ML20044B859
| ML20044B859 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/05/1993 |
| From: | Chrzanowski D COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| IEB-90-001, IEB-90-1, NUDOCS 9303110007 | |
| Download: ML20044B859 (6) | |
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/ 1400 Opus Place Downers Grove, filinois 60515 March 5, 1993 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk
Subject:
Response to NRC Bulletin 90-01 Supplement 1, dated December 22, 1992.
Braidwood Units 1 and 2, (NRC Docket Numbers 50-456 and 50-457)
Reference:
NRC Bulletin 90-01 Supplement 1, " Loss of Fill Oil in Transmitters Manufactured by Rosemount," dated December 22, 1992.
4
Dear Dr. Murley:
The purpose of this letter is to provide the Braidwood Station response to the requested actions of Bulletin 90-01 Supplement 1. The details of the Braidwood response are contained in Attachment 1 and a tabular summary is provided in Attachment 2.
Braidwood has a total of forty-two (42) transmitters within the scope of the referenced Bulletin; however, no enhanced monitoring more frequently than a refueling cycle will be required. This determination is based on transmitter maturity, operating pressure and Bulletin categorization.
Consistent with the Bulletin's reporting requirements, Braidwood Station has reviewed the requested actions and agrees to comply with all applicable actions. Specifically, Braidwood will:
maintain an enhanced surveillance program, at a refueling outage frequency, for the eight (8) transmitters in Bulletin category 1.c until the transmitters reach maturity.
This action satisfies completely the recommendations of the Supplement and-no additional actions or justifications are required.
096009 I
9303110007 930305 PDR G
ADOCK 05000456 n0 l
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INLD/2521/1 I-
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s, Dr. Hurley March 5, 1993 To the best of my knowledge and belief, the statements contained in this-document are true and correct. In some respects these statements are not based on my personal knowledge, but on information furnished by other Commonwealth-Edison employees, contractor employees, and/or consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
If there are any questions or comments, please contact me.
Sincerely, 3
D\\
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David J. Chrzanowski Generic Issues Administrator Nuclear Regulatory Services Attachments: Attachment 1 - Response to NRCB 90-01 S1 Actions - Tabular Summary of Transmitter Status cc:
Regional Administrator-RIII Braidwood Project Manager-NRR/PDIII-2 S. DuPont, Senior Resident Inspector (Braidwood) t'en ~1N
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Attochment 1 1
Braldwood Station Response to NRCD 90-01 S1 Requested Actions i
Requested 3ctions l
1.
Review Plant records and identify any Rosemount Model 1153 Series B, Model f
1153 Series D, and model 1154 transmitters manufactured before July 11, i
1989, that are used or may be used in the future in either safety-related f
systems or systems installed in accordance with 10 CFR 50,62 (the ATHS l
rule), and Braidwood Station has completed this review and has determined that a total i
Mrty-two (42) Rosemount transmitters are installed in the described
.jstems.
f a.
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 operating pressure greater than 1500 psi and that are installed in reactor protection trip systems, ESF actuation systems or ATHS systems.
Action for those transmitters that have not met the Rosemount psi-month threshold criterion should be expedited.
Braidwood Station does not have any transmitters in this category.
At their discretion, licensees may monitor using an enhanced survelliance 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 i
specific safety function.
Braidwood Station does not have any transmitters in this category.
b.
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 ATHS systems, Braidwood Station does not have any transmitters in this category.
At their discretion, licensees may monitor using an enhanced surveillance program at least once every refueling cycle, but not exceeding 24 months, i
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.
Braidwood Station does not have any transmitters in this category.
ZNLD/2521/3
4 U.-
Braidwood Station Response to NRCB 90-01 S1 Requested Actions 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 recommended by Rosemount, any transmitters that have a normal operating pressure greater than 500 psi and less than or equal to 1500 psi, that are installed.in reactor protection trip systems, ESF actuation systems or ATHS systems.
The BNR requirements are not applicable to Braidwood Station.
On a case-by-case basis except for transmitters that initiate reactor protection or ATWS trips for high pressure or low water level, licensees may monitor using an enhanced surveillance program at least once every refueling cycle, but not exceeding 24 months, if sufficient justification is provided based upon transmitter performance in service and its specific safety function.
The BNR requirements are not applicable to Braidwood Station.
[For PHRs) 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 ATHS systems.
Braidwood Station has eight (8) non-nature transmitters in this category.
d.
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 ATHS systems.
Braidwood does not have any transmitters in this category.
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 psi-month threshold criterion recommended by Rosemount (60,000 psi-months-or 130,000 psi-nonths 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 degree of reliability should be maintained for the function consistent with its safety significance.
Braidwood does not have any transmitters in this category.
1 Attachment I t
l Braidwood Station Response to NRCB 90-01 51 Requested Actions l
l f.
At licensee discretion, exclude from the enhanced 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.
Braldwood has thirty-four (34) transmitters in this category. The Braidwood program will maintain confidence that failures can be detected.
2.
Evaluate the enhanced 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.
Braidwood Station has an enhanced surveillance program that nonitors, with required accuracy, the parameters indicative of a loss of fill oil condition.
ZNLD/2521/5
s i
Summary of Transmitter Status for Braidwood Station Bulletin Transmitter Frequency of Discussion /Conments i
Category Pressure / Function Maturity Enhanced Surveillance l
1.a Not Mature, Braidwood does not have any transmitters in Normal Operating Pressure
< 60,000 N/A this category
>1500 psi and transmitter psi
- Mature, Braidwood does not have any transmitters in
> 60,000 N/A this category psi
- months 1.b Not Mature, Braidwood does not have any transmitters in I
Normal Operating Pressure
< 60,000 N/A this category
>1500 psi. Transmitter is psi
- months
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safety related but is not installed in RPS, ESF 7
- Mature, Braidwood does not have any transmitters in l
ATWS systems
> 60,000 N/A this category psi
- months 1.c Operating pressure from Not Mature, N/A Not applicable to Braidwood Station (BWR) 500 to 1500 psi and
< 60,000 transmitter is in RPS, ESF psi
- months N/A Not applicable to Braidwood Station or ATWS systems
- Mature, N/A Not applicable to Braidwood Station
> 60,000 psi
- months Braldwood has 8?transniitteisicisthlA'categ6ry 7
1.c Operating pressure from Not Mature, Ref'uel{ng (PWR) 500 to 1500 psi and
< 60,000 0;atage" '
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transmitter is in RPS, ESF psi
- months or ATWS systems
- Mature, Braidwood does not have any transmitters in
> 60,000 N/A this category psi
- months 1.d operating pressure from Not Mature, 500 to 1500 psi and
< 60,000 N/A Braidwood does not have any transmitters in transmitter is nel in RPS, psi
- Mature, Braidwood does not have any transmitters in 500 to 1500 psi
> 60,000 N/A this category psi
- months 1.f Operating pressure less N/A EdEmpt ErEidwbod has[7d[tf siEmittefs f{this i
than or equal to 500 psi category 2
Braidwood Station has an enhanc' surveillance monitoring program that provides measurement data with an accuracy range consistent for determining degradation caused by loss of fill oil.
1 Sixteen of these 34 transmitters are Auxiliary Feed System transmitters that normally operate at <100 psi. Per the Rosemount Technical Bulletin these transmitters are considered " Standby" and are exempt from enhanced surveillance.
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