ML20034F974
| ML20034F974 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/04/1993 |
| From: | Marsh W SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-90-001, IEB-90-1, NUDOCS 9303080024 | |
| Download: ML20034F974 (8) | |
Text
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b y g.g Southem California Edison Company 23 PARKER STREET IRVi WE, CALIFORNIA 92718,
WALTER C. MARSH TMIPHONE NUCL HC G TORY A F AsR$
March 4, 1993 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and'3' Reference NRC Bulletin 90-01, Supplement I dated December 22, 1992;
Subject:
Loss of Fill-Oil in Transmitters Manufactured by Rosemount.
This letter orovides Southern California Edison's (SCE's) response to NRC.
Bulletin 90-01, Supplement 1,," Loss of-Fill-Oil in Transmitters Manufactured by Rosemount" for San Onofre Units 2 and 3.
The details of our response to the Bulletin Supplement are documented in the enclosure of this letter and are summarized below.
SCE will comply with the actions requested by the NRC for Rosemount Model 1153 Series B and D, and Model 1154 transmitters manufactured prior to July 11, 1989 except for the monitoring frequency of category Ib transmitters which may exceed the 24 month monitoring frequency limit provided in the Bulletin (San Onofre Units 2 and 3 operate on a 24 month refueling cycle).
The enhanced monitoring program is being accomplished through the plant's computerized data retrieval system and is currently performing the requested enhanced surveillances for the applicable transmitters. A separate procedure for the enhanced monitoring program will be issued by November 19, 1993.
If you have any questions, please contact me.
Very truly yours, C. Na~
Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V C. W. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2 & 3 H. B. Fields NRC Project Manager, San Onofre Units 2 & 3 050070
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i Response to NRC Bulletin 90-01, Supplement 1 San Onofre Units 2 and 3 NRC Reportino Reauirement 1:
Provide a statement whether the licensee will take the actions requested I
above.
SCE Response:
SCE will comply with the actions requested by the NRC for Rosemount Model 1153 Series B and D, and Model 1154 transmitters manufactured prior to July 11, 1989 except for the monitoring frequency of category lb transmitters which may exceed the 24 month monitoring frequency limit provided in the Bulletin (San Onofre Units 2 and 3 operate on a 24 month refueling cycle).
NRC Reportino Recuirement 2a:
With regard to the actions rt quested above that the licensee is taking, provide 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 justification as appropriate.
SCE Resoonse: (Response numbering corresponds to Actions la-1f in Bulletin 90-01, Supp. 1) la.
High Pressure - SCE will monitor, on a monthly basis for the life of the transmitter, Rosemount Model 1153, Series B and D, and Model 1154 transmitters manufactured before July 11, 1989 installed in high pressure applications in the Reactor Protection System (RPS),
Engineered Safety Feature (ESF) systems, or Anticipated Transients Without Scram (ATWS) systems.
Ib.
High Pressure - SCE will monitor, at least once every refueling cycle *, safety-related Rosemount Model 1153, Series B and D, and Model 1154 transmitters manufactured before July 11, 1989 installed in high pressure applications other than the Reactor Protection System (RPS), Engineered Safety Feature (ESF) systems, or Anticipated Transients Without Scram (ATWS) systems.
This monitoring frequency may not comply with the "not exceeding 24 months" monitoring frequency limit provided in the Bulletin.
SCE's response to NRC reporting requirement 3 provides the required justification.
1
Ic.
Medium Pressure - SCE does not have any safety-related Rosemount Model 1153, Series B and D, and Model 1154 transmitters manufactured before July 11, 1989 installed in medium pressure applications in the Reactor Protection System (RPS), Engineered Safety Feature (ESF) systems, or Anticipated Transients Without Scram (ATWS) systems.
Id.
Medium pressure - For safety-related Rosemount Model 1153, Series B and D, and Model 1154 transmitters manufactured before July 11, 1989 installed in medium pressure applications other than the Reactor Protection System (RPS), Engineered Safety Feature (ESF) systems, or Anticipated Transients Without Scram (ATWS) systems, SCE will monitor each transmitter every 24 months.
le.
Medium Pressure - As permitted by Item 1.e of the subject bulletin, SCE will exclude from the monitoring program, any safety-related Rosemount Model 1153, Series B and D, or Model 1154 transmitter manufactured before July 11, 1989 installed in any medium pressure application that has satisfied its psi-month maturity criterion after SCE has established a high degree of confidence of detecting a loss of fill-oil transmitter failure and after a high degree of reliability has been established for these transmitters.
If.
Low Pressure - As permitted by Item 1.f of the subject Bulletin, SCE will exclude from the monitoring program, any Rosemount Model 1153, Series B and D, and Model 1154 transmitters manufactured before July 11, 1989 in any low pressure application after SCE has established a high degree of confidence of detecting a loss of fill-oil transmitter failure and after a high degree of reliability has been established for these transmitters.
The table attached to this Enclosure lists the Rosemount transmitters installed at San Onofre Units 2 and 3 that are subject to the requirements of Bulletin 90-01, Supplement 1.
NRC Reportina Reauirement 2b:
With regard to the actions requested above that the licensee is taking, provide the schedule for completing licensee actions to meet Item 1 of the Requested Actions provided in this supplement.
SCE Response:
l l
In response to NRC Bulletin 90-01, SCE developed an enhanced surveillance i
monitoring program for all subject Rosemount transmitters. As required by Supplement 1 to Bulletin 90-01, SCE has updated this program to comply with the NRC's new monitoring requirements. Our updated monitoring program uses the techniques described on page 6 of Rosemount Technical Bulletin Number 4 for output drift analysis (trending of actual operating data for some transmitters and evaluation of normal calibration data to determine drift trends for other transmitters).
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4 Although our updated program is currently in place, incorporating these program modifications into a procedure will require several months to I
complete. SCE expects our formal program to be completed by November 19, 1993. SCE is confident that the use of a less formal program prior to completion of our program procedure will not degrade our ability to detect a loss of fill oil condition.
4 NRC Reportina Recuirement 2c:
When completed, provide a statement confirming that Items 1 and 2 of the Requested Actions for 0perating Reactors provided in this supplement have been completed.
SCE Response:
The actions requested by the NRC in this bulletin can be summarized as follows:
Actions la-1f Enhanced transmitter monitoring or transmitter replacement, and Action 2 Evaluation of the enhanced surveillance program to ensure it is adequate to detect a failed transmitter.
Although SCE believes our enhanced surveillance program is adequate to detect a failed transmitter, we will compieta an evaluation of our enhanced monitoring program to verify program adequacy during the preparation of the program procedure. When these actions have been completed, SCE will send the requested notification letter to the NRC.
NRC Reportina Reauirement 3:
Provide a statement identifying those actions requested by the NRC that the licensee is not taking and an evaluation which provides the basis for not taking the requested actions.
SCE Response:
SCE is completing all actions requested in NRC Bulletin 90-01, Supp 1 with one exception. As stated in our response to reporting requirement 2a, SCE will monitor Category Ib transmitters once every refueling outage which may exceed the 24 month limit provided in the Bulletin.
Justification San Onofre has 4 pressurizer pressure low range transmitters per unit.
Two of these transmitters per Unit are manufactured by Foxboro and two by Rosemount and have a calibrated range of 100 psig to 750 psig. These transmitters are used a few weeks per cycle during operation in Modes 3, 4 and 5.
During operation in Modes 1 and 2 (nominal operating pressure a
i 3
2250 ps g) or Mode 6 (RCS pressure at 0 psig with the reactor vessel head removed these transmitters are off scale and cannot be monitored.
The Bulletin allows a surveillance interval of once every refueling outage, but "not exceeding 24 months," for category Ib transmitters which have reached their appropriate psi-month maturity criterion. San Onofre Units 2 and 3 operate on a 24 month refueling cycle with the normal cycle length of approximately 20-22 months. The )ossibility exists, however, for a cycle to last longer than 24 months w11ch would therefore result in the 24 month surveillance limit for these four transmitters being exceeded. SCE believes it is the intent of the Bulletin to monitor category Ib transmitters during refueling outages and not impose an unnecessary plant shutdown to perform this surveillance.
SCE believes this interval is appropriate considering: (1) the safety significance of these transmitters is low, (2) they have reached their a
psi-month threshold criteria recommended by Rosemount, and (3) they are paired with Foxboro transmitters serving the same function.
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f.M EMOUNT 1153 AND 1154 TRANSMITTER 3 MANUFACTURED BEFORE 7/11/89 INSTALLED IN SAFETY RELATED SYSTEMS PAGE 1 OF 2 a.
High Pressure (>1500 psia)
Installed in RPS/EFS/ATWS Systems - Monitor Monthly NATURE NOT MATURE TAG NO.
MODEL FUNCTION P8I-MO*
TAG NO.
MODEL FUNCTION PSI-MO*
2PT01021 1153GD9N PER PRESS WIDE RANGE TR A 156,375 3PT01024 1153GD9N PZR PRESS WIDE RANGE TR D 42,750 3PT01021 1153GD9N PZR PRESS WIDE RANGE TR A 135,000 2PT0114A 1154GP9RA PZR PRESS ATWS/ DSS 58,500 2PT01022 1153GD9N PZR PRESS WIDE RANGE TR B 156,375 3PT0114A 1154GP9RA PZR PRESS ATWS/ DSS 45,000 3PT01022 1153GD9N PZR PRESS WIDE RANGE TR B 135,000 2PT0114B 1154GP9RA PZR PRESS ATWS/ DSS 58,500 2PT01023 1153GD9N PZR PRESS WIDE RANGE TR C 156,375 3PT0114B 1154GP9RA PZR PRESS ATWS/ DSS 45,000 3PT01023 1153GD9N PER PRESS WIDE RANGE TR C 135,000 2PT0114C 1154GP9RA PZR PRESS ATWS/ DSS 58,500 2PT01024 1153GD9N PZR PRESS WIDE RANGE TR D 156,375 3PT0114C 1154GP9RA PZR PRESS ATWS/ DSS 45,000 2PDT09781 1153HD6N SG E089 PRIMARY FLOW D.P.
156,375 2PT0114D 1154GP9RA PER PRESS ATWS/ DSS 58,500 3PDT09781 1153HD6N SG E089 PRIMARY FLOW D.P.
135,000 3PT0114D 1154GP9RA PZR PRESS ATWS/ DSS 45,000 2PDT09782 1153HD6N SG E089 PRIMARY FLOW D.P.
156,375 3PDT09784 1153HD6N SG E089 PRIMARY FLOW D.P.
88,875 3PDT09782 1153HD6N SG E089 PRIMARY FLOW D.P.
135,000 2PDT09783 1153HD6N SG E089 PRIMARY FLOW D.P.
156,375 3PDT09783 1153HD6N SG E089 PRIMARY FLOW D.P.
135,000 2PDT09784 1153HD6N SG E089 PRIMARY FLOW D.P.
156,375 2PDT09791 1153HD6N SG EOSE PRIMARY FLOW D.P.
156,375 3PDT09791 1153HD6N SG Eb60 PRIMARY FLOW D.P.
135,000 2PDT09792 1153HD6N SG E088 PRIMARY FLOW D.P.
156,375 3PDT09792 1153HD6N SG E088 PRIMARY FLOW D.P.
135,000 2PDT09793 1153HD6N SG E088 PRIMARY FLOW D.P.
156,375 3PDT09793 1153HD6N SG E088 PRIMARY FLOW D.P.
135,000 2PDT09794 1153HD6N SG E088 PRIMARY FLOW D.P.
156,375 3PDT09794 1153HD6N SG E088 PRIMARY FLOW D.P.
135,000 High 4ressure (>1500 psia) - safety Related but not installed in RPS/EFS/ATWS Systems - Monitor Quarterly b.
8 MATURE NOT MATURE 2PT01042 1153GD9N PZR PRESS LOW RANGE 2E087 157,500 NONE 3PT01042 1153GD9N PZR PRESS LOW RANGE 3E087 136,125 2PT01064 1153GD9N PZR PRESS LOW RANGE 2E087 157,500 3PT01064 1153GD9N PZR PRESS LOW RANGE 3E087 136,125
ROSEMOUNT 1153 AND 1154 TRANSMITTERD MANUFACTURED BEFORE 7/11/89 INSTALLED IN SAFETY RELATED SYSTEMS PAGE 2 OF 2
- c. Medium Pressure (500-1500 psia) - Installed in RPS/EFS/ATws systems - Monitor each Refueling NOT MATURE NONE
- d. Medium Pressure (500-1500 pela) - Safety Related but not installed in RPS/EF8/ATW8 Systems - Monitor each Refueling NOT MATURE 2LT11151 1153HD5N SG E089 LEVEL WIDE RANGE 29,000 3LT11152 1153HD5N SG E089 LEVEL WIDE RANGE 39,000
- e. Medium Pressure (500-1500 psia) - safety Related but not installed in RPS/EFS/ATWS - May be excluded from enhanced monitoring MATURE 3LT11151 1153HD5N SG E089 LEVEL WIDE RANGE 60,500 2LT11152 1153HD5N SG E089 LEVEL WIDE RANGE 70,000 2LT11251 1153HD5N SG E088 LEVEL WIDE RANGE 70,000 3LT11251 1153HD5N SG E088 LEVEL WIDE RANG 60,500 2LT11252 1153HD5N SG E088 LEVEL WIDE RANGE 70,000 3LT11252 1153HD5N SG E088 LEVEL WIDE RANGE 60,500-
- f. Low Pressure (<500 ps.iv) - May be excluded from enhanced monitoring NOT MATURE 2LT4355 1153DD3PB CDST T121 LVL NARROW RANGE 860 3LT4355 ll53DD3PB CDST T121 LVL NARROW RANGE 397 2LT4356 1153DD3PB CDST T121 LVL WIDE RANGE 265 3LT4356 1153DD3PB CDST T121 LVL WIDE RANGE 698 PSI-MO as of January 15, 1993 m,w n
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