ML20012C712
| ML20012C712 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/13/1990 |
| From: | Beuchel B YANKEE ATOMIC ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20012C709 | List: |
| References | |
| REF-PT21-90, RTR-REGGD-01.097, RTR-REGGD-1.097 IEB-90-001, IEB-90-1, IEIN-89-042, IEIN-89-42, OL, NUDOCS 9003230098 | |
| Download: ML20012C712 (52) | |
Text
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p 6-s March 13, 1990 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
before the j
ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL-NEW HAMPSHIRE, et al.
)
50-444-OL
)
(Seabrook-Station, Units 1 and 2)
)
(Off-site Emergency
)
Planning Issues)
)
AFFIDAVIT OF BRUCE E.
BEUCHEL I,
Bruce E.
Beuchel, hereby depose and say as follows:
1.
I am the Instrumentation and Controls Engineering Supervisor in the Plant Engineering Department at Seabrook Station.
I am employed by Yankee Atomic Electric Company.
My group's primary responsibilities include the preparation of design change packages, preparation of engineering evaluations and responding to-requests for engineering-services in the area of instrumentation and controls at Seabrook Station.
A statement of my professional qualifications is attached and marked as "A".
2.
I am the engineer at Seabrook Station-responsible for the evaluation of *.he safety' significance of the 10 CFR Nhh G
F 21
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21 Notification made by Rosemount concerning their Model 1153 and 1154 transmitters.
I also have the responsibility to develop the technical response to NRC Bulletin 90-01.
I have followed'the. issue closely since being informed of the concern in December of 1988.
I have been in close k
communication with Rosemount over this entire-period.
I have attended briefings on this subject at Yankee Atomic Electric Co.'("YAEC") by Rosemount and Electric Power Research Institute ("EPRI") and at an Instrument Society of America
("ISA") meeting by a representative from Northeast Util,'. ties, I or my representative have also attended the briefingr for the.NRC by Rosemount on this subject in August of 19r,9 and December, 1989.
I have reviewed the Technical Bulletins and letters to Seabrook from Rosemount on this issue and have received and reviewed material from other industry presentations on this subject.
I am aware of the activities I
l-g of.the BWR Owners Group concerning Rosemount transmitters.
I r
have read and am aware of the contents of NRC Information Notice 89-42, the proposed draft.NRC bulletin on Rosemount 1~
transmitters and NRC Bulletin 90-01.
I prepared a-preliminary evaluation on this subject shortly after the original notification.
I also developed the guidelines from which the present Seabrook enhanced surveillance program are-I' based.
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3.
'The purpose of my affidavit is to address the Intervenors' allegations and affiant Minor; and to provide some factual information for the Board's use in determining whether a significant safety issue is present.
4.
In a letter dated February 7, 1989, Rosemount, Inc.
informed New Hampshire Yankee ("NHY"), pursuant to 10 CFR 21, of a potential defect involving some manufacturing lots of its Model 1153 and 1154 transmitters.
These' transmitters
-have been since referred to by the NRC Staff in the proposed draft bulletin and Bulletin 90-01 as the transmitters from manufacturing lots which have a high failure fraction.
The potential defect involved the possible loss of fill fluid (referred hereinafter as fill-oil) from the transmitter sensing module due to internal leakage.
This condition may cause a slowly responding or drifting transmitter.
At that time the reported failures had occurred within the first 30' months of operation and Rosemount believed that the existing-data indicated, but did not confirm, that such failures after 36 months of' operation are unlikely, o
Subsequently in'a-letter dated May 10,-1989, the original 10 L
CFR 21 notification was expanded.to include all Model 1153 B and D and 1154 transmitters.
In a letter dated September 8, L
l 1989 Rosemount advised that as of July 11, 1989, the loss of L
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. fill-oil notification no longer applied to new production units.
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5.
Upon receiving the initial notification, NHY in.
- g accordance with Station procedures, evaluated the issue for its applicability to Seabrook Station.
As part of the notification, Rosemount identified the serial numbers of the transmitters from the high failure fraction lots which it had shipped to Seabrook Station.
From this it was determined-that there was one inservice transmitter from the high failure fraction lots.which had not exhibited any of the then known symptoms associated with a loss of fill-oil and had been operating satisfactorily.
This transmitter continues to operate satisfactorily.
This transmitter does not perform an-actuation function but is used for indication of Condensate Storage Tank level which is a Regulatory 1.97 Guide Design Category 1 variable.
Although this one-transmitter from the high failure fraction lots has been operating satisfactorily
.and has not exhibited any of the signs of a potential fill-oil loss condition, NHY has decided to replace it. -The replacement. transmitter will be installed before the close of business on' March 14, 1990.
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<5.
Three (3) spare transmitters from.the high failure.
faction lots were identified and were returned to Rosemount for: replacement of the sensing modules.
As part of this-p review NNY also identified all the Model 1153B and D and 1154 t'
transmitters installed at Seabrook Station.
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7.
When NHY received the May 10, 1989 supplemental
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notification from Rosemount, as indicated above, the 61 inservice Rosemount transmitters involved, including the one discussed above in Paragraph 5, had already been identified.
Upon receipt of the notification NHY developed an action plan for evaluating the inservice transmitters.
Since the problem with potential fill-oil loss occurs slowly over time, NHY's action plan to address the concerns. raised included a special calibration program, transmitter performance trending, and replacement of spare Rosemount Model 1153 and 1154 transmitters on a schedule which is consistent with the support of station activities.
8.
The above is reflected in USNRC Inspection Reports 50-443/89 (dated 3/30/89) and 50-443/89-13 (dated 1/9/90),
USNRC Information. Notice No. 69-42 (dated 4/21/89), USNRC Bulletin No. 90-01 (dated 3/9/90) and NHY Letters NHY-90056
- (dated 3/8/90).and NYN-90061 (dated 3/12/90).
Excerpts from the Inspection Reports and a copy of NYN-90061 are provided as
Attachment:
B, C,
and D respectively.
9.
Following receipt of the proposed draft bulletin NHY undertook a review, under my supervision, to determine'if the scope-of the proposed draft bulletin identified additional installed transmitters which were performing a' safety-related or ATWS related function.
This review identified all j
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applications which-used Model 1151, 1153 and 1154 Rosemount transmitters and which used original equipment manufacturers' l
transmitters, for the manufacturers' identified in the
. proposed draft bulletin, which may have used Rosemount parts or have been manufactured by Rosemount.
The results of that review, as provided in Attachment D, are that there are no
-Model 1152 transmitters, there are no installed Model 1151 transmitters which perform safety-related or ATWS related functions.
Also there are no other original equipment manufacturers' transmitters, containing Rosemount parts or that were manufactured by Rosemount, which perform safety-related or ATWS related functions.
10.
All 61 installed Model 1153 and 1154 Rosemount transmitters were purchased directly from Rosemount, Inc.
i' Rosemount has indicated that they have not supplied _Model 1153 or 1154' sensing modules to other manufacturers.
Therefore there was no need to determine if the 61 installed transmitters were provided by an unauthorized remanufacturer l-or refurbisher.
This was further verified by Rosemount and l
NHY confirming the serial numbers of the installed transmitters with Rosemount's records of the units shipped to l
Seabrook.
11.
The NRC subsequently issued Bulletin 90-01 concerning loss of fill-oil in transmitters manufactured by Rosemount.
Bulletin 90-01, among other things, does not.
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require a Licensee to take action regarding Model 1151 or 1152 Rosemount transmitters as did the proposed draft bulletin.
However, since NHY's prior evaluation concluded that there were none of these transmitters performing safety-
'related or ATWS related function, the difference is of no practical consequence.
12.
The. issued and proposed bulletins require the replacement of two categories of Rosemount transmitters:
subject Model 1153 and 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to the loss of fill-oil which are used in the reactor protection system ("RPS") or engineered safety features actuation system ("ESFAS"), or subject Model 1153 and.1154 transmitters which are not from a high failure fraction lot but which exhibit the symptoms indicative of fill-oil loss, that do not conform to the established operability acceptance criteria and.that are not addressed by the action statements in the Technical l'
Specifications.
Proposed Bulletin, Requested Action
- 5 at 6-7 and Issued Bulletin, Requested Action #5 L
l at 7.
L 13. - Intervenors' Motion at 5 states that Applicant's corrective action plan is inadequate because it does not l l'
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9-I address Model11151 or-1152 Rosemount transmitters or original equipment manufacturers who may have used Rosemount transmitters or parts.
Intervenors' statements appear to 1
-incorrectly assume that the action plan. described in Inspection Report 50-443/89-13 was the action plan to address-the proposed draft bulletin.
This could not be the case because the proposed draft bulletin had not even been released for comment.
As indicated in that inspection report, the plan described-therein was to address transmitters which were the subject cf the Part 21 notification.
The proposed draft bulletin appeared to be considering expanding the scope of review to include transmitters which had not been the subject of Rosemount's Part 21 notification.
It should be noted that Bulletin 90-1 01 did not.'
14.
Intervenors' Motion at 6-7 claims that the issue is of' safety significance because:
(1) it raises serious questions with regard to the adequacy of environmental qualification; (2) the reliability of equipment has been called into question; (3) the, failure may not be detectable l
through plant monitoring; (4) there are unknown number of Models 1151 and 1152, as well as Rosemount transmitters or.
transmitter parts that may be installed under different manufacturers' labels; (5) some of the known applications are I
safety related; and (6) other applications are unknown.
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would appear that the statements in the Motion rely on d
statements made in the Minor Affidavit at Paragraphs 6-11.
The following addresses these claims.
15.
In regards to the unknown' numbers and applications, items (4), (5) and (6) from Paragraph 14 above, it would appear that the basis for this allegation is as stated by Minor "New Hampshire Yankee has not produced a publicly available list of each Rosemount application.
Minor Affidavit at Paragraph 9.
l 16.
As indicated in Attachment D and as discussed.above in Paragraphs 5-10, an extensive review of plant records.was performed.
This review identified all the applications of the transmitters which are the subject of the proposed draft bulletin.
The review concluded that only 61 installed Model 1153 and 1154 Rosemount transmitters were in safety-related or ATWS related applications.
Thus, all the transmitters and-their applications are known.
17.
The claim that there exists an environmental i
qualification issue,. item (1)-from paragraph 14 above, is without merit.
As described-in the referenced Inspection Reports, Rosemount's Part '1 Letters, the proposed draft bulletin,Bulletin 90-01, and Information Notice 89-42, the fill-oil loss failure mechanism has been attributed to the manufacturing process prior to July 11, 1989.
The available information indicates that the process fluid operoting = ---2--
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' pressure may have an'effect on the time before a transmitter might fail.
This information does not indicate-that the environment the transmitter is exposed to is a failure mechanism for tne sensing module.
- 18. 'In regards to'the reliability of equipment, item (2) from paragraph 14 above, it would appear that the basis for this is Minor's conclusion that the potential for Rosemount
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transmitter failures undermines confidence in Seabrook's ability to comply with requirements for adequate levels of' reliability.
Minor Affidavit at Paragraph 10.
19.
In general terms, reliability is an indication of the availability of a transmitter to perform its function-within the required performance specifications.
In sum, it is a prediction of a transmitter's failure rate and a prediction of the repeatability of a transmitter's readings.
t 20.
I would be incorrect to presume from the proposed draft bulletin-or Bulletin 90-01, the current literature or information from Rosemount that these transmitters are predicted to fail.
Rather the-literature and these bulletins l
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' indicate that Model 1153 B and D and 1154 Rosemount transmitters manufactured prior to July 11, 1989, appear to be susceptible to loss of fill-oil due to a glass to metal seal' failure.
It would also appear'from this information that some of these transmitters (i.e., those from the high 1:
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s failure faction lots) may be more susceptible than the.
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.others,
- 21.. In Rosemount Report D8900115 Rev. A the following information was provided.. Rosemount has shipped over 14,000 Model 1153B and D and 1154 transmitters and has information regarding the number of transmitters which have a confirmed fill-oil loss failure.
In February, 1989 approximately 1,000 transmitters had been shipped from the lots referred to as e
the high failure fraction lots, of which 62 transmitters had confirmed fill-oil loss failures.
Of the 13,000 shipped transmitters from the other manufacturing lots only 24 transmitters had confirmed fill-oil loss failures.
22.
As indicated in Attachment D and as discussed in paragraph 5 above, the only installed transmitter from a high failure fraction will be replaced.
As also indicated in Attachment D and discussed below in paragraph 30, the only transmitter which is exhibiting symptoms indicative of a potential fill-oil loss condition, has been replaced.
Therefore, with the replacement of the two transmitters the installed transmitters at Seabrook Station should have a predicted failure rate on the order of 0.2% or less.
l Westinghouse has determined that a higher failure rate, i.e.
5% failures over a three-year period, does not affect their l
I calculations on the unavailability of the reactor trip l
functions.
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.x 23.
Based on information from Rosemount all of the transmitters providing input into RPS or ESFAS are from-
- manufacturing _ lots which have not had a confirmed fill-oil failure (i.e. a failure rate of 0%).
24.
As discussed below, an enhanced surveillance program, which includes a monitoring and trending program,
- has been established at Seabrook Station.
The primary purpose of this program is to provide'the means to detect a potential fill-oil loss condition.
This trending and i
i mon tor ng program assesses, weekly or monthly, the performance of the installed transmitters.
This continuing assessment and trending of transmitter provides additional assurance that the reliability of the 61 installed transmitters'is being maintained.
2 5. - In regards to the detectability of a failure, item i
(3) from paragraph 14 above, it would appear that the bases for this are:
that it is difficult if not impossible in some cases to detect a failure during operation; and that it is possible for these transmitters to fail without detection of the trends identified _by-Rosemount.
Minor Affidavit at t,
Paragraph 8.
As discussed below, the enhanced surveillance
- program will detect the trends identified by Rosemount which are indicative of the symptoms of a potential-fill-oil loss condition prior to the transmitter becoming incapable of
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performing its safety function.
Therefore, this program is capable of. detecting.a failure during operation.
26.
The failure mechanism allows the fill-oil to leak out of the sensing module.
This loss of fill-oil is a very small leak occurring over a long period of time.
This causes
)
a-gradual change in the performance of the transmitter.
The testing information available from Rosemount shows that f
transmitters with this failure mechanism will exhibit a sustained drift-(i.e. a drift in the same direction) prior to it being incapable of. performing its intended function.
27.
Therefore, given the long period of time required for the accumulated fill-oil losses to lead to a degraded condition and given that this condition causes a sustained V
drift prior to degradation,.an enhanced surveillance program.
1' was established at Seabrook Station to detect a potential l
fill-oil loss condition for the 61 identified Rosemount g
1 transmitters.
i This program was initiated prior to the issuance of the proposed bulletin,-as described above in i
paragraph 7 and has been further enhanced as discussed below
^
in paragraph 33.
28.
As indicated in Attachment D, as part of the l
program, NHY has; reviewed available calibration data since January,-1987; began periodic channel checks-for transmitter drift,'and performet a special calibration of thene l'
transmitters starting in November, 1989 prior to starting the l
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power ascension test program.
These special calibrations l
included' observation for a sluggish response and an over-j range test of selected transmitters to ensure that the
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transmitter was capable of responding over its full range.
I 29.
Prior to performing these special calibrations the I o
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& C technicians were made aware of the symptoms of potential fill-oil loss, including that a transmitter could exhibit a sluggish response during its calibration.
No transmitter,
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including the one from the high failure fraction lots, was identified as having a sluggish response or being incapable of being calibrated (i.e. incapable of performing its safety function).
30.
The calibration reviews have been completed and the l
channel checks initiated.
Only one of the 61 identified
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transmitters has' exhibited the symptoms of a potential fill-f L
oil loss.
This transmitted exhibited symptoms of drifting in the same direction.
In this regard it should be noted sustained drift in the same direction is an indication that there may be a leak, not confirmatitt that there is a loss of f
fill-oil due to a glass to metal seal failure.
NHY,'as explained below, has since replaced this transmitter.
l 31.
As indicated in paragraph 30 above, one transmitter has exhibited a sustained drift indicative of a potential fill-oil loss condition.
However, as also indicated above in
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response during its recent calibration and was capable of being calibrated so it could perform its safety function.
32.
Even though this transmitter had not been confirmed as having a fill-oil loss due to a glass to metal seal failure and had been capable of performing its safety function, for plant operational reasons this transmitter was replaced.
In accordance with NHY's program, this transmitter was removed from service and will be sent to Rosemount for testing and evaluation to determine the cause for the transmitter's sustained drift.
33.
Since the issuance of Inspection Report 50-443/
89-13, NHY's program has been further enhanced based on additional information frem Rosemount, information in the proposed draft bulletin, and discussions with the NRC Staff.
The enhanced surveillance program now contains the following elements discussed in more detail in the referenced enclosure and NHY response from Attacnment D Enhanced transmitter monitoring program to identify sustained drift indicative of the subject concern (See Attachment D, Enclosure 1 Response to Action 13, paragraph b)
Trending program to evaluate transmitter performance based on input from routine calibration activities and on input from the enhanced monitoring program a
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[See Attachment D, Enclosure 1, Response to Action
- 2) i Qualitative response time testing in routine calibration activities (See Attachment D, Enclosure 1, Response to Action #3, paragraph d)
'l Prescribed operability acceptance criteria for a transmitter which is identified as having a-potential fill-oil loss condition.
(See l
Attachment D, Enclosure 1, Response to Action #3, i
paragraph f) l Ensuring that appropriate personnel, such as I&C technicians, are aware of the symptoms and the need for prompt identification of transmitters which might be exhibiting these symptoms (See Attachment D,, Response to Action #3, paragraph a) 34.
The enhanced surveillance program described above in i
paragraph 33, uses techniques and equipment wnich are capable of observing and identifying the s'ymptoms that are associated with a potential fill-oil loss condition (e.g., the drifting caused by the gradual and slow loss of fill-oil).
35.
Therefore, the. enhanced surveillance program as described above is capable of detecting a potential fill-oil loss condition before the transmitter's performance degrades to the point that it would no longer be capable of performing t.
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i its safety function.
This program satisfies the requirements
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of the proposed draf t Bulletin 90-01, GDC-21 and 10 CFR i
50.55a(h).
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36.
Based upon the foregoing it is my opinion that no significant safety issue arises at Seabrook from the so-
]
called " defective Rosemount Transmitter" problem.
I l
i uw Y by f
Bruce E. Beuchel l
COMMONWEALTH OF MASSACHUSETTS Suffolk, ss.
March 13, 1990 Then appeared before me the above subscribed Bruce E.
1 Beuchel and made oath that he had read the foregoing affidavit and that the statements set forth therein are true o
l to the best of his knowledge.
Before me, Wm s,,
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fotary Publuc *
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My M ulon Expires: 1./At/9j l
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W l%'s% t s'..,
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!L, ATTACHMENT A BRUCE E. BEUCHEL SENIOR ELECTRICAL ENGINEER EDUCATION BS Marine Engineering, United States Naval Academy, 1975.
I am presently employed by Yankee Atomic Electric Co. and am filling the position of Instrumentation and Controls Engineering Supervisor on the NHY Plant Engineering Department Staff.
I have been in this position for 15 months.
I presently supervise eight engineers and 3 designers.
My group's primary responsibilities are the preparation of all of the design change packages for the station and responding to requests for engineering services in the area of instrumentation and controls.
I joined Yankee Atomic Electric Company in March, 1985 as a Senior Engineer in the Instrumentation and Control Engineering Group of the Seabrook Project Department.
This position involved performing engineering evaluations and preparing engineering design changes involving a broad spectrum of instrumentation and control systems for Seabrook Station. I came to Yankee Atomic Electric Company from General Electric Company where I was employed from September, 1984 to March, 1985.
During this period of time I was in training for and received a Senior Reactor Operator Certificate from the General Electric Company for a Boiling Water Reactor.
I also spent two months as a start-up test engineer at the Shoreham Nuclear Power Station.
Prior to this I was employed by Public Service Company of New Hampshire at Seabrook Station as a Senior Engineer in the field of instrumentation and controls.
One of my collateral duties was the development of the station work control program.
Between 1975 and 1980 I was a Commissioned officer in the U.S. Navy where I went through the nuclear power training program, was assigned as a division officer on a nuclear powered submarine and completed the qualifications to be assigned as an Engineer on a nuclear-powered submarine.
I an a member of the American Nuclear Society and the Instrument Society of America ("ISA").
I am the Chairman of ISA Standard committee SP 67.15.
This committee is preparing recommended practice RP 67.04, Part II
" Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation."
i
I an an active member of ISA Standard Committee SP 67.04, "Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants."
I an also a member of the Nuclear Power Plants Standards Committee for ISA (SP 67).
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An10tu2n B WieD states
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'I NUCLEAR REGULATORY COMMI55 TON i
ReQICN I i,q
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478 ALLENDALE ROAD KINO QF PRL'sstA. PENNsYLVAN'A 1940%
Cocket No. 50-443 Public Service Comoany of New Hampshire ATIN:
Mr. Ec.ard A. Brown Presicent and Chief Executive Officer New Hampshire Yankee Divisten Post Office Box 300 Seabrook, New Hampshire 03B74 Gentlemen:
Subject:
NRC Region 1 Inspection Report No.
50-443/E9-01 This refers to the routine resicent safety inspection c:ncyctec cy February 27, 1959, at tre Mr. O. Ruscitto of tnis effice :n January 10 Seabrook Station, Unit No. 1, Seacreck, New kampshire.
The ins ecti:n c e r.-
sistea of eeservations of activities, interviews with personnel, anc selective examination of procecures and representative records..The results :f the inspection are cescribed in the NRC Region I Inspection Report enclosed with this letter and were ciscussec with Mr. D. Moody and others of your staf f af ter the conclusion of the inspection.
Within the scope of this inspection, no safety significant violati:ns were observed.
In accorcance with 10 CFR 2.790 of the NRC's " Rules of Practice", a Opy of this letter and the enclosure will te placec in the NRC Putlic Document Room.
Youe cooperation with us is appreciatec.
Sincerely, hl 0
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v 04ree s T.
iggins,<' ief
@ ctor Projects ranen No. 3 Division of Reactor Projects
Enclosure:
NRC Region i Inspection Report No. 50-443/E9-01 i
U. S. NUCLEAR REGULATORY COMvlSSION Recien 1 Report No.:
50-443/Bg-01 Docket No.:
50-443 License No.:
NPF-56 Licensee:
Dublic Service Company of New Fam: shire 1000 Elm Street Manchester, New Hampshire 03105 Facility:
Seabrock Station, Unit No. 1 Location:
Seabrcok, New Hampshire Cates:
January 10 ebruary 27, Ig!;
Insoector:
D. G. Ruscitto, Senior Resident Inspector I
Approved By:
C/ k /cw L d 3ho/f4 Donalc R. nevertamp, Chief D&te Reactor Projects Section Ho. 3C Inseection Summary:
a.
Areas Inseected Routine inspection by the Senior Resident inspector. Areas of inspection included operational safety, design changes and modifications, licensee reportable events and station information reports, maintenance, training and licensee actions on previous inspection findings, b.
Inspection Resuits An unresolved item regarding a deficiency in storing the diesel engine-driven cooling tower makeup pump was identified by the inspector.
The pump was not being stored in a seismically designed building and therefore did not meet the tecnnical specification requirements wnen previously entering Moce 4 (paragraph 3.a).
A second incidence occurred of damage to a primary auxiliary builcing coor due to excessive dif ferential pressure. Additional licensee attention t:
preventing recurrence of this or similar incidents is warranted (para;rasn 3.b).
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,.-..--,,.----,--M
e, InspectionSummary(Continued) 2 s.
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'The thermal / hydraulic response of " bottled up" main steam lines continues to present operational problems. During this ins:ection a fetcwater 150-lation occurred, the third ESF actuation relate: to steam line pressure i
It appears that.. corrective - actions for such incidents are l
viewed on an-isolated case basis.
Future.similar occurrences as well as i
incicents such as the previously reported reactor coolant system / refueling water. storage tank sluicing warrant a more temprehensive root cause analysis than'these have received (paragraph 4.a),
t i
The report of the NHY Independent Review Team ccncerning;the meteorolog-ical tower Unusual Event was thorough and insightful.
The scope of ~ the
.- f initial ' event was expanced and several-useful lessons were' learned that -
might otherwise have been lost, The performance cf the IRT continues to l
be a strength at $eabrook (paragraph 4.b).
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f we TABLE OF CCNTENTS
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once l-.
. Persons Contactee.........................................
1
-1.-
- t h
10 S umma ry o f Fa c i l i ty a nd N RC A:*.1 vi t i e s'......................, -
1, n-4.
Resident Inspect:r Activities.....................
1 b.
Visiting Inscect:r Activities..........................
1 4
s b
c.
Plant Status............
1-9 3.
Operational-Safety........
1-
?'
Plant Inspection Tours (IP 71707)*....................
I a.
b.
0:erational Events (:P 93702)......................,
3 L
4 Li cen see Repo rt s ( I P 52700)................................
_4 F-a.
Licensee Event Reoort 88-003: Feedwater. Isolation......
4 i
b.
Licensee Event Reoort 56-010: Meteorological
?
Monitoring Tower Instrument Power Failure...........
6
?
c.
10 CFR 21 Report'!S-00-03: Qualification of Agastat E
7000 Series Ti.te Celay Relays........................
7 b
5.
Followup Issues-(IP 92701)...................................
9-a.
Rosemount Transmitter Potential Failures...............
9 b.
Limitorque Melamine Torcue Switch Failures.............
9
.c.
Environmental Osalification of RG-SB Coaxial Cable.....
9 d.
Residual Heat Removat System Valve Limit Switches.....
_10 e,
-Containment Evilding Spray Sump' Level Indicators.....
10 f.
Radiation Monitoring System Database....................
10 6.
' Design Changes and Modifications (IP 37828).................
11-a.
Eme rgency Feecwa te r. Sy s tem..............................
11
(
b.
Containment Building Spray Pump Suction Piping.......
11 7.
Maintenance (IP 62703)......................................
'll p
i a.
M0 VATS _ Testing of Service Water valves.................
11 b.
Main Steam isolation Valve Actuators...................
12 I
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1 kj Tab 1'e of Centents~(Continued)'.
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T r a i n i n g ( I P 414 00 ) e.......................................
23 l
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Simulator Training for Startup Quality Control Inspectors..'.......................
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Plant Systems Training for Tecnnical. Staff............-
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-Startup: Test' Personnel Qualifications ~and Training.....
13_
. 9: - Management Meeting s - (IP : 30702)............................:.
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_ guidance is. listed for each applicable report section.
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a.
Rosemount Transmitter Eetential Failures.
In a letter dated February 7,1959 Rosemount, Inc. informed NHY of a potential defect pursuant to 10 CFR 21. The cefect involves a loss of fill fluid f rom the transmitter sensing module cue to intertal leakage.
This condition may cause a slowly resconding or drif ting transmitter prior to detectacle f ailure. Recorted failures to date have occurred within tne first 30 months of service and Rosemoun believes that the existing data in:1cate but do not confirm that transmitter f ailures af ter 36 months of operation are unlikely. A records check by NHY personnel revealed two affected transmitters onsite.
One was a spare locate: in storage and the other is installed in the emergency feecwater (EFW) system.
The transmitte-in st:res will be returnec to Rosemount. The EFW transmitter will te recaldtrated; Since it has oeen in service greate than 36 ontns with no detectable problem, it will be used if the calibration is satisfa: tory. Once Rosemount c:moletes their more detailed analysis on the acceptability of the 36-month time restriction, NHY will re-evaluate the acceptability of the EFW transmitter.
If at any time the instrument cannot De calibrated or exhibits sluggish or otnerwise abnormal response, it will be replaced.
While licensee activities in this area appear well directed, this item is subject to subsecuent NRC inspection pending Rosemount evaluation of the 36-month time restriction, b.
Limitoroue Melamine Toroue Switch :ailures.
On November 3, 19BS, limitorque Corporation notified Yankee Atomi:
Electric Company (YAEC) of a potential defect in melamine tor:ue swit:nes in certain Limitoroue valves.
The YAEC cuality assurance department advised NHY of the relevant information and a review was conou:ted at Seabrook.
Engineering evaluation 89-004 issuec en FeDruary 14, 1989, concluded that certain Limitorque valve motor operators at Seabrook could possibly contain these torque swit:hes.
The environtrental qualification files for 110 operators were eneckee by NHY tecnnical personnel, who verified that no operators had i
melamine torque switches. Spare parts from storage were also enecked with negative results. Additionally, the subject switches are being added to the restricted material listing to preclude future pro:ure-ment of similar equipment containing melamine switches.
Licensee action on this issue was thorough and timely.
c.
Environmental Qualification of RG-53 Coaxial Cable On January 17, 1989, the Atomic Safety and Licensing Appeal Boar:
(ASLaB) issued a Memorantum and Order ( ALAB-909) which af firre: a L
prier Memorandum and Occer (LEP-BB-31) issued ey tne Atomic Safety and Licensing Board.
The ASLAB noted an uncertainty with res:ect o observance of the color-cocing scheme of the twelve RG-59 caoles wnich were installe: by the licensee to replace the RG-53 C A:'es l
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Ta NUCLEAR REOULATORY COMMSSON nsOION I
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478 ALLENDALE ROAD eONO OF PRUS$1A PENNSYLVANIA 1Daol i
Docket No. 50 443 0I18 Public Service Company of New Hampshire ATTN: Mr. Edward A. Brown Presicent and Chief Executive Officer New Hampshire Yankee Division Post Office Box 300 Seabrook, New Hampshire 03874 Gentlemen:
Subject:
HRC Region 1 Inspection 50-443/E9-13 (10/11/89 - 12/11/S9)
This refers to the above subject safety inspection at the Seabrook Station, Unit No.1. Seabrook, New Hampshire.
Aspects inspected includec operational-i Safety. ESF system walkcowns, reportable events, open items and event follow-vo, the Containment Integrated Leak Rate Test, quality assurance activities, security controls and plan implementation, and design modification activities.
The results of the inspection were discussed with Mr. O. Moody and other mem-bers of your staff.
Two violations of HRC requirements, identified by your staff, were reviewed.
One involved failures to follow maintenance procedures; the other involved non-compliance with technical specification action statements. These violations are not being cited because the criteria specified in V.G of the NRC Enforce-ment Policy (10 CFR 2, Appendix C) have been satisfied. However, management attention to potential root cause relationships between these violations and other procedural or personnel errors is warranted.
No reply t,o this letter is required. Thank you for your cooperation.
Sincerely, W Q, f Y-Jon R. JoYnson, Chief Projects Branch No. 3 i
Olvision of Reactor Projects
Enclosure:
NRC Region ! Inspection Report No. 50-443/89-13*
- Contains Safeguards Information l
^
Public Service Company of 2
M N e s its New Hampshire ec w/o Page 21 of encl:'
J. Duf fett, President and Chief Executive Of ficer, PSNH T. Feigenbaum, Senior Vice President anc Chief Operating Officer NHY J. Peschel, Operational Programs Manager, NHY D. Moody, Station Manager. NHY T. Harpster, Director of Licensing Services R. Hallisey, Director, Department of Public Health Commonwealth of Massachusetts Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector (w/cy of encl)*
State of New Hampsnire Commonwealth of Massachusetts Seabrook Hearing Service List
'Contains Safeguards Information i
i 1
F a:
U.S. NUCLEAR REGULATORY COMM!$$ ION, REGION I Docket / Report No:
50-443/59-13 License No.: NPF-67 Licensee:
Public Service Company of New Hampshire 1000 Elm Street Manchester, N.H.
03105 Facility:
Seabrook Station, Unit No.1, Seabrook, New Hampshire Dates:
Octeter 11 - December 11, 1989 Inscectors:
A. Cerne, Senior Resident Inspector R. Fuhrmeister, Resident Inspector
- 5. Barr, Reactor Engineer N. Dudley, Project Engineer W. Lancaster, Physical Security Inspector E. Sylvester, Senior Reactor Engineer J. Yerokun, Reactor Engineer i
Reviewer:
N. Ervin, NRC Office of Nuclear Reactor Regulation i
Approvec By:
b O. b Il6 ho Ete C. McCate, Chief, Reactor Projects Section 3B Date Areas Inseected: Operational safety, ESF system walkdowns, reportable events, open items, the Containment Integrated Leak Rate Test, quality assurance acti-vities, security, and design modification activities, f
Results: Licensee planning, corrective measure implementation and overall re-sponse to potential problems with plant equipment (e.g., Westinghouse Technical Bulletin section 3.5.4; Rosemount Part. 21 Report - section 8.2) has been com-prehensive and technically sound.
L Two non-cited violations (sections 3.4 and 8.1) were identified by the Itcen-l Both procedural adherence and personnel errors were involved. Other ex-see.
amples where licensee action was required to correct procedure / personnel inter-action problems are also discussed in this report (sections 3.5.2 and 8.3).
Continued management emphasis upon associated interdepartmental coordination and monitoring of work is appropriate.
Successful performance of the Containment Integrated Leak Rate Test was wit-nessed.
A recurrent problem with one leaking valve was identified, indicating that a repeat valve repair may not prevent recurrence (section $).
Routine involvement of Quality Assurance personnel in work and corrective action in-plementation, as well as in surveillances and audits, was evident.
A revision to the Seabrook Station Physical Security Plan is needed to resolve safeguards issues raised by an NRC security evaluation (section 9).
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TABLE OF CONTENTS PAGE
)
1.
Persons Contacted....................................................
1 2.
S umma ry o f Ac t i v i t i e s ( 3 0 702 )........................................
1 3.
Operational Safety (71707)..........................
3 3.1 Plant Operations.....-...........................................
3 3.2 Plant Tours..............................................
4 3.3 Operating Procedures Rev1ew..............................
6 i
3.4 Follow up of Operating.Ecuipment Ouestions from P 6
Ope rating Event Fo11ow up........................ lant Heatup....
3.5 8
4 Engineered Sa fety Features System Wal kcown (71710)................... 11 5.
Containment Integrated Lea k Rate Test (70313)........................ 12 1.
Installation and Testing of Cesign Modifications (37828)............. 14 7.
Quality Assurance / Corrective Action Activities (40500, 92702)........ 16 7.1 Low Powe r Te s t P rog ra m Audi t.................................
16 7.2 Corrective Action Plan Review.................................. 16 S.
Follow up of Licensee Reports and Open Items (92700, 92701).......... 17 8.1 Licensee Event Reports..........................................
17 8.2 10 CFR 21 Report................................................
18 8.3 Licensee Action on Previously Identified Items,.................
19 9.
Physical Security Plan Implementation and Controls (81052)........... 20
- 10. Management Meetings (30703)..........................................
22 1
i I
.o 18 In the second case, a portable monitor, installed to meet the actien statement of technical specification 3.3.3.1 with the containment post-LOCA monitor out of service, was mistakenly unplugged for approximately five hours.
The HP technician who unplugged the monitor to use the electrical receptacle for another purpose was not f amiliar with the technical specification require-ments or aware of the conseovences of unplugging the portable monitor.
In both cases, the technicians involved were counseltd, acditional train-ing was conducted within the departments, and procedures were reviewed to en-sure accuracy and clarity of directions provided to the technicians performing the work.
A caution 45 to the consecuences of unplugging energitec ecbipment within the plant was also ciscussed in a station newsletter disseminated throughout the site and caution tag usage for electrical power c.ords was in-corporatec into health pnysics procecures for portable equipment.
l The inspector reviewed the LERs and the licensee corrective action and determinec that the ciscretionary criteria of 10 CFR 2, Appencix C, section V.G.1 have been satisfied.
Basec upon licensee identification, reporting and initiation of comprenensive corrective measures with respect to both of t,hese examples of noncompliance with technical specification requirements anc also in consiceration of the minimal safety significance of the actual events, these violations are not being citec.
Non-cited violation number 69-13-02 documents icentification of this issue, whic,h is hereby closed.
B.2 10 CFR 21 Recort (Closed) 10 CFR Part 21 Report No. 69-00-01:
Potential Failure of Rose-mount Transmitters.
As discussec in NRC Region ! Inspection Report 50-443/
89-01, a potential defect involving the loss of oil in the transmitter sensing module was identified by Rosemount, Inc., for certain transmitters manufactured prior to July, 1989.
The licensee's review has found 61 of the subject Rose-mount Mocel 1153 and 1154 transmitters installed at Seabrook.
Since the problem with potential oil loss occurs slowly over time, the licensee's corrective action plan includes a special calibration program, transmitter performance trending, and replacement of the pressurizer pressure transmitters and any spare Rosemount transmitters in stock on a schedule which is consistent with the support of station activities. The inspector verified that all the subject transmitters had been or were being calibrated in a manner which would check for any degradation due to oil loss. The inspector also re-viewed the Rosemount 10 CFR 21 notification, dated February 7, 1989, and evalv-ated the licensee's plan for addressing the stated concerns, based upon Rose-mount's discussion of how the transmitters would exhibit reduced performance.
It was also noted that testing by Rosemount, Inc. was conducted to determine limits in the performance degracation and methods in the detection of affected transmitters.
The inspector confirmed that the licensee has reviewed and evaluated all of the latest relevant Technical Bulletin and report information from Rosemount, Inc., on this potential problem.
19 The inspector determined that licensee response and corrective action planning for this Rosemount Part 21 report to be both timely and comprehensive.
Ghen the slowly developing nature of the potential problem, the licenste's monitoring program was assessec as adequate. Quarterly channel checks, over-range tests and normal calibrations of the subject transmitters should indicate performance degradation prior to component failure.
Special calibrations, re-I cently accomplished, provide adequate indication of transmitter acceptability and a baseline for future performance. The inspector considers licensee meas-ures to address this vendor identified problem to be extensive and conducive to the identification of any actual hardware problems in the future.
10 CFR 21 Report No. 89-00-01 is closed.
t 8.3 Licensee Action on Previously Identified Items (Closec) Unresolved item 89 08-01: Unmonitored Release from the Tu*bine Building $ ump. The inspector reviewed the licensee analysis of technical specification action statement recuirements relative to Station Information Report SIR 89-042.
The specific incident involving bypass of the turbine builcing sump raciation monitor was evaluated from both design basis and con-trol aceovacy standpoints.
While it was determined that the turbine building sump was not intenced to be dedicated solely to processing radioactive efflu-ents, the program used to control temporary sump pump usage and coordinate at-I tion statement status recuirements with control room operators required in-A procedure for the installation of temporary pumps was issued on provement.
October 5,1989 to delineate the necessary administrative controls and coordi-nation recuirements. The use of Temporary Pump Recuest forms was formalized.
The inspector reviewed station operating procedure UN0599.047 governing temporary pump controls and checked other operating procedures affected by its L
issuance. Temporary Pump Requests were spot-checked, both in process in the l_
control room and in their final documented closecut format.
Technical specifi-t l
cation action statement coordination and clearance were noted to be properly J
controllec for the times the temporary turbine building sump pump was installed. The inspector also determined that the program of controls estab-itshed by the licensee to address the original problem was broad enough in scope to adequately cover all temporary pump usage within the protected area.
1.icensee controls in this area have been strengthened and procedural com-
_ pliance with the new program of controls was checked by the inspector.
The inspector identified no concerns with the licensee's current program for in-stalling temporary pumps within the station and no specific problems were found with the use of the temporary turbine building sump pump.- This unresolved item is closed.
(Closed) Unresolved item 89-09-03: Failure to Perform Technical Specifi-cation Surveillances. The inspector reviewed the licensee's reportability de-termination for SIR 89-061, in which it was documented that certain radioactive l
liquid effluent and gaseous effluent monitoring instrumentation surveillances l
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- - - - - ^ ~ ~ ^ ^ ^
New HsmPshiro
- c'rTONENT D w C. %
senior v.ce Pres oene and Chief Operahng CAcer i
NYN-90061 March 12, 1990 United States Nuclear Regulatory Coestission i
Washington. DC 20555 i
Attention: Document Control Desk
References:
(a)
Facility Operating License No. NPF-67. Docket No'. 50 643 (b)
NYW-90056 dated March 8.1990 ' Response to Proposed Draf t NRC Bulletin on Loss of Fill 011 in Roseacunt Transmitters.
T.C. Feigenbaua to Document Control Desk'
Subject:
Supplemental Response to Proposed Draft NRC Bulletin on Loss of Till 011 in Rosemount Transmitters Gentlemen During recent discussions with the NRC Staff. New Maapehire Yankee (NHY) was requested to supplement the response contained in Reference (b) to confira the completion of the calibration reviews, to identify the further enhancements to the surveillance program and to provide additional information. NNY is providing the supplemental information in the form of the enclosed revisions to l
Reference (b).
The changes are identified by revision bars.
i l
As provided in Reference (b). NNY determined that there is only one r
transmitter installed at Seabrook Station from the Model 1153 and 1156 l'
manufacturing lots, which were identified by Rosemount as having a high failure fraction.
This transaitter is not utilised in the reactor protection system (RPS) or engineered safety features actuation systeme (ESFAS) and has been installed and in service for over 3 1/2 years. During this time period, the transmitter has been operating satisfactorily and has not exhibited any eyeptoms j
of potential fill-oil lose.
Nonetheless, for conservatism. NNY has decided to replace this transmitter. Yhe replacement transmitter will be installed before the close of business on March 16. 1990.
l' As indicated in the encicoures, the review of calibration data has been performed for all the identified transmitters. 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 exhibited early symptome of potential fill-oil lose has been replaced.
New Hompshire Yankee Division of Public Service Company of New Hompshire P.O. Box 300 * %dgA NH 03874
- Telephone (603) 474 9521 l
United States Nuclear Regulatory Commission Attention:
Document Control Desk March it. 1990 Page 2 1
Should you have any questions regarding the enclosed.-please contact Mr.
Terry L. Harpeter at (603) 474 9521. extension 2765.
/
-t Very trul your.o.
\\
6ks/M Ted C. Feigtnbaum cci Mr. William T. Russell
\\-
Regional Administrator i
United States Nuclear Regulatory Commiselon Region I 473 Allendale Road King of Prussia. PA 19406 Mr. Victor Nerees. Project Manager
- Project Directorate I.3 United States Nuclear Regulatory Commission Division of Reactor Projects Washington. DC 20533 Mr. Noel Dudley
[
NRC Senior Resident Inspector P.O. Box 1149 Seabrook. NM 03874 AtoadC Safety and Licensing Board Service List t
k e
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m ru m-
l ASLB SERVICE LIST Alan S. Rosenthal. Chairman Adjudicatory File Atomic Safety and Licensing Appeal Panel Atomic Safety and Licensing 1
" S. Nuclear Regulatory Commission Board Panel Docket (2 copies)
U.S. Nuclear Regulatory Commissien Vashington. DC 20555 Washington. DC 20!$$
Thomas S. Moore Philip Ahrens. Esquire Atomic Safety and Licensing Assistant Attorney General Appeal Panel U.S. Nuclear Regulatory Ccumission Office of the Attorney General State House Station 46 Vashington. DC 20555 Augusta. ME 04333
.Howard A. Vilber Athod N. Amirian. Esquire Atomic Safety and Licensing Assistant City Solicitor Appeal Panel City of Haverhill U.S. Nuclear Regulatory Commission Haverhill MA 01830 Vashington. DC 20535 O. Paul Bo11verk. III. Chairman Robert A. Backus. Esquire lackue. Meyer & Solomon Atomic Safety and Licensing 116 Lowell Street Appeal Panel P.O. Box 516 U.S. Nuclear Regulatory Commission Manchester KE 0310S Vashington, DC 20555 George Dana Bisbee. Esquire Atomic Safety.and Licensing Assistant Attorney General Appeals Board Panel U.S. Nuclear Regulatory Commission office of the Attorney General 25 Capitol Street Vashington. DC 20555 Concord. NM 03501 66397 Ivan W. Smith. Chairman Diane Curran. Esquire Atomic Safety and Licensing Board Andrea C. Forster. Esquire Panel U.S. Nuclear Regulatory Commission Harmon Curran & Tousley 2001 S Street. N.V.
Suite 430 Vashington, DC 20$55 Washington. DC 20009 1125 Robert R. Pierce. Esquire Mr.-Jack Dolan t
Atomic Safety and Licensing Board Federal Emergency Management Agency Panel Region I U.S. Nuclear Regulatory Commission J. W. McCormack Post Of fice &
Vashington, DC 20555 Courthouse Building. Room 442-Boston, MA 02109 Admin. Judge Kenneth A. McCollom.
Member Mr. Richard R. Donovan 1107 West Knapp Street Federal Emergency Management Agency Stillwater. OK 74075 Federal Regional Center Richard F. Cole 150 228th Street. S.W.
Bothell. Washington 98021 9796 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Vashington, DC 20555 m
~
'q ASLB SERVI E LIST Susanne P. Egan. City Solicitor Judith H. Mitner. Esquire Lagoulis, Hill.'.*hilton &
79 State Street,
& Rotondi Second flopt 79 State Street Newburyport. MA 01950 Newburyport. MA 01950
!artara J. Saint Andre. Esquire H. Joseph Plynn, Esquire Kopelman and Paige. P.O.
Office of General Counsel 77 Franklin Street Federal Emergency Management Agency Boston. MA 02110 300 C Street. SW Vashington, DC 20472 John Traficonte. Esquire Assistant Attorney General R. Scott Hill Whilton, Esquire Office of the Attorney General Lagoulis, Clark, Hill Vhilton One Ashburton Place, 19th Ticer
& Rotondi Boston, MA 02108 79 State Street Newburyport, MA 01950 Mitti A Young. Esquire Edwin J. Reis. Esquire Gary V. Holmes Esquire Office of General Counsel Holmes & Ells U.S. Nuclear Regulatory Commission 47 Winnacunnet Road Vashington, DC 20535 Hampton, NH 03842 Senator Gordon J. Humphrey*
i L'nited States Senate Vashington, DC 20510 Attention Tom Bursch Senator Gordon J. Humphrey*
1 Eagle Square. Suite 507 t
1
' Concord, NH 03301 Attention Mary Jane Colton l-George Iverson. Director N.H. Office of Energency Management State House Office Park South 107 Pleasant Street Concord NH 03301 1
I-Paul McEachern. Esquire l
Matthew 7. Brock Esquire L
Shaines & McEachern 25 Maplewood Avenue. P.O. Box 360 Portsmouth. NH 03801 l
L l-l
- 1etter only I
l
l New H33pshtte Yonkee March 12, 1990 ENCLOSURE 1 TO NYN.90061 Preceaed Draft Bulletin en Loss of F111 011 in les== aunt Transmitters testense to Recuested Actionat Onoratina Reacters
New Hampshire Yank 3e March 12. 1990 Preneaed Draft tulletin on 1.cas of F111-011 in kon== ant Transmitters 1aananaa to annumated Actions: Onaratina lanctora i
NRC Ranuantad Action di Identify. within 60 days af ter the receipt of this bulletin, all pressure or differential pressure transmitters. including Model 1151. 1152. 1153, and 1154 transmitters but escluding 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 j
safety.related systems or systems installed in accordance with 10 CFR 50.62 (the ATVS ru),e). Addressees may find it necessary to perform, in addition to document-i reviews, system walkdowns to complete this action.
[ Note:
In additica to the above, the proposed draft bulletin provided additional information to f acilitate addressing the above. This additional information has 1
not been repeated herein.)
NNY Rennense In regards to Rosemount Model 1151 and 1152 transmitters, there are u Model 1152 i
transmitters installed at Seabrook Station and there are u Model 1151 transmitters at Seabrook Station which perform a safety.related or ATWS related functions. There are kosemount Model 1153 and 1154 transmitters at Seabrook Station which perform safety related functions. These transmitters are identified on Table 1.
A review was undertaken to determine if the original equipment manufacturer's
( C Dt ' s ), identified in the proposed draft bulletin. had provided transmitters to Seabrook Station which, as described in the draf t bulletin, may have been i
l, manufactured by Rosemount or contained a sensing module manufactured by i
Rosemount.
The review concluded that only Bailey controls had supplied transmitters to Seabrock Station which utilised a Model 1151 transmitter sensing module.
These transmitters do not perfom a safety-related or ATWS related function.
NRC Raouested Action #2 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
[
criteria should be developed and applied to transmitters identified as having exhibited symptoms indicative of loss of fill. oil from this plant record review.
Transmittere identified as having er.hibited 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 and are not addressed in the technical specifiestions should be replaced at the earliest appropriate opportunity.
NNY Reanonne As indicated in NHY's response to Action il above, the response to this action item need only address the Model 1153 and 1154 Rosemount transmitters identified i
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.
i New Hampshire Ycnkee March 12. 1990 NNY Reanonna transmitters has been perf ormed. The results of this review are provided in. Requirement 1(b).
The method of review utill es the guidelines of Rosemount Technical Bulletin $4 Appendix A Section 3.
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 determine 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 attention a)
A transmitter will be tested against the operability acceptance criteria if s (1) it exhibits the trend that, between three or more consecutive calibrations, it drif ted in the same direction such that the total cumulative drift exceeds the total maximum allowable cumulative drift, as provided in Table 1 of Appendix A of Rosemount Technical Bulletin 4. or (2) if the drift observed during the channel checks causes the total observed drif t to exceed the maximum allowable cumulative drif t.
In this regard, it should also be noted that the appropriate range down factors will be applied in the calculation of the drift for the comparison to the data in the aforementioned table.
b)
For those transmitters which have safety.related setpoints, during the review of the channel checks and the calibration data, the measured drift of the transmitter will be compared to the combination of the assumed drif t 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 more 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 checks 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 calibrated on a more frequent basis so as not to exceed this value, d) If the transmitter has not met the above criteria 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 determine if the operability acceptance criteria is satisfied. The criteria for time response testing is based on Rosemount Technical Bulletin $4 Appendix 5 Section 2 and is as follows:
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 range code 5 9 the transmitter should respond (or follow since the pressure
-~~
New Hampshire YOnkCe o
March 12, 1990 NHY Rappense change any be a fast ramp) to this pressure change within i second. Range l
code 3 should respond within 35 seconds and range code 6 should respond l
within 6 seconds. Where this criteria is less stringent than the time i
response values required to meet the response time specified the Technical Requiremente Manual The Technical Requirements Manual values will take precedence in determining operability.
+
Transmitters identified as having exhibited symptome indicative of loss of fill.
f oil that are included in the Technical Specifications and that do not conform to the operability acceptance criteria vill be addressed in accordance with the applicable Technical hpecification. 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 will be replaced at the earliest appropriate opportunity. Those transmitters that 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 l
determine a specific course of action.
NRC Raouested Action A3 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 prtgram should consider the following or equally effective actions:
a)
Ensuring appropriate licensee personnel are aware of the symptoms that a transmitter. both during operation end during calibration activities, may exhibit if it is esperiencing a loss of fill. oil and the need for prompt identification of transmitters that may exhibit these symptomes 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:
i d)
Inclusion of sensor response time testing into routine channel calibration activities:
e)
Development and implementation of a program to detect a decrease in transmitter noise level amplitudes and f)
Development and application to transmitters identified as having exhibited symptome indicative of loss of fill. oil of an appropriate operability acceptance criteria. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria should be addressed in accordance with the applicable technical specification. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria and are not addressed in the technical specifications should be replaced at the earliest appropriate opportunity.
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_...m.
New Hampshire Yankee NMY laemonas March 12, 1990 The enhanced surveillance program for the installed Rosemount transmitters is presently being implemented. This program addresses the considerations of the draf t NkC Bulletin as follows:
a) 16C personnel are aware of the symptoms that a transmitter both during operation and during calibration activities. may exhibit if it is esperiencing a loss of fill-cil. I&C Department personnel have been on -
distribution for all pertinent information pertaining to Rosemount Technical Bulletins and this -inforantion has been included into the required reading program in the I&C Department. In addition. the training department will be scheduling formalized training of operations and I&C personnel regarding the i
above over the next 4 months.
b)
The enhanced surveillance program will include weekly and monthly chat.nel checks of the transmitters identified in Table 18 the scheduling of 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 t
transmitters providing an input to the RPS and ESFAS will be checked on a weekly basis.
Channel checks will be done on a weekly basis using the Main Plant Computer System (MPCS) for those channels that provide inputs to the 1
MPCS except as described below. The channels that do not provide inputs to the MPCS will be checked on a monthly basis using test equipnent in the i
process electronics cabinets.
In seven cases, only one of the transmitters monitoring the same process persmeter provides an input into the MPCS. Therefore in these cases all of the transmitters for those process parameters will be monitored on a monthly basis using test equipment in the process electronics cabinets. For the four pressuriser pressure and sixteen steam generator level channels weekly channel checks 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 fill-oil loss.
For most of the channels, the channel check will determine drift by comparing the amount of change in the output of the transmitter from a baseline value to the amount of change of other transmitters monitoring 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 zero check since the system will not be in operation.
c)
Based on the information from Rossaount, monitoring for drift should give the first indication of failure long before sluggish response in a transient would be identified. However, the enhanced surveillance program will include a review of HPCS data following transients. Specifically the program will review MPCS data following planned transients during the power asceasion test program for the Rosemount model 1153 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 mortem report will be reviewed. The post mortes report includes the two charging pump discharge flow channels, the four pressuriser pressure channels, the three pressuriser level channels and twelve of the steam generator level channels (three on each generator).
4 1
New Hampshire Ifankee March 12. 1990 j
NHY Reasonne d)
The I&C technicians have been made aware to observe for sluggish reppense when calibrating Rosemount Transmitters. During the calibration the technician will observe the qualitative time response performance due to a i
rapid change in the input. Based on the Rosemount literature a quantitative response time test during routine. calibration is not required since the degradation in response time should be noticeable to the i
technician. However, a quantitative time response test will be performed to Ij verify operability of any transmitter identified by the trending pregram as
!{
discussed in the response to requested action $2 above.
5 e)
The primary method of detection of a potential loss of oil in a sensing j
module will be the trending of the performance of the instrument channel.
1 that is, the drift observed during the monthly channel checks and the j
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 I
noise level amplitude method has not been included in the Station's trending i
program. If in the future we identify a possible use for this method we will 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 transmitters which do not meet the acceptance criteria see the response to Action #2 above.
NRC Recuented Action d6 1
Determine, within 60 days after receipt of this bulletin, whether any Model 1153 J
and 1154 transmitters identified in Item 1 are from the manufacturing lots that have been identified by Rosemount as 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).
Addressets are requested not to utillie transmitters from these suspect lots in the reactor protection or s
engineered safety features actuation systems -therefore, transmitters from these suspect lots in use in the reactor protection or engineered safety features actuation systems should be replaced at the earliest appropriate opportunity.
NNY Resnonne There is only one installed 1153 or 1154 transmitter from one of the high failure L
fraction lots identified by Rosemount at Seabrook Station. This transmitter monitors EFW suction pressure transmitter which is used in a RG 1.97 Category 1 L
- indicating loop to monitor Condensate Storage Tank Level. It is not used for
[
l Reactor Protection System (RPS) or Engineered Safety Features Actuation System (ESFAS). This transmitter is in a low pressure application and has been in service at normal operating pressure for over 4 years. After the issuance of l
the 10 CFR 21 notification, it was calibrated in May 1989 and again in Dec 1989 L
and was determined to be operating satisfactorily and has not exhibited any symptoms.of potential fill-oil loss.
- NRC Recuested Action f$
Document, within 60 days after receipt of this bulletin. and maintain in accordance with plant procedures a basis for continued plant operation covering the time period from the present until such time that the Model 1155 and 1154 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 e
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-March 12. 1990 1
KRC Raouested Action #S-prot : tion or engineered safety features actuation systems can be replaced.
In addition, while performing the actions requested above, addressess may identify transmitters exhibiting symptome' indicative of loss of fill-oil that oo not ecnfers 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 perica 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 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 component tests, or (if necessary) immediate replacement of certain suspect transmitters.
KNY Reseense At,..vided in paragraph 4 above there are no 1153 or 1154 transmitters from the c.c. f e cturing lots that have been identified by P.osemount as having a high f.s...re fraction due to loss of fill oil used in the RPS or ESFAS. As also indicated in Enclosure 2 in the Response to Requirement #1(b), there are no trtnamitters identified which have a confirmed fill-oil loss failure or do not meet the established operability acceptance criteria. Calibration of all the Rosemount 1153 and 1154 transmitters identified on Table 1 was begun in November.
1989 and has been completed. Therefore, basis for continued plant operation at Seabrook Statier. is not required at this time.
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New H&mpshire Yankos March 12, 1990-SAFETY art 2TED 105tMOUNT T'aSMITTERS TRANSMITTER FUNCTION MODEL NO, L
CC-FT-2091-1*
RCP Coolers outlet Flow Loop A 1153DD3 (Pump Coastdown Protection)
?
CC-FT-2091-2*
RCP Coolers outlet Flow Loop A.
1153DD3 f
(Pump Coastdown Protection)
CC-FT-2291-1*
RCP Coolers outlet Flow Loop'B 1153DD3 l
(Pump Coastdown Protection)
CC-FT-2291-2*
RCP Coolere Outlet Flow Loop B 1153DD3 l
(Pump Coastdown Protection)
CC-FT-2175A*
RCP TB Outlet FR P-322A & B 1153DD5 k
Thorinal Barrier Cooling (Pump Start 1E Interface)
CC-PT-2175B*
RCP TB outlet FR P-322A & B 1153DD5 l
[
Thermal Barrier Cooling (Pump Start 1E k
Interface)
]
CC-LT-2172-1*
PCCW Head Tank 19A Level (NNS Header 1153DB4 Isolation Signal)
.CC-LT-2172-2 PCCW Head Tank 19A Level (NNS Header 1153DB4 Isolation Signal)
CC-LT-2172-3 PCCW Head Tank 19A Level (NNS Header 1153DB4 Isolation Signal)
L CC-LT-2192 1 PCCW Head Tank 19A Level (NNS Header 1153DB4 Isolation Signal)
CC-LT-2192-2 PCCW Head Tank.19A Level (NHS Header 1153DB4 Isolation Signal)
CC-LT-2192-3 PCCW Head Tank 19A Level (NNS Header 1153DB4 5
Isolation Signal)
CC-LT-2272-1*
PCCW Head Tank 195 Level (NNS. Header 1153DB4 Isolation Signal)
CC-LT-2272-2 PCCW Head Tank 198 Level (NNS Header 1153DB4 Isolation Signal)
CC-LT-2272-3 PCCW Head Tank 198 Level (NNS Header 1153DB4 Isolation Signal)
CC LT-2292 1 PCCW Head Tank 195 Level (NNS Header 1153DB4 Isolation Signal)
- CC-LT-22 92-2 PCCW Head Tank 198 Level (NNS Header 1153DB4 Isolation Signal)
CC-LT-2292 3 PCCW Head Tank 198 Level (NNS Header 1153DB4 Isolation Signal)
CS-FT-7325*
CS-P-2A Chg Pmp Disch Flow (Pump Deadhead 1153HB4 Protection)
-CS-FT-7326*
CS P-28 Chg Pmp Disch Flow (Pump Deadhead 1153HB4 l
3 Protection)
FV-FT-4214-2 SG A EFW Hde Flow (Isolation of Flow to 1153DB5 Faulted SG)
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C New Hampshire Yankse March 12. 1990 TABLE 1 SAFETY-aMATED ROSEMOUNT TRANSMITTERS TRANsglftg FUNCTION MODEL NO, FW-FT-4214-4' SG A EPW Edr Flow (Isolation of Flow to 1153DB5 Faulted SG)
FW-FT-4224-2 SG B E W Mdr Flow (Isolation of Flow to 1153DB5 Faulted SG)
FW-FT-4224-4 SG B EFW Edr Flow (Isolation of Flow to 1153DB5 Faulted SG)
FW-FT-4234 2 SG C EFW Hde Flow (Isolation of Flow to 1153DB5 Faulted SG)
FW FT-4234-4 SG C EFW Hdr Flow (Isolation of Flow to 1153DB5 Faulted SG)
FW FT-4244-2 SG D EFW Hdr Flow (Isolation of Flow to 1153DB5 Faulted SG)
FW FT-4244 4 SG D EFW Edr Flow (Isolation of Flow to 1153DB5 Faulted SG)
FW.PT-4252**
Condensate Storage Tank Level (FW.P-37A 1153GB5 Suction Pressure)
FW PT-4257*
Condensate Storage Tank Level (FW.P-37B 1153GB5 l
Suction Pressure)
SW-LT-6129*
Cooling Tower Loop A SW Basin Level 1153DB5 b
SW.LT-6139-Cooling Tower Loop B SW Basin Level 1153DB5 SW-PT-8272' SW-P-41A/C Swp Disch Hdr Press (CT Tower 1153DB6 Actuation Signal)
SW-PT-8273*
SW-P-41A/C Swp Disch Edr Press (CT Tower 1153DB6
.\\.
Actuation-Signal)
SW-PT-8274 SW.P-41A/C Swp Disch Hdr Press (CT Tower 1153DB6 Actuation Signal)
SW.PT-4282 SW-P-415/D Swp Disch Edr Press (CT Tower 1153DB6 Actuation Signal)
SW-PT-8283*
SW-P-418/D Swp Disch Edr Press (CT Tower 1153DB6 Actuation Signal)
SW-PT-8284 SW-P-41B/D Swp Disch Hdr Press (CT Tower 1153DB6 Actuation Signal)
+
RC-PT-455*
Pressuriser Pressure 1154GP9 RC PT~456*
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 Harrow Range Level 1154DP4 FW-LT-516*
Steam Generator A Narrow Range Level 1154DP4 FW.LT-519*
Steam Generator A Narrow Range Level 1154DP4
New Hampshire Yankee March 12. 1990 F
SAFETY tRLATED ROSEMOUNT T* nRMITTRie TRANSMITTER FUNCTION MODEL NO, 1
FW-LT-552*
Steam Generator S Harrow Range Level 1154DP4 FW-LT-527*
Stena Generator 8 Narrow Range Level 1154DP4 1
FW.LT-520*
Steam Generator B Narrow Range Level 1154DP4 FW-LT-529*
Steam Generator B Narrow ka33e Level 1154DP4 i
i FW-LT-553*
Steam Generator C Narrow Range Level 1154DP4 i
FW.LT-537*
Steam Generator C Narrow Range Level 1154DP4 FW-LT-558*
Steam Generator C Narrow Range Level 1154DP4 i
FW-LT-3398 Steam Generator C Narrow Range Level 1154DP4
{
FW-LT-554*
Steam Generator D Harrow Range Level 1154DP4 FW-LT-547*
Steam Generator D Narrow Range Level 1154DP4 f
FW-LT-548*
~ Steam Generator D Narrow Range Level 1154DP4 i
FW.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 Transaltter which has an input to the Main Plant Computer System (MPCS).
Transmitter which has an input to the Main Plant Computer System (MPCS)atd is the only transmitter from the high failure fraction lote identified by Rosemount installed at Seabrook Station.
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New Hampshire Yankoo:
- o-March 12.-1990 to NYN-90061 Prenosed Draft Bulletin en Less of Fill-011 in Rosemount Transmitters Roanonne-to Recortina Ranuiramants Oneratina_Remeters l
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- 4; New Hampshire Yonkso
=v March 12, 1990 Pronosed Draf t Bulletin on Losa of Fill.0il in Roma=^unt Tranami tters Rennenas to Renortime Renuira= ants: Oneratine teactora NRC Renortina tenuirement fl(a) a:
Confirms that those Requested Actions for Operating Reactors in Items 1, 2, 3, 4, and 5 that are to be completed within 120 days after receipt of this bulletin have been completed and that programs are in place to perform the remaining requested actions.
NNY Rosconse
.The status or scheduled completion for the Requested Actions for Operating Reactors in Items 1,2,3,4 and 3 of the proposed draf t tulletin is as follows:
Item 1:
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 follows:
a)
Most of the preventive maintenance activities are in place, the remaining activities which were identified after 3/9/90 will be in place by 3/13/90.
The majority of'the monthly channel checks have been completed, for the second month of this program.
b)
The procedure describing the trending program and lists the operability acceptance criteria is expected to be approved by 3/21/90. The basis for this program and criteria were used to review the past calibration data, c)
The procedure for performing-the response tims tert which is used to establish the operability of a transmitter with.
possible fill-cil leakage is expected to be approved by-3/30/90. This procedure is.not needed at this time-to verify the operability of any of the-transmitters in Table 1.
Item 4:
This ites has been completed.
Item 5:
A basis for continued operation is not required at this time, therefore this item is not applicable.
KRC Renort na tenuiramant #1(b) i
. Identifies the indicated manufacturers the model numbers the saf ety-related system the transmitter was utilized 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 Item 2 of Requested Actions for Operating Reactors above, that are believed to have exhibited spaptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil.
New Baapshire Yanke3 t
March 12, 1990 NEY Resnonne I
At the present time there are no transmitters that have been confirmed to have a fill-oil lose failure at Seabrook. There was one transmitter which exhibited the symptoms that could be early signs of fill-oil lose. This transmitter, as provided below, has since been replaced. The following information applies to this transmitteri' i
Indicated Manufacturer Rosemount Mode 1 Humberi 1153D55 System Emergency Feedwater (E N )
Function: Flow measurement for isolation of EW flow to a faulted Steam Generator.
Time in Service:
Installed since September, 1985.
Observed Symptomes. The transmitter has drifted in the same direction over two calibration periods and the first sero check of the j
transmitter as part of the monthly channel check has shown a continuation of the drift.
Corrective Action Taken: Although the drift observed was within that assumed in-the setpoint calculation and the transmitter performed normally during-ite last calibration it was replaced.
This transmitter was not subjected to operating pressure for a significant period of time.' Therefore it is expected that the cause of the observed drift is
.something other than a loss of fill-oil.
However.
because of the trend of-poor ~ performance and the possibility of fill-oil leakage the transmitter was replaced. The replacement transmitter was also manufactured before July 11, 1989 and will therefore be included in the enhanced surveillance program.'
. Disposition:
The transmitter will be returned' to Roseacunt for a determination of the.cause of the observed drift.
NRC Renort 4== Raauir-nt fit c )
1 Identifies the safety-related system in which the Model 1153 or 1154 transmitters
.high-failure fraction due to loss of fill-oil are utilised and schedule for replacement of these transmitters which are in use-in the reactor protection or engineered safety features actuation systems.
'NHY Roanonne i
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 los of fill-oil utilized 'in the reactor protection or engineered safety features actuation system.
there is one installed transmitter, performing an accident mo from the high failure fraction lots identified by Rosemount.
- unction, Although this g
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New Hampshire Yankoo-9 March 12. 1990 i
NEY Reanonne transmitter has been operating satisfactorily and has not ezhibited any of the-signs of a potential fill-oil loss condition. NEY has. decided to replace it with an available spare ' transmitter. The replacement transmitter will be installed before the close of business on March 14. 1990. The replacement transmitter will be included in the enhanced surveillance program. In addition. NNY has requested Rosemount to-supply a replacement transmitter outside the Part 21 notification on an expedited basis.
NRC Renortina Recuirement #2 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 regulations.
l 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.
NHY Resnonne
{
If a Rosemount Model 1153 or 1154 transmitter exhibits the symptoms of loss of 1
fill-oil or are confirmed to have esperienced a loss of fill-oil this condition will be reviewed for reportability under existing NRC regulations.
If it is determined not to be reportable, information consistent with that requested in Item lb of _ the Reporting Requirements for Operating Reactors of the Draf t
- Bulletin will be documented and maintained in accordance with plant procedures.
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00CKElE0 USNRC CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys f1 e
Applicants herein, hereby certify that on March 13,~1990, I made' service of the within document by depositing espit@F SECREIARY.
whereindicated,bydepositingintheUnitedStatesmail,fjC thereof with Federal Express, prepaid, fordeliveryM6Lig first class postage paid, addressed to):
Alan S. Rosenthal, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing.
Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory-Commission Commission East West Towers Building East West Towers Building 4350 East. West Highway 4350 East West Highway Bethesda, MD-20814 Bethesda, MD 20814 Thomas S. Moore Mr. Richard R.
Donovan Atomic Safety and Licensing Federal Emergency Management Appeal Panel.
Agency U.S. Nuclear Regulatory Federal Regional Center Commission 130 228th Street, S.W.
East West Towers Building Bothell, Washington 98021-9796 4350 East West Highway Bethesda, MD 20814 Administrative Judge Ivan W.
H. Joseph Flynn, Esquire Smith, Chairman, Atomic Safety Office of General Counsel and Licensing Board Federal Emergency Management U.S. Nuclear Regulatory Agency Commission 500 C Street, S.W.
East West. Towers Building Washington,'DC 20472
.4350 East West' Highway Bethesda, MD-20814-Administrative Judge Richard F.
Gary W.- Holmes,-Esquire Cole Holmes & Ells Atomic Safety and Licensing Board 47 Winnacunnet Road U.S. Nuclear Regulatory Commission Hampton, NH 03842 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Kenneth A.
Judith H. Mizner, Esquire McCollom 79 State Street, 2nd Floor F
1107 West Knapp Street Newburyport, MA 01950 Stillwater, OK 74075 l
3 io)
George Dana Bisbee, Esquire-Robert R. Pierce, Esquire Associate Attorney General Atomic Safety and Licensing Office of the Attorney General Board 25 Capitol Street
- U.S. Nuclear Regulatory i
Concord,.NH 03301-6397 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Mitzi A. Young, Esquire Diane Curran, Esquire
.Edwin J. Reis, Esquire Andrea C.
Ferster, Esquire Office of the General-Counsel Harmon, Curran-& Tousley U.S.-Nuclear Regulatory Commission Suite 430 One White Flint North, 15th F1.
2002 S Street, N.W.
11555 Rockville Pike Washington,-DC 20009
.Rockville, MD 20852
. Adjudicatory File Robert A. Backus, Esquire Atomic Safety and, Licensing 116 Lowell Street Board Panel Docket (2 copies)
P.O.
Box 516 U.S. Nuclear Regulatory Manchester, NH 03105 Commission East West Towers Building 4350 East. West Highway Bethesda, MD 20814
- Atomic Safety and Licensing Suzanne P.
Egan, City Solicitor Appeal Board Lagoulis, Hill-Whilton &
U.S. Nuclear Regulatory Rotondi Commission 79 State Street Washington, DC 20555 Newburyport, MA. 01950 Philip Ahrens, Esquire John Traficonte, Esquire
-Assistant Attorney General Assistant-Attorney General Department of-the Attorney Department of the Attorney General General Augusta, ME 04333 One-Ashburton Place, 19th Fl.
Boston,'MA 02108 Paul McEachern, Esquire Barbara J. Saint Andre, Esquire Shaines & McEachern Kopelman and Paige, P.C.
25 Maplewood Avenue 77 Franklin Street P.O.
Box 360 Boston, MA 02110 Portsmouth, NH 03801~
R. Scott Hill-Whilton, Esquire Ashod N. Amirian, Esquire Lagoulis, Hill-Whilton &
145 South Main Street Rotondi-P.O.
Box 38 79 State Street Bradford, MA 01835 Newburyport, MA 01950 _
M o
- Senator Gordon J. Humphrey'
- Senator Gordon J. Humphrey U.S. Senate One Eagle Square, Suite 507?
Washington, DC' 20510 Concord, NH 03301.
.(Attnt. Tom Burack)
(Attn: -Herb Boynton)-
G;-LPaul Bollwerk, III, Chairman George Iverson, Director
' Atomic Safety and Licensing N.H.. Office of= Emergency-
. Appeal ~ Panel Management
{
U.S. Nuclear Regulatory Commission State House Office Park South l
East West Towers Building 107 Pleasant Street.
I 4350 East West Highway Concord, NH 03301 Bethesda, MD 20814 Mr. Jack Dolan-Federal Emergency Management Agency
' Region I J.W. McCormack Post Office &
I Courthouse Building, Room 442 Boston, MA 02109 L
I n
Thomas G.
Digtfan,' Jr.
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(*= Ordinary U.S. First Class Mail.)
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