ML20033F077

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Forwards Supplemental Response to Proposed Draft NRC Bulletin on Loss of Fill Oil in Rosemount Transmitters. Transmitter Exhibiting Early Symptoms of Potential Fill Oil Loss Replaced & Review of Calibr Data Performed
ML20033F077
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 03/12/1990
From: Feigenbaum T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-90 NYN-90061, NUDOCS 9003150416
Download: ML20033F077 (18)


Text

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  • . -New Hampshire i

Tod C. F.

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Senior Vice Prnident and i

Chief Operating Officer l

-r NYN-90061 March 12, 1990' l

United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk

References:

(a)

Facility Operating License No. NPF-67, Docket No. 50-445 l

(b)

NYN-90056 dated March 8, 1990, ' Response to Proposed Draft NRC Bulletin on Loss of Fill Oil in Rosemount Transmitters.

T.C. Feigenbaum to Document Control Desk' Subject Supplemental Response to Proposed Draft NRC Bulletin on Loss of Fill 011 in Rosemount Transmitters Gentlemen:

i During recent discussions with the NRC Staff, New Hampshire Yankee (NHY) was

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-requested to supplement the response contained in Reference (b) to confirm the completion of the calibration reviews, to identify the further enhancements to i

the surveillance program and to provide-additional information. NHY is providing the supplemental information in the form of the enclosed revisions to e

Reference (b). The changes are identified by revision bars.

I As provided in Reference (b), NHY determined that there is only one transmitter installed at Seabrook Station from the Model 1155 and 1154 manufacturing lots, which were identified by Rosemount as having a high failure l

fraction.

This transmitter is not utilized in the reactor protection system

.l l-(RPS) or engineered safety features actuation systems (ESFAS) and has been installed and in-service for over 5 1/2 years. During this time period, the transmitter has been operating satisfactorily and has not exhibited any symptoms I

of potential fill-oil loss.

Nonetheless, for conservatism, NHY has decided to j

replace this transmitter. The replacement transmitter will be installed before the close of business on March 14, 1990.

As indicated in the enclosures, 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 loss failure or which did not meet the established operability acceptance criteria. As indicated in the enclosures, one transmitter which had exhibited early symptoms of potential fill-oil loss has been replaced.

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New Hampshire Yonkee Division of Public Service Company of New Hompshire P.O. Box 300

  • Seabrook, NH 03874
  • Telephone (603) 474 9521

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, United States Nuclear Regulatory Commission March 12, 1990 Attention:

Document Control Desk Page 2

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Should you have any questions regarding the enclosedr-glease contact Mr.

. Terry L. Harpster at (603) 474-9521, extension 2765.

/

p Very trul yours,/

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A-Ted C. Feigenbaum cci Mr. William T. Russell

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Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Victor Nerses Project Manager Project Directorate I-3 United States Nuclear Regulatory Commission Division of Reactor Projects Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident Inspector P.O. Box 1149 Seabrook, NH 03874 Atomic Safety and Licensing Board Service List j

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s ASLB SERVICE LIST i

Alan S. Rosenthal, Chairman Adjudicatory File i

Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel Docket (2 copies)

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Thomas S. Moore Philip Ahrens Esquire Atomic Safety and Licensing Assistant Attorney General Appeal Panel Office of the Attorney General U.S. Nuclear Regulatory Commission State House Station #6 Vashington, DC 20555 Augusta, ME 04333 Howard A. Wilber Ashod N. Amirian, ELquire Atomic Safety and Licensing Assistant City Solicitor l

Appeal Panel City of Haverhill U.S. Nuclear Regulatory Commission Haverhill, MA 01830 Washington, DC 20555 Robert A.'Backus, Esquire G. Paul Bollwerk. III, Chairman Backus, Meyer & Solomon Atomic Safety and Licensing 116 Lowell Street Appeal Panel P.O. Box 516 U.S. Nuclear Regulatory Commission Manchester NH 03105 Washington, DC 20555 George Dana Bisbee, Esquire Atomic Safety and Licensing Assistant Attorney General Appeals Board Panel Office of the Attorney General U.S. Nuclear Regulatcry Commission 25 Capitol Street Washington, DC 20555 Concord, NH 03301-66397 Ivan W. Smith, Chairman Diane Curran, Esquire Atomic Safety and Licensing Board Andrea C. Ferster, Esquire Panel Harmon, Curran & Tousley U.S. Nuclear Regulatory Commission 2001 S Street N.W.

Suite 430 Washington, DC 20555 Washington, DC 20009-1125 Robert R. Pierce, Esquire Mr. Jack Dolan Atomic Safety and Licensing Board Federal Emergency Management Agency Panel Region I U.S. Nuclear Regulatory Commission J. W. McCormack Post Office &

Washington, 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 a

130 228th Street, S.W.

Richard F. Cole Bothell, Washington 98021-9796 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555

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c ASLB SERVICE LIST I

Suzanne P. Egan, City Solicitor Judith H. Minner, Esquire l

Lagoulis, Hill-Whilton &

79 State Street,-

& Rotondi Second Floor 79 State Street Newburyport, MA 01950 Newburyport, MA 01950 Barbara J. Saint-Andre. Esquire l

l H. Joteph Flynn, Esquire Kopelman ar.d Paige, P.C.

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Office of General Counsel 77 Franklin Street L

Federal Emergency Management Agency Boston, MA 02110

$00 C Street. SW Washington, DC 20472 John Traficonte. Esquire Assistant Attorney General R. Scott Hill-Whilton, Esquire Office of the Attorney General Lagoulis, Clark, Hill-Whilton One Ashburton Place, 19th Floor

& Rotondi Boston, MA 02108 79 State Street Newburyport, MA 01950 Mital A Young, Esquire Edwin J. Reis. Esquire t

L Cary W. Holmes, Esquire Office of General Counsel Holmes & Ells U.S. Nuclear Regulatory Commission 47 Winnacunnet Road Washington, DC 20555 Hampton, NH 03842 l

Senator Gordon J. Humphrey*

United States Senate Washington, DC 20510 Attention:

Tom Burack E

Senator Gordon J. Humphrey*

1 Eagle Square Suite 507 Concord, NH 03301 Attention: Mary Jane Colton George Iverson, Director-N.H. Office of Emergency Management State House Office Park South 107 Pleasant Street Concord, NH 03301 Paul McEachern Esquire Hatthew T. Brock, Esquire Shaines & McEachern 25 Maplewood Avenue P.O. Box 360 Portsmouth, NH 03801

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N;w H::pshiro Yank:o g-March 12, 1990 U

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'x ENCLOSURE 1 TO NYN-90061 Proposed Draft Bulletin on Loss of F111-011 in Rosemount Transmitters Response to Reouested Actions: Operatina Reactors s

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March 12, 1990 Proposed Draft Bulletin on Loss of F111-011 in Rosemount Transmitters Response to Recuested Actionst Operatinn Reactors NRC Recuested Action #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 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). Addressees may find it necessary to perform, in addition to document reviews, system walkdowns to complete this action.

[ Note:

In addition to the above, the proposed draft bulletin provided additional information to facilitate addressing the above. This additional information has not been repeated herein.)

NHY Response In_regards to Rosemount Model 1151 and 1152 transmitters, there are Ist Model 1152 transmitters installed at Seabrook Station and there are D2 Model 1151 transmitters at Seabrook Station which perform a safety-related or ATWS related functions. There are Rosemount 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 (OEM's), identified in the proposed draft bulletin, had provided transmitters to Seabrook Station which, as described in the draft bulletin, may have been manufactured by Rosemount or contained a sensing module manufactured by Rosemount. The review concluded that only Bailey Controls had supplied transmitters to Seabrook Station which utilized a Model 1151 transmitter sensing module.

These transmitters do not perform a safety-related or ATWS related function.

NRC Reauested 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 de+armine whether any of these transmitters may have already exhibited symptoms indicative of loss of fill-oil. Appropriate operability acceptance criteria should be developed and applied to transmitters identified as having exhibited symptoms indicative of loss of fill-oil from this plant record review.

Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptsnce 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 specifications should be replaced at the earliest appropriate opportunity.

NHY Response 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 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

J NIw H:cpshiro Ycnkte March 12, 1990 NHY Response transmitters has been performed. The-results of this review are provided in. Requirement 1(b).

The method of review utilizes the guidelines of Rosemount Technical Bulletin f4 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 utilized to determine if there is a possible fill-oil leak. The following criteria will be used to decide if a transmitter should be placed in the category of needing to be recalibrated or requiring special attentions a)-

A transmitter will be tested against the operability acceptance criteria ifs (1) it exhibits the trend that, between three or more consecutive calibrations, it drifted in the same direction such that the total cumulative i

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 drift to exceed the maximum allowable cumulative drift.

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 drift and the transmitter accuracy as used in the setpoint calculation.

If the measured drift exceeds this value between calibrations or if it appears from the channel checks, that the transmitter will exceed this value, it will be calibrated on a 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.

i A transmitter will be time response tested to determine if the operability acceptance criteria is satisfied. The criteria for time response tecting is based on Rosemount Technical Bulletin #4 Appendix B 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 ranBe code 5-9 the transmitter should respond (or follow since the pressure

L, N:w H:mpshire Yank:e Ly March 12, 1990 NHY Resnonse change may be a fast ramp) to this pressure change within 1 second. Range code 3 should respond within 35 seconds and range code 4 should respond within 6 seconds. Where this criteria is less stringent than the time response values required to meet the response time specified the Technical Requirements Manual, The Technical Requirements Manual values will take precedence in determining operability.

Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that are included in the Technical Specifications and that do not conform to the operability acceptance criteria will be addressed in accordance with the applicable Technical Specification.

Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria and are not addressed in the Technical Specifications will be j

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 determine a specific course of action.

NRC Reauested Action #3 Develop and implement, within 120 days after receipt of this bulletin, an j

enhanced surveillance program to monitor transmitters identified in item 1 for l

symptoms of loss of fill-oil. This enhanced surveillance program should consider I

the following or equally effective actions j

l a)

Ensuring appropriate licensee personnel are aware of the symptoms that a j

transmitter, both during operation and during calibration activities, may i

exhibit if it is experiencing a loss of fill-oil and the need for prompt l

l identification of transmitters that may exhibit these symptoms:

i b)

Enhanced transmitter monitoring to identify excessive transmitter drift:

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c)

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

Inclusion of sensor response time testing into routine channel calibration j

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Development and implementation of a program to detect a decrease in transmitter noise level amplitude: and f)

Development and application to transmitters identified as having exhibited l

symptoms indicative of loss of fill-oil of an appropriate operability acceptance criteria. Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria should be addressed in accordance with the applicable

-technical specification.

Transmitters identified as having exhibited i

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.

S New H:mpshire Ycnk:e, March 12, 1990

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NHY Response The enhanced surveillance program for the installed Rosemount transmitters is presently being implemented. This program addresses the considerations of the draft NRC Bulletin as follows:

a)

_IEC personnel are aware of the symptoms that a transmitter, both during operation and_during calibration activities, may exhibit if it is experiencing a loss of fill-oil.

IEC Department personnel have been on distribution for all pertinent information pertaining to Rosemount Technical Bulletins and this information has been included into the required reading program in the IEC Department. In additior., the training department will be scheduling formalized training of operations and I&C personnel regarding the above over the next 4 months.

b)

The enhanced surveillance program will include weekly and monthly channel checks of the transmitters identified in Table li the scheduling of additional calibrations for a transmitter identified as requiring special attention and the review of calibration records for these transmitters to look for transmitter drift, as discussed in Action #2 above.

The transmitters providing an input to the RPS and 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 HPCS except as described below. The channels that do not provide inputs to i

the MPCS will be checked on a monthly basis using test equipment in.the l

process electronics cabinets.

In seven cases, only_one of the transmitters monitoring the same process parameter provides an input into the MPCS. Therefore in these cases all of the transmitters for those process parameters will be monitored on a monthly l;

basis using test equipment in the process electronics cabinets.

For the four pressurizer 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 y

if any of these transmittere are exhibiting drift which may be an l

indication of a possible fill-oil loss.

l 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 L

baseline value to the amount of change of other transmitters monitoring the L

same process parameter from week to week or month to month.

It may be noted L

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 Rosemount, monitoring for drift should give L

the first indication of failure long before sluggish response in a transient would be identified. However, the enhanced surveillance program will 1

include a review of MPCS data following transients.

Specifically the program will review MPCS data following planned transients during the power ascension-test program for the Rosemount model 1153 and 1154 transmitters

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which provide an input to the MPCS. Also following unplanned transients l<

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 mortem report includes the two charging pump discharge flow channels, the four pressurizer pressure channels, the three pressurizer level channels and twelve of the steam generator level channels (three on each generator).

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March 12, 1990-NNY Response d)

The-I&C technicians have been made aware to observe for sluggish response 1

when calibrating Rosemount Transmitters.

During the calibration the technician vill observe the qualitative time response performance due to a rapid-change in the input. Based on the Rosemount literature a

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quantitative response time test during routine calibration is not required since the degradation in response time should be noticeable to the_

4 technician. However, a quantitative time response test will be performed to verify operability of any transmitter identified by the trending program av discussed in the response to requested action #2 above.

i e)

The primary method of detection of a potential loss of oil in a sensing module will be the trending of the performance of the instrument channel, that is, the drift observed during the monthly channel checks and the calibrations.

Based on the information from Rosemount, monitoring for zero and span shift should give the first indication of failure before a decrease in transmitter noise level of amplitude would be identified.

Therefore, the noise level amplitude method has not been included in the Station's trending 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 Reouested Action #4 Determine, within 60 days after receipt of this bulletin, whether any Model 1153 l

and 1154 transmitters identified in Item 1 are from the manufacturing lots that j

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).

Addressees are requested not

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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.

NHY Response There is only one installed 1153 or 1154 transmitter from one of the high failure 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 indicating loop to monitor Condensate Storage' Tank Level.

It is'not used for

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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 3 years. After the issuance of the 10 CFR 21 notification, it was calibrated in May 1989 and again in Dec 1989 and was determined to be operating satisfactorily and has not exhibited any symptoms of potential fill-oil loss.

NRC Reauested Action #5 Document, within 60 days after receipt of this bulletin, and maintain in 4

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 identified by Rosemount as having a high failure fraction due to loss of fill-oil in use in the reactor

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N;w H:mpshire Yankee March 12, 1990 NRC Reauested Action #5 6

protection or engineered safety features actuation systems can be replaced.

In addition, while performing the actions requested above, addressees may identify transmitters exhibiting symptoms indicative of loss of fill-oil that do not conform to the established operability acceptance criteria and are not addressed in the technical specifications. As these transmitters are identified, this basis for continued plant operation should be updated to address-these transmitters covering 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 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.

NHY Response As provided in paragraph 4 above there are no 1153 or 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having a high L

failure 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 transmitters 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 Station is not required at this time.

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March 12. 1990 TABLE 1 SAFETY-RELATED ROSEHOUNT TRANSMITTERS TRANSMITTER FUNCTION MODEL NO.

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CC-FT-2091-1*

RCP. Coolers Outlet Flow Loop A 1153DDS 3

(Pump Coastdown Protection)

CC-FT-2091-2*

RCP Coolers' Outlet Flow Loop A-1153DD3_

l 3

(Pump Coastdown Protection)

CC-FT-2291-1*

RCP Coolers Outlet Flow Loop B 1153DD3 l

(Pump Coa;tdown Protection)

CC-FT-2291-2*

RCP Coolers Outlet Flow Loop B 1153DD3 l

(Pump Coastdown Protection)

CC-FT-2175A*

RCP TB Outlet FR P-322A & E, 1153DD5 lf Thermal Barrier Cooling (Pump Start 1E Interface)

CC-FT-2175B*

RCP TB Outlet FR P-322A & B 1153DD5 l

Thermal Barrier Cooling (Pump Start 1E 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)

CC-LT-2192-1 PCCW Head Tank 19A Level (NNS Header 3153DB4 Isolation Sign.a CC-LT-2192-2 PCCW Head Tank 19A Level (NNS Header 1153DB4 Isolation Signal)

CC-LT-2192-3 PCCW Head Tank 19A Level (NNS Header 1153DB4 Isolation Signal)

CC-LT-2272-1*

PCCW-Head Tank 19B Level (NNS Header 1153DB4 Isolation Signal)

CC-LT-2272-2 PCCW Head Tank 19B Level (NNS Header 1153DB4 Isolation Signal)

CC-LT-2272-3 PCCW Head Tank 19B Level (NNS Header 1153DB4 Isolation Signal)

CC-LT-2292 PCCW Head Tank 19B Level (NNS Header 1153DB4 Isolation Signal)

CC-LT-2292-2 PCCW Head Tank 19B Level (NNS Header 1153DB4 Isolation Signal)

CC-LT-2292-3 PCCW Head Tank 19B 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-2B Chg Pmp Disch Flow (Pump Deadhead 1153HB4 Protection)

FW-FT-4214-2 SG A EFW Hdr Flow (Isolation of Flow to 1153DB5 Faulted SG)

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N;w H pshirs Yank:0 March 12, 1990

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TABLE 1 SAFETY-RELATED ROSEMOUNT TRANSMITTERS TRANSMITTER FUNCTION MODEL NO.

'FW FT-4214-4 SG A EFW Hdr Flow-(Isolation of Flow to 1153DB5 L

Faulted SG)

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'FW-FT-4224-2 SG B EFW Hdr Flow (Isolation of Flow to 1153DB5 r

Faulted SG)

FW-FT-4224-4 SG B EFW Hdr Flow (Isolation of Flow to 1153DB5 Faulted SG)

FW-FT-4234-2 SG C EFW Hdr 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 Hdr Flow (Isolation of Flow to 1153DB5 Faulted SG)

FW-PT-4252**

Condensate Storage Tank Level (FW-P-37A 1153GB5 Suction Pressure) l-FW-PT-4257*

Condensate Storage Tank Level (FW-P-37B 1153GB5 Suction Pressure) l

.SW-LT-6129*

Cooling Tower Loop A SW Basin Level 1153DB5 SW-LT-6139 Cooling Tower Loop B SW Basin Level 1153DBS 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 Hdr Press (CT Tower 1153DB6 l

Actuation Signal)

'SW-PT-8274 SW-P-41A/C Swp Disch Hdr Press (CT Tower 1153DB6 Actuation Signal)

SW-PT-8282 SW-P-41B/D Swp Disch Hdr Press (CT Tower 1153DB6 Actuation Signal)

SW-PT-8283*

SW-P-41B/D Swp Disch Hdr Press (CT Tower 1153DB6 l

Actuation Signal)

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SW-PT-8284 SW-P-41B/D Swp Disch Hdr Press (CT Tower 1153DB6 Actuation Signal)

RC-PT-455*

Pressurizer Pressure 1154GP9 RC-PT-456*

Pressurizer Pressure 1154GP9 RC-PT-457*

Pressurizer Pressure 1154GP9 RC-PT-458*

Pressurizer. Pressure 1154GP9 FW-LT-551*

Steam Generator A Narrow Range Level 1154DP4 FW-LT-517*

Steam Generator A Narrow Range Level 1154DP4 i

FW-LT-518*

Steam Generator A Harrow Range Level 1154DP4 FW-LT-519*-

Steam Generator A Narrow Range Level 1154DP4 L

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U-N;w Hampshiro Ycnk:0 March.12, 1990 TABLE 1 4

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SAFETY-RELATED ROSEMOUNT TRANSMITTERS TRANSMITTER FUNCTION MODEL NO.

'FW-LT-552*

Steam Generator B Narrow Range Level 1154DP4

' FW-LT-527*

Steam Generator B Narrow Range Level 1154DP4 FW-LT-528*

. Steam Generator B Narrow Range Level 1154DP4 FW-LT-529*

Steam Generator B Narrow Range Level 1154DP4 r,

- FW-LT-553*

Steam Generator C Narrow Rang 6 Level 1154DP4 FW-LT-537*

Steam Generator C Narrow Range Level 1154DP4 FW-LT-538*

Steam Generator C Harrow Range Level 1154DP4 FW-LT-539*

Steam Generator C Narrow Range Level 1154DP4

. FW-LT-554*

Steam Generator D Narrow Range Level

-1154DP4 FW-LT-547*

Steam Generator D Narrow Range Level 1154DP4-FW-LT-548*

Steam Generator D Narrow Range Level 1154DP4 FW-LT-549*

Steam Generator D Narrow Range Level 1154DP4 RC-LT-459*

Pressurizer Level 1154DP5 RC-LT-460*

Pressurizer Level 1154DP5 RC-LT-461*

Pressurizer Level-1154DP5 Transmitter which has an input to the Main Plant Computer System (MPCS).

Transmitter which has an input to the Main Plant Computer System (MPCS)and is the only transmitter from the high failure fraction lots identified by 7

Rosemount installed at Seabrook Station.

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N:w Hanpshiro Ycnkso March 12, 1990 t

% to NYN-90061-1 Proposed Draft Bulletin on Loss of Fill-Oil in Rosemount Transmitters i

Response to Reporting Recuirements: Operatina Reactors r

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March 12, 1990.

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I Pronosed Draft Bulletin on Loss of Fill-011 in Rosemount Transmitters i

Resoonse to Renortina Reauirements: Operatina Reactors NRC RfDor+1nn Reauirement #1(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 1

have been completed and that programs are in place to perform the remaining requested actions.

NHY Response The status or scheduled completion for the Requested Actions for Operating.

Reactors in Items l',2,3,4 and 5 of the proposed draft Bulletin is as follows:

j Item 1:

This item has been completed.

Item 2:

This item has been completed.

-l 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 j

to review the past calibration data.

c)

The procedure for performing the response time test which is used to establish the operability'of a transmitter with possible fill-oil leakage is expected to be approved by

~

3/30/90. This procedure is not needed at this time to verify q

the operability of any of the transmitters-in Table 1.

Item 4:

This-item has been completed.

Item 5:-

A basis for continued operation is not required at this time, therefore this item is not applicable.

i

-NRC Reportina Reauirement difb)

Identifies the indicated manufacturer the model numbers the safety-related system the transmitter was utilized in; the approximate amount of time in services the corrective actions taken and the disposition (e.g., returned to vendor for analysis) of transmitters, including thoce identified while performing-Item 2 of Requested Actions for Operating Reactors above, that are believed to have exhibited symptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil.

1

i 1

f

'New H=pshira Ycnkse j

March 12, 1990 NHY Response J

- :At the present time there are no transmitters that-have been confirmed to have a

' fill-oil loss-failure at Seabrook.

There was one transmitter which exhibited the:

~

, symptoms that.could be early signs of fill-oil loss.

This transmitter, as j

' provided below, has since.been replaced. The following information applies to-this transmitters-Indicated Manufacturer: Rosemount Model Number:

1153DB5

' Systems-Emergency Feedwater (EFW)

Function: Flow measurement for isolation of EFW flow to'a faulted Steam ll

^'

' Generator.

Time in Service:

Installed since September, 1985.

u observed Symptoms:

The transmitter has drifted in the same direction over two calibration periods and the first zero check of the transmitter as part of the monthly channel check has shown a nontinuation of the drift.

1

. Corrective Action Taken: Although the drift observed was within that assumed in the setpoint calculation and the transmitter performed normally during its last calibration. it was. replaced.

'l

'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 in 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.

Dispositions.

The transmitter will be returned to Rosemount for a determination of the cause of the observed drift.

?

.NRC'Recortinn Reauirement #1(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 l:

.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 f

protection'or engineered safety features actuation systems.

l' NHY Resoonse l

j.

There are no Model 1153 or 1154 transmitters from the manufacturing lots that chave been identified by Rosemount as having a high failure fraction due to loss ofLfill-oil utilized in the reactor protection or engineered safety features

. actuation system. -As indicated in NHY's Response to Action #4, in Enclosure 1, there.isione installed transmitter, performing an accident monitoring function, from the high failure fraction lots identified by Rosemount. Although this

4 I.N.

N:w H:mpshiro Y:nk:0 March 12, 1990 NHY Response transmitter 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 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, NHY has requested Rosemount to supply a replacement transmitter outside the Part 21 notification on an expedited basis.

NRC Reportinn Reouirement #2 Transmitters that, subsequent to providing the response required by ITEH 1 above, 1

exhibit-symptoms of loss of fill-oil or are confirmed to have experienced a loss of fill-oil should be reviewed for reportability under existing NRC regulations.

If determined not to be reportable, addressees are requested to document and maintain. in accordance with plant procedures, information consistent with that requested in Item 1 (b) above for each suspect transmitter identified.

NHY Response i

If a Rosemount Model 1153 or 1154 transmitter exhibits the symptoms of loss of fill-oil or are confirmed to have experienced 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 ib of the Reporting Requirements for Operating Reactors of the Draft Bulletin will be documented and maintained in accordance with plant procedures.

.l