ML20034E676

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Forwards Response to Suppl 1 to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Util Does Not Intend to Develop Quarterly Enhanced Surveillance Monitoring Program for Transmitter BG-FT-0215A
ML20034E676
Person / Time
Site: Callaway 
Issue date: 02/23/1993
From: Schnell D
UNION ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-90-001, IEB-90-1, ULNRC-2766, NUDOCS 9303010181
Download: ML20034E676 (6)


Text

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311.E5L2L53 E UNIOh, DonstdF. Schnell sa, me even LECTIUC nm

$*3 February 23, 1993 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Mail Station P1-137 Washington, D.C.

20555 Gentlemen:

ULNRC-2766 DOCKET NUMBER 50-483 CALLAWAY PLANT NRC BULLETIN 90-01, SUPPLEMENT 1:

LOSS OF FILL-OIL IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT

Reference:

ULNRC-2255 dated July 18, 1990 The attachment to this letter addresses the requested reporting requirements in Bulletin No. 90-01 Supplement 1 concerning failure of Rosemount transmitters.

If there are any questions concerning this issue, please contact us Very truly yours,

/

ODL Donald F.

Schnell GGY/plh 010C55 9303010181 930223

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t STATE OF MISSOURI )

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SS CITY OF ST. LOUIS )

j Donald F.

Schnell, of lawful age, being first duly sworn i

upon oath says that he is Senior Vice President-Nuclear and an officer l

of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By

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doi 1ald F. Schnell Senior Vice President I

Nuclear SUBSCRIBED and sworn to before me this d'3 deb day of J'a elLa s-t > ss 1

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cc:

T. A.'Baxter, Esq.

Shaw,/Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C.

20037 Dr:

J.

O. Cermak CFA, Inc.

18225-A Flower Hill Way Gaithersburg, MD 20879-5334 j

L.' Robert Greger Chief, Reactor Project Branch 1

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U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road i

Glen Ellyn, Illinois 60137 l

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Bruce Bartlett 1

Callaway Resident Office' U.S. Nuclear Regulatory Commission i

RR#1 Steedman,-Missouri 65077 t

L. R. Wharton (2)

Office of Nuclear Reactor Regulation l

U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 l

11555 Rockville Pike

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Rockville, MD 20852 l

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Manager, Electric Department j

Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 f

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Provide within 60 days after receipt of this bulletin a response that includes the following t

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1.

A statement whether the licensee will take the actions i

requested above (as stated on pages 9-11 of the supplement).

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Union Electric ResDonse Union Electric will replace one transmitter (used to monitor CVCS l

Seal Water Injection Flow), as discussed below.

No other j

specific actions are required at Callaway.

i 2.

With regard to the actions requested above that the licensee

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is taking:

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a.

A list of the specific actions that the licensee will complete to meet Item 1 of the Requested Actions for Operating Reactors provided in this supplement, including justifications as appropriate.

b.

The schedulc for completing licensee actions to meet Item 1 of Requested Actions provided in this

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supplement.

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When completed, a statement confirming that Items 1 and 2 of Requested Actions for Operating Reactors provided in this supplement have been completed.

Union Electric Resoonse i

Our original Bulletin No. 90-01 response, ULNRC-2255 dated July f

18, 1990, discussed the identification of 118 Rosemount Model j

1153 Series B and D transmitters at Callaway.

That letter should j

have clarified that three of those 118 are used in non-safety i

applications such that 115 transmitters fell under the scope of the Bulletin.

Since that time, two additional Rosemount Model i

1153 Series B transmitters have been installed in applications that previously used Barton transmitters (i.e. BG-FT-0215A & B, CVCS Seal Water Injection Flow).

As of this date there are'117 i

Rosemount Model 1153 Series B and D transmitters used in safety-related applications at Callaway.

Of these 117, 60 transmitters are non-1E and safety-related for pressure boundary integrity

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only.

Loss of fill-oil from the sensor module of these nrn-1E-transmitters would have no safety impact since the safety function, pressure boundary integrity, is ensured by the process O-ring.

These 60 transmitters were not included in the following i

scope of activities, as originally highlighted in ULNRC-2255.

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The 57 Class 1E Rosemount transmitters fall into the following i

categories as called out in the supplement:

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Fage 1 of 3 l

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1.

RPS, ESEAS, and AMSAC systems, normal operating pressure l

>1500 psi - No such Rosemount transmitters are used at Callaway.

2.

All other safety-related systems, normal operating pressure l

>1500 psi - There are five such Rosemount transmitters used at Callaway.

Four of these five have sensor modules manufactured after July 11, 1989 (sensor module serial numbers greater than 2182605).

On August 9, 1990 one of the transmitters used to measure CVCS Seal Water Injection Flow,

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BG-FT-0215A, was replaced with a Rosemount Model 1153 Series B transmitter that has a sensor module manufactured before July 11, 1989.

This transmitter will be replaced with one manufactured after July 11, 1989.

This replacement will be made as soon as possible, certainly prior to startup from the next refueling outage, scheduled for the fourth quarter of this year.

We have no spare transmitters for this application, therefore a new transmitter has been ordered.

l Were it not for two refueling outages since it was installed, this transmitter would have surpassed the 60,000 l

psi-month service threshold criterion after which quarterly monitoring could be extended to 18-24 months per the supplement.

With consideration given to this service i

period as well as to the indication-only function of this transmitter and the fact that its redundant transmitter, BG-i FT-0215B, has a sensor module manufactured after July.11, i

1989, we do not intend to develop an enhanced surveillance monitoring program for this one transmitter prior to its being replaced later this year.

3.

RPS, ESFAS, and AMSAC systems, normal operating pressure I

>500 psi and s1500 psi - No such Rosemount transmitters are i

used at Callaway.

4.

All other safety-related systems, normal operating pressure

>500 psi and s1500 psi - There are eight such transmitters used at Callaway.

Five of these eight have sensor modules i

manufactured after July 11, 1989.

The other three have surpassed the 60,000 psi-month service threshold criterion and, as allowed by the supplement, will not be subjec., to an enhanced surveillance monitoring program.

5.

All safety-related systems, normal operating pressure 5500 psi - There are 44 such transmitters used at Callaway, including 7 auxiliary feedwater (AFW) flow transmitters that l

are subject to AFW pump discharge pressures greater than i

1000 psi when the pumps are running; however, since this standby system is not normally operating there is no i

pressure on these transmitters during normal operation.

i There has been no indication at Callaway that these AFW flow l

transmitters have experienced any symptoms of a loss of l

fill-oil.

As allowed by the supplement, these transmitters L

will not be subject to an enhanced surveillance monitoring program.

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With regard to the above transmitters with sensor modules l

manufactured prior to July 11, 1989 that either have surpassed

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the 60,000 psi-month service threshold criterion or are used in low pressure applications, we will maintain a high degree of confidence for detecting failures caused by a loss of fill-oil

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and we will maintain a high degree of reliability for these transmitters, commensurate with their safety significance.

In summary, there is no requirement for an enhanced surveillance monitoring program at Callaway given the replacement of one transmitter prior to startup from the next refueling outage.

The NRC will be notified after the BG-FT-0215A transmitter is replaced.

3.

A statement identifying those actions requested by the NRC that the licensee is not taking and an evaluation which provides the bases for not taking the requested actions.

i As discussed above, we do not intend to develop a quarterly enhanced surveillance monitoring program for one transmitter, BG-FT-0215A, prior to its being replaced later this year.

This transmitter will be replaced with one manufactured after July 11, 1989.

This replacement will be made as soon as possible, i

certainly prior to startup from the next refueling outage, scheduled for the fourth quarter of this year.

Prior to being

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replaced, the installed transmitter will surpass the 60,000 psi-month service threshold criterion after which quarterly monitoring could be extended to 18-24 months per the supplement.

We do not believe it to be cost-effective or necessary to implement an enhanced surveillance monitoring program on an interim basis for this~one transmitter if consideration is given I

to its service thus far as well as to its indication-only function and the fact that it has a redundant transmitter, BG-FT-t 0215B, which has a sensor module manufactured after July lle j

1989.

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I Page 3 of 3