ML20058F962

Evaluation of Util Response to Suppl 1 to NRC Bulletin 90-01:Limerick-1/2 & Peach Bottom-2/3, Technical Evaluation Rept

ML20058F962
Person / Time
Site:	Peach Bottom, Limerick
Issue date:	08/31/1993
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20058F548	List: ML20058F544 ML20058F564 ML20058F962
References
CON-FIN-L-1695 EGG-RTAP-10864, IEB-90-001, IEB-90-1, TAC-M85403, TAC-M85404, TAC-M85424, TAC-M85425, NUDOCS 9312090054
Download: ML20058F962 (19)

Text

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ENCLOSURE 2 1

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EGG-RTAP-10864 1

l TECHNICAL EVALUATION REPORT Evaluation of Utility Response to Supplement I to i

NRC Bulletin 90-01: Limerick-1/-2 and Peach Bottom-2/-3 Docket Nos. 50-352, 50-353, 50-277, and 50-278 Alan C. Udy l

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Published August 1993 t

EG&G Idaho, Inc.

Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 i

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Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761D01570 FIN No. L1695, Task No.'ll TAC Nos. MS5403, MS5404, MS5424, and M85425 I

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SUMMARY

This report documents the EG5G Idaho, Inc., revier of the submittal for l

Unit Nos. I and 2 of the Limerick Generating Station and Unit Nos. 2 and 3 of the Peach Bottom Atomic Power Station that responds to Supplement I to NRC Bulletin 90-01. This NRC Bulletin provides information regarding the loss of fill-oil in certain pressure and differential pressure transmitters manufactured by Rosemount, Inc. This report identifies areas of non-conformance to the requested actions and the reporting requirements, t

Exceptions to the requested actions and the reporting requirements are i

evaluated.

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FIN No. Ll695, Task No. 11 B&R No. 320-19-15-05-0 Docket Nos. 50-352, 50-353, 50-277, and 50-278 TAC Nos. M85403, M85404, M85424, and M85425 ii r

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PREFACE i

This report is supplied as part of the " Technical Assistance in Support of the Instrumentation and Controls Systems Branch."

It is being conducted for the U.S. Nuclear Regulatory Comission, Office of Nuclear Reactor 2

Regu'ation. Division of Reactor Controls and Human Factors, by EC&G Idaho, Inc., Regulatory and Technical Assistance Program Unit.

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I CONTENTS i

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SUMMARY

ii PREFACE.............................................................

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INTRODUCTION............

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NRC SPECIFIED REQUESTED ACTIONS.................................

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3.

EVALUATION......................................................

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3.1 Evaluation of Licensee Response to Reporting Requirements.

7 3.2 Evaluation of Licensee Response to Requested Actions......

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CONCLUSIONS.....................................................

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REFERENCES.......................................................

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Evaluation of Utility Response to SuDDiement ] to NRC Bulletin 90-01:

limerick-1/-2 and peach Bottom-2/-3 1.

INTRODUCTION The NRC issued Bulletin 90-01 on March 9, 1990 (Reference 1). That Bulletin discussed certain Rosemount pressure and ' differential pressure transmitter models identified by the manufacturer as prone to fill-oil leakage.

The bulletin requested licensees to identify whether these transmitters were or may later be installed in safety-related systems.

Actions were detailed for licensee implemen;ation for identified transmitters presently installed in a safety-related system. The same actions apply to identified transmitters presently held in inventory for later installation in a safety system.

With the gradual leakage of fill-oil, the transmitter would not have the I

long term accuracy, time response, and reliability needed for its intended safety function.

Further, this condition could go undetected over a long l

period.

Redundant instrument channels are subject to the same degradation mechanism. This increases the potential for a common mode failure. Thus, this potential failure mechanism raised concern for the reliability of reactor protection systems (RPS), engineered safety features (ESF) actuation. systems, and anticipated transient without scram (ATWS) mitigating systems.

To achieve high functional reliability, there must be a low probability of component failure while operating, with any f ailures readily detectable.

Supplement ' to NRC Bulletin 90-01 (Reference 2) was issued on December 22, 1992.

The Supplement informed licensees of NRC staff activities regarding the subject transmitters, and noted continuing reports of transmitter failures. The NRC requested licensee action to resolve the issue.

The Supplement also updated the information contained in the original bulletin. The licensee was requested to review the information and determine if it was applicable at their facilities. Further, the licensee was requested to modify their actions and enhanced surveillance monitoring programs to conform with the direction given.

Finally, the licensee was instructed to i

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respond to the NRC. The Reauested Actions in Supplement I to NRC Bulletin 90-01 supersede the original NRC Bulletin 90-01 Recuested Actions.

in responding to Supplement I to NRC Bulletin 90-01, the licensee is directed to address three items.

3.

A statement either committing the licensee to take the NRC Bulletin 90-01, Supp2ement 1, Reave.s,ted Actions or taking l

exception to those actions.

2.

Addressing the actions committed to in the above statement, 1

provide:

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a list of specific actions, including any i

justifications, to be taken to complete the l

commitment, l

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a schedule for completion, and c.

after completion, a statement that confirms the actions committed to have been completed.

3.

A statement identifying the NRC Bulletin 90-01, Supplement 1, Reauested Actions not taken, along with an evaluation providing the basis for exemption.

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in implementing the replacement option of the NRC Recue zed Actions, plant shutdown exclusively for replacing the transmitters is not required.

.I This allowance infers that replacements can be scheduled. With replacement in a timely manner, enhanced surveillance monitoring for interim operation is not j

required.

l The Philadelphia Electric Company, the licensee for the Limerick Generating Station, Unit Nos. I and 2. and the Peach Bottom Atomic Power Station. Unit Nos. 2 and 3, responded to Supplement I of NRC Bulletin 90-01 with a letter dated March 5,1993 (Reference 3). This technical evaluation

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report evaluates the completeness of that submittal.

It also determines I

whether proposed surveillance methods are adequate to determine fill-oil loss-l 2

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caused degradation of the transmitter. Finally, this report addresses the interval of surveillance proposed by the licensee for any transmitters i

i included in the enhanced surveillance program.

Many Rosemount transmitter failures have been attributed to the use of i

t stainless steel "0"-rings between the sensing module and the process flanges.

j Rosemount improved the manufacturing process for transmitters manufactured after July 11, 1989. Those improvements included a limit of the torque applied to the flange bolts. This limits the stress caused in the sensing module by the *0"-ring.

Post-production screening, including pressure testing of the sensing module for this potential latent defect, was also implemented at that time. Therefore, as described in Supplement 1 of NRC Bulletin 90-01, j

.those Rosemount transmitters manufactured after July 11, 1989, are not sub ect i

to this review.

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2.

NRC SPECIFIED REQUESTED ACTIONS The NRC staff specified the following Reouested Actions of licensees of operating reactors.

1.

Review plant records and identify the following Rosemount transmitters (if manufactured before July 11,1989) that either are used in or may be used in either safety-related or ATWS mitigating systems.

Rosemount Model 1153, Series B a

Rosemount Model 1153, Series D Rosemount Model 1154 Following identification, the licensee is to establish the following:

a.

For those identified transmitters having a normal operating pressure greater than 1500 psi, and are installed as part of reactor protection trip systems. ESF actuation systems, or ATWS mitigating systems, either replace the transmitter in an expedited manner, or monitor monthly, for the life of the transmitter, using an enhanced surveillance program.

If the identified transmitter exceeds the 60,000 psi-month or the 130,000 psi-month criterion (depending on the range code nf the transmitter) established by Rosemount, enhanced surveillance on a refueling (not exceeding 24 months) basis is acceptable. Under this option, justification must be based on the service record and the specific safety function of the transmitter. That justification can be based on high functional reliability provided by redundancy or diversity.

b.

For those identified transmitters having a normal operating pressure greater than 1500 psi, and are installed as part of a safety-related system other than reactor protection trip systems, ESF actuation, or ATWS mitigating systems, either replace the transmitter or monitor quarterly, for the life of the transmitter, using an enhanced surveillance program.

If the identified transmitter exceeds the 60,000 psi-month or the 130,000 psi-month criterion (depending on the range code of the transmitter) established by Rosemount, enhanced surveillance on a ref ueling (not exceeding 24 months) basis is acceptable. Under i

this option, justification must be based on the service record and the specific safety function of the transmitter.

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justification can be based on high functional reliability provided by redundancy or diversity.

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For boiling water reactors (BWR)--

For those identified transmitters having a normal operating i

pressure greater than 500 psi and less than or equal to 1500 psi, and are installed as part of reactor protection trip systems, ESF actuation systems, or ATWS mitigating syete";, either replace the transmitter, or monitor monthly with an enhanced surteillance monitoring program, until the transmitter reaches the designated (by Rosemount) psi-month criterion (60,000 psi-month or 130,000 psi-month, depending on the transmitter range code).

For transmitter $ that provide signals to the RPS or ATWS trips for high ssure or low water level, the enhanced surveillance must be monthly.

For other transmitters in this classification, enhanced surveillance on a refueling (not exceeding 24 months) basis is acceptable.

Under this I

option, justification must be based on the service record i

and the specific safety function of the transmitter. That justification can be based on high functional reliability provided by redundancy or diversity.

for pressurized water reactors (PWR)--

For those identified transmitters having a normal operating i

pressure greater than 500 psi and less than or equal to 1500 psi, and are installed as part of reactor protection trip systems, ESF actuation systems, or ATWS mitigating systems, either replace the transmitter, or monitor with an enhanced surveillance monitoring program, until the transmitter reaches the designated (by Rosemount) psi-month

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criterion (60,000 psi-month or 130,000 psi-month, depending on the transmitter range code) on a refueling (not exceeding 24 months) basis, i

d.

For those identified transmitters having a normal operating l

pressure greater than 500 psi and less than or equal to 1500 psi, and are installed as part of a safety-related system other than reactor protection trip systems, ESF actuation, or ATWS mitigating j

systems, either replace the transmitter or monitor with an enhanced surveillance monitoring program, until the transmitter reaches the designated (by Rosemorit) psi-month criterion (60,000

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psi-month or 130,000 psi-month, cepending on the transmitter range j

code) on a refueling (not exceesing 24 months) basis.

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Those transmitters father than 0"C high pra,.u.e ur-le" wo e -

_ trips fu, RF5 ur ATW5 octu.Ren)-having a normal operating pressure greater than 500 psi and less than or equal to 1500 psi, and have accumulated sufficient psi-month operating history to 1

exceed the criterion established by Rosemount, may be excluded i

from the enhanced surveillance monitoring program at the discretion of the licensee. However, the licensee should retain a high level of confidence that a high level of reliability is maintained and that transmitter f ailure due to loss of fill-oil is detectable.

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Those transmitters having a normal operating pressure less than or equal to 500 psi may be excluded from the enhanced surveillance monitoring program at the discretion of the licensee.

However, the licensee should retain a high level of confidence that a high level of reliability is maintained and that transmitter failure due to loss of fill-oil is detectable.

2.

Evaluate the enhanced surveillance monitoring program.

The evaluation is to ensure the measurement data has an accuracy commensurate with the accuracy needed to compare the data to the manufacturers drift data

criteria, it is this comparison that determines the degradation threshold for loss of fill-oil failures of the subject transmitters.

The Supplement also states the NRC may conduct audits or inspections in the future to verify compliance with the established requirements.

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3.

EVALUATibN The licensee provided a response to Supplement 1 of NRC Bulletin 90-01 on March 5, 1993. That response was compared to the Bulletin Reportino Reauirements and Reauested Actions as described below. The licensee reports having 294 Rosemount model 1153, series B and D, transmitters at their four nuclear units that are subject to the Recuested Actions.

There are no Rosemount model 1154 transmitters at either station within the scope of the Supplement.

l Rosemount transmitters manufactured or refurbished with sensing modules manufactured after July 11, 1989, are excluded from the licensee submittal as directed by the Supplement.

3.1 Evaluation of Licensee Response to ReDortino Recuirements 1

The licensee states all that all the Reauested Actions detailed in Supplement 1 of NRC Bulletin 90-01 have been completed.

Included with that statement is clarification, interpretation, and a description of the ;pecific actions taken to implement the Regpested Actions.

The licensee submittal conforms with the ReDortino Recuiremtnts of i

Supplement 1 of NRC Bulletin 90-01.

3.2

[ valuation of Licensee Response to Recuested Actions Supplement 1 of NRC Bulletin 90-01 requested licensee action to resolve the issue of fill-oil leakage in Rosemount transmitters.

In this Technical Evaluation Report, the Recuested Actions and associated transmitter criteria are summarized in Section 2 of this report.

The licensee identified a total of 214 transmitters that are in the scope of this review at the Limerick j

Generating Station.

The licensee identified a total of 80 transmitters that are in the scope of this review at the Peach Bottom Atomic Power Station. The j

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1 licensee response to t upplement for these transmitters is discussed in the following sections.

3.2.1 Licensee Resoonse to Recuested Action 1.a l

The licensee states there are no Rosemount transmitters from this citssification at the Limerick Generating Station. The licensee states there are no Rosemount transmitters from this classification at the Peach Bottom j

Atomic Power Station, j

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3.2.2 licensee Resoonse to Recuested Action 1.b The licensee states there are no Rosemount transmitters from this classification at the Limerick Generating Station. The licensee states there are no Rosemount transmitters from this classification at the Peach Bottom i

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Atomic Power Station.

3.2.3 Licensee Resoonse to Recuested Action 1.c Rosemount transmitters from this classification at both the Limerick Generating Station and the Peach Bottom Atomic Power Station are included in an enhanced surveillance monitoring program.

The transmitters are monitored monthly for potential signal degradation using the following methods.

a.

Drif t trending of process operating data of redundant channels by

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the plant computer.

b.

Zero drif t trending of operational data of transmitters normally at a zero state.

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Zero drift trending of calibration data.

d.

Extended span (to 130 percent) response check for transmitters that are not reverse calibrated (sucn as reactor vessel level) and l

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observed by indicator.

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Extrapolation of drift rate to the next routine surveillance testing.

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The number of Rosemount transmitters in this classification will decrease over time due to transmitter replacement, refurbishment, or reclassification as permitted by the Supplement. As these transmitters become eligible for lessened monitoring requirements, the licensee will provide justification to the NRC if less frequent monitoring is desired. That justification would j

J document why an increase in the surveillance interval is acceptable.

I Limerick Generatina Station The licensee reported there are currently 93 Rosemount transmitters from this classification at the Limerick Generating Station. All identified transmitters are part of the enhanced surveillance monitoring program. The enhanced surveillance monitoring program is acceptable for Rosemount I

transmitters used at a BWR.

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Peach Bottom Atomic Power Station The licensee reported there are currently 72 Rosemount transmitters from this classification at the Peach Bottom Atomic Power Station. All identified transmitters are part of the enhanced surveillance monitoring program. The enhanced surveillance monitoring program is acceptable for Rosemount transmitters used at a BWR.

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I 3.2.4 Licensee Resoonse to Recuested Action 1.d i

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Limerick Generatiro Station The licensee reported there are currently 16 Rosemount transmitters from

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transmitters are part of the enhanced surveillance monitoring program.

The transmitters are monitored on a refueling basis for potential signal degradation using methods c, d, and e ou'. lined above. The enhanced j

surveillance monitoring program is acceptable for Rosemount transmitters used at a BWR.

The number of Rosemount transmitters in this classification will decrease over time due to transmitter replacement, refurbishment, or I

reclassification as permitted by the Supplement. As these transmitters become

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eligible for lessened monitoring requirements, the licensee will provide j

justification to the NRC if less frequent monitoring is desired.

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justification would document why an increase in the surveillance interval is acceptable.

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i Peach Bottom Atomic Power Station The licensee states there are no Rosemount transmitters from this f

classification at the Peach Bottom Atomic Power Station.

3.2.5 Licensee Response to Recuested Action 1.e l

The Supplement requires the licensee to maintain a high degree of confidence that the Rosemount transmitters in this classification are highly reliable.

The licensee assures this confidence as discussed Section 3.2.6.

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1 Limerick Generatino Station The licensee reported there are currently 21 Rosemount transmitters from l

this classification at the Limerick Generating Station. These Rosemount transmitters are excluded from the enhanced surveillance monitoring program as permitted by the Supplement. The number of these transmitters will increase over time due to transmitter reclassification as permitted by the Supplement.

As these transmitters become eligible for exclusion from the enhanced surveillance monitoring program, the licensee will provide justification to the NRC if this exclusion is determined suitable for that transmitter.

i Peach Bottom Atomic Power Station i

The licensee states there are no Rosemount transmitters from this classification at the Peach Bottom Atomic Power Station.

However, the number of transmitters in this classification can increase over time due to transmitter reclassification as permitted by the Supplement. As these I

transmitters become eligible for exclusion from the enhanced surveillance monitoring program, the licensee will provide justification to the NRC if this exclusion is determined suitable for that transmitter.

4 3.2.6 L1.censee Response to Reauested Action 1.f The licensee reported there are currently 84 Rosemount transmitters from this classification at the Limerick Generating Station. The licensee reported there are currently eight Rosemount transmitters from this classification at the Peach Bottom Atomic Power Station. These transmitters are excluded from the enhanced surveillance monitoring program as permitted by the Supplement.

l The Supplement requires the licensee to maintain a high degree of confidence that the transmitters identified with Recuested Actions 1.e and }.f are highly reliable.

The licensee maintains this confidence with several techniques.

First, all transmitter calibration procedures direct the 11 1

l performing technician to look specifically for symptoms that indicate a loss of fill-oil.

These symptoms include sluggish response, inability to calibrate to tSe full span, and abnormal responses to process noise.

Second, operations staff and instrument and control technicians are trained in the potential problems and symptoms that indicate a transmitter with a loss of fill-oil.

Extended span response checks will continue where they are now part of regular surveillance procedures. Transmitters with symptoms of a loss of fill-oil condition will have an operability acceptance test. This test will further screen for potential degradation of the transmitter signal.

3.2.7 Enhanced Surveillance Monitorina Proaram The licensee submittal includes a description of their enhanced surveillance monitoring program.

The program analyzes calibration data, taken from routine surveillance testing, and operational data comparisons to identify symptoms of fill-oil leakage. The surveillance calibration data is taken from tighly accurate measurement and test equipment. The operational data is taken from cont.ol panel indicators (one percent accuracy or better) in the control room.

Indicators that normally read zero on a scale with zero k

as a span limit are excluded from this provision, using digital. voltmeters to collect that operational data instead. Where no panel meter exists, digital voltmeters are used to collect operational data. The data is analyzed against s

the drif t limits documented in Rosemount Technical Bulletin No. 4.

Expanded span (to 130 percent) response tests are performed, except on reverse calibrated transmitters or where the indicator cannot display a signal of 130

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percent, i

The result of the analysis is a determination if the performance of the j

transmitter is acceptable.

If the analysis shows degraded performance, an j

operability performance test is performed. The operating performance test results confirm acceptable transmitter performance, or the need for i

replacement or refurbishment. The licensee's enhanced surveillance monitoring I

program is acceptable.

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Rosemount transmitters that are subject to the requested actions of the Supplement are included in the enhanced surveillance monitoring program described in the above sections. Those transmitters included in the response f

i to Reouested Action 1.c also have operating data comparisons between redundant channels monthly.

The weighed average process value is included in that comparison.

This method applies when there is normally an operating pressure or when the normal pressure is zero. The surveillance calibration data for transmitters included in the enhanced surveillance monitoring program is analyzed, and any resulting drift calculated.

Due to the transient process conditions during startup and shutdown

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operation, there are no monthly data collections during those operating i

conditions, i

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CONCLUSIONS-Based on our review, we find that the licensee has completed the reporting requirements of Supplement 1 of NRC Bulletin 90 01.

Further, the licensee conforms to the requested actions of Supplement I to NRC Bulletin j

90 01.

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REFERENCES i

1.

NRC Bulletin No. 90-01:

" Loss of Fill-oil in Transmitters Manufactured by Rosemount," March 9, 1990, OMB No. 3150-0011.

2.

NRC Bulletin No. 90-01, Supplement 1:

" Loss of Fill-oil in Transmitters Manufactured by Rosemount," December 22, 1992, OMB No. 3150-0011.

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Letter, Philadelphia Electric Company (G. J. Beck) to NRC, " Response to j

NRC Bulletin 90-01 Supplement 1

' Loss of fill-011 in Transmitters Manufactured by Rosemount'," March 5, 1993.

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