tank 19A Level (NNS Meader 1153DB4 Isolation Signal) l CC.LT-1192 1 PCCW Head Tank 19A Level (NNS Beader 1153DB4 l
1 solation Signal) l CC-LT-2192-2 PCCW Head Tank 19A Level (NN$ Reader 1153t54 L
tsolation Signal)
CC.LT-2192-3 PCCW Mead Tank 19A Level (NWS Header 1153DB4 Isolation Signal) l CQ-LT-2272,-1 PCCW Head Tank-19B Level (NNS Header 1153CB4 Isolation Signal)
CC.LT-2272-2 PCCW Head Tank 195 Level (NN8 Header 1153DB4 Isolation Signal)
CC LT-2272-3 PCCW Head Tank 19B Level (NNS Header 1153DB4 Isolation Signal).
CC-LT-2292-1 PCCW Head Tank 19B Level (ENS Header 1153DB4 l
Isolation Signal) t CC.LT-2292-2 PCCW Head Tank 195 Level (NNS Usader 1153DB4 i
Isolation Signal)
CC-LT-2292 3 PCCW Head Tank 198 Level (NNS Header 1153DB4 Isolation Signal) 1;
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CS-FT-7325 CS-P-2A Chg Pmp Disch Flow (Pump Deadhead 1153HB4 Protection)-
CS-FT-7326 CS-P-2B Chg Pep Disch Flow (Pump Deadhead 1153534 I
Protection) l FV-FT-6214-2 SG A EFW Edr Flow (Isolation of Flow to 1153DB5 Fanised SC) l l
- 3 iL C. e tw TABLE 2 SAFETY-1 ELATED ROSEMOUNT TRANSMITTERS TRANSMITTER FUNCTIONMODEL FW.FT.4214-4 S3 A RFW Mdr Flow (Isolation of Flow to 1153235 Faulted 80)
FW.FT.4224 2 53 B EFW Edr Flow (Isolation of Flow to 1153DBS Faulted SC)
FW-TT-4224.4 33 3 BFW Edr Flow (Iselation of Flow to 1151DBS Faulted SC)
FW.FT.4234 2 53 C IFW Edr Flow (Iselation of Flow to 1153DB5 l
Faulted 80)
FW.FT-4234.4 SG C EFW Edr Flow (Isolation of Flow to 1153D35 e
Faulted SG)
FW.FT-4244-2 SG D 8FV Edr Flow (Isolation of Flow to 1153D35 Faulted 80)
FW-FT-4244-4 SG D EFW Edr Flow (Icelation of Flow to 1153DBS Faulted SC)
FW PT.4252 N Condensate Storage Tank Level (FW-P.37A 1153085 Suction Pressure)
FW.PT.4257 Condensate Storage Tank Level (FW-P-375 1153G35 Suction Pressure)
SV.LT.6129 Cooling Tower Loop A SV Basin Level 1153D85 SV.LT-6139 Cooling Tower Loop B SW Basin Level 1153DB5 BV-PT-8272 SW-P.41A/C $wp Diech Edr Press (CT Tower 1153DB6 Actuation Signal)
SW-PT-8273 SW-P.41A/C $wp Disch Edr Press (CT Tower 1153D36 l
Actuation Signal) f SW-PT-8274 SW-P.41A/C $wp Disch Edr Press (CT Tower 1153DB6 Actuation Signal)
L SV-PT-6282 SW.P-413/D $wp Disch Edr Press (CT Tower 1153DB6 Actuation Signal)
SV-PT-8283 SW-P-418/D Swp Disch Edr Press (CT Tower 1153D36 Actuation Signal)
$V-PT-8284 SW.P-415/D Swp Disch Edr Press (CT Tower 1153DB6 Actuation Signal) l-i RC-PT-455 Pressuriser Pressure 1154GP9 RC-PT-450 Pressuriser Pressure 1154GP9 RC.PT-457 Pressuriser Pressure 1154GP9
-RC-PT-458 Pressuriser Pressure 1154GP9 FW-LT-551 steam Generator A Narrow Range Level 1154DP4 FW-LT-517 Steam Generator A Narrow Range Level 1154DP4 FW-LT-518 Steam Generator A Harrow Lange Level 1154DP4 FW-LT-519 Steam Generator A Harrow Range Level 1154DP4 l
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TABLE 1
!pSE*Y.REIA*'ED 10SEMQUNT TRANEMITTE15 TRANSMITTER FtTNCTION M0 DEL NO, W.LT.552 Steam Generator 3 Narrow Range Level 1154DP4 W.LT.527 Steam Generator B Narrow Range Level.
1154DP4 W. LT. 52 B Steam Generator B Harrow Range Level 1154DP6 N.LT.529 Stetti Generator B Harrow Range Level 1154DP4 W.LT.553 Steam Generator C Narrow Range Level 1154DP4 W.LT.537 Steam Generator C Narrow Range Level 1154DP4 W.LT.53P Steam Generator C Narrow Range Level 1154DP4 W.LT.539 Steam Generator C Narrew Range Level 1154DP4
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W.LT-556 Steam Generator D Narrow Ramle Level 1154DP4 W.LT 567 Steam Generator D Narrow Range Level 1154DP4 W.LT.548 Steam Generator D Narrow Range Level 1154DP4 W.LT.549 Steam Generator D Narrow Range Level 1154DP4 RC.LT.459 Pressuriser Level 1154DP5 RC.Lt.460 Pressuriser Level 1154DP5 RC.LT-461 Pressuriser Level 1154DP5 i
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'harCA 8, 1990 i
1 1
l Enelemure 2 to NYN.gj g g, Procesed Draft Bulletin on Loss of 7111-011 in Lesemount Tranaeltters Resoonse to Resortina Reauirements: Operatina Roseters 9.
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ti Precomed Draft Bulletin en Lane of Fill. oil in Reenmount Transmitters Reneense to Romertine Reauira==mts oeerattne Reactors
)
'I NRC lacertina Raeuirement dif a) 1 Confirms that those Requested Actions for Operating Ranctors in Iteme 1, 2, 3. 4 and 5 that are 7.o be completed within 120 days af ter receipt of this bulletin j
have been coepleted and that programs are in piece to perfers the remaining requested actions.
NEY Response The status or scheduled completion for the Requested Actions for Operating Reactors in Items 1.2.3,4 and 5 of the proposed draft Bulletin is as follows:
Item 1:
This item has been completed.
Item 2:
This item will be complete by 3/14/90.
Item 3:
The major elements of the program, the establishment of the preventive maintenance actions and the first two monthly channel checks for the majority of the channels is complete. The procedare describing the trending program is drafted and espected to be formally approved by 3/1&l90. The procedure documenting the operability acceptance criteria and associated testing expected to be approved by 3/30/90. The review of the calibration information has not identified a need to verify the operability of any of the transmitters on Table 1.
Item 4:
This item has been completed.
Item 5:
A basis for continued operation is not required at this time, therefere this item is not applicable.
mtc Reeertinn keouirement #1(b) i l'
Identifies.the indicated manufacturers.the model numb 6rs the safety.ralated I
system the transmitter was utilized in the approximate amount of time in services the corrective actions taken and the disposition (e.g., returned to vender for analysis) of transmitters, including those identified while performing.
Item 2 of Requested Actions for Operating Reactors above, that are believed to have exhibited symptoms indicative of lose of fill oil or have been confirmed to have experienced a lose of fill. oil.
W.1tesconst At the present time there are no transmitters that have been confirmed to have a 1
fili. oil less failure at Seabrook. There is one transmitter which is under study I
because a review of calibration records indicates that it may be exhibiting the
~
early signs of fill oil loss. The following information applies to this transmitters l
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.,4 March 8. 8990-Indicated'Hanufacturers Rosescunt Hodel Number: 1153 Systeau F.mergency Feedwater (EN)
Function: Flow measurement for isolation of E W flow to a faulted Steam Generator.
Time in Service:
Installed since September, 1935.
Observed Symptoms: The transmitter has drifted in the same direction over two calibration periods.
Corrective Action Taken: The transmitter has been identified to be Calibrated 7
sere frequently to determine if it continues to display the symptoms of fill-oil leakage.
If, the transmitter continues to display the symptoms of fill-oil leakage then the actions described in Enclosure 1. Response to Action f2 will be implemented.
Disposition:
The transmitter is being evaluated in accordance with the program.
NRc Reeertine Py uirement dife)
Identifies the safety-related system in which the Model 1153 or 1134 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-cil are utilised and provides a schedule for replacement of these transmitters which are in use in the reactor protection er engineered safety features actuation systems.
J NNY konsonne l
There are no 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 utilised in the reactor protection or engineered safety features i
actuation system.
NRC'ReSertine Reauirement d2 Transmitters that, subsequent to providing the response required by ITIN 1 above, exhibit symptoms of loss of fill-oil or are' confirmed to have experienced a lose of fill-oil should be reviewed for reportability under existing Ntc regulations.
If determined not to be reportable, addressees are requested to document and-
-maintain, in accordance with plant procedures. information consistent with that requested in Item 1 (b) above for each suspect transmitter identified.
NNY Reneense If's Rosemount Model 1153 or llSa transmitter exhibits the symptoms of loss of fill-oil or are confirmed to have experienced a loss of fill-cil this condition L
will be reviewed for reportability under existing NRC regulations. If it is l
determined not to be reportable information consistent with that requested in
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a, e t'11 Restonee i
Ites 1b of the Reporting Requiremente for Operating Reactors of the Draft
' lu11etin will be documented and maintained in accordance with plant procedures.
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Serier Vies Presidem and CWelOperseg Ober NYN.90061 March it. 1990 United states Nuclear Regulatory consalesion Vashington, DC 10353 Attentions Document Control Desk
References:
(a)
Facility operating License No. NFF.67, Docket No.30-643 (b)-
NYN.9cc56 dated March 6, 1990, ' Response to Proposed Draft NRC sulletin on Loss of Fill 011 in Rosemount francaitters.
T.C. Feigenbaua to Doc eent Control Desk' subjects supplemental Response to Proposed Draft NRC Sulletin on Loss of fill 011 in Rosemount transmittore Gentlemen During recent discussions with the NRC Staff. New Maapehire Yankee (NMY) was requested to supplement the response contained in Reference (b) to confirm the con:pletion of the calibration reviews, to identify the further enhanceaants to the surveillance program and to prw ide additional information.
NEY is providing the supplemental information in the form of the enclosed revisions to.
Reference (b).
The changes are identified by revision bare.
As provided in Reference (b) NMY determined that there is only one transmitter installed at Seabrook 8tation frasa the Model 1153 and.1156 manufacturing lots, which were identified by Roemnount as having a high failure fraction.- This transmitter is not utilised in the reactor protection system (RPS) or engineered safety. features actuation systems (R$FAS) and has been installed and in-service for over 3 1/2 years.
During this time period, the transmitter has been operating eatisfactorily and has not exhibited any synytose of potential fill-oil lose.
Nonethelees, for conservaties. NSY has accided to replace this transmitter.
the close cf business on MarchThe replacement trantaitter will be installed before
- 16. 1990.
As indicated in the enclosures, the review of calibration data has been performed for all the identified transmittore.
The conclusions from this review are that there are no transmitters identified which have a confirmed fill-oil lose failure or which did not meet the established operability acceptance criteria.
As indicated in the enclosures, one transmitter which had eahibited early symptoms of potential fill. oil lose has been replaced.
New Hampshire Yonkee Division of PuWie Service Company of New Hompshire P.O. Boi. 300 * $eabrook, NH 03874
- Telephone (603) 474 9521 i i
x
- United States Nuclear Regulatory Commission March it. 1990 Attention:
Document Control Desk Page 2 1
should you have any questione regarding the enclosed. g$ ease contact Mr.
Terry L. Harpeter at (603) 674 9511 extension 2765.
/
Very trul yours.
(4-cci Mr. Willian 7. Russell Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road Iting of Prussia, PA 19406 Mr. Victor Nerees, Project Manager Projoct' Directorate 2 3 United states Nuclear Regulatory Commission
-Division of Reactor Projects Washington, DC 20555 Mr. Ncel Dudley NRO Senior Resident Inspector P.O. Boa 1149 Seabrook. NR 03874 Atomic Safety and Licensing Board Service List
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ASLR SERVICE LIST Alth S. Rosenthal, Chairman Adjudicatory File Atomic Safety and Licensing Appeal Panel Atomic Safety and Licensing U.S. Nuclear Regulatery CoenLLesion Boar 6 Panel Docket (1 copies)
U.S. Nuclear Regulatory Cosadesion Washingten. DC 20555 Vashington. DC 20335 Thomas 5. Moore Philip Ahrens. Esquire Atomic Safety and Licensing Assistant Attorney General Appeal Panel U.S. Nuclear Regulatory Commission Office of the Attorney General State Reuse Station #6 Vashington. DC 10555 Augusta. H2 04333 Eoward A. Wilber t '.
Atomic Safety and Licensing '
Ashod W. Amirian. Esquire -
L Appeal Panel Assistant City Solicitor City of Haverhill L
U.S. Nuclear Regulatory Committien Vashington, DC -10535 Raverhill. NA 01830 C. Paul lo11werk. III. Chairman Robert A. Backue. Esquire Backus. Meyer & Sciomon Atomic Safety and Licensing 116 Lowell Street i
Appeal Panel P.O. los $16 U.S. Nuclear Regulatory Commission Manchester, NE 03103 Vashington. DC 2CS$3 Coorse Dana Bisbee. Esquire Atomic Safety and Licensing Assistant Attorney General Appeals Aoard Panel U.S. Nuclear Regulatory Commission Office of the Attorney General 25 Capitol Street Washington. DC 20$55 Concord. NH 03301-66397 Ivan W. Smith. Chairman Diane Curran. Esquire Atomic Safety and Licensing Board Andrea C. Forster. Esquire Panel U.S. Nu* clear Regulatory Commiselon Earmen. Curran & Toutley 2001 S Street. N.V.
Suite 430 Vashingten. DC 20S53 Vashington, DC 20009 1125 Robert R. Pierce. Esquire Mr. Jack Dolan t-Atomic Safety and Licensing Board Pans 1 Federal Emergency Management Agency Region I U.S. Nuclear Regulatory Commission J. V. McCormack Post' Office &
Vashington. DC 20$S3 Courthouse Building. Room 442 Boston. MA 02109 Admin.-Judge Kenneth A. McC0110m.
Member 1107 Vest Knapp Street Mr. Richard R. Donovan Federal Energency Management Agency Stillwater CK 74073 Federal Regional Center Richard F. Cole 130 228th street. S.V.
Rothe11 Washington 98021-9796 Atesic Safety and Licensing Board Panel U.s. Nuclear Regulatory Commission Washington. DC 20335
i n-ASLS SERVICE LIST Susanne F. Egan. Oity Sclicitor Judith M. Misner. Esquire Lagoulis Elli.Vhilton &
79 state street.
& Rotondi second Floor 79 State street Newburyport. MA 01950 s
Newburyport MA 01950 Barbara J. saint Andre. Esquire H. Joseph Flynn. Esquire Kopelman and Paige,
P.C.-
Office of General Counsel 77 Franklin street Federal Er.orgency Management Agency Boston. MA 02110 500 0 Street. $W Vashington, DC 20472 John Traficonte. Esquire Assistant Attorney General-
- 1. Scott Bill.Vhilton. Esquire Office of the Attorney General Lagoulis. Clark Mill-Vhilton-one Ashburton Place. 19th F1Cor
& Rotondi Boston MA 02105 L
79 State Street Newburyport. MA 01950 Mitti A Young, Esquire Edwin J. Reis. Esquire Cary V. Holmes. Esquire Office of Seneral Connsel He'Ames & Ells U.S. Nuclear Regulatory Oommission of Winnaeunnet Road Vashington DC 20535 Hampton, NH 03842 Senator Cordon J. Humphrey*-
United States Senate Washington, DC-20510 Attentions Tom Burack
. Senator Corden J. Humphrey*
1 Eagle Square. Suite 507 Concord. NE 03301 Attenti,on: Mary Jane Colter.
George Iverson. Director N.H. Office of Energency Manegament -
' state House office Park Scuth 107 Fleasant Street-Concord. NH 03301 Paul McEachern.- Esquire
' Matthew T. Brock. Esquire 3haines & McBechern 15 Maplewood Avenue. P.O. Box 360 Portsr.outh. NH 03801
= letter only
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New Maapshire Yankee March it. 1990
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ENCLC$t2E 1 70 NYN-90061
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- Prenosed braft Bulletin on Lena of F111 011 in knammeunt *ransmittern Reseense to Raouented Actions: Dearatine naaetors l
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New Rampshire Yankee March it. 1990 Pronosed Draft tulletin en Loss of Fill-cil in Rosa-e t Trana=8ttern Raammaa to Raananted Actiema Oberatin Res.cing.g NRC leauested Action 31 2dentify within 60 days after the receipt of this bulletin, all pressure or differential pressure transmitters. including Model 1131, 1152, 1183. and 1134 transmitters but escluding Model 1153 and 115a transmitters manufactured by Rosemount subsequent to July 11, 1989, that were manufactured by Rosemount or that centain Rosemount manufactured sensing modules and are utilised in either safety-related systems or systans installed in accordance with 10 CFR 50.82 (the L,
ATVS rule).- Addressees may find it necessary to perform, in addition to document reviews, system walkdowns to complete this action.
{ Note la addition to the above the proposed draft bulletin provided additional information to facilitate addressing the above. This additional information has not been repeated herein.)
NMY Resoonee J
In regards to Rosemount Model 1151 and 1132 transmitters, there are g Model 1152 transmitters installed at seabrook station and there are g Model 1151 transmitters at Seabrook Station which perform a safety-related or ATVS related functions. There are Rosemount Model 1153 and 1154 trantaitters at seabrook L
Station which perform safety-related functions. These transmittore are identified on Table 1.
A review was undertaken to determine if the original equipment manufacturer's (08H's), identified in the proposed draft bulletin, had provided transmitters to Seabrock Station which, as described in the draft bulletin, may have been manufactured by Rosemot.nt or contained a sensing module manufactured by Rosemount. The review concluded that only Bailey Controle had supplied transmitters to Seabrock Station which utilised a-Model 1151 transmitter sensing
. module. These transmitters do not perform a safety-related or ATWS related function. *
'NRC Recuested Action #2 Review within 90 days after receipt of this bulletin, plant records (for example, calibratice records) associated with the transmittore identified in Item 1 above to determine whether any of these transmitters may have already exhibited symptoms indicative of Icss of fill-oil. Appropriate operability acceptance criteria should be developed and applied to tranessitters identified as having exhibited sy1aptoms indicative of lose of fill-oil from this plant record review.
Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that de not conform to the operability acceptance criteria should be addressed in accordance with the applicable technical specification.
o
- ransmitters identified as having exhibited symptoms indicative of loss of fill-oil and are not addressed in the technical specificatione should be replaced at the earliest appropriate opportunity.
NHY Reseoqgg As indicated in NHY's response to Action $1 above., the response to this action item need only address the Model 1153 and 1154 Rosemount transmitters identified in Table 1.
A review of plant calibration records for the period between January 1987 and the present associated with the identified model 1153 and 1154 m
New Hampshire Yankee March 12, 1990 NRY Raanonae transmittere has been performed. The results of this review are provided in. Requirement 1(b).
The method of review utilises the guidelines of Restaount Technical Bulletin de Appendix A Section 8.
This technical bulletin and its guidance was developed from the extensive testing and evaluation performed by Rosemount in regards to the fill-oil leakage issue. This guidance is utilised to detesinine if there is a possible fill-oil leak. The following criteria vill be used to decide if a transmitter should be placed in the category of needing to be recalibrated or requiring special attentions a)
A transmitter will be tested against the operability acceptance criteria ift (1) it exhibits the trend that, between three or more consecutive calibratione, it drifted in the same direction such that the total cumulative drift exceeds the total maximum allowable casulative drift. as provided in Table 1 of Appendix A of Rosesount Technical.Sulletin 4. or (2) if the drift cheerved during the channel checks causes the total observed drift to exceed the maximum allowable cumuistive drift. In this regard. It should ateo be noted that the appropriate range down factors will be applied in the calculation of the drift f or the comparison to the data in the aforeewntioned table.
b)
For those transmitters which have safety-related setpoints, during the review of the channel checks and the calibration dats, the measured drift of the transmitter will be compared to the combination of the assumed drift and the transmitter accuracy as used in the setpoint calculation. If the measured drift exceeds this value between calibrations or if it appears from the channel checks. that the transmitter will exceed this value,_it will be calibrated on a scre frequent basis so as not to exceed the assumptions of the setpoint calculation.
c)
For those channels that do not have setpoints, during the review of the channel chetko and the calibration data, the measured drift of the transmitter will be compared to the combination of the drift value from the manufacturers specifications and the transmitter accuracy. If the measured drift exceeds this value between calibrations or if it appears from the channel checks, that the transmitter will exceed this value. it will be enlibrated on a more frequent basis so as not to saceed this value.
d) If the transmitter has not met the above critoria but has exhibited behavior which warrants further evaluation. the system engineer may choose to calibrate the transmitter more frequently or to perform the operability test to aid in his evaluation of the transmitter performance.
A transmitter will be time response tested to detetlaine if the operability acceptance criteria is satisfied. The criteria for time response testing to based on Rosemount Technical Bulletin #4 Appendix 5 Section 2 and is as followes Apply a pressure transient of the full range of the transmitter to test the time response cf the side of the DP cell which is suspected of leaking. For range code 3-9 the transmitter should respond (or follow since the pressure
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New Naapshire Yankee March 12. 1990 l}
WY Reenonse change may be a fast ramp) to this pressure change within 1 second. Range code 3 should respond within 35 seconde and range code 4 should respond within 6 seconds. Where this criteria is less stringent than the tima L'
response values required to meet the response time specified the Technical e
Reguirements Manual. The Technical Requirements Manual values will take L
precedence in determining operability.
h Transmitters identified as having exhibited symptoms indicative of loss of fill-
[
oil that are included in the Technical Specifications and that do not conform to L,.
the operability acceptant.e criteria vill be addressed in accordance with the j
applicable Technical specification. Transmitters identified as having exhibited symptoms indicative of loss of fill. oil that do not conform to the operability i',
i *"
acceptance criteria and are not addressed in the Technical specifications will be j
replaced at the earliest appropriate opportunity. Those transmitters that l'
exhibit the symptoms indicative of a possible loss of fill-oil but that satisfy the operability acceptance criteria will be evaluated on a case by case basis to determine a specific course of action.
NRC Recuested Actiee J_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 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 r'outine channel calibration activities:
e) ' Development and implementation of a program to detect a decrosee in transmitter noise level amplitudes and f)
Develcpment and application to transmitters identified as having exhibited symptoms indicative of loss of fill-cil 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.
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New Eampshire Yankee NRY leseense March 12, 1990
- The enhanced surveillance program for the installed Restmount transmitters is presently being implemented. This pro nam addresses the consideraticas of the draft NRC Sulletin as follovoi 1
m) nc personnel are aware of the symptoms that a transmitter, both during.
operation and during calibration activities, any exhibit if it is experiencing a loss of ill1. oil. 160 Department personnel have been on distribution for s11 pertinent information pertaining to Rosemount Technical Bulletins and this information has been included into the required reading program in the H C Department. In addit. ion, the trattiing department will be l#
scheduling formalised training of operations and 26C personnel regarding the above over the neat 4 months.
b)
The enhanced surveillance program will include weekly and monthly channel checks of the transmitters identified in Table it the scheduling cf additional calibrations for a transmitter identified as requiring special attentions and the review of calibration records for these transmitters to look for transmitter drift as discussed in Action $2 above. The transmitters providing an input to the RPS and 36 fag will be checked on a weekly basis.
Channel checks will be done on a weekly basis using the Main Plant Computer System (NPC8) for those channels that provide inputs to the MPCS except as described below. The channels that do not provide inputs to the MPCS will be checked on a monthly basis using test equipment in the process electronics cabinets.
In seven cases, only one of the transmitters monitoring the same procese parameter provides an input into the MPC8. Therefore in these cases all of the transmitters for those process parameters will be monitored on a monthly basie using test equigaent in the process electronics cabinets. For the four pressuriser pressure and sixteen stoaa generator level channels weekly channel checke using test equipment will be performed. This channel check data and the data from transmitter calibrations will be trended to determine if any of these transmitters are exhibiting drift which may be an indication of a possible (111.o11 loss.
r For most of the channels, the channel check will determine drift by conparing the amount of change in the output af the transmitter from a baseline value to the amount of change of other transmitters manitoring the same process parameter from week to week or month to month. It may be noted that for some of the flow channels, the monthly channel check will be a aero check since the system will not be in operation.
c)
Based on the information-from Rosemount, monitoring for drift should give the first indication of failurs long before sluggish response in a transient would be identified. However, the enhanced surveillance program will incluse a review of MPCS data following transients. Specifically the program will review MPCs data following planned transients during the power ascension test program for the Rosemount model 1133 and 1154 transmitters which provide an input to the MPCs. Also following unplanned transients which result in or from a reactor trip or safety injection initiation, the Rosemount transmitters which provide an input to the MPCS post morten report will be reviewed.
The post morten report includes the two charging pump discharge flow channels, the four pressuriser pressure channels, the three pressuriter level channels and twelve of the' steam generator level channels (three on each generator).
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Mew Maapahire Yankee HY Resnones March 12, 1990 d)
The I&C technicians have been made aware to observe for slugg'ieh response when calibrating Rosemount transmittore.
During the calibration the technician.will observe the gualitative time response performance due to a rapid change in the input. Based on the Rosemount literature a' quantitative response time test during routine calibration te not required since the degradation in responto time should be noticeable to the technician. Ilowever, a quantitative time response teet will be perferad to verify operability of any transaitter identified by the trending program u discuseed in the response to requested action it above.
The primary method of detection of a potential loss of oil in a sensing e) module will be the trending of the performance of the inetrument channel.
that is, the drift observed during the sonthly channel checke and the calibratione.
Based on the information from Rosemount, monitoring for sere-and span shift should give the first indication of failure before a decrease in transmitter notes level of amplitude would be identified. Therefore, the noise level amplitude method has not been included in the Station's trending program. If in the future we identify a possible use for this method we vill incorporate it into our enhanced surveillance program.
f)
The operability acceptance criteria is as identified in the response to Action #2 above. For the actions to be taken for transmittore which do not meet the acceptance criteria ese the response to Action it above.
NRC Reeuested Action de Determine, within 60 days after receipt of this bulletin, whether any Model 1153 and 1154 transmitters identified in Item 1 are from the manufacturing lots that have been identified by Rosemount se having a high failure fraction due to loss of fill-oil.
(Information concerning these transmitters was provided to industry by Rosemount concurrent with Reference 4).
Addressess are requested not to utilise transmitters from these suepoet tote in the reactor protection or engineered safety features actuation systems: ther6 fore, trancaittore from these suspect lote in use in the reactor protection or engineered safety features actuation systems should be replaced at the earliest appropriate opportunity.
HY Reneense There is only one installed 1153 or 1154 transmitter from one of the high failure fraction lote identified by Rosemount at Seabrook Station. This transmitter monitore EfV suction pressure transmitter which is used in a RC 1.97 Category 1 indicating loop to monitor condenente Storage Tank Lovel. It is not used for Reactor Protection System (RPS) or Engineered Safety peatures Actuation gyetem (E3FAS). This transmitter is in a low pressure application and has been in service at normal operating pressure for over 34 years. After the leeuance of the_10 CFR 21 notification, it was calibrated in May 1989 and again in Dec 1989 and was determined to be operating eatisfactorily and has not exhibited any symptoms of potential fill-oil lose.
Nlte Renuanted Action #5 Document, within 60 days af ter 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 1133 and 11$4 i
transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil in use in the reactor
New Hampshire Yankee NRC Reauestad Action Al protection or engineered safety features actuation systems can be replaced.
addition. while performing the actions requested above, addressees may identify In transsisters 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 16entified this basis for continued plant operation should be updated to address these transmitters covering the time period from the tias these transmitters are identified until such time that these transmitters can be replaced.
1then developing and updating this basis for continued plant operation, addressees may
.which 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 compon9nt tests, or (if necessary) isandiate replacement of certain suspect transmitters.
- I. -
NNY Restense As provided in paragraph 4 above there are no 1153 or 1154 transmitters from the
.manufacturir.g lots that have been identified by Rosemount se having a high failure fraction due to loss of fill oil used in the RPs or E8FAS. As also indicated in Enclosure 2 in the Responsa to Requireannt #1(b). there are no transmitters identified which have a confirmed fill-oil less failure er do not meet the established operability acceptance criteria.
Calibration of all the Rosemount 1153 and 1154 transmitters identified on Table I was begun in November.
i 1989 and has been completed. Therefore. basis for continued plant operation at Seabrook Station is not required at this time.
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(y New Baapshire Yankee March it. 199C RAFETY RRtAvED RoamtRff TRANEM27tEta IRAN 8MITTER g
CC-FT-2091 1*
RCP Coolers Outlet Plow Loop A 1133DDS (P ap Coastdtron Protection)
CC-PT 2001 2*
RCP Coolers Outlet Plow Loop A 1133DD3 I
(Pump Coastdown Protection)
CC-FT-2291-1*
RCP Coolers Outlet Ploo Loop B 1153DD3 l
(Pump Coastdown Protection)
RCP Coolers outlet Plow Loop B 1153DD3 l
(Pump Coastdown Protection)
CC-PT 217$A*
RCP TB Outlet PR P-322A 6 B 1153DD5 l
Thermal Barrier Cooling (Pump Start 1E Interface)
CC FT 2173B' RCP TB Outlet FR P-322A & 5 1153DDS l
Thermal Barrier Cooling (Pump Start II Interface)
.CC.LT-2172 1*
PCCW Bead Tank 19A Level (WNs Header 1153DB4 l
Isolation Signal)
CC-LT-2172-2 PCCW Head Tank 19A Level (NNS Beader 1153D84 Isolation Signal)
CC LT 2172-3 PCCW Need Tank 19A Level (NN8 Header 1153D84 Isolation Signal)
CC-LT-2192-1 PCCW Head Tank 19A Level (NR8 Heeder 11$3D84 Isolation Signal)
CC.LT-2192-2 PCCW Head Tank 19A 1Avel (NNS Ioader 1153D84 Isolation signal)
CC LT-2192-3 PCCW Mead Tank 19A Level (NNS Beader 1133D84 Isolation Signal) i CC-LT-2272-1*
PCCW Bead Tank 198 Level (NNB Reader 1153D84 Isolation signal)
CC-LT-2272-2 FCCW Head Tank 195 Level (NNS Beader 1153DB4 Isolation signal)
CC.LT 2272-3.
PCCW Mc.d Tank 193 Level (NN8 seader 1153DB4 Iselation signal)
CC.LT-2292-1 PCCW Head Tank 198 Level (NN8 Header 1133D94 Isolation Signal)
CC-LT 2292-2 PCCW Head Tank 198 Level (NNS Neader 1153Dl4
! solation Signal)
CC-L'I 2292-3 PCCW Mead Tank 195 Level (NNS Neader 1153DB4 Isolation Signal)
C5-PT-7323*
C5-P-2A Chg Pap Disch Flow (Pump Deadhead 1153HB4 Protection)
CS-PT-7326*
C3-P-2B Chg Pap Disch Flow (Pump Deadhead 1153HB4
{
Protection)
FW-PT-4214-2 SC A EFW Edr Flow (Isolation of Flow to 1153DB5 Faulted SG)
3 New Maapshire Yankee March 12, 1990 TABLE 1 sArrTY n*urEn mostwotnet tuur mran TRANSMITTER M
IOD$L NC.
W FT-621&-4 90 A E W udt Flow (Isolation of Flow to 1153D85 Paulten 80).
N FT-4224-2 30 B EPV Edr Flow (Isolation of Flow to 1153D85 Faulted SG)
W FT-6224 6 SG B EFW Edr Flow (Isolation of Flow to 1153D85 Paulted S0)
W FT-4234-2~
SG C BW Edr Flow (Isolation of Flow to 1153D85 Faulted 80)
W-FT-4234-4 SG C SW Edr Flow (Isolation of Flow to 1153D35 Paulted 80)
W-PT 6244-2 50 D E W Rdr Flow (Isolation of Flow to 1153D35 Faulted SG)
W-FT-6244-4 SG D IW Ndr Flow (Isolation of Flow to 1153DB5 Faulted SG)
WEPT-4252**
Condensate Storage Tank Level ( W-P-37A 1153:55
(
Suction Pressure)
W PT 4157' Condensate Storage Tank Level (W P 373 1153035 l
Suction Pressure)
SV LT-6129*
Cooling Tower Loop A SW Basin Level 1153DB5 SV-LT-6139 Cooling Tower Loop 8 SV Basin Level 1153DB5 SV PT-8172 SV P 41A/C Swp Disch Edr Press (CT Tower 1153DB6 Ac'..ttion Signal)
SV-/ 41A/C Swp Disch Ndr Press (CT Tower 1153DB6
{
Actuation $1gnal)
SW-PT-6274 SW.P-61A/C Swp Disch Edr Press (CT Tower 1153D56 Actuation Signal)
SV-PT-8222 SV-P-415/D Swp Disch Edr Press (CT Tower 1153DB6 Actuation Signal)
SW-PT 8283*
SV P 418/D Swp Disch Edr Press (CT Tower 1153D86 Actuation Signal)
SV-PT-8284 SV-P 618/D Swp Disch Edr Press (CT Tower 1153D86 Actuation Signal)
RC PT 455'
'Pressuriser Pressure 1154GP9 RC-PT-456' Pressuriser Pressure 1154GP9 RC-PT-457' Pressuriser Pressure 11540P9 RC-PT-458' Pressuriser Pressure 1154GP9 FV-LT-551*
Steam Centrator A Narrow Range Level 1154DP4 W-LT-517*
Steam Generator A Narrow Range Level 1154D04 FW-LT-518e steam Cenerator A Harrow Range Level 1154DP4 FW.LT-519*
Steam Generator A Harrow Range Level 1154DP4
New Hampshire Yankee March 11. 1990 TABLE 1 1AFETY artATED tegrwo3NT TRANaM???tta N SMII.TER natcTion gongt go, W-LT-552*
Steam Generator 3 Marrow Range Level 1154DP4 W-LT-527' Steaa Generator 3 Marrow Range Level 1156DP4 W-LT-520*
Steaa Generator 3 Marrow Range Level 1154DP4 W-LT 519*
Steaa Generator 3 Marrow Range Level -
115&DP4 W-LT-553e Steta 9enerator C Barrow Range Level 1156DP4 W.LT-537' 8 team Senerator C Narrow Range Level 1154DP4 W-LT-530*
Steam Generator C Marrow Range Level 1154DP4 N-LT-339' Steam Generator C Narrow Range Level 1154DP4 W.LT-5 5 4 * -
Steta Generator D Marrow Range Level 1154DP4 W-LT-547' Steam Generator D Marrow Range Level 1154DP4 W-LT-346*
Steam Generator D Narrow REM devel 1154DP4 W-LT-549*
Steaa Generator D Narrow Ri.yf 3 tevel 1154DP4 RC-LT-459*
Pressuriser Level 1154DP5 RC.LT-460*
Pressuriser Level 1184DP5 RC.LT-461*
Pressuriser Level 1154DP5 Transmitter which has an input to the Main Plant Computer System (MPC8).
Transmitter which has an input to the Main Plant Computer System (MPCS)and is the only transw.itter from the high failure fraction lott identified by Rosescunt installed at Seabrook station.
e 4
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New Hampshire Yankee i
March 12. 1990 L
1;
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u to NYm enosi i
l-l-
Prenesed Draf t Bullitin on Loma of 7111.011 in ten==-ust Transmittare l,*
Reasonne to Renortina Raouiramanten Omaratina teactora
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4 I
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New Hampshire Yankee March 12, 1990 Pronosed Draft Bulletin on imas of F111-011 in Ree = sat Transmittern Reanonne to lanertime maauframantan anaratine naaetera MRe Reoortime Raouir nt sifai Confirme that those Requested Actions for Operating Reactore in Item 31, 2, 3, 4, and 3 that are to be completed within 120 days after receipt of this bulletin have been completed and that programe are in place to perform the remaining requested actions.
Muy teneonae The' status or scheduled completion for the Requested Actions for Operating Reactore in Items 1,2,3,a and 5 of the proposed draft Sulletin is se followe p**
Iten 2:
This item has been completed.
Item 2:
This item has been completed.
Item 3:
Most of the program is presently in place. The remaining activities and expected completion dates are as followes a)
Most of the preventive maintenance activities are in place, the remaining activittee which were identified after 3/9/90 will be in place by 3/13/90. The majority of the monthly 1-channel cheeke have been completed, for the second month of this program.
b)
The procedure describing the trending program and liets the operability acceptance criteria le espected to be approved by 3/21/90._ The basis for this program and criteria were used to review the poet calibration data.
c)
The procedure for performing the response time test which le used to establish the operability of a transmitter with possible fill-oil leakage is expected to be approved by 3/30/90. This procedure is not needed at this tias to verify-the operability of any of the transmitters in Table 1.
Item 4:
This iten has been completed.
Iton 5:
A basie for continued operation is not required at this time, therefore this item is not applicable.
NRC Resortime Recuirement #1(b)
Identifies the indicated manufacturers the model numbers the safety-related
-system the transmitter was utilised in; the approximate amount of time in services the corrective actions takens and the disposition (e.g., returned to vendor for analysis) of transmitters, including those identified while performing Iten 2 of Requested Actione for Operating Reactors above, that are believed to have exhibited eyaptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil.
t l
F i
New Bampshire Yankee l
March it. 1990 t
Nrf Lasannaa i
At the present time there are at transmitters that have been confirmed to have a fill. oil lose failure at Sestrook. There was one transmitter skish eahibited the eyaptoms that could be early signs of filt.eil less. This tremenister, se provided below, has since been replaced. Fhe following infeessation applies to this tronomitters Indicated Manufacturers Rosemount
]
Model pueber: 1153Dt3 systems amorgency Feedwater (EFW l-Function: F1pv measurement for teolation of EFW flow to a faulted Stena Generator.
Time la Service:
lastalled since september, 1983.
observed symptomes the temasaitter has drifted in the same direction over two calibration periode sad the first more check of the tramenhter as part of the monthly channel check has shown a continuation of the drift.
Corrective Action takes Although the drift observed was within that sessmed in the setpcint calculation end the transaatter performed normally during its last calibraties. At was replaced.
This transmitter was not subjected to operating pressure for a algaificant persed of time. Therefore it is espected that the cause of tAe observed drif t is something other than a less of f111 011. Newever.
because of the trend of poor perft:1mance and the possibility of (111.o11 leakage the transmitter was replaced. The replacement transmitter wee also manufactured before July 11, 1989 and will therefore be included la no enhanced eurveillance program.
Dispositioni The trantaitter will be returned to Rosemount for a determination l
of the cause of the ebserved drift.
NR* Rerertime Ranuir at dite)
Identifies the safety-related system in which the Model lill or 1134 trancaitters from the asaufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill. oil are utilised and provides a schedule for replacement of these transaatters which are in att in the reactor protection or engineered safety features actuation erstese.
HvY 1memonse there are no Model 1153 or 1184 tranWtters from the menufar turing lete that have been identified by Rosemount as having a high failure fraction due to loss of fill.cil utilised in the reactor protection or engineered safety features actuation systoa. As indicated in NNY's Response to Action de, in Rnclosure 1 there is one installed transmitter, performing an accident monitoring function, from the high failure fraction lote identified by Rosemount. Although this 1
T*
r Neo Naapehire Yankee March it. 1990 EEL 3t&RBh&h i
transmitter has been operating satisietterily and has not omhibited any of the signs of a potentist fill.eil lose condition. NIY has decided to replace it with an available spare trenealtter.
The replacement tranealtter will be installed ufere the cleet of businese en March 14, 1990. The replacement transmitter will be included in the enhanced surveillance program. In addition. MKY has roguested koetasunt to espply a replacement tramenitter outside the Part 11 notification en an expedited beets.
Mit samartime leantr --- :.t di Transaatters that, oubeequent to providing the response required by Ith 1 above.
I omhibit eyaptens of lose of fill.eil or are confirmed to have esperienced a lose of fill.cil sheald be reviewed for reportability under esteting NEC regulations.
+
if determined not to be reportable, addressees are requested to document and maintain in atterdance with plant procedures. information consistent with that regnetted in Item 1 (b) above for each suspect tronomitter identified.
NMY tannenee if a Rosemount Model 1133 or 1134 trancaitter omhibite the eyaptoms of loss of f111 011 er are confirmed to have emperienced a loss of fill. oil this condition vill be reviewed for repertability under esisting NRC regulations.
If it is determined not to be repcrteblo. inforestion consistent with that requested in Iten ib of the Reporting Requirements for operating Reactere of the Draf t tulletin will be documented and maintained in accordance with plant procedures.
G s
4 9
9 TOTnL P.19 9
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New Hampshire Ted C. k,2 :
Senior Vice Prennt and Chief Operehng OHicer NYN-90066 March 13, 1990 United States Nuclear Regulatory Comission Washington DC 20555 Attention: Document Control Desk
References:
(a)
Facility Operating License No. NPF.67. Docket No. 50-443
+-
(b)
NYN-90061 dated March 12, 1990 ' Supplemental Response to Proposed Draft NRC Bulletin or Loss of Fill Oil in Rosemount Transmitters. T.C. Feigenbaum to Document Control Desk'
Subject:
Clarification to Supplemental Response to Proposed Draft NRC Bulletin on Loss of Fill 011 in Rosemount Transmitters Gentlemen As discussed with the NRC Staff in a telephone conversation on March 13 1990, the following clarifies the response to Action #2 Paragraph (a) provided in of Reference (b): The operability acceptance test will be performed at or prior to the time of exceeding the maximum allowable cumulative drif t.
Should you have any questions regarding the enclosed, please contact Mr.
-Terry L.'Harpster at (603) 474-9521 extension 2765.
7 Very yours.
rAA2S gTedy.Feie um cc:
Mr. William T. Russell Regional Administrator United States Nuclear Regulatory Comission Region I i
475 Allendale Road King of Prussia. PA 19406 a
Mr. Victor Nerses. Project Manager Project Directorate I-3 United States Nuclear Regulatory Comission Division of Reactor Projects Washington, DC ~ 20555 Mr. Noel Dudley NRC Senior Resident Inspector P.O. Box 1149 Seabrook. NH 03874 Atomic Safety and Licensing Board Service List New Hampshire Yonkee Division of Public Service Company of New Hompshire P.O. Box 300
- Seobrook, NH 03874
- Telephone (603) 474 9521
New Hampshire gg senisas. e,e.., ea i
CNeiOperahne ONw NYN.90071 March 16. 1990 United States Nuclear Regulatory Coeuniesion Washington, DC 20$$$
i Attention Document Control teek keforencess (a)
Facility Operating License No. NPF.67. Dcchet No. 30 463 i
)
(b)
NYW.90061 dated March 12, 1990. 'Supploesntal Response to Propened Draft NR0 BM 1stin on Loss of Fill 011 in Rosemount i
i transmitters, f.C. FnSenbaum to Document Control Desk' l
Subjects Clarification to Supplemental Respense to Proposed Draf t NRC Bulletin on Loss of Pill 011 in Rosemount Transmittore l
1 Gentiomen Ao discussed with the NRC Staff in a telephone conversation on March 13 1990, the following clarifteetions to Enclosure a of Reference (b) are provided:
In additioc. to the comunitments in the response to Requested Action it itses l
b and c. if a more troquent calibration le required, the transmitter will be time response tested to the operebility acceptance criteria during the subsequent refueling outage.
Also in clarification of the response to Requested Action (3(4), if when &
calibration is performed the IEC technician notes a sluggish response of the tranesdtter, a time response test vill be performed.
Should y0u have any questions regarding the enclosed, please contact Mr.
Terry L. Harpeter at (603) 474 9321. extension 1763.
i l
l Very truly yours.
Q f
Ted C. Folgenbawn 1
New Hampshire Yankee Diviolon of Pubte SeNice Compor'y of New Hompshire P.O. Box 300 * $eobok, NH 03874
- Telephone 403) 474 932) l
- r
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United States Nielear KoguletCry Commitolon March 14, 1990 Attention:
Document centrol Desk Page !
ee:
Mr. William f. Raseell Regional Administrater United States Nuclear Regulatory Commission Region I 473 Allendale Road King of Prussia. PA 19406 Hr. Victor Perses. Project Manager Project Directorate 1 3 United States Nuclear Regulatory Cour.ieston Division of Reactor Projecte Washington DC 20$33 t.'
- Mr. Noel Dudity HRC 8enior Resident inspector P.O. Box 1149 Seatrock. NM D5876 Ator.ie saf ety and Licensing Board Service List 4
9
-. -... ~ -.,,, _. -
t t
i A8kl $ERVICE L2st l
Alan 8. Rosenthat ::hairman Atomit Safety and Licensing Adjudicatory Film Appeal Fanel Atomit lafety and Licensing U.S. Nucisar tegulatery Commission Board Panet Docket (1 copies)
?
i Vasnington. DC 20$$$
U.S. Nuclear tegulatory Commission Washington. DC 20855 themas S. Meere j
Atomic latety and Licensing Philip Ahrene. Require i
Appeal Panel Assistant Attorney General U.S. Nuclear Regulatory Commission Cf fita af the Attorney Seneral State Neuse Station f6 Washingtsn. DC 20$$$
e i
Augusta, MR 04333 5,
Howard A. V11ber Atosie safety and Licensing Ashed W. Amirian, teguire Appeal Panel Assistant City Solicitor U.S. Nuclear Regulatory Commission City of Beverh111 Waverhill. HA 01830 Washington, DC 20$33 l
j C. Paul to11werk. III. Chairman Robert A. Backus. Ioguire Atomit $afety and Licensing laskus. Meyer 8 Solomon Appeal Panel 1*g LDwell Street
'J.S. Nuclear Regulatory Commission P.O. non 516 Manchester. NM 03105 Washington, DC 20555 1
i Atomic Safety and Licensing George Dans liebee. Esquire Appeals leard Panel Assistant Attorney Generet U.S. Nuclear Regulatory Cosmission Cffice of the Attertty Central 25 Capitol Street Washington. DC 10885 Ccatord. NN 03301-66397 Ivan W. Smith. Chairman Atomic Safety and Licensing neard Diane Curran, taquire Penel Andrea C. Forster. Require U.S.* Nuclear Regulatory Commission Marasa, Curran 6 Tousley 2001 8 Street. N.V.
suite a30 Vashington. DC 10355 Washington, DC 20009 1125 Robert R. Pierce. Esguire Mr. Jack Dolan Atomic Safety and Licensing leard Panel Federal Emergency Management Agency Region I U.S. Nuclear Regulatory Coussission Vashington, DC 20$$$
J. W. McCormack Post Office 4 Courthouse Suilding. Room 442 letton HA 02109 Acain. Judge Kenneth A. McCollos.
Member 1107 Vest Xnapp Street Mr. Richard R. Denevan Stillwater. OK 74075 Federal toergency Management Agency Federal Regional Center Richard F. Cole ISO 228th Street. 3.W.
Atomic Safety and Licensing leard 30thell. Washir.ston 90011-9796 Panel U.S. Nuclear Regulatory Commission Vashington, bc 20535
A$'S $5VICE L157 tutanne P. tgan. City sclietter Judith 8. Mitner. Esquire t
Lagoulle. Hill.Vhilton 6 78 State Street.
L totendi locona fleer 79 State Street Newburyport. HA 01930 Wewburyport. NA 01980 larbeta J. Saint Andre. Esquire M. Joseph 71ynn. Require Ecpelman and Paige. P.C.
Office of General counsel 77 Freak 11a street l
Federal Emerlency Hanagement Agency Scoton. MA 01110 100 C Street. SW Vashington DC 10472 Jctr. Traficente, tequire Assistant Attorney General
- k. Scott Will.Whilton. Esquire Cffice of the Attorney General I
Latoulie. Clark. Bill.Whilton Cr.e Ashburton Place 19th rioet t
+
& notondi Scoton, MA 01104 79 State Street l
Newburyport. NA 01980 Mital A Young. Esquire Edwin J. Reis. Require Gary V. Helmes, seguire Cffice of General Ceunsel Holmes & tile U.S. Nuclear Regulatory Commissien af Vinnacunnet Road Washington, DC 10333 Maapton, NH 08868 senator Corden J. Humphrey*
United Statee Senate Washington, DC 20$10 Attentions ten turack Senator Cordon J. Numphrey*
1 Eagle Square. Suite 307 Concord. NH 03301 T
Attentions Mary Jane Colton George Iverson DLrector N.M. Office of Energency Management State Mouse Office Park South 107 Pleasant Street
=
Concord NH 03801 Paul Hetachera. Require t
Hatthew T. Brock, teguire
$haines & McEachern 28 Haplewood Avenue. F.C. 80s 380 Pertemouth. NN 03801
- 1etter enly TOTAL P.05
ri p
i l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-443 OL o
PUBLIC SERVICE COMPANY OF
)
50-444 OL
,2 NEW HAMPSHIRE, g d.
o (Seabrook Station, Units 1 and 2)
)
l NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.
In accordance with 10 C.F.R. 62.713(b),the_followinginformationisprovided:
Name:
Charles A. Barth Address:
U.S. Nuclear Regulatory Commission Office of the General Counsel Washington, DC 20555 o
Telephone Number:
(301)492-1589 Admission:
Supreme Court State of Indiana United States Court of Appeals.
Seventh Circuit United States Supreme Court Name of Party:
NRC Staff Respectfully submitted, Ah&
Charles A. Barth Counsel for NRC Staff Dated at Rockville, Maryland this 13th day of March, 1990
l l
000KliED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'90 ftAR 15 A9:11 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BQ4RD U0CbbchshMY-In the Matter of aRAscq Docket Nos. 50-443 PUBLIC SERVICE COMPANY OF 50-444 i
NEW HAMPSHIRE, g al.
)
)
i o
(SeabrookStation, Units 1and2)
)
l CERTIFICATE OF SERVICE i
)
I hereby certify that copies of "NRC STAFF RESPONSE IN OPPOSITION TO F
INTER'JENORS' MOTION TO THE APPEAL BOARD TO RE0 PEN THE RECORD AND ADMIT A LATE FILED CONTENTION REGARDING ROSEMOUNT TRANSMITTERS" in the above captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk,.by deposit in the Nuclear Regulatory Commission's internal mail system, as indicated by double asterisks, by express mail, this 14th day of March 1990:
IvanW. Smith, Chairman (2)*
Peter Brann, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission State House Station 6 Washington, DC 20555 Augusta, ME 04333 Richard F. Cole
- John Traficonte. Esq.**
l Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Coninission One Ashburton Place,19th Floor Washington, DC 20555 Boston, MA 02108 i
Kenneth A. McCollom**
Geoffrey Huntington, Esq.**
l Administrative Judge Assistant Attorney General 1
l 1107 West Knapp Street Office of the Attorney General L
Stillwater. OK 74075 25 Capitol Street L
Concord, NH 03301 Thomas G. Dignan, Jr., Esq.**
Robert K. Gad, III, Esq.
Diane Curran, Esq.**
Ropes & Gray Harmon, Curran & Tousley l -
One International Place 2001 S Street, NW l'
Boston, MA 02110-2624 Suite 430 Washington, DC 20009 1
i i
t -
)
l
-2, l
4 Robert A. Backus,'Esq.**
Jack Dolan Backus, Meyer & Solomon Federal Emergency Management Agency j
116 Lowell Street Region I Manchester, NH 03106 J.W. McCormact Post Office &
fourthouseBu'.1dinge Room 442 Boston, MA 02109 H. J. Flynn, Esq.
Judith H. Mizner, Esq.
t o
Assistant General Counsel 79 State Street Federal Emergency Management Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Robert Carrigg, Chairman Board of Selectmen Paul McEachern, Esq.**
Town Office Shaines & McEachern Atlantic Avenue 25 Maplewood Avenue North Hampton, NH 03862 P.O. Box 360 Portsmouth, NH 03801 Mrs. Anne E. Goodman, Chairman Board of Selectmen George Hahn, Esq.
13-15 Newmarket Road Attorney for the Examiner Durham, NH 03824 1
Hahn & Hesson 350 5th Ave, Suite 3700 Hon. Gordon J. Humphrey New York, NY 10118 United States Senate 531 Hart Senate Office Building R. Scott Hill-Whilton, Esq.
Washington, DC 20510 Suzanne P. Egan, Esq.
Lagoulis, Hill-Whilton
& Rotondi Richard R. Donovan 79 State Street Federal Emergency Management Agency l
Newburyport, MA 01950 Federal Regional Center l
130 228th Street, S.W.
l Allen Lampert Bothell, Washington 98021-9796 Civil Defense Director l
Town of Brentwood Peter J. Matthews, Mayor 20 Franklin City Hall l
Exeter, NH 03833 Newburyport, MA 01950 L
William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter, NH 03833 South Hampton, NH 03827 10 Front Street Exeter, NH 03833 Ashod N. Amirian, Esq.
Town Counsel for Merrimac i
Gary W. Holmes, Esq.
145 South Main Street Holmes & Ellis P.O. Box 38 47 Winnacunnet Road Bradford, MA 01835 Hampton, NH 03842 Barbara J. Saint Andre. Esq.
Kopelman and Paige, P.C.
77 Frankin Street Boston, MA 02110
Ms. Suzanne Breiseth George Iverson, Director Board of Selectmen NH Office of Emergency Management Town of Hampton Falls State House Office Park South Drinkwater Road 107 Pleasant Street Hampton Falls, NH 03844 Concord, NH 03301 Atomic Safety and Licensing Robert R. Pierce. Esq.*
Board Panel (1)*
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission o
. ~..
Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Secretary (2)*
i U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, DC 20555 Appeal Panel (6)*
Attn:
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555 Charles A. Barth Counsel for NRC Staff
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