ML20055G714

Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Plant Has Four Rosemount Model 1153DD6 Differential Pressure Transmitters Installed to Associated Logics for Safety Injection

ML20055G714
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/19/1990
From:	Cross J PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-90 IEB-90-001, IEB-90-1, NUDOCS 9007240095
Download: ML20055G714 (6)

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W M BEKiriCCarmeny James E. Cross Vice President, Nuclear

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July 19, 1990

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Trojan Nuclear. Plant 4-Docket 50-344 License NPF-1 it.$ Nuclear Regulatory Commission

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.J Dear Sirst J

Response-to NRC Bulletin 90-01,

" Loss of F111-011 in Transmitters Manufactured by Rosemount" j

Information provided in the attachment'to this letter is in response to the request made by NRC Bulletin 90-01.

Specifically, this information

' includes response to-Requested Actions for Operating Reactors, Items 1 j

through'5; and response to Reporting Requirements for Operating Reactors,-

Items ~1.a.

1.b 1.c. and 2 identified-in Bulletin 90-01.

This information i

is provided pursuant to your request under I'tle 10 Code of Federal l

. Regulations, Part 50, Section 54(f) (10 CFR 50.54(f)) to describe the actions taken by Portland General Electric Company (PCE) in-response.to Bulletin 90-01.

Sincerely, Attachment J. E, CROSS c:. Mr. John B. Martin Regional Administrator, Region V U.S.' Nucioar Regulatory Commission Mr. David. Stewart-Smith State of Oregon I

Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant

' Subscribed and sworn to before me this 19th day of July 1990.

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PDC Notary Public of Oregon My Commission Expires:

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121 SW Salmon St. Portland OR 97204

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16!4 *i Trojan Nuclear: Plant Document Control Desk

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Docket:50-344 July 19, 1990

. License NPF-1 Attachment

-i Page 1 of 5 f

PORTLAND GENERAL ELECTRIC COMPANY (PCE)

RESPONSE TO NRC BULLETIN 90-01 j

Reporting Requirements. Item 1.a Confirm that Items 1, 2, 3. 4, and 5 of Requested Actions for Operating

..i Reactors have been completed.

1 Requested Action Item 1 Identify Model 1153 Series B, 1153 Series D, and Model 1154 pressure or differsntial 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).

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Response

Based on~ review of Plant records it has been determined that-Trojan has.four Rosemount Model 1153DD6 differential pressure transmitters installed to monitor Containment pressure and provide inputs to the.

s associated logics for safety injection, containment isolation, Containment spray actuation, and main steam line isolation signals.

Review of the calibration records for these transmitters indicates they have been installed for more than eight years and therefore i

these transmitters were manufactured prior to July. 11, 1989.

t Requested Action Item 2 Determine whether any transmitters identified in Item 1 are from the manufacturing lots that have-been identified by Rosemount as having a high failure fraction due to loss of fill-oil. Addressees are requested not to utilize transmitters from these suspect lots in the reactor protection or engineered safety features actuation systems; therefore, addressees are requested to develop and implement a program to replace, at the earliest appropriate opportunity, transmitters from these suspect lots in use in the reactor protection or engineered safety features actuation systems.

Response

The serial numbers for the four Containment pressure transmitters and two spare Rosemount Model 1153DD6PA transmitters were identified from review of Plant records. These serial numbers were compared with the serial numbers listed in Rosemount's December 22, 1989 list of transmitters identified as having a high failure fraction due to loss of fill-oil and found to be different.

From this review it is concluded that Trojan does not have Rosemount transmitters from suspect lots in the reactor protection or engineered safety features actuation system.

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Trojan' Nuclear' Plant -_

Document Control' Desk l DocketL50-344 July 19, 1990' License NPF-1 Attachment Page.2 of 5-Requested Action Item 3 Review plant records (for example, the three most recent calibration

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records) associated with the transmitters' identified in Item l'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 from this plant record review.

. Transmitters identified as having c

exhibited symptoms indicative of loss of fill-oil that do not conform to the operability acceptance criteria should be addressed in accordance with the=applicabic technical ~ specification. Transmitters identified 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.

Response

Annual Containment pressure transmitter calibration and response time I

testing results were reviewed for the parlod from 1982 through 1990 to detect symptoms indicative of loss of fill-oil. This review did not identify any symptoms indicative of loss of fill-oil..

! Requested Action Item 4 Develop and implement an enhanced surveillance program to monitor j

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

Ensuring appropriate licensee personnel are aware of the symptoms 5

a.

that a transmitter, both during operation and during calibration activities, may exhibit if it is experiencing a loss of fill-oil and

-the need for prompt identification of transmitters that may exhibit these symptoms; b.

Enhanced transmitter monitoring to identify sustained transmitter delft; c.

Review of transmitter performance following planned or unplanned plant. transients or tests to identify sluggish transmitter response; d.

Enhanced awareness of sluggish transmitter response to either increasing or decreasing test pressures during calibration activities; e.

Development and implementation of a program to detect changes in process noise; and

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Document Control Desk Docket 50-3447 July.19, 1990-

. License NPF-11 Attachment Page 3 of 5 1

f. Development and application to transmitters identified as having'

. exhibited symptoms indicative of loss'of fill-oil of an appropriate operability 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.

64 accordance with the applicable technical specification. Transmitters-

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identified as.having exhibited symptoms indicative of. loss of 1

fill-oil thatLdo not conform to the' operability acceptance criteria

.and,are not addressed in the technical specifications should be l'

replaced at the earliest appropriate opportunity.

Response

The Containment pressure-transmitters will be replaced with Rosemount-t Model 1153. Series D transmitters manufactured after July 11, 1989 i

I during the 1991 refueling outage.

Annual calibration and response time testing records for the Contcinment pressure transmitters for the past eight years were evaluated using criteria based on Rosemount Technical Bulletins l' through 4 to determine if there is evidence of a loss of fill-oil.

. Based on'a review and evaluation of calibration and response time i

testing records for the past eight years, it is concluded'that a zero shift' indicative of a loss of fill-oil has not occurred, t

The Containment' pressure transmitters have a normal operating.

-pressure-range between negative 1.1 psig and positive 1.6 psig, as limited by Trojan Technical Specifications ~. This low normal

-operating pressure range and the slow rate of change in pressure experienced during normal plant operation does not present conditions conducive to locs of fill-oil.

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Reference:

Rosemount Technical j

Bulletin 4, page 3; Eloctric Power Research Institute (EPRI) Final Draft Report, " Methods for Enhancing Surveillance to Detect Incipient Failure of Rosemount Pressure Transmitters"; and Nuclear Management and Resources Council letter dated July 2, 1990, " Clarification' Regarding Enhanced Monitoring Considerations".)

Based on the above considerations and the scheduled replacement, enhanced awareness and monitoring for sustained drift, sluggish response to pressure changes, and process noise will not be performed prior to replacement.

Also based on the absence of exhibiting

-symptoms indicative of loss of fill-oil, development of special operability acceptance criteria is not warranted.

Requested Action Item 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 e

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Document Control Desk L*i, Trojan Nuclear Plant Docket 50-344 July 19, 1990 Attachment License NPF-l' Page 4 of 5 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 transmitters are identified until such1 time that these transmitters can be replaced.

When developing and updating this basis for continued plant operation, addressees may wish 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.

Response

A documented bases for continued operation is not required because review of plant records indicates transmitters from manufacturing lots that have been identified by Rosemount as having a high-failure rate are not in use at Trojan. Additionally, this review of plant

' records indicates Rosemount transmittors-in service at Trojan show no evidence of loss of fill-oil. In the unlikely event any of the containment pressure transmitters f ail, the appropriate Technical Specification Action Statements will be followed pending repair or replacement of the failed transmitter.

Reporting Requirements. Item 1.b Identify the indicated manufacturer; the model number; the system the transmitter was utilized in; the approximate amount of time at pressure; the corrective actions taken; and the disposition (e.g., returned to vendor for analysis) of Rosemount Model 1153 Series B, Model 1153 Series D, and Model 1154 transmitters that are believed to have exhibited symptoms indicative of loss of fill-oil or have been confirmed to have experienced a loss of fill-oil. This should include Model 1153 Serios B, Model 1153 Series D, and Model 1154 transmitters manufactured after July 11, 1989.

Response

Rosomount transmitters that are or have been in service at Trojan have shown no signs indicative of loss of fill-oil based on evaluation of past calibration and response time testing records.

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Document Control Desk

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Trojan Nuclear Plant

= Docket ~50-344

. July 19. 1990-Attachment License NPF-1 Page 5 of 5 Reporting Requirements. Item 1.c Identify the system in which Model.1153. Series B. Mode 111153 Series D.

.and ModelL1154 transmitters from the manufacturing lots that have been-

-identified by Rosemount as having a high-failure fraction due to loss of fill-oil are utilized and provide a schedule for replacement of these transmitters which are in use in the reactor protection or Engineered-Safety Features' Actuation Systems.

Response

Based on review of Plant records, PGE has no Rosemount transmitters from manufacturing lots that have been identified by Rosemount as=

having a high-failure. fraction due to;1oss of fill-oil in service at Trojan.

Reporting Requirements. Item 2 Model 1153 Series B, Model 1153 Series D and Model 1154 transmitters that,. subsequent to providing the response required by Item 1 above, exhibit symptoms of loss of fill-oil or are confirmed to have experienced-

<a loss of, fill-oil should be reviewed for reportability under existing NRC regulations.

If determined not to be reportable, addresses are' requested to document and maintain, in accordance with existing Plant procedures, information consistent with that requested in Item 1.b above for each transmitter identified.

Response

Rosemount transmitters in service at Trojan that exhibit symptoms of loss of fill-oil or are confirmed to have experienced a loss of fill-oil will be evalusted and reported as required by NRC regulations. The information requested in-Item 1.b above will be available as part of the Trojan equipment history flies for any failures.

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