ML20034H042

Responds to Suppl 1 to NRC Bulletin 90-001 to Resolve Concerns Re Potential Loss of fill-oil in Transmitters Mfg by Rosemount.Mature,Medium Pressure Transmitters Currently Included in Enhanced Surveillance Program

ML20034H042
Person / Time
Site:	Beaver Valley
Issue date:	03/08/1993
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-90-001, IEB-90-1, NUDOCS 9303150165
Download: ML20034H042 (6)

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l YM Q ver Valley Power Station Shippingport. PA 15077-0004 JOHN D. SIEBER (412) 393-5255 Senior Vice President and Fax (412) 643-8069 Chief Nuclear Officer March 8, 1993 Melear Power Division i

U.

S.

Nuclear Regulatory Commission Attn:

Document Control Desk Washington, DC 20555

Subject:

Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 i

Response To NRC Bulletin 90-01, Supplement 1 Bulletin 90-01, Supplement 1,

requested a

response which describes DLC actions to resolve concerns related to potential loss of fill oil on some Rosemount transmitters.

DLC has identified pertinent models manufactured before July 11, 1989 which are used in safety-related or ATWS applications.

The following responses are provided for each of the requested actions found in the Supplement:

1.a. Reauested ActioD*

Expeditiously

replace, or monitor for the life of the transmitter on a

monthly basis using an enhanced surveillance monitoring

program, any transmitters that have-a normal

.i 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 met the Rosemount psi-month threshold criterion should be expedited.

At their discretion, licensees 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 threshold criterion recommended by Rosemount has been reached, and the monitoring interval is justified based upon transmitter performance in service and its specific safety function.

The justification should show that 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 to the NRC a

copy of the licensee justification to:

extend the enhanced surveillance program beyond the monthly test interval for transmitters that have reached the appropriate psi-month threshold criterion recommended by Rosemount.

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Beaver Valley Power Station, Unit No. 1 and No. 2

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BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 R'esponse To NRC Bulletin 90-01, Supplement 1 Page 2 l

Response

DLC has no immature high pressure transmitters in service.

Three mature high pressure transmitters are installed in BVPS-1 and are currently included in an enhanced surveillance program with an 18-month frequency.

Since the Unit is scheduled for a refueling outage which begins in less than one month, DLC plans to provide a

supplemental response containing written justification for a frequency which is less often than monthly.

This response will be provided prior to startup from this outage (currently scheduled for May 31, 1993).

1.b.

Reauested Action:

Replace, or monitor for the life of the transmitter on a quarterly basis using an enhanced surveillance monitoring

program, any transmitters that have a normal operating pressure greater than 1500 psi and that are used 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

months, transmitters in this category if the appropriate psi-month threshold criterion recommended by Rosemount has been

reached, and the monitoring interval is justified based upon transmitter performance in service and its specific function.

Provide to the NRC a

copy of the licensee justification to extend the enhanced surveillance program beyond the quarterly test interval for transmitters that have reached the appropriate psi-month threshold criterion recommended by Rosemount.

Response

i i

J DLC has no immature high pressure transmitters in service.

Four mature high pressure transmitters are installed in BVPS-1 and are currently included in an enhanced surveillance program with an 18-month frequency.

Since the Unit is scheduled for a refueling outage which begins in less than one month, DLC plans to provide a

supplemental response containing written justification for a

frequency which is less often than quarterly.

This response will be provided prior to startup from this outage (currently scheduled for May 31, 1993).

i

i Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 1

BV-2 Docket No. 50-412, License No. NPF-73

' Response To NRC Bulletin 90-01, Supplement 1 Page 3 1.c.

Reauested Action:

Replace, or monitor at least once every refueling cycle, but not exceeding 24 months, using an enhanced surveillance program until the transmitter reaches the appropriate psi-month threshold criterion recommended by Rosemount, any transmitters that have a normal operating pressure greater than 500 psi and less than or equal to 1500 psi and that are installed in reactor protection trip

systems, ESF actuation systems, or ATWS systems.

Response

Immature medium pressure transmitters are currently i

included in an enhanced surveillance program with an interval not exceeding 24 months.

This action is complete.

1.d.

Recuested Action:

Replace, or monitor at least once every refueling cycle, but not exceeding 24 months, using an enhanced surveillance monitoring program until the transmitter reaches the appropriate psi-month threshold criterion recommended by Rosemount, any transmitters used in safety-related systems that have a normal operating pressure greater than 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.

Response

Immature medium pressure transmitters are currently included in an enhanced surveillance program with an interval not exceeding 24 months.

This action is complete.

1.e.

Recuested Action:

At licensee discretion, exclude from the enhanced surveillance program any transmitters that have a normal i

operating pressure greater than 500 psi and less than or equal to 1500 psi that have reached the appropriate psi-month threshold criterion recommended by Rosemount

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(60,000 psi-months or 130,000 psi-months depending on the range code of the 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 t

degree of reliability should be maintained for the function consistent with its safety significance.

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Beaver Valley Power Station, Unit No. 1 and No. 2 I

BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Bocket No. 50-412, License No. NPF-73 l

R'esponse To NRC Bulletin 90-01, Supplement 1 Page 4 i

Response

Mature medium pressure transmitters are currently included in an enhanced surveillance program with an interval not exceeding 24 months.

When DLC is satisfied that a high degree of confidence is maintained for detecting failure i

due to loss of fill oil and that a

high degree of reliability is being maintained consistent with its safety significance, these transmitters may be eliminated from the enhanced surveillance program.

This action is complete.

1 1.f. Reauested Action:

At licensee discretion, exclude from the enhanced t

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 detecting failure of these transmitters caused by a loss of fill-oil and a

high degree of reliability should be maintained for the function consistent with its safety significance.

Response

i y

Low pressure transmitters are not currently included in an i

enhanced surveillance program.

DLC plans to further evaluate these transmitters prior to the end of the BVPS-1 f

refueling outage.

Where DLC is satisfied that a high degree of confidence is maintained for detecting failure due to loss of fill oil and that a

high degree of reliability is being maintained consistent with its safety significance, these transmitters will not be added to the enhanced surveillance program.

All other low pressure transmitters which the Bulletin describes will be added to the program.

A supplemental response to this item will be i

provided prior to startup from the BVPS-1 outage (currently scheduled for May 31, 1993).

2.

Reauested Action:

t Evaldate the enhanced surveillalce monitoring program to i

ensure that the program provides measurement data with an accuracy range consistent with that needed for comparison l

with manufacturer drift data criteria for determining

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degradation caused by a loss of fill-oil.

Response

The enhanced surveillance program provides measurement data with an accuracy range as described in the staff conclusion 3 of the supplement.

This action is complete.

i

t Beaver Valloy Power Station, Unit No. I and No. 2 BV-1 Docket-No._50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 i

Response To NRC Bulletin 90-01, Supplement 1 Page 5

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Should you have any questions regarding our actions related to this

Bulletin, please direct them to G.

L.

Beatty at (412) 393-5225.

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Sincerely,

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ff.

D.

Sieber l

cc:

Mr.

L. W.

Rossbach, Sr. Resident Inspector Mr. T. T. Martin, NRC Region I Administrator i

Mr.

G.

E.

Edison, Project Manager Mr. M.

L. Bowling (VEPCO)

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AFFIDAVIT FOR APPLICATION OF AMENDMENT COMMONWEALTH OF PENNSYLVANIA)

) SS:

COUNTY OF BEAVER

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Subject:

Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Responso To NRC Bulletin 90-01, Supplement 1 Before me, the undersigned notary public, in and for the County and Commonwealth aforesaid, this day personally appeared John D.

Sieber, to me known, who being duly sworn according to law, deposes and says that he is Senior Vice President and Chief Nuclear Officer of the Nuclear Power

Division, Duquesne Light Company, he is duly authorized to execute and file the foregoing submittal on behalf of said

Company, and the statements set forth in the submittal are true and correct to the best of his knowledge, information and belief.

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~ John D.

Sieber

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r Subscribed and sworn to before me on this d /

day of (24#/[f

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Notary Public--

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