ML20056A207

Forwards Response to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Record Review Performed & Sys Walkdowns Completed to Assemble Requisite List

ML20056A207
Person / Time
Site:	Oyster Creek
Issue date:	07/30/1990
From:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-90 IEB-90-001, IEB-90-1, NUDOCS 9008060144
Download: ML20056A207 (5)

Text

. . .

. i OPU Nuclear Corporation l

Nuclear o

en:r388 Forked River, New Jersey 0S7310388 609 971 4000 i Writer's Direct Dia! Number. ,

1 July 30,1990 Document Control Desk U. S. Nuclear Regulatory Commission i Washington. DC 20555 Dear Sir Subject Oyster Creek Nuclear Generating Station l Docket No. 50-219 j NRC Bulletin 90-01, " Loss of Fill-Oil in Transmitters Manufactured by Rosemount" By letter dated March 9, 1990, the USNRC issued NRC Bulletin 90-01, ' Loss of F111-011 in Transmitters Manufactured by Rosemount". Pages 8 and 9 of

• NRCB 90-01 contained reporting requirements, due within 120 days of receipt by the licensee. Attachment I to this letter contains the GPU Nuclear response to the bulletin and fulfills the reporting requirement.

If any further information is required, please contact Mr. John Rogers at (609)971-4893. ,

Very truly yours, M

E .EfFitzpatrick W ee President and Director yster Creek EEF/JJR/dmd ,

Attachment j 90BU01 i

cca NRC Resident Inspectors Oyster Creek Nuclear Generating Station Sworn to and Subscribed 1 before me this 8 M Mr. Alexander W. Dromerick day ofb /u- , 1990.

US Nuclear Regulatory Commission / M Washington, DC 20555 bM ./)/. A 8_ m .e -

Mr. Thomas T. Martin, Administrator DIANA M De9t.ASIO' 1 US Nuclear Regulatory Commission NOTARY PUBUC 0F NS 475 Allendale Road My Commission Emp!=== L- -

King of Prussia, PA 19406 9008060144 900739

{,DR ADOCK 03000;jp FDC I

f GPU Nuclear Corporation is a subsidiary of General Pubhc UtSties Corporattori \

l ATTACHMENT I o l Reportino Reeuirement let

" provide within 120 days of receipt of this bulletin a response that ... ]

confirms Items 1, 2, 3, 4, and 5 of the Requested Actions for Operating ,

Reactors have been completed." l I

Reauested Action 1:

" Identify Model 1153 Series B, 1153 Series D, and Model 1154 pressure or 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)."

GPU Nuclear Responset A record review was performed and system walkdowns were completed to assemble the requisite list. A total of 32 transmitters were identiffsd which were within the scope of NRCB 90-01 and are installed in the Oyster Creek plant. This list does not include one transmitter which was replaced. The replacement was for a transmitter which had received minor mechanical damage to the external case. The replacement transmitter was manufactured after July 11, 1989 and is not in the scope of NRCB 90-01.

Recuested Action 2t

" Determine whether any transmitters identified in Item 1 are from the manufacturing lots that have been identified by Ross.wount has having a high failure fraction due to loss of fill-oil. Addresses are requested not to utilise transmitters from these suspect lots in the reactor protection or engineered safety features actuation systems therefore, addresses are requested to develop and implement a program to replace, at the earliest appropriate opportunity, transmitters from these subject lots in use in the reactor protection or <ngineered safety features actuation systems."

GPU Nuclear Responses None of the 32 installed transmitters within the scope of NRCB 90-01 appears on the list of suspect transmitter lots supplied by Rosemount. The Reactor Protection System and Engineering Safeguards system are not affected.

Recuested Action 3:

" Review plant records (for example, the three most recent calibration records) associated with the tranomitters identified in Item 1 above to determine whether any of these transmitters may have already exhibited symptoms indicative of loss of fill-oil. Appropriate operabililty acceptance criteria should be developed and applied to transmitters l

identified as having exhibited symptoms indicative of loss of fill-oil from this pleet record review. Transmitters identtfied as having exhibited -

symptoms - i-r'cative of loss of fill-oil that do not conform to the operabile acceptance criteria should be addressed in accordance with the applicable 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 specification should be replaced at the earliest appropriate opportunity."

' CPUN Responses Computerized tracking and trending spreadsheets were developed for each of the specified 32 transmitters. Results obtained from recent Technical specification surveillances were placed into the database for analysis. A total of five transmitters exceeded the guidelines contained in Rosemount Technical Bulletin No. 4, Table A1. Four of these five exceeded guidelines only once, and the fifth exceeded the guidelines twice. The two drift occurrences on the fif th transmitter were opposite in magnitude, and the transmitter exhibited no signs of sluggishness. Additionally, it has since passed two consecutive surveillances with no additional adjustments.

Therefore, although tracking and trending is continuing, none of the 32 transmitters is suspected of experiencing a fill-oil loss.

I Recuented Action 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 "

]

1A1

" Ensuring appropriate licensee personnel are aware of the symptome

, 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;"

A.C.L

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

151L

" Enhanced awareness of sluggish transmitter response to either increaring or decreasing test pressures during calibration activities;"

GPUN ReeDonset Maintenance Technicians were trained in the symptoms of transmitter fill-oil loss during Cycle 89-4 training. Licensed operators were trained in the symptoms of transmitter fill-oil loss during cycle 90-2 training. Training was completed on March 14, 1990.

Indicating transmitters are routinely compared to other available channels of instrumentation to check for unexpected drift. Most instruments have a daily Technical Specification required surveillance to compare multiple indications of a single parameter. The sole occurrence to date of a Rosemount transmitter which was identified as exhibiting the symptoms of fill-oil loss was first noted by operators

! and then confirmed by a maintenance technician during routine surveillance. In summary, training has been accomplished and

! awareness has been significantly increased to the noted symptoms of l fill-oil loss.

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• Enhanced transmitter monitoring to identify sustained transmitter drift;"

QEER Responset Transmitter surveillance frequency was increased for all transmitters in the 32 subject to the bulletin, except for five transmitters which are only subjected to atmosphsric pressure. All of the 32 instruments are being tracked and trended for preliminary indications of fill-oil loss.

ALL

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

CPUN Responset Noise monitoring has not been implemented at the Oyster Creek site.

Technical Bulletin No. 4 from the vendor does not endorse this technique as reliable. Interpretation of noise data is difficult.

Most of the 32 transmitters in the scope of 90-01 are not monitored by the plant computer, therefore, significant modifications would be required to perform process noise monitoring. The 32 transmitters within the scope of NRCB 90-01 are presently scheduled for replacement prior to restart from the upcoming refueling outage. For these reasons, GpUN will not develop a noise monitoring program for Oyster Creek.

ALL

" Development and application to transmitters identified as having exhibited symptoms indicative of loss of fill-oll 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 thould be addressed '.) i accordance with the applicable technical specifications. 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."

OPUN Responset only one transmitter at the Oyster Creek site has exhibited symptoms of fill-oil losw. It was replaced. Any additional transmitters which become questionable will be replaced during the first available maintenance opportunity, consistent with the plant Technical Specifications.

Recuested Action %

" 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 has 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. -

s

• ' In addition, while performing the actions requested above, addresses 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 tranet.tters are identified until such time that these transmitters can be repleced. When develor .ng and updating this basis for continued plant operation, addresses may wish to consider transmitter diversity and redundancy, diverse trip functions (a separate trip function that may also provide a  !

corresponding trip signal), a special system and/or component tests, or (if necessary) immediate replacement of certain suspect transmitters." .

GPUN Retoonset There are no transmitters installed at the Oyster Creek site from the ,

manufacturing lots which were identified by the vendor to have a high failure i fraction.

Reoortino Reauirement 1bt

" Provide within 120 days after receipt of this bulletin a response that ...

identifies the indicated manufacturor; 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 Serien 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 Series B, Model 1153 Series D and Model 1154 tran6mitters manufactured after July 11, 1989.*

GPUN Resoonset one transmitter was identified to exhibit symptoms of fill-oil loss:

Manufacturers Rosemount Model Number 1153GB9RJ Serial Numbers 434107 Type 1153 Pressure (Gauge)

Operating Pressure: 1020 psig >

Time at Pressure: 38,420 psi-months System Used In: Reactor Vessel Tuel Zone Channel B The suspect unit was replaced on January 25, 1990, and returned to Rosemount on April 10, 1990, for analysis. Transmitter history was-also provided to the vendor.

Reportino Reauirement let

" Provide within 120 days after the receipt of this bulletin a response that ...

identifies the system in which the Model 1153 Series B, 1153 Series D, and Model 1154 transmitters from the manufacturing lots that have been identified by Rosemount as havina a high failure fraction due to loss of fill-oil.are utilized and provides a schedule fro replacement of these transmitter. which are in use in the reactor protection or engineered safety features actuatisn systems."

I l GPUN responset There are no transmitters installed at the Oyster Creek site from the manufacturing lots which are identified by the vendor to have a high failure fraction.