ML20033E045
| ML20033E045 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1990 |
| From: | Sniezek J Office of Nuclear Reactor Regulation |
| To: | Jordan E Committee To Review Generic Requirements |
| References | |
| NUDOCS 9002070093 | |
| Download: ML20033E045 (22) | |
Text
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8 Ig UNITED sTATf s NUCLEAR REGULATORY COMMISSION o
{t j;1 wAsmwofoN, p. c. ems JAN g 91990 MEMORANDUM FOR: Edward L. Jordan, Chairman Committee to Review Generic Requirements FROM:
James H. Snierek, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
REQUEST FOR RJIEW OF A DRAFT BULLETIN ON LOSS OF FILL-0!L IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT On April 21, 1989 the NRC staff issued Information Notice No. 89-42
- Failure of Rosemount Models 1153 and 1154 Transmitters." This information notice alerted addressees to 1otential problems relating to Rosemount Model 1153 and 1154 transmitters t1at may be susceptible to failure due to loss of fill-oil from the sensor's sealed sensing module. These transmitters are widely used throughout industry in plant safety systems, including the reactor protection and engineered safety features actuation systems.
The performance of a transmitter that is leaking fill-oil gradually deteriorates and may eventually lead to failure. Although some failed transmitters have shtAn symptoms of loss of fill-oil prior to failure, it has been reported that in some cases the failure of a transmitter that is leaking fill-oil may not be detectable during-operation. Loss of fill-oil may result in a transmitter not performing its intended safety function.
Rosemount has recently indicated that, in addition to Model 1153 and 1154 transmitters, they have also identified confirmed failures of both Model 1151 and 1152 transmitters due to loss of fill-oil. Rosemount has also indicated that they manufacture both complete transmitters and transmitter parts (including sensing modules) for other manufacturers who supply equipment for use in nuclear power plants.
In addition, Rosemount has indicated that unauthorized remanufacturers and refurbishers exist for Model 1151 and possibly Model 1152, 1153, and 1154 transmitters.
General Desi Testability"gn Criterion (GDC) 21." Protection System Reliability and of 10 CFR Part 50 Ap bedesignedforhighfunctionalre$endixArequirestheprotectionsfstemto1 ability and wit allow periodic testing of its functioning when the reactor is in operation in order to readily detect failures of subcomponents and subsystems within the protection system as well as loss of the required protection system redundancy as they occur. 10 CFR 50.55a(h) requires that protection systems meet the Institute of Electrical and Electronics Engineers Standard: " Criteria for Protection Systems for Nuclear Power Generating Stations" (IEEE-279).
IEEE-279 states that means shall be provided for checking, with a high degree j
CONTACT: Jack Ramsey, NRR 492-1167 e20780
q he rd,L. - Jordan
- JAN29 gg of confidence, the operational availability of each system input sensor during reactor operation. Thus, we conclude that facilities that utilize transmitters that may be susceptible to loss of fill-oil may not be in full compliance with these regulations because undetected transmitter failure could occur.
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Enclosed are the proposed bulletin and appropriate supporting background information. We request that CRGR review of this matter be scheduled as quickly as possible.
The bulletin is sponsored by Charles E._ Rossi, Director, Division of Operational Events Assessment, and by Ashok Thadani, Director, Division of Systems Technology.
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4 a es H. Sniezek, Deput Director ice of Nuclear Reactor Regulation
Enclosures:
1.
NRC Bulletin No. 90-XX 2.
CRGR Item IV.B.
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OMB No.: 3150-0011-NRCB 90-XX UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555 January xx,1990 NRC BULLETIN NO. 90-XX: LOSS OF FILL-0IL IN TRANAMUTRtS EO!UTACTURED BY ROSEMOUNT Addressees:
All holders of operating licenses er construction permits for nuclear power reactors.
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Purpose:
This bulletin is being provided to request that addressees take actions to 4
promptly identify and replace transmitters manufactured by Rosemount that may be leaking fill-oil.
Description of Circumstances:
NRC Information Notice No. 89-42
- Failure of Rosemount Models 1153 and 1154 Transmitters," dated April 21, 1989, was issued to alert industry to a series of reported failures of Rosemount Models 1153 and 1154 pressure and differential pressure transmitters. The reported failures occurred at Northeast Utilities' Millstone Unit 3 between March and October 1987. Subsequent investigation into the cause of the failures by Rosemount confirmed that the failure mode was a gradual lo" 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.
have shown symptoms of loss of fill-oil prior to < a11ureAlthoughsomefailedtransmitters it has been reported that in some cases the failure of a transmitter that is leaking fill-oil is not detectable during operation. Loss of fill-oil may result in a transmit-ter not performing its intended safety function.
Discussion:
Model 1151, 1152, 1153, and 1154 Rosemount transmitters are utilized exten-sively in nuclear power plants. Model 1153 and 1154 transmitters are supplied by Rosemount as both seismically and environmentally qualified equipment.
Model 1152 transmitters are supplied by Rosemount only as seismically qualified equipment. Model 1151 transmitters are supplied by Rosemount as commercial-grade equipment.
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NRCB 90-XX January xx, 1990 Page 2 of 10 Rosemount has indicated, to date, that failure of approximately 91 Model 1153 j
and 1154 transmitters due to loss of fill-oil from a glass to metal seal failure have been confirmed. Since the sensing module is sealed, loss of' i
fill-oil usually cannot be confirmed without destructive analysis of the sensing module. NRC staff review of this issue has identified additional failed Model 1153 and 1154 transmitters with symptoms indicative of loss of fill-cil that may not have been brought to Rosemount's attention. Thus, the number of failed Model 1153 and 1154 transmitters that have experienced a loss of fill-oil may be greater than that confirmed by Rosemount.
l Rosemount has indicated that similar sensing modules are utilized in Model 1151, 1152, 1153, and 1154 transmitters and that failures of both Model 1151 and 1152 transmitters due to loss of fill-oil from a glass to metal seal failure have been confirmed. The NRC staff believes that, while Model 1153 and 1154 transmitters have a greater susceptibility to loss of fill-oil, Model 1151 and 1152 transmitters may also be susceptible to loss of fill-oil. Thus, loss of fill-oil may be generically applicable to Rosemount' manufactured sensing modules. Accordingly, for the purposes of the actions requested in this bulletin, Model 1151 and 1152 transmitters utilized in safety-related systems should be addressed in a manner comparable to that of Model 1153 and 1154 transmitters.
In addition, Rosemount has-indicated that they have insti-tuted additional quality control and quality assurance steps in the manufactur-ing process that they believe will minimize the potential for Model 1153 and 1154 transmitter failures due to loss of fill-oil.
As a result, Rosemount has 1
indicated that Model 1153 and 1154 transmitters manufactured after July 11, 1989 are not subject to their Nay 1989 10 CFR Part 21 notification. The NRC staff has not, to date, received indications that Model-1153 and.1154 transmit-I ters manufactured by Rosemount subsequent to July 11, 1989 are susceptible to loss'of fill-oil; therefore, the NRC staff concludes that Model 1153 and 1154 transmitters manufactured by Rosemount subsequent to July 11, 1989 are not subject to the actions requested in this bulletin. The NRC staff has not, to date, received sufficient information to address the applicability of these l
manufacturing process modifications to Model 1151 and 1152 transmitters.
1 Rosemount had previously indicated that Model 1153 and 1154 transmitters that were experiencing a loss of fill-oil should fail within approximately 36 months of in-service time. Recent information indicates that the rate at which fill-oil leaks is application and pressure dependant. Therefore,while transmitters that are experiencing a loss of fill-oil that are subject to continuous high-pressure (e.g. reactor operating pressures) may fail within this timeframe, transmitters utilized in low-pressure systems or not subject to continuous high-pressure may take longer to fail.
Rosemount has indicated that they manufacture both complete transmitters and transmitter parts (including sensing modules) for other manufacturers. At least one vendor purchases complete transmitters from Rosemount and then
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", I NRCB 90-XX-January xx,1990 Page 3 of 10 provides these transmitters for use in nuclear pceer plants under a different arandname. At least one other instrument manufacturer purchased Rosemount manufactured sensing modules and incorporated these sensing modules into transmitters supplied to nuclear >ower plants. Thus, equipment supplied for use in nuclear power plants by otier manufacturers may also be susceptible to loss of fill-oil.
In addition, Rosemount has indicated that unauthorized remanufacturers and refurbishers exist for Model 1151 and possibly Model 1152, 1153, and 1154 transmitters.
The symptoms a Model 1153 or 1154 transmitter may exhibit during nonnal opera-tion if it is leaking fill-oil include:
a slow setpoint drift of 1/4 of 1 percent per month deviation from the normal system signal fluctuation that is consistent in-only the increasing or decreasing direction ("one-sided-noise")
slow response to or inability to follow planned or unplanned plant transients a decrease in noise amplitude an output that deviates from that of redundant transmitters The symptoms a Model 1153 or 1154 transmitter may exhibit during calibration activities if it is leaking fill-oil include:
inability to respond over the entire design range slow ~ response to either an increasing or decreasing test pressure drift of greater than 1 percent from the previo1s calibration The NRC staff believes these symptoms can also be utilized to detect other transmitter models that may be experiencing a loss of fill-oil.
In addition, addressees may wish to consult References 1, 2, 3, and 4 to obtain additional detailed technical information concerning loss of fill-oil. However, address-i ees are cautioned that the NRC staff has reviewed Reference 4 and concludes that, while Rosemount has provided sufficient bases to support their proposed diagnostic procedures (trending calibration data, trending operational data, l
sluggish transient response, and process noise analysis) for detecting whether a transmitter may be leaking fill-oil, Rosemount has not provided sufficient bases to support their proposed methodology for identifying which transmitters should be put into the enhanced surveillance program (pressure versus time-in-service and only Model 1153 and 1154 transmitters).
". I NRCB 90-XX January xx,1990 Page 4 of 10 Certain manufacturing lots of Model 1153 and 1154 transmitters have been previously identified by Rosemount as having had a high failure fraction (on the order of 6%) due to loss of fill-oil. Specific information needed to identify transmitters that are from these suspect lots has been provided to industry by Rosemount.
The NRC staff believes that transmitters from these suspect lots have an unacceptably high susceptibility to failure from loss of fill-oil and should not be utilized in the reactor protection or engineered safety features actuation systems.
General Design Criterion (GDC) 21 ' Protection System Reliability and Testabil-ity" of 10 CFR 50, Appendix A requires the protection system to be designed for high functional reliability and with sufficient capability to allow periodic testing of its functioning when the reactor is in operation in order to readily detect failures of subcomponents and subsystems within the protection system as well as loss of the required prote: tion system redundancy as they occur.
s 10 CFR 50.55a(h) requires that protection systems meet the Institute of Elec-trical and Electronics Engineers Standard: " Criteria for Protection Systems for NuclearPowerGeneratingStations"(IEEE-279).
IEEE-279 states that means shall be provided for checking, with a high degree of confidence, the opera-tional availability of each system input sensor during reactor operation.
Thus, the NRC staff concludes that facilities that utilize transmitters that may be susceptible to loss of fill-oil may not be in full compliance with these regulations because undetected transmitter failure could occur.
Accordingly, the NRC staff requests that addressees take the actions requested below.
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Requested Actions:
Operating Reactors 1.
Identify, within 60 days after the receipt of this bulletin, all pressure or differential pressure transmitters, including Model 1151, 1152, 1153, and 1154 transmitters but excluding Model 1153 and 1154 transmitters manufactured by Rosemount subsequent to July 11, 1989, that were manu-factured by Rosemount or that contain Rosemount msnufactured sensing modules and are utilized in either safety-related systems or systems installed in accordance with 10 CFR 50.62 (the ATWS rule). Addressees may find it necessary to perform, in addition' to document reviews, system:
walkdowns to complete this action.
In addition, the following information is provided to facilitate addres:;ee's activities in this area.
All Model 1153 and 1154 transmitters, whether obtained directly from Rosemount, obtained through intermediary suppliers, or provided as an integral part of another component (such as an emergency diesel generator), should a) indicate manufacture by Rosemount, b) have a distinctive Rosemount model and serial number, c) have the physical profile characteristics of a Rosemount transmitter, and d) have a blue or stainless steel housing. Rosemount has indicated that Model 1153 and 1154 transmitters are not provided to other manufacturers for resale under a different brandname.
In addition, a simplified diagram that describes the typical physical characteristics of a Rosemount transmitter is provided by Attachment 1.
4.i NRCB 90-XX 4
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January xx,1990 Page 6 of 10 Model1152 transmitters,exceptasnotedbelow,shoulda) indicate manufacturebyRosemount,b)haveadistinctiveRosemountmodeland serialnumber,c)havetheph Rosemount transmitter, and d)ysical profile characteristics of a.
have a blue or stainless steel housing.
Rosemount has indicated that they have supplied Model 1152 transmitter sensing modules to Bailey Controls (formerly Bailey Meter). Bailey manufactured transmitters that contain Rosemount manufactured Model 1152 sensing) modules have gray housings that appear slightly_ different (more-rounded than Rosemount housings.
Model1151 transmitters,exceptasnotedbelow,shoulda) indicate manufacture by Rosemount, b) have a distinctive Rosemount model and a
serial number, c) have the physical profile characteristics of a Rosemount transmitter, and d) have a blue housing. Model 1151.
transmitters manufactured by Rosemount may have been supplied for use in nuclear power plants by other original equipment manufacturers (OEM's).
4 The OEM's identified in Attachment 2 may offer for resala under their own brandname Model 1151 transmitters purchased from Rosemount. These transmitters should have the physical profile characteristics of a Rosemount transmitter and have a blue housing.
Fisher Controls may also offer for resale under their own brandname Model 1151 transmittert purchased from Rosemount. These transmitters should have the physical profile characteristics of a Rosemount transmitter, but have a green housing.
In addition, Rosemount has indicated that they have supplied Model 1151 transmitter sensing modules to Bailey Controls. Bailey I
manufactured transmitters that contain Rosemount manufactured Model.1151
'i sensing) modules have gray housings that appear slightly different (more rounded than Rosemount housings, t
2.
Review, within 90 days after receipt of this bulletin, plant records (for example,calibrationrecords)associatedwiththetransmittersidentified in Item 1 above to determine whether any of these transmitters may have
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already exhibited symptoms indicative of loss of fill-oil. Appropriate 1
operability acceptance criteria should be developed and applied to transmitters identified as having exhibited symptoms indicative of loss of fill-oil from this plant record review. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil.that.do not 1
conform to the operability acceptance criteria should be addressed-in accordance with the applicable technical specification.
Transmitters-identified as having exhibited symptoms indicative of. loss of fill-oil that do not conform to the operability acce)tance criteria and are not addressed in the technical specifications siould be replaced at the earliest appropriate opportunity.
3.
Develop and implement, within 120 days after receipt of this bulletin, an enhanced surveillance program to monitor transmitters identified in Item 1 for symptoms of loss of fill-oil. This enhanced surveillance program
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should consider the following or ecnally effective actions:
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'4 1 t NRC8 90-XX~
January xx,1990-Page 6 of 10 a)
Ensuring appropriate licansee-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
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drift; c)
Review of transmitter output date following planned or unplanned plant transients or. tests to identify sluggish transmitter response; d)
Inclusion of sensor-response time ?.esting into routine channel calibration activities; e)
Development and implementation of a program to detect a decrease in transmitter noise level amplitude; and f)
Development and application to -transmitters identified as having:
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exhibited symptoms indicative of loss.of fill-oil of an appropriate-operability acceptance criteria.
Trancmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform-to the operability acceptance criteria thould 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 techriical specifications should be replaced at the earliest appropriate opportunity.
1 4.
Determine, within 60 days after receipt of this bulletin, whether any Model 1153 or 1154 transmitters identified in Item 1 are from the manufacturing lots that have been identified by Rosemount as'having'a high failure fraction due to loss of fill-oil.
(Informationconcerning these transmitters was provided to industry by Rosemount concurrent with Reference 4). Addressees are requested-not to utilize transmitters from these suspect lots in the reactor protection or engineered safety features actuation systems; therefore, transmitters from these suspect lots in use in the reactor protection or engineered safety features actuation systems should be replaced at the earliest appropriate opportunity.
i 5.
Document, within 60 days after receipt of this bulletin, and maintain in accordance with plant procedures a basis for continued plant operation-covering the time period from the present until such time that the Model 1153 and 1154 transmitters from the manufacturing lots that have been
NRCB 90-XX.
i January xx,1990 Page 7 of 10 3
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' dentified by Rosemount as having a high failure fraction due to loss of l
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fill-oil in use in the reactor protection or engineered safety features l
actuation systems can be replaced.. In addition, while performing the actions requested above addressees may identify transmitters exhibiting-t symptoms indicative of loss of fill-oil that do not conform to the established operability acceptance criteria and are not addressed in the u
L 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 tirae 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 tunctions (a separate trip function that may also provide a-correspondingtripsignal),specialsystemand/orcomponenttests,or(if necessary) innediate replacement of certain suspect transmitters.
t Construction Permit Holders i
1.
All construction permit holders are requested to complete Items 1 and 3 of Requested Actions for Operating Reactors prior to the date scheduled for fuel loading or in accordance with the timeframes specified for Operating Reactors, whichever is later..
2.
All construction permit holders that are completing Items 1 and 3 of Requested Actions for Operating Reactors in accordance with the timeframes specified for Operating Reactors are requested to complete Items 4 and 5 of Requested-Actions for Operating Reactors in accordance with the-timeframes specified for Operating Reactors.
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3.
All c.onstruction permit holders.that are completing Items 1 and 3 of Requested Actions for Operating Reactors prior to the date scheduled for fuel loading are requested to address the intent of Items 4 and 5 of t
Requested Actions for Operating Reactors by performing the following actions:
a)
Identify and replace, prior to the date scheduled for fuel loading, any Model 1153 or 1154 transmitters from the manufacturing-lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil that are installed in the reactor protection or engineered safety features. actuation systems; and s
b)
Document and maintain in accordance with plant procedures a basis for continued plant operation that addresses transmitters that, subsequent to fuel loading, are identified as exhibiting symptoms i
indicative of loss of fill-oil that do not. conform to the established operability acceptance criteria and are not addressed in the technical specifications covering the time period from the time these transmitters are identified until such time that these transmitters can be replaced.
When developing and updating this basis for continued plant operation, addressees may wish to consider transmitter diversity and redundancy, diverse trip functions (a separate trip function that may also provide acorresponding-tripsignal),specialsystemand/orcomponenttests, or (if necessary) immediate replacement of certain suspect transmitters.
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t NRCB 90-XX January xx,1990 Page 8 of 10 Reporting Requirements:
Operating Reactors 1.
Provide, within 120 days after receipt of this bulletin, a response that:
a)
Confirms that those Requested Actions for Operating Reactors in i
Items 1, 2, 3,. 4, and 5 that are to be completed within 120 days after receipt of this bulletin have been completed and that programs are in place to perform the remaining requested actions; b)
Identifies the indicated manufacturer; the model number; the safety-related system the transmitter was utilized in; the approxi-1 mate amount of time in service; the corrective actions taken; 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 sym) toms indicative of loss of fill-oil or have been confirmed to lave experienced a loss of fill-oil; and c)
Identifies the safety-related system in which the Model 1153 or 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil are utilized and provides a schedule for replacement of these transmitters which are in use in the reactor protection or engineered safety features actuation systems.
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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 1
existing NRC regulations.
If determined not to be reportable, addressees are requested to document and maintain, in accordance with plant proce-i dures,information-consistentwiththatrequestedinItem1b)abovefor each suspect transmitter identified.
Construction Permit Holders 1.
All holders of construction permits that perform Items 1 and 3 of Requested Actions for Operating Reactors in accordance with the timeframes specified for Operating Reactors should provide, within 120 days after receipt of this bulletin, a response that:
a)
Confirms that those Requested Actions for Operating Reactors in Items 1, 3, 4, and 5 that are to be completed within 120 days after receipt of this bulletin have been completed and that programs are in place to perform the remaining requested actions; and b)
Identifies the safety-related system in which the Model 1153 or 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil are utilized and provides a schedule for replacement of these transmitters which are in use in the resctor protection or s
engineered safety features actuation systems.
NRCB 90-XX l
January xx,1990 Page 9 of 10 L
2.
All holders of construction permits that perform Items 1 and 3 of Requested Actions for Operating Reactors prior to the date scheduled for o
fuel loading should provide, prior to the date scheduled for fuel loading, g
a response that:
a)
Confirms that all actions in. Items 1 and 3 of Requested Actions for, i
Operating Reactors have been completed; and b)
Confirms that Model 1153 or 1154 transmitters from the manufa G uring lots that have been identified by Rosemount as having a high failure fraction due to loss of fill-oil are not utilized in the reactor protection or engineered safety features actuation systems..
P 3.
Transmitters that, subsequent to providing the response required by-Item-t 1 or 2 above, exhibit symptoms of loss of fill-oil-or are confirmed to
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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 and maintain. in accordance with plantprocedures,informationconsistentwiththatrequestedinItem1b) of the Reporting Requirements for Operating Reactors above for each suspect transmitter identified.
The written reports required above shall.be addressed to the U.S. Nuclear Regulatory Comission, ATTN: Document Control: Desk, Washington, D.C.
- 20555, and shall be submitted under oath or affirmation pursuant to the provisions of Section 182a, Atomic Energy Act of '1954, as amended and 10 CFR 50.54(f). _ In addition, a copy shall be submitted to the appropriate Regional Administrator.
Backfit Discussion The objective of the actions requested in this bulletin are to ensure that I
transmitter failures due to loss of fill-oil are promptly ' detected. Loss of fill-oil may result in a transmitter not performing its intended safety function.
The actions requested in this bulletin represent new staff positions and thus, this request is considered a backfit in accordance with.NRC procedures.
Because established regulatory requirements exist but were not-satisfied, this backfit is to bring facilities into compliance with existing. requirements.
Therefore, a full backfit analysis was not performed. An evaluation of the type discussed in 10 CFR 50.109(a)(6) was performed, including.a-statement of the objectives of and reasons for the modification and the basis for invoking the compliance exceptioa.
It will be made available in the Public Document Room with the minutes of the meeting of the Comittee to Review Generic Requirements.
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J NRCB 90-XX
- January xx,1990 Page 10 of 10 This request is covered by Office of Management and Budset Clearance Number 3150-0011 which expires January 31, 1991. The estimated average burden hours are 100 person-hours per licensee response, including assessment of the new requested actions, searching data sources, gathering and anclyzing the data, and preparing the required letters. These estimated average burden hours pertain only to these identified response-related matters and do not include.
the time for actual implementation of.the-requested actions. SenTcomments 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 Comission, Washington, D.C.
20555;andtothePaperworkReduction_ Project (3150-0011),
Office of Management and Budget, Washington D.C.
20503.
If you have any questions about this matter, please contact one of the techni-cal contacts listed below or the appropriate NRR project manager.
Charles E. Rossi, Director Division of Operational Events Assessment-Office of Nuclear Reactor Regulation Technical Contacts: Jack Ramsey, NRR l
(301)492-1167 Vince Thomas, NRR r
(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 l
l : Typical Physical Characteristics of a-Rosemount Transmitter : Original Equipment Manufacturers That May Resell Rosemount Manufactured Model 1151 Transmitters Under Their Own Brandname
) : List of Recently Issued NRC Bulletins l
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NRCB-90-XX January xx,1990 -
. TYPICAL PHYSICAL CHARACTERISTICS OF A ROSEMOUNT TRANSMITTER ELECTRONIC,8 HOUSING b,
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NRCB 90-XX January xx,- 1990 ORIGINAL EQUIPMENT MANUFACTURERS THAT MAY RESELL ROSEMOUNT MANUFACTURED MODEL IISI TRANSMITTERS UNDER THEIR OWN BRANDNAME 1.
BAILEYCONTROLS(FORMERLYBAILEYMETER) 3.
DIETRICH STANDARD 4.
DANIEL INDUSTRIES 5.
CLEVELAND CONTROLS 6.
F..B. LEOPOLD 7.
HAYS REPUBLIC 8.
MOORE PRODUCTS i
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NORTH AMERICAN MANUFACTURING
- 10. OMEGA ENGINEERING 11.
LEEDS & NORTHRUP i
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l-CRGR Item !Y.B.
Contents of Packages Submitted to CRGR (Rev. 4, Stello to List 042387, des 41860342ff) i The following requirements apply for proposals to reduce existing requirements or (regulatory) positions as well as pro >osals to increase requirements or 1
(regulatory) positions. Each package suamitted to the CRGR for review shall include twenty (20) copies of the following information:
SUBJECT:
PROPOSED BULLETIN ON LOSS OF FILL-0IL IN TRANSMITTERS MANUFACTURED BY ROSEMGUNT Question:
I.
The proposed generic requirement'or staff position as it is proposed to be sent out to licensees.
Response
Theproposedstaffpositionissetforthinthebulletin(Enclosure 1).
Question:
II. Draft staff papers or other underlying staff documents supporting the requirements or staff position.
(A copy of all materials referenced in the document shall be made available upon request to the CRGR staff. Any comittee member may request CRGR staff to obtain a copy of any referenced l
materialforhisorheruse.)
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Response
1.
NRC Information Notice 89-42 " Failure of Rosemount Models 1153 and 1
1154 Transmitters," April 21, 1989.
2.
Memorandum from C.H. Berlinger to C.E. Rossi dated January 11, 1990 (MeetingminutesofDecember1989meetingwithRosemount).
3.
Memorandum from C.H. Berlinger to C.E. Rossi dated September 12, 1989 (Meeting minutes of August 1989 meeting with Rosemount).
4.
Memorandum from C.H. Berlinger to C.E. Rossi dated May 10, 1989 (Meeting minutes of April 1989 meeting with Rosemount).
5.
Rosemount 10 CFR Part 21 notification dated May 12, 1989.
Ouestion:
III. Each proposed requirement or staff position shall contain the sponsoring..
office's position as to whether the proposal would. increase staff require-ments or staff positions, or would implement existing requirements or staff positions.
1
' Response:-
A.
-Transmitters manufactured by Ros: mount are utilized extensively in-safety-related systems in nuclear power plants. The performance of a transmitter that is-leaking fill-oil gradually deteriorates and may eventually lead to failure. Although some failed transmitters have-shown symptoms of loss of fill-oil prior to failure, the failure of a transmitter that is leaking fill-oil will-very likely: not be detectable during operation.
Loss of fill-oil may result in a transmitter (ortransmitters)..notperformingits(their) intended safety function. Accordingly, the staff has determined that it is necessary to. request that licensees and construction permit holders -
for nuclear power reactors perform the actions requested in the bulletin.
B.
The actions requested in the proposed bulletin would ensure com--
p11ance with General-Design Criterion'(GDC) 21 of 10 CFR Part 50,;
Appendix A and with 10 CFR 50.55a(h).relat9d to protection system reliability and testability. These requirements state that trans-mitters must be reliable and that means must be provided to check and test for failures when the reactor is in operation.
Question:
1 IV. The proposed method of implementation along with the concurrence (and.any comments)ofOGConthemethodproposed.
Response
The method of implementation will be the proposed bulletin (Enclosure 1).
A copy of this bulletin has been reviewed by OGC. OGC's comments have been incorporated.
OGC has no legal-objection.
Question:
i V.
Regulatory analysis generally conforming to the directives and guidance of NUREG/BR-0058 and NUREG/CR-3568.
Response
This is a compliance issue.
In accordance with 10 CFR 50.109, a formal value/ impact analysis was not performed.
Question:
VI.
Identification of the category of reactor plants to which the generic requirement or staff position is to apply (that is, whether it is to apply to new plants only, new OLs [ operating licensees] only, OLs after e certain date, all Ots, all plants under construction, all plants all water reactors, all pWRs [ pressurized water reactors] only, some, vendor-types, some vintage types such as BWR 6 and 4,. jet pump and nonjet pumps plants,etc).
Response
The proposed bulletin would apply to all holcers of operating licenses or construction permits for nuclear power reactors.
2
()uestion:
II'I. FN each catagory of reactor plants, an evaluation which demonstrates how the action should be prioritized and scheduled in light of other ongoing regulatory activities. The evaluation shall document for consid-eration information available concerning any of the following factors as may be appropriate and any other information relevant and material to the proposed action:
j A.
Statement of the specific objectives that the proposed action is designed to achieve....
Response
The primary objective of the proposed bulletin is to ensure that addressees promptly detect and replace transmitters that may be-leaking fill-oil.
Question:
B.
General description of the activity that would be required by licensees in order to complete the action...
Response
To complete the action, addressees would need to identify transmit-ters that were manufactured by Rosemount or that contain Rosemount manufactured sensing modules and are utilized in either safety-related systems or systems installed in accordance with 10.CFR 50.62 (the ATWS rule), review plant records to determine whether any of the identified transmitters may already be exhibiting symptoms indicative of loss of fill-oil, develop and implement an enhanced surveillance program to monitor the identified transmitters for symptoms indicative of loss of fill-oil, and replace transmitters that are either identified as having exhibited symptoms of loss of fill-oil and do not meet the operability acceptance criteria or are from the.
suspect manufacturing lots and are installed in the reactor protection or engineered safety features actuation systems.
Question:
C.
potential change in risk to the public, from the accidental offsite release of radioactive material....
Response
The proposed bulletin would ensure that-the risk to the public from
{
the accidental offsite release of radioactive material is consistent with that intended by the promulgation of the previously identified i
GDC's and the design bases of the FSAR.
Question:
D.
potential impact on radiological exposure of facility employees and other onsite workers....
3
A
?.
.4 - 't sp e
Certain activities associated with' the actions requested in the bulletin do not necessitate access to the transmitters themselves; therefore, no increase'in radiological exposure o' facility employees and other onsite workers is expected for these activities.
Certain activities associated with the actions requested in the bulletin may necessitate access to the transmitters themselves.
However, since the transmitters are normally accessed every refueling outage for calibration related activities the additional radiologi-cal exsosure of facility employees and other onsite workers resulting from t11s bulletin is expected to be minimal.
Question:
E.
Installation and continuing costs associated with_the action, includ-ing the cost of facility downtime or construction delay...
Response
The NRC staff's estimate of the impact of the actions requested in the proposed bulletin is as follows:
i There are approximately 6,000 Rosemount transmitters (Models 1151, 1152,1153 and 1154) in safety-related NPRDS reportable systems. The 1
staff estimates that general record review for these' transmitters will necessitate approximately 3 staff-hours per transmitter.
Assuming a rate of $100 per staff-hour results in an impact of approximately $1.800,000 to industry.
Assuming records for 1,000 transmitters may need a more detailed review results in an additional impact of approximately $300,000 to industry.
It is the staff's understanding that the cost of replacin safety-related transmitter is on the order of $5,000 to $g a10,000 per j
transmitter. Assuming 250 safety-related transmitters will need to be replaced results in an impact of approximately $1,250,000 to
$2,500,000 to industry.
It is the staff's understanding, based upon feedback from industry, that an effective transmitter nionitoring program can be developed and implemented for approximately $10,000 to $100,000 per facility.
Assuming the actions requested in the proposed bulletin affect 110-facilities, this results in an impact of approximately $1,100,000 to
$11,000,000 to industry.
Thus, the staff concludes that the actions requested in the proposed bulletin will result in an impact of from approximately $4.450,000 to
$15,600,000 to industry. The impact to an individual plant will' vary significantly and will be strongly influenced by the number of potentially affected transmitters utilized and by the number of transmitters that need to be replaced.
4 l
' t)uestion -
F.
The potential safety im>act of changes in plant _or operational complexity, including t$e relationship to proposed and existing regulatory requirements and staff positions...
Response:'
A slight increase in operational complexity may, due to corrective actions taken, result from transmitters that are identified as exhibiting symptoms indicative of loss of-fill-oil. _ However, this increase in operational complexity is not as significant as the operational problems that_ may arise should a transmitter fail to perform its safety function.
Question:
t G.
The estimated resource burden on the NRC associated with the proposed action and the availability of such resources....
i
Response
The bulletin does require that licensees provide a written response that identifies transmitters that are believed to have exhibited i
symptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil, as well as confirming that actions consistent with those requested in the bulletin have been or will be taken. The responses will assist the NRC staff in determining transmitter failure rates,'as well as confirming-actions taken by addressees are consistent with those requested in the bulletin.
The impact of reviewing this information on the NRC staff l
is not expected to be significant.
In addition, no requirement for regional review is anticipated.
Question:
H.
The potential impact of differences in facility type, design or age on the relevancy and practicality of the proposed action....
Response
Based on the currently available information, no differences are-expected.
Question:
I.
Whether the proposed action is interim or final, and if interim, the justification for-imposing the proposed action on an interim basis, r
Rygny:
The NRC staff believes that the actions requested in the proposed bulletin are needed to ensure that addressees promptly detect and replace transmitters that may be leaking fill-oil.
- However, continuing NRC staff review of this and related issues may indicate the need for further regulatory action.
5
e. 0mstions' YIII.'For each evaluation conducted pursuant to 10 CFR 50.109, the
~
_ proposing Office Director's determination together with the rationale for the determination based on the consioeration of paragraphs I._
through VII. above that:
A.
There is a substantial increase in the overall protection of public-health and safety or the common defense and security to be derived from the proposal.
B.
The direct and indirect costs of implementation, for the facilities affected, are justified in view of this increased protection.
Response
The actions requested in this bulletin would ensure that licensees' comply with those commitments pursuant to their license which require-that safety-related equipment perform their intended function when required to do so. Therefore,under10CFR50.109(a)(4)(1)no further cost analysis is required.
Question:
IX. For each evaluation conducted for proposed relaxations or decreases'in l
current requirements or staff positions, the pro>osing Office Director's determination, together with the rationale for tio determination based on the considerations of paragraphs I. through VII, above that:
A.
The public health and safety and the common defense and security would be adequately protected if the proposed reduction in require-ments or positions were implemented.
B.
The cost savings attributed to the action would be substantial = enough to justify taking the action.
l
Response
No relaxation of requirements will occur from this bulletin.
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-Material Related to CRGR Meeting No.179 to be made Publicly Available 1.
Memo dated March 30,1990 for J. - Taylor from E, Jordan, subject:
Minutes of CRGR Meeting Number-179, including two enclosures which were not'previously released:
- a., a summary of discussions of proposed bulletin on loss of fill-oil in transmitters' manufactured by Rosemount, including 3 attachments.
b.
Enclosure.3, a' summary of discussions of a proposed generic letter to correct a deficiency in-BWR critical power ratio calculations involving channel box low, 1 attachment..
2.
Memo' dated January 29,-1990 for E.' Jordan lfrom:J. Sniezek-forwarding review materials on a proposed bulletin of loss of fil.1-oil:in' transmitters manufactured by Rosemount.
3.
Memo dated January
','1990 for E.' Jordan from J..Sniezek' forwarding.
J review materials on a proposed generic letter to: correct a_dpficiency in-
-l BWR critical power ratio calculations involving channel boxdow.
I Sent to PDR on:
4/27/90 j
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