ML20055E064

Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Outstanding Procurement Actions for Rosemount Pressure & Differential Pressure Transmitters Modified to Specify Mfg After 890711

ML20055E064
Person / Time
Site:	Maine Yankee
Issue date:	07/03/1990
From:	Frizzle C Maine Yankee
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-90 CDF-90-62, IEB-90-001, IEB-90-1, MN-90-66, NUDOCS 9007100332
Download: ML20055E064 (5)

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KTdADLE EttdiE6iilOA MAINE ENCQJj EDISON DRIVE e AUGUSTA, MAINE 04336 e (207) 622 4868 -

l July 3, 1990 MN-90-66 CDF-90-62 l

. UNITED STATES NUCLEAR REGULATORY COMMISSION 1

Attention:

Document Control Desk' Washington, DC 20055 t

References:

(a)

License No. DPR-36 (Docket No. 50-309) 1 (b) USNRC Letter dated March 19, 1990 - NRC Bulletin No. 90-01, loss of Fill-0il in Transmitters Manufactured by Rosemount n

Subject:

NRC Bulletin No. 90-01: Loss of Fill-0il in Transmitters Manufactured by

.Rosemount Gentlemen:

NRC Bulletin 90-01, Reference (b), informed licensees that reported failures of

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Rosemount Model:: 1153 and~1154 transmitters were caused by a gradual loss of fill-oil from the transmitters' sealed sensing module. In order to preclude further failures,

.the NRC requested licensees'to promptly identify and take appropriate actions for Model'1153 Series _B, Model 1153 Series D, and Model 1154 transmitters manufactured by Rosemount that may be leaking fill-oil. Reference (b) further requested licensees to provide-a response that confirms the requested actions have been completed and that provides certain other specified information concerning transmitters suspected or confirmed of having a loss of fill-oil or from the high failure fraction lots.

-The status of.ths Reporting Recuirements of Reference (b).at Maine'. Yankee, consistent with the presentation of tie Requested Actions, are as follows:

NRC Reauested Action Item No 1:

Identify.Model 1153 Series _ B,1153 Series D, and Modol 1154 pressure or m

~ differential pressure transmitters, excluding Model 1153 Series B,1153 Series D, and Model 1154 transmitters manufactured by Rosemount subsequent to July 11, 1989, that are currently utilized in either safety-related systems or systems installed.in.

accordance with 10 CFR 50.62 (the ATWS rule).

Maine Yankee Resoonse:

e All model 1153 Series B,1153 Series D, and Model 1154 Rosemount transmitters l

manufactured prior to July 11, 1989 and installed at Maine Yankee in either safety-Lm class systems or systems installed in accordance with the ATWS rule have been L

identified.

In addition, a QC hold was placed on those transmitters manufactured prior to July 'll,1989 currently in stock to preclude their being installed' in safety-class systems.

Outstanding procurement actions for Rosemount pressure and differential pressure transmitters were modified, as necessary, to specify L

manufacture after July 11, 1989.

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Attention: Document Control: Desk Page 2 i

NRC Reauested Action Item No. 2:

Determine whether any transmitters identified in Item 1 are from the I

manufacturing lots that have been identified by Rosemount as having a high failure fraction due to = loss of fill-oil.

Addressees are recuested not to utilize transmitters from these suspect lots in the reactor protect on or engineered safety 1

features actuation systems; therefore, addressees are requested to develop and implement a program to replace, at the earliest appropriate opportunity, transrdtters

-form these-suspect lots in use -in the reactor protection or engineered safety

' features actuation systems.

Maine Yankee Response:

One Rosemount Model 1154 transmitter (Serial No. 415631) was identified to have been from the manufacturing lots having a high. failure fraction due to loss of fill-oil.

This transmitter was located in the Steam Generator Level System and was replaced on February 14,-1990 with a transmitter manufactured after July 11, 1989.

NRC Reauested Action Item No. 3:

Review plant records (for example, the three most recent calibration records)

. associated with the transmitters identified in Item 1 above to determine whether any of these transmitters may have already exhibited symptoms indicative of loss of fill-oil. Appropriate operability acceptance criteria should be developed and applied to transmitters identified as having exhibited symptoms indicative of loss of fill-oil o

from'this plant record review. Transmitters identified as having exhibited symptcms

indicative of loss of fill-oil that do not' conform to the operability acce)tance criteria should be addressed in accordance with the applicable tecinical specification.- Transmitters identifled as having exhibited symptoms indicative.of

-loss of fill-oil that do not conform to the operability acceptance criteria and are not addressed in the technical specifications should be replaced at the earliest appropriate opportunity.

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-Maine Yankee Resoonse:

Because Maine Yankee was scheduled to start a refueling outage within one month ofi the issuance of Reference (b), a special test program was developed to y

functionally test each transmitter during the outage in lieu of the review of plant j

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records.

This program required each installed instrument to be calibrated to its

~1 maximum range limit. During this process, the instrument's output was verified to p

track consistently with no ' observed sluggish operation, t.fter this test, the.

. instrument was recalibrated to its normal band. This approach was considered to be far more definitive in identifying a loss of fill-oil. As a result of this special test program, two Rosemount Model 1154 transmitters in the Primary Inventory Trend System (PITS) (Serial Nos. 412512 and 416074) exhibited symptoms indicative of a loss 1

of fill-oil.

These transmitters had approximately 14 months time at pressure and were replaced. If required to support future replacements, the replaced instruments will be rebuilt by Maine Yankee on-site.

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' Attention: Document Control Desk Page 3-a NRC Reauested Action Item No. 4:

Develop and implement an enhanced surveillance program to monitor transmitters identified:in Item 1 for symptoms of loss of fill-oil. This enhanced surveillance program should consider the following or equally effective actions:

a.

Ensuring appropriate licensee personnel are aware of the symptoms that a, transmitter, both during operation and during calibration activities, may j

exhibit if it is experiencing a loss of fill-oil and the need for prompt n

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identification of transmitters that may exhibit thesc ',ymptoms; L,

b.

Enhanced transmitter monitoring to identify sustained transmitter drift; y

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c.

Review of transmitter performance following planned or unplanned plant t

L transients or tests to identify sluggish transmitter response; P'

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Enhanced awareness of sluggish transmitter response to either increasing.~

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p or decreasing test pressures during calibration activities; 1-h

'e.

Development and implementation of a program to detect changes in process T

noise; and' f.'

- Development and application to transmitters identified as having e'xhibited symptoms indicative of loss of fill-oil.of an appropriate operability l

acceptance criteria. Transmitters identified as having exhibited symptoms

' indicative of loss of fill-oil that do not conform to the operability-acceptance criteria should be. addressed in'accordance with the applicable l

Ltechnical specification.

Transmitters identified as having exhibited symptoms indicative of loss of fill-oil that do not - conform to the 1

operability acceptance criteria and are not addressed in the technical 1

specifications should be replaced at the earliest appropriate opportunity.

. Maine Yankee Response:

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. A description of the symptoms - that an instrument may exhibit if'it is

experiencing a loss of fill-oil as well as a listing of those transmitters by. system that may

be susceptible to the problem has been provided to appropriate personnel.

LThis description included symptoms associated with sluggish transmitters.

.Each transmitter's performance was reviewed for sluggish response during the l

accomplishment of-the special test conducted during the outage as discussed in the response to Item 3. - This portion of our enhanced surveillance program identified two

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.. transmitters exhibiting symptoms indicative of a loss of fill-oil and provides a high degree of assurance that our remaining transmitters are satisfactory for continued operation.

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. UNITED STATES NUCLEAR REGULATORY COMMISSION MN-90-66

- Attention: - Document Control Desk Page 4 Our process noiss monitoring program is still under development.

We - are adopting for all RPS/ESF Rosemount inputs a process similar to the one presently used to determine RCS flow setpoint noise. The method used in this procedure requires a bucking voltage to be inserted across the signal developing resistor. This voltage is equal and opposite to the signal voltage.

The resultant signal is related to process: noise.

Any changes in this noise trace will be evaluated by the Plant' Engineering Department. In particular, changes that include clipping in the positive or negative direction and/or downward frequency shifts could indicate a potential oil loss, and the transmitter will be tested per Rosemount Technical Bulletin No. 4.

The frequency of this new test will be monthly or any time a transmitter is suspected.

The procedures to perform this testing will be completed and implemented by August 31, 1990.

- NRC Reauested Action Item No. 5:

Document and maintain in accordance with existing plant procedures a basis for continued plant operation covering the time period from the present until such time that the Model 1153 Series B,1153 Series D, and Model 1154 transmitters from the manufacturing lots that have been identified by Rosemount as having'a high' failure fraction due to loss of fill-oil in use in the reactor protection.or engineered safety features actuation systems can be replaced. In addition, while performing the actions requested above, addressees may identify transmitters exhibiting symptoms indicative of -loss of fill-oil that do not conform to the established operability -

~ acceptance criteria and are not addressed in the technical specifications.- As these transmitters are-identified, this basis for continued plant operation should be updated to-address these transmitters covering the time period from the time these transmitter are identified until such time that these transmitters can be replaced.

When developing and updating this basis for continued plant operation, addressees may lwish' to consider transmitter diversity 'and redundancy, diverse. trip functions (a -

separate trip function that may also provide a corresponding trip signal), special system and/or component tests, or (if necessary) immediate replacement of'certain-suspect transmitters.

Maine Yankee Resoonse:

.The one transmitter from the high failure fraction lots has been replaced. The

. two transmitters exhibiting' symptoms of loss of fill-oil, as a result of the special outage test program, have been replaced.

Pending receipt of additional guidance providing a time at pressure basis for acceptance of our present transmitters, Maine Yankee. intends to replace all Model 1153 Series B, Model 1153 Series D and Model 1154 Ltransmitters manufactured by Rosemount prior to July 11, 1989 installed in safety-

class systems with transmitters manufactured after July 11, 1989 or restored to post July 11,1989 standards consistent with Rosemount guidance. We plan to complete the repair / replacement of those transmitters by the end of our next refueling outage.

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' UNITED STATES: NUCLEAR REGULATORY COMMISSION,

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.:We_ trust this information'is satisfactory.

Please contact us should you have i

any; questions'in this. matter..

g LVery truly yo rsy arles D. Frizzle ((

f President xWBD:SJJ

. STATE.0F MAINE w~

q Then' personally appeared before me, Charles D. Frizzle, who being duly sworn did:

i state. that. he:is President of _ Maine Yankee Atomic Power Company, that hevis duly H

h authorized to execute and file the. foregoing response in the name and on behalf ofs

. Maine Yankee. Atomic Power Company, and that the statements therein are true to the best of his-knowledge _and belief.

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/ Notary Public

.i gganARA J. PADAVAMA W

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.c::' Mr. Eric J. Leeds I

Mr. Richard J.: Freudenberger m

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