ML20044B883
| ML20044B883 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/05/1993 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1005, IEB-90-001, IEB-90-1, NUDOCS 9303110265 | |
| Download: ML20044B883 (12) | |
Text
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l CENTEmon ENERGY Donald C. Shelton 300 Maison Avenue Vice President-Nacisar Toledo, OH 43652 0001 Davis Besse (419)249 2300 l
Docket Number 50-346 License Number NPF-3 Serial Number 1-1005 March 5, 1993 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 1
Subject:
Response to NRC Bulletin Number 90-01, Supplement 1, " Loss of i
Fill-Oll in Transmitters Manufactured by Rosemount" Gentlemen:
Nuclear Regulatory Commission Bulletin Number 90-01, Supplement 1 provided updated information on the performance of various models of pressure and differential pressure transmitters manufactured by i
Rosemount, Inc.
In addition, the supplement requested that Toledo Edison (TE) review the updated information and modify actions taken as described in the response to NRC Bulletin Number 90-01 (Serial Number 1821), as necessary. provides TE's response to the Requested Actions and Reporting Requirements detailed in NRC Bulletin Number 90-01, Supplement 1.
As was requested, TE also provides the following information regarding the costs associated with complying with the guidance of the bulletin supplement:
1.
TE staff time and costs to complete the requested reports and documentation:
240 man-hours.
2.
Additional short-term costs incurred as a result of performing the requested actions such as the costs of additional corrective actions: TE estimates the cost of replacing one transmitter to be $11,000.
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Docket Number 50-346 i
License Number NPF-3 Serial Number 1-1005 Page 2 3.
Additional long-term costs which will be incurred in the future as a result of implementing commitments such as the estimated cost of conducting the future surveillances and increased maintenance: TE estimates staff time required to implement the current enhanced surveillance program to be 400 man-hours / year j
of Engineering time and 400 man-hours / year of Maintenance i
Technician time during 1993. As transmitters mature and are removed from the enhanced surveillance program, costs will be l
reduced.
Should you have any questions concerning this response, please contact Mr. Robert V. Schrauder, Manager - Nuclear Licensing, at l
(419) 249-2366.
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Very tr ly yours, g/,g/
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NKP/dle Attachments cc:
A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NRC Senior Project Manager Utility Radiological Safety Board
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S. Stasek, DB-1 NRC Senior Resident Inspector l
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Docket Number 50-346 Licensa Numb 2r NPF-3 Serial Number 1-1005 Enclosure Page 1 RESPONSE TO NRC BULLETIN NUMBER 90-01, SUPPLEMENT 1 FOR DAVIS-BESSE NUCLEAR POVER STATION UNIT NUMBER 1 This letter is submitted in conformance with Atomic Energy Act of 1954 Section 182a as amended and 10CFR50.54(f), in response to 180 Bulletin 90-01, Supplement 1 (Log No. 1-2784), " Loss of Fill-Oil in Transmitters Manufactured by Rosemount."
By:
\\'h D.
C.
Shelton, Vice President - Nuclear Sworn and subscribed before me this 5th day of March, 1993.
///lH1 JP Notary Publig,' $ tate of Ohio EVELYNLDRESS NOTARYPUBUC,STATEOFOHO Myon-reemE ttsMy28,19H l
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1005 Page 1 Response to NRC Bulletin Number 90-01, Supplement 1 Requested Action 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 safety-related systems or systems installed in accordance with 10 CFR 50.62 (the ATUS rule), and Requested Action 1.a.
Expeditiously replace, or monitor for the life of the transmitter on a monthly basis using the enhanced surveillance monitoring program, any transmitters that have a normal operating pressure greater than 1500 psi and that are installed in the reactor protection trip systems,-ESF actuation systems or ATVS 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 transmitters 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 actuation systems, or ATVS 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-mouth threshold criterion recommended by Rosemount.
Toledo Edison's Response to Requested Action 1.a.
Table 1 identifies two transmitters subject to Requested Action 1.a.,
transmitters PT6365A and PT6365B (Model 1154GP9). These transmitters measure reactor coolant system loop pressure and provide inputs for Channels 1 and 2 of the Diverse Scram System (ATVS Hitigation), and-Remote Shutdown Panel and Post Accident Honitoring indication. Both of these transmitters have exceeded the psi-month threshold (> 60K psi-months) established by Rosemount Technical Bulletin Number 4.
Transmitter PT6365A vill be replaced during the current refueling outage (8RFO) with a new range code 9 transmitter and subsequently vill not be subject to the requirements of NRC Bulletin 90-01, Supplement 1.
An enhanced surveillance program (ESP) interval of once every refueling cycle for PT6365B is justified based on satisfactory transmitter performance as trended since the original NRC Bulletin Number 90-01.
In addition, a high probability of detecting an oil loss failure vill be ensured by the replacement of the redundant transmitter PT6365A and subsequent comparisons between the two transmitters. Transmitter PT6365B vill be calibrated once per refueling outage as the transmitter
Docket Numbar 50-346 License Numbar NPF-3 Serial Number 1-1005 Page 2 is located in containment and is not readily accessible for calibration during power operations.
Calibration data vill be evaluated against Rosemount drift limits for the life of the transmitter to satisfy the ESP requirements.
In addition, weekly computer point trending for PT6365A and PT6365B vill continue to maintain a high degree of confidence for detecting transmitter failures.
Requested Action 1.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 ATUS 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 specified 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.
Tcledo Edison's Response to Requested Action 1.b.
Table 2 identifies transmitters subject to Requested Action 1.b.
Transmitter LTRC14-2 is non-safety-related and is not required to be included in the ESP. Transmitter LT5448A, hot leg level transmitter, is nuclear safety related and has not exceeded the psi-month threshold.
Therefore, LT5448A vill require a quarterly ESP interval which vill consist of an evaluation of computer point trend data compared with data of a mature, redundant transmitter.
In addition, an evaluation of calibration data vill be performed once per refueling cycle.
Transmitters LT5448B, UTRC14-1 and LTRC14-3 have exceeded the psi-month threshold (>130K psi-months). Transmitters LTRC14-1 and LTRC14-3 measure pressurizer level and provide indications, alarms,-interlocks, and level control input to normal makeup line flow control valve HU-32.
These tr;nsmitters are redundant'and either of the two can be selected to provide the alarm and control functions in the event one fails.
Transmitter LT5448B provides Post Accident Monitoring indication of-reactor coolant system inventory. Toledo Edison vill establish'a once
,wr refueling cycle ESP interval for these transmitters due to demonstrated satisfactorily performance as trended since the original NRC Bulletin Number 90-01.
Transmitter FTHU31, makeup flow transmitter (vide range), uses the same flow element but is not truly redundant to 1
FTMU34 which is calibrated for narrow range indication.
However, a
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once per refueling cycle ESP interval vill be established for FTHU31 as 1
it has exceeded the psi-month threshold and a failure vill not adversely affect operability of the makeup system.
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Docket Numbar 50-346 License Numbar NPF.
Serial Number 1-1005 Page 3 Requested Action 1.c.
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 ATVS systems.
Toledo Edison's Response to Requested Action 1.c No transmitters were identified at the Davis-Besse Nuclear Power Station (DBNPS) that are subject to Requested Action 1.c.
Requested Action 1.d Replace, or monitor at least once every refueling cycle, but not exceeding 24 months, using an enhanced surveillance monitoring pror; ram 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 grerster than 500 psi and less than or equal to 1500 psi, and that are nct installed in reactor protection trip systems, ESF actuation systems, or ATVS systems.
Toledo Edison Response to Requested Action 1.d.
Table 3 identifies transmitters subject to Requested Action 1.d.
Transmitters LTCF3A1, LTCF3A2, LTCF3B1, LTCF3B2, LTSP9A1,-LTSP9B1, LTSP9B2, and LTSP9B5 are safety-related as they provide a system pressure boundary. The signals from these transmitters do not provide inputs to safety related systems and, therefore, these transmitters are not required to be included in the ESP. Transmitters LTSP9A3, LTSP9A4, LTSP9B3, and LTSP9B4 have not exceeded the psi-month threshold (> 60K psi-months) recommended by Rosemount. Therefore, these transmitters.
vill have an ESP interval of once per refueling cycle. These transmitters vill exceed the psi-month threshold in October 1993 and vill subsequently be removed from the ESP. Veekly computer point trending vill continue for all transmitters listed in Table 3 to maintain a high degree of confidence of detecting transmitter failures.
Requested Action 1.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-mor
~.s or 130,000 psi-months depending on the range code of the transmit
- A high degree of confidence should be maintained'for detecting f are of these transmitters caused by a loss of fill-oil and a hic <egree of reliability should be maintained for the function consistent with its safety significance.
Docket Numbar 50-346 License Number NPF-3 Serial Number 1-1005 i
Page'4 Toledo Edison's Response to Requested Action 1.e.
f No transmitters vere identified at the DBNPS that are subject to l
Requested Action 1.e.
Requested Action 1.f.
At licensee discretion, exclude from the enhanced surveillance program i
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 a high degree of reliability should be maintained for the function consistent with its safety significance.
Toledo Edison's Response to Requested Action 1.f.
Table 4 identifies transmitters subject to Requested Action 1.f.
These transmitters are not required to be included in the ESP. Veekly computer point trending vill continue for all transmitters listed in Table 4 to maintain a high degree of confidence for detecting transmitter failures.
Requested Action 2.
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Evaluate the enhanced surveillance monitoring program to ensure that the program provides measurement data vith an accuracy range consistent with that needed for comparison with manufacturer drift data criteria for determining degradation caused by a loss of fill-oil.
Toledo Edison's Response to Requested Action 2.
The transmitters required to be included in the ESP vill be calibrated with sufficient accuracy for comparison with zero and span drift limits established by Rosemount Technical Bulletin Number 4.
Although not required by NRC Bulletin Number 90-01, Supplement 1, TE vill continue to trend computer point data from Rosemount Model 1153 (B&D) and 1154 transmitters on a veekly basis. Toledo Edison vill
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evaluate statistical data (deviation from average, variance, etc.) to i
identify potential transmitter failures. This data vill be plotted l
periodically to maintain a record of transmitter / instrument string performance.
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v Reporting Requirements l
Provide within 60 days after receipt of this bulletin, a response that f'
includes the following:
l.
A statement whether the licensee vill take the actions. requested above.
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a
i Docket Numb:r 50-346 i
License Number NPF-3 Serial Number 1-1005 Page 5 2.
With regard to the actions requested above that the licensee is f
taking:
a.
A list of the cpecific actions that the licensee vill complete to meet Item 1 of Requested Actions for Operating Reactors
-l provided in this supplement, including justifications as appropriate.
i b.
The schedule for completing licensee actions to meet Item 1 of l
Requested Actions provided in this supplement.
f c.
When completed, a statement confirming that Items 1 and 2 of Requested Actions for Operating Reactors provided in this supplement have been completed.
3.
A statement identifying those actions requested by the NRC that the t
licensee is not taking and an evaluation which provides the bases for not taking the requested actions.
Toledo Edison's Response The DBNPS Enhanced Surveillance Program currently meets or exceeds the requirements of Requested Action 1 as described above. However, one ATVS system transmitter with normal operating pressure >1500 psi is scheduled for replacement during the present refueling outage (8RFO).
Therefore, Davis-Besse vill complete licensee actions required to meet Requested Actions 1 and 2 by the completion of 8RF0.
t No exceptions to the Requested Actions have been identified and therefore, no further evaluation is required.
1 Davis-Besse vill remove transmitters exceeding the psi-month threshold (subsequent to the date of this response to NRC Bulletin Number 90-01, Supplement 1) from the ESP vithout further correspondence. Mature transmitters vill continue to be monitored for symptoms of oil loss to i
ensure a high degree of reliability.
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Docket Number 50-346 License Number NPF-3 l
Serial Number 1-1005 Page 6 ROSEHOUNT TRANSMITTERS MODELS 1153 AND 1154 TABLE 1 t
INSTRUMENT HODEL SERIAL HONTHS IN OPERATING PSI-ESP NUMBER NUMBER NUMBER SERVICE PRESSURE (PSI)
MONTHS INTERVAL
- PT 6365A 1154GP9 418642 44 2155 94820 R'
i PT 6365B 1154GP9 419440 44 2155 94820 R
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R = Once per Refueling Cycle
- Transmitter vill be replaced during the present Refueling Outage (BRF0).
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1005 Page 7 ROSEMOUNT TRANSHITTERS MODELS 1153 AND 1154 TABLE 2 INSTRUMENT MODEL SERIAL MONTHS IN OPERATING PSI-ESP NUMBER NUMBER NUMBER SERVICE PRESSURE (PSI)
MONTHS INTERVAL FT MU31 1154HP6 415081 59 2500 147500 R
LT 5448A 1153HD6 417642 52 2155 112060 0
LT 5448B 1153HD6 406501 62 2155 133610 R
LT RC14-1 1153HD5 364861 62 2155 133610 R
P LT RC14-2 1153HD5 364862 62 2155 133610 NA LT RC14-3 1153HD5 364863 62 2155 133610 R
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R - Once Per Refueling Cycle r; - Once per Quarter NA = Not Applicable I
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1005 Page 8 ROSEMOUNT TRANSMITTERS MODELS 1153 AND 1154 TABLE 3 INSTRUMENT MODEL SERIAL MONTHS IN OPERATING PSI-ESP NUMBER NUMBER NUMBER SERVICE PRESSURE (PSI)
MONTHS INTERVAL LT CF3Al 1153DD5 364804 73 600 43800 NA LT CF3A2 1153DD5 364805 77 600 43800 NA t
LT CF3B1 1153DD5 364806 73 600 43800 NA I
LT CF3B2 1153DD5 370312 73 600 43800 NA LT SP09Al 1153DD5 364794 73 900 65700 NA LT SP09A2 1153DD5 362795 73 900 65700 NA LT SP09A3 1153DD5 364798 62 900 55800 R
LT SP09A4 1153DD5 364799 62 900 55800 R
i LT SP09A5 1153DD5 364802 73 900 65700 NA LT SP09B1 1153DD5 420883 31 900 27900 NA l
LT SP09B2 1153DDS 364797 73 900 65700 NA LT SP09B3 1153DDS 364800 62 900 55800 R
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LT SP09B4 1153DD5 364801 62 900 55800 R
LT SP09BS 1153DD5 364803 73 900 65700 NA 4
R - Once per Refueling Cycle NA - Not Applicable l
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Docket Number 50-346-License Number NPF-3 Serial Number 1-1005-Page 9 ROSEHOUNT TRANSMITTERS MODELS 1153 AND 1154 TABLE 4 INSTRUMENT MODEL SERIAL MONTHS IN OPERATING PSI-ESP NUMBER NUMBER NUMBER-SERVICE PRESSURE (PSI)
MONTHS INTERVAL FT 4630 1153DD5 370816 82 0
0 NA FT 4631 1153DD5 370817 82 0
0 NA FT 6425 1154HP6 419930 44 0
0 NA FT 6426 1154DP5 419755 44 0
0 NA FT 6427 1154DP5 505583 10 0
0 NA FT 6435 1154DP4 419691 44 0
0 NA FT 4594 1153AD7 375381 82 0
0 NA FT 4595 1153AD7 375382 82 0
0 NA' PDT 5000 1153DD3 413203 59 0
0 NA PT 4587 1153AD7 375383 82 0
0 NA PT 4588 1153AD7 375384 82 0
0 NA PT 4694 1153GB9 403577 73 0
0 NA PT 4695 1153GB7 403335 73 0
0 NA PT 5898 1153GD7 370786 59 0
0 NA PT 5899 1153GD7 370787 59 0
0 NA NA - Not Applicable