ML20044G913

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Responds to NRC Bulletin 90-001,Suppl 1, Loss of Fill-Oil in Transmitters Mfg by Rosemount
ML20044G913
Person / Time
Site: Beaver Valley
Issue date: 05/28/1993
From: George Thomas
DUQUESNE LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-90-001, IEB-90-1, NUDOCS 9306070024
Download: ML20044G913 (4)


Text

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g Beaver Valley Power Statim -

l Shippingport. PA 15077-0004 i

(412) 393-5206 (412) 643-8069 FAX l

GEORGE S. THOMAS Divmon Vice President Nuclear Services Nuclear Power Division May 28, 1993 U.

S.

Nuclear Regulatory Commission Attn:

Document Control Desk Washington, DC 20555

Subject:

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

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

" Loss Of Fill-Oil In Transmitters Manufactured By Rosemount"Bulletin 90-01, Supplement 1,

requested a

response which describes Duquesne Light Company's (DLC) actions to resolve' concerns related to potential loss of fill oil on some Rosemount transmitters.

DLC. has identified pertinent _ models manufactured l

before July 11,

'1989 which are used in. safety-related' or.ATWS l

applications.

The following supplemental responses are provided for each item remaining from our March 8, 1993 response:

1.a. Reauested Action:

i 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 ATWS systems.

Action for those transmitters that have.not met the Rosemount psi-month threshold-criterion

.should be expedited.

At thoir discretion, licensees nay 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 sufficiently high level of reliability for should show that a

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.

9306070024 930528

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i 1 and No. 2 Beavor Valley Powar Station, Unit No..

BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No._50-412, License No. NPF-73 Response To NRC Bulletin 90-01, Supplement 1 Page 2 i

Resoonse:

DLC has no immature high pressure transmitters in service.. Two mature-high pressure transmitters _ are installed in BVPS-1 and are currently. included.in an enhanced surveillance. program _with q

an 18-month frequency.

'An ' evaluation ' of. their maintenance and:

L calibration history data-- for the last two _ operating cycles l

reveals no symptoms of fill-fluid loss'.

In addition, a channel to channel deviation trend review of: these transmitters has been' l

conducted monthly.through -the'.SPDS : computer'for the last:two-i years and will continue to'be monitored until they are replaced I

or retired.

The combination of - the-18-month. enhanced surveillance and the monthly ' trending through-SPDS provides adequate confidence 'that-loss of fill-fluid _will be detected-before significant degradation occurs'.

Please note-that our-1 previous: submittal indicated that three mature.high~ pressure' transmitters are installed in'BVPS-1.

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1.b. Recuested 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 1

applications but are not installed'in reactor protection trip i

systems, ESF' actuation
systems, or ATRS.1 systems.

At their discretion, licensees may monitor using aus enhanced surveillance program at least once every refueling cycle, but not' exceeding j

24

months, transmitters in_ this~ category if the-appropriate psi-month threshold. criterion' recommended by Rosemount has been
reached, and the monitoring interval is1 justified based upon transmitter performance in. service and'its specific ~ function.

Provide to the NRC a

copy of' the licensee. justification to l

extend the enhanced-surveillance program.beyond the quarterly test interval for-transmitters that have reached the_ appropriate l

psi-month threshold criterion recommended by_Rosemount.

Response

DLC has no immature high pressure transmitters in service.

Five mature' high pressure transmitters are installed in BVPS-1 and j

are ' currently included in an enhanced surveillance _ program with an 18-month; frequency.

An evaluation of-their maintenance and calibration history data for'.the last-two operating' cycles reveals no symptoms of fill-fluid loss..In addition, a channel to channel deviation trend review of these transmitters hasLbeen conducted monthly through the -SPDS -computerifor the~lastitwo years and will continue to be monitored until they are replaced e-v.-

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Beaver Valley Powsr Station, Unit No. 1 and No. 2 l

BV-1 Docket No. 50-334, License No. DPR-66

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

Response To NRC Bulletin 90-01, Supplement 1 l

Page 3 l

l or retired.

The combination of the 18-month enhanced surveillance and the monthly trending through SPDS provides adequate confidence that loss of fill-fluid will be' detected before significant degradation occurs.

Please note that our previous submittal indicated that four mature high pressure transmitters were installed in BVPS-1.

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1.f. Reguested Action:

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.

l

Response

Low pressure transmitters were not previously included in an enhanced surveillance program.

However, a failure detection program consistent with the guidelines established by Rosemount l

has been developed.

Calibration data will be evaluated every time the transmitter is calibrated and the results will be compared with the previous data.

This will provide reasonable assurance that transmitter fill-fluid loss will be detected before significant degradation of instrument function occurs.

If it is determined that a

high degree of confidence can be maintained through alternate means, for detecting failure due to fill-fluid loss and that a high degree of reliability can also be maintained, transmitters may be excluded from this program.

l No exclusions are currently planned.

This completes our response to the subject Bulletin.

Should you have any questions regarding our actions related to this Bulletin, please direct them to G.

L.

Beatty at (412) 393-5225.

Sincerely, f

MS George S. Thomas cc:

Mr.

L. W.

Rossbach, Sr. Resident Inspector Mr. T.

T. Martin, NRC Region I Administrator Mr.

G.

E.

Edison, Project-Manager Mr. M.

L. Bowling (VEPCO) l

AFFIDAVIT 1

9 COMMONWEALTH OF PENNSYLVANIA)

) SS:

COUNTY OF BEAVER

)

1 I

Subject:

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.

Response To NRC Bulletin 90-01, Supplement 1 l

i l

Before-me, the undersigned notary public, in and for the County

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and Commonwealth aforesaid, this day personally' appeared George S.

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Thomas, to me known, who being duly-sworn according to law, deposes i

and says that he is Division Vice President, Nuclear Services.of the l

l Nuclear Power Division, Duquesne Light Company, he is duly authorized i

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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M eorgs S.

Thomas Subscribed and sworn to before me i

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on this day of i

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Notary Public tbtanalSeal S5eila M.Fa' tore, Nctary Public i

Sm:r,2rrpon Boro, BeaverCourr.y

-l 8.4 ';omnnson Expres Sept. 26.1994 l,

L..s. nxvisyw.vu Aetovaten of retanes t.

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