ML20034G478
| ML20034G478 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/01/1993 |
| From: | Parker T NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-90-001, IEB-90-1, NUDOCS 9303090571 | |
| Download: ML20034G478 (10) | |
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Northem States Power Company s:.
414 Nscollet Mall fAnneapohs, tAnneso %401 Telephone (612) 3304, Ou March 1, 1993 NRC Bulletin 90-01 Supplement 1 i
US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
.i PRAIRIE IS1AND NUCLEAR GENERATING PIANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 l
Response to NRC Bulletin No. 90-01 Supplement 1 lays of Fill-Oil In Transmitters Manuf..tured By Rosemount The following information is provided in response to the reporting requirements contained in NRC Bulletin 90-01, Supplement 1. " Loss of F111-011 l
in Transmitters Manufactured by Rosemount."
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Reporting Requirement No. 1 states:
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[ Provide within 60 days) a statement whether the licensee will take the actions requested [by NRC Bulletin 90-01, Supplement 1).
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Response
The actions requested by NRC Bulletin 90-01, Supplement 1, that are applicable to the Rosemount transmitters located at the Prairie Island Nuclear Generating Plant, have been taken and completed, a
Reporting Requirement No. 2 states:
With regard to the action requested above that the licensee is taking
[ provide]:
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- a. A list of the specific actions that the licensee will complate to meet Item 1 of Requested Actions for Operating Reactors provided in'INRC Bulletin 90-01, Supplement 1.]
- b. The schedule for completing licensee action to meet Item 1 of Requested Action provided in [NRC Bulletin 90-01, Supplement 1.]
- c. When completed, a statement confirming that Items 1 and 2 of requested Actions for Operating Reactors provided in [NRC Bt'~'atin 90-01, Supplement 1] have been completed.
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9303090571 930301
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i USNRC NORTHERN STATES POWER COMPANY March 1, 1993 Page 2
Response
- a. Details of specific actions taken and/or justifications are contained in Attachment 2.
- b. All actions required to meet Item 1 of the Requasted_ Actions are currently being performed at Prairie Island. The actions to meet Item 1 of the Requested Actions have been performed at Prairie Island since our response to the original Bulletin 90-01.
The high pressure transmitters have been voluntarily monitored at Prairie Island on quarterly _and/or refueling intervals.
- c. All the actions required to meet Items 1 and 2 of the Requested Actions are currently being performed. We censider the actions to meet Items 1 and 2 of the Requested Actions to be complete. The actions to meet Items 1 and 2 of the Requested Actions of Supplement I have been I
performed at Prairie Island since our response to the original Bulletin 90-01.
Reporting Requirement No. 3 states:
[ Provide) a statement identifying those actions requested by the NRC that I
the licensee is not taking and an evaluation which provides the bases for not taking the requested actions.
Response
Actions to meet Item 1 and 2 of the Requested Actions have been completed as applicable. See Attachment 2 for additional detail.
t With this response we are making the following new commitments:
- 1. The eight Rosemount transmitters used for post accident monitoring of reactor coolant system pressure and as such are installed in a safety-related application that has a normal operating pressure greater than 1500 psi, will be monitored, using an enhanced surveillance program, at least once each refueling cycle, but not exceeding every 24 months.
- 2. Tbe sixteen transmitters installed Ln reactor protection trip systems, ESF actuation systems, or ATWS systems that have a normal operating pressure greater than or equal to 500 psi and-less than or equal to 1500 psi will be monitored at least once each refueling cycle, not to exceed every 24 months, using an enhanced surveillance program until the transmitter reeches the appropriate psi-month threshold criterion recommended by Rosemount.
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- 3. Three Spare 2ransmitters for the reactor protection trip systems, ESF actuation systems, or ATWS systems that have a normal operating pressure greater than or equal to 500 psi and leas than or equal to 1500 psi will be returned te Rosemount for rafurbishment
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USNRC NORTHERN STATES POWER COMPANY March 1, 1993 I
Page 3 Please contact Gene Eckholt (612) 388-1121 ext 4663 if you have any_ questions j
related to the information we have provided.
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//*w Thomas M Parker i
Director Nuclear Licensing c: Regional Administrator - III, NRC NRR Project Manager, NRC Sr Resident Inspector, NRC l
State of Minnesota Attn: Kris Sanda J Silberg i
Attachments:
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- 1) Affidavit
- 2) Prairie Island Response to Requested Actions for Operating Reactors j
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ATTACH!iENT 1 UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PIANT DOCKET NO. 50-282 50-306 LOSS OF FILL-0IL IN TRANSMITTERS MANUFACTURED BY ROSEMOUNT Northern States Power Company, a Minnewta corporation, with this letter is submitting information requerted by NM Bulletin 90-01, Supplement 1.
This letter contains no restricted or other def nse information.
NORTHERNSTAJESPW4 C iPANY
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By
/M'J"#
- Tisomits M Parker Director Nuclear Licensing Onthis!
day of
[f before me a notary public in and for said County, personaTy appeared Tinmas M Parker, Director Nuclear Licensing, and being first duly sworn acknowledged that he is authorized to execute this document on behalf of Northern States Power Company, that he knows the contents thereof, and that to the best of his knowledge, information, and belief the statements made in it are true and that it is not interposed for delay.
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\\l m::::::::::::::::::::.v::::::::: ve MARCA K LaCORE NOTARY PUBLIC-MINNESDIA HENtJEPIN COUNTY Wy Commeson Expires Sept 24,1933 r::::::::::::::::::::::::::::::::::n
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't ATTACHMENT 2
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l Prairie Island Response to Recuested Actions for Operatinn Reactors
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.t Recuested Action No. 1 Review plant records and identify any Rosemount Model 1153 Series B.
Model 1153 Series D, and Model 1154 transmitters manufactured: before July.
11, 1989, that are used or may be used in the future in~either i
safety-related systems or systems installed in accordance with 10 CFR 50.62 (the ATWS rule), and
- a. Expeditiously replace, or monitor for the life of the transmitter on a f
monthly basis using an enhanced surveillance monitoring program, any.
transmitters that have a normal operating pressure greater than 1500 psi-and that are installed in reactor protection trip systems, ESF actuation systems or ATWS systems. _ Action for those transmitters that have,not
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met the Rosemount psi-month threshold criterion should be expedited. At t
their discretion, licenses may monitor using an enhanced surveillance program at least once every refueling cycle, but not exceeding 24 months, transmitters in this category if the appropriate psi-month i
threshold criterion recommended by Rosemount has been reached, and the monitoring interval is justified based upon transmitter performance in '
service ano its specific safety function. The justification should show l
that a sufficiently high level of reliability for the function is provided by the redundancy or diversity of applicable instrumentation -
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and control systems, commensurate with the importance of the function,.
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when considered in conjunction with the overall performance of the reactor protection trip system, ESF actuation systems,'or ATWS system.
Provide to the NRC a copy of the licensee justification to extend the enhanced surveillance program beyond the monthly test interval for.
l transmitters that have reached the appropriate psi-month threshold l
criterion recommended by Rosemount.
- b. Replace, or monitor for the life of the transmitter on a quarterly basis using an enhanced surveillance monitoring program, any transmitters that
-i have a normal operating pressure greater than 1500 psi and that are used t
in safety-related applications but are not installed in reactor protection trip systems, ESF actuation systems, or ATWS systems. At their discretion, licensees may monitor using an enhanced surveillance program at least once every refueling cycle, but not exceeding 24 l
months, transmitters in this category if the appropriate psi-month
.i threshold criterion recommended by Rosemount has been reached, and the
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monitoring interval is justified based upon transmitter performance in service and its specific function.
Provide to the NRC a copy of the
'i licensee justification to extend the enhanced surveillance program
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beyond the quarterly test interval for transmitters that have reached the appropriate psi-month threshold criterion recommended by Rosemount.
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- c. [For BWRs) Replace, or monitor on a monthly basis using an enhanced surveillance monitoring program, until the transmitter reaches the-appropriate psi-month threshold criterion recommendad by Rosemot* ;, any transmitters that have a normal operating pressure greater thar 300 psi and'less'than or equal to 1500 psi,.that are installed in reactor protection trip systems, ESF actuation systems or ATUS systeas. On a.
t case-by-case basis except for transmitters that initiate' reactor
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protection or ATWS trips for high pressure or low water level, licensees j
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March 1, 1993 Page 2 i
i Prairie Island Response to Reauested Actions for Operatinn Reacte,g
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.f may monitor using an enhanced surveillance program at'least once every i
refueling cycle, but not exceeding 24 months, if sufficient'.
justification is provided based upon transmitter performance in service and its specific safety function. The justification should show ti.it a-sufficiently high level of reliability for the function is provided by the redundancy or diversity of applicable instrumentation and control systems, commensurate with the importance of,the function, when considered in conjunction with the overall performance of the reactor protection trip system, ESF actuation systems, or ATWS system.
Provide
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to the NRC a copy of the licensee justification to extend the enhanced surveillance program beyond the monthly test interval.
[For PWRs) Replace, or monitor at least once every refueling cycle, but not exceeding 24 months, using an enhanced surveillance program unti1~
the transmitter reaches the appropriate psi-month thrcshold criterion recommended by P.osemount, any transmitters that have a normal operating j
pressure greater than 500 psi and less than or equal to 1500 psi and
-l that are installed in reactor protection trip systems, ESF actuation.
systems, or ATWS systems.
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- d. Replace, or monitor at least once every refueling cycle, but not f
exceeding 24 months, using an enhanced surveillance monitoring program-l until the transmitter reaches the appropriate psi-month threshold criterion recommended by Rosemount, any transmitters used in i
safety-related systems that have a normal operating pressure greater then 500 psi and less than or equal to 1500 psi, and that are not installed in reactor protection trip systems, ESF actuation systems, or ATWS systems.
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- e. At licensee discretion, exclude from the enhanced surveillance program any transmitters that have a normal operating pressure greater than 500 psi and less than or equal to 1500 psi that have reached the appropriate l
psi-month threshold criterion recommended by Rosemount (60,000
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psi-months or 130,000 psi-months depending on the range code of the j
transmitter). A high degree of confidence should be maintained for detecting failure of these transmitters caused by a loss of fill-oil and a high degree of reliability should be maintained for the function
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consistent with its safety significance.
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- f. At licensee discretion, exclude frca the enhanceo surveillance program any transmitters that have a normal operating pressure less than or equal to 500 psi. A high degree of confidence should be maintained for i
detecting failure of these transmitters caused by a loss of fill-oil and e
a high degree of reliability should be maintained for the function consistent with its safety significance.
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March 1, 1993 Page 3 frairie Island Response to Recuested Actions for Operating Reactors
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Resnonse
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Plant records have been reviewed and Rosemount Model 1153 Series B, Model 1153 Series D, and Model 1154 transmitters manufactured before July 11, 1989 that are used or may be used in the future in either safety-related systems or systems installed in accordance with 10 CFR 50.62 (ATUS) have been id'ntified i
as follows:
TAG NO DESCRIPTION SYSTEM PRESS i
1FT-177 11 RCP SEAL LEAK 0FF FLOW VC 50 1FT-178 12 RCP SEAL LEAKOFF FLOW VC 50 f
IFT-464 11 STEAM GENERATOR STEAM FLOW RP 710 l
1FT-465 11 STEAM GENERATOR STEAM FLOW RP 710
-IFT-466 11 STEAM GENERATOR FEEDWATER W
1130 FIDW
- IFT-467 11 STEAM GENERATOR FEEDWATER FW 1130 l
FLOW
- 1FT-474 12 STEAM GENERATOR STEAM FLOW RP 710 t
IFT-475 12 STEAM GENERATOR STEAM FIDW RP 710 1FT-476 12 STEAM GENERATOR FEEDWATER W
1130 FLOW
- 1FT-477-12 STEAM GENERATOR FEEDWATER FW 1130 f
FLOW
1FT-925 1 S1 COLD LEG INJ LINE FLOW SI 2200t i
i 1PT-709 11 REACTOR C001>.NT LOOP FRESSURE EM 2235 IPT-710 12 REACTOR COOLANT _ LOOP PRESSURE EM 2235 1FT-751 11 REACTOR COOLANT LOOP PRESSURE EM 2235 i
1PT-761 12 REACTOR COOLANT LOOP PRESSURE EM 2235 2FT-177 21 RCP SEAL LEAK 0FF F1hW VC 50 2FT-178 22 RCP SEAL LEAK 0FF FLOW VC 50
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2FT-464 21 STEAM GENERATOR STEAM FLOW RP 710
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2FT-465 21 STEAM GENERATOR STEAM F1hV RP 710 2FT-466 21 STEAM GENERATOR FEEDWATER FW 1130 FLOW
- 2FT-467 21 STEAM GENERATOR FEEDUATER W
11 1 l
FLOW
- t 2FT-474 22 STEAM GENERATOR STEAM FIDW RP 710 l
2FT-475 22 STEAM GENERATOR STFAM FLOW RP 710 j
2FT-476 22' STEAM GENERATOR FEEDWATER FW 1130 l
MAW
- l 2FT-477 22 STEAM GENERATOR FEEDWATER FW 1130 FIEW
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Page 4 I
'I Prairie Island Response to Recuested Actions for Operatine Reactors TAG NO DESCRIPTION SYSTEM PRESS i
2FT-924-2 SI RX VESSEL INJ LINE FLOW SI 2200t
.i 2FT-925 2 SI COLD LEG INJ LINE FLOW SI 2200t 2PT-709 21 REACTOR COOLANT LOOP PRESSURE EM 2235 l
2PT-710 22 REACTOR COOLANT LOOP PRESSURE EM 2235 2PT-751 21 REACTOR COOLANT LOOP PRESSURE EM 2235 l
t 2PT-761 22 REACTOR COOLANT LOOP PRESSURE EM 2235 I
415083 Spare Xmtr Model 1153HD6RC N/A N/A 409658 Spare Xmtr Model 1153HD6RC N/A N/A 409659 Spare Xmtr Model 1153HD6RC N/A N/A j
- ATWS Related t
- Normally at Ambient Pressure EM - Event Monitoring (post-accident)
RP - Reactor Protection SI - Safety Injection (Non-Safety Related)
VC - Volume Control (Non-Safety Related)
N/A - Not Applicable
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- a. No Rosemoun;. Model 1153 Series B, Model 1153 Series D or Model 1154
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transmitters manufactured prior to July 11, 1989 are currently installed in reactor protection trip, ESF actuation or ATWS systems that have a normal operating pressure of greater than 1500 psi.
- b. Eigit of the transmitters listed above, which monitor Reactor Coolant Pressure, are installed in safety-related applications that have a normal opersting pressure greater than 1500 psi These eight transmitters will be monitored at least once each refueling cycle, but not exceeding every 24 j
months.
f Justification:
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These eight transmitters were installed to monitor Reactor Coolant System l
Pressure to satisfy Regulatory Guide 1.97 and NUREG-0737 requirements for i
Post-Accident Monitoring.
These instruments provide control room
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indication for use during the performance of the Emergency Operating Procedures. Multiple redundant sources of Reactor Coolant Pressure are
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indication l
available.
The operators are provided training to use redundant when available.
The plant Emergency Response Computer System automatically' l
alarms when redundant indication deviates by more than a pre-set amount, alerting the operator to the degraded information.
These transmitters have been part of an crihanced surveillance program since the original Bulletin l
90-01 was issued. This program included trending calibration information since installation of the transmitters, in accordance with the published manufacturer guidelines. None of the transritters have shown indication of i
loss of fill-oil as evidenced by calibrati<.u-trending and/or quarterly process noise analysis.
Each of these transmitters were installed between i
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March 1, 1993 Page 5 1
Prairie Island Response to Recuested Actions for Operatinz-Reactors j
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December 1981 and December 1987. Normal process pressure for each of the-l transmitters is 2235 psi. Each of the transmitters has well exceeded the-
-j time at pressure criteria of 60,000 psi-months'and is considered mature.
Actual transmitter maturity ranges from 124,000 to 270,000 psi-months.
- c. Sixteen of the transmitters listed above, are installed in reactor
.l protection trip systems, ESF actuation systems, or ATWS systems that have a j
normal operating pressure greater than or equal to 500 psi and less than or equal to 1500 psi.
Each of these transmitters will be monitored-at least
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once each refueling cycle, not to exceed every 24 months, using an' enhanced
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surveillance program until the transmitter reaches the appropriate psi-month threshold criterion recommended by Rosemount. Three Spare transmitters for these functions are' listed above. These transmitters will l
be returned to Rosemount for refurbishment.
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- d. No Rosemount Model 1153 Series B, Model 1153 Series D or Model 1154 transmitters manufactured prior to July 11, 1989 are currently installed in i
safety-related systems other than reactor protection trip, ESF actuation or
- l ATWS systems that have a normal operating pressure of greater than 500 psi and less than 1500 psi.
- e. Safety-Related transmitters that have a normal operating pressure greater
-j than 500 psi and less than 1500 psi that reach the appropriate psi-month i
threshold criteria recommended by Rosemount will be excluded from the enhanced surveillance program at Northern States Power's discretion'.
.l Existing administrative controls for Instrument _and Control, Operations and' i
Engineering ensure a high degree of confidence in detection of a loss of-fill oil problem. Redundant and diverse transmitters exist to ensure that a high degree of reliability is maintained for the applicable functions.
Four transmitters are installed in non-safety related applications that f
have a normal operating pressure greater than 500 psi and less than 1500 psi.
These transmitters only see normal operating pressure for one hour-per month during testing of the associated system.
For the remainder of-the month these transmitters see ambient pressure.
The average pressure for these transmitters is well below 500 psi.
Therefore, these transmitters will be excluded from the enhanced surveillance program at r
Northern States Power's discretion.
Existing administrative controls for Instrument and Control, Operations and Engineering ensure a high degree of confidence in detecting a loss of fill-oil problem. The low average pressure for this application precludes the mechanism for oil-loss, thus a high degree of reliability will be maintained.
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- f. Four of.the transmitters listed above have normal operating pressures less j
than 500 psi. 1These transmitters will be excluded from the enhanced surveillance program at Northern States Power's discretion.
Existing administrative controls for Instrument and Control, Operations and Engineering ensure a high' degree of confidence in detecting a loss of fill oil problem.
The. low operating pressure for this application precludes the mechanism for oil-loss thus a high degree of' reliability will be j
maintained.
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' Attachment 2-
-March:1, 1993-
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b Prairie Island Resnonse to Recuested Actions' for Oneratine Reactoru Reouested Action-No. 2 e
Evaluate the erManced surveillance monitoring program to ensure that the program provides measurement data with an accuracy range consistent with that needed for comparison with manufacturer drift data. criteria for determining degradation caused by a loss of fill-oil.
Resoonse The enhanced surveillance program consists of trending accumulative i
transmitter zero and spaa drift and comparison with Rosemount specified drift acceptance criteria. The program requires additional testing be performed if
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cumulative drift exceeds the acceptance criteria. This testing-is consistent with that recommended by Rosemount.
Zero and Span data are recorded during refueling interval calibrations using calibrated test equipment.
Data is-i recorded to an accuracy consistent with that-to permit. comparison with manufacturer drift acceptance criteria.
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