ML20059L224
| ML20059L224 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/30/1993 |
| From: | Udy A EG&G IDAHO, INC. |
| To: | NRC |
| Shared Package | |
| ML20058F082 | List: |
| References | |
| CON-FIN-L-1695 EGG-RTAP-10816, TAC-M85358, NUDOCS 9311160368 | |
| Download: ML20059L224 (18) | |
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EGG-RTAP-10816 l
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TECHNICAL EVALUATION REPORT
-l Evaluation of Utility Response to Supplement I to NRC Bulletin 90-01: Big Rock Point i
Docket No. 50-155 Alan C. Udy Published June 1993
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l EG&G Idaho, Inc.
Idaho National Engineering Laboratory Idaho Falls, Idaho. 83415 Prepared for the i
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. L1695, Task No. 11 TAC No. M85358
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SUMMARY
This report documents the EG&G Idaho, Inc., review of the Big Rock Point Plant submittals that respond 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. Exceptions to the requested actions and the reporting requirements are evaluated.
l FIN No. L1695, Task No. 11
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B&R No. 320-19-15-05-0 Docket No. 50-155 TAC No. M85358 11
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i CONTENTS
SUMMARY
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l PREFACE...............................................................
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1.
INTRODUCTION....................................................
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2.
NRC SPECIFIED REQUESTED ACTIONS.................................
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3.
EVALUATION......................................................
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i 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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r PREFACE 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 Commission, Office of Nuclear Reactor Regulation, Division of Reactor Controls and Human Factors, by EG&G Idaho, Inc., Regulatory and Technical Assistance Program Unit.
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Evaluation of Utility Resoonse to Sunnlement I to NRC Bulletin 90-01:
1.
INTRODUCTION l
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.
If the identified transmitters were either installed in or held in inventory for.
later installation in a safety-related system,. actions were detailed for.
i licensee implementation.
f With the gradual leakage of fill-oil, the transmitter would not have the l
long term accuracy, time response, and reliability needed for its intended safety function. Further, this condition could go undetected over a long
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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 failures readily detectable.
l Supplement I to NRC Bulletin 90-01 (Reference 2) was issued on December 22, 1992. The' supplement informed licensees of NRC staff activities l
.egarding the subject transmitters, and noted continuing reports of l
transmitter failures. The NRC requested licensee action to resolve the issue.
The supplement also updated the information contained in the original bul.etin. The licensee was requested to review the information and detemine if it was applicable at their facility. 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 1
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i respond to the NRC. The Reauested Actions in Supplement I to NRC Bulletin 90-
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01 supersede the original NRC Bulletin 90-01 Reauested Actions.
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In responding to Supplement I to NRC Bulletin 90-01, the licensee is directed to address three items.
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1.
A statement either comitting the licensee to take the NRC Bulletin 90-01, Supplement 1, Reauested Actions or taking,
j exception to those actions.
2.
Addressing the actions comitted to in the above statement, provide:
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a list of specific actions, including any justifications, to be taken to complete the comitment, l
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a schedule for completion, and 4
c.
after completion, a statement that confirms the actions comitted to have been completed.
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A statement identifying the NRC Bulletin 90-01, Supplement 1, l
Reauested Actions not taken, along with an evaluation providing
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the basis for exemption.
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In implementing the replacennt option of u.. NRC Reauested Actions, plant i
shutdown exclusively for replacing the transmitters is not required. This
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allowance infers that replacements can be scheduied. With replacement in a l
timely manner, enhanced surveillance monitoring for interim operation is not i
required.
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Consumers Power Company, the licensee for the Big Rock Point Plant, responded to Supplement 1 of NRC Bulletin 90-01 with a letter dated January 8, 1993 (Reference 3). A letter dated hr.:::ry 26, 1993 (Reference 4) confirmed that all Reauested Actions were complete. This technical evaluation report evaluates the completeness of those submittals.
It also determines whether proposed surveillance methods are adequate to determine fill-oil loss-caused l
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degradation of the transmitter. Finally, this report addresses the interval j
of surveillance proposed by the licensee for any transmitters included in the j
enhanced surveillance program.
I Many transmitter failures were attributed to the use of stainless steel "0"-rings between the sensing module and the process flanges.
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 for this potential latent defect was also implemented at that time. Therefore, as described in Supplement 1 of NRC Bulletin 90-01, those Rosemount transmitters manufactured after July 11, 1989, are not subject to this review, if so identified by the licensee.
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2.
NRC SPECIFIED REQUESTED ACTIONS I
i The NRC staff specified the following Reauested Actions of licensees of operating reactors.
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1.
Review plant records and identify the following Rosemount transmitters-(if manufactured before July 11,198g) that either are used in or may be
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used in either safety-related or ATWS mitigating systems.
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'l Rosemount Model 1153, Series B Rosemount Model 1153, Series D Rosemount Model 1154 i
Following identification, the licensee is to establish the following:
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For those identified transmitters having a normal operating i
pressure greater than 1500 psi, and are installed as part of l
reactor protection trip systems, ESF actuation systems, or ATWS 1
mitigating systems, either replace the transmitter in an expedited manner, or monitor monthly, for the life of the transmitter, using l
an enhanced surveillance program.
If the identified transmitter exceeds the 60,000 psi-month or-the i
1 130,000 psi-month criterion (depending on the range code of the i
transmitter) established by Rosemount, enhanced surveillance on a
-i refueling (not exceeding 24 months) basis is acceptable. Under this option, justification must be based on the service record and j
the specific safety function of the transmitter. That-justification can be based on high functional reliability-provided i
by redundancy or diversity.
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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, j
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 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.
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f justification can be based on high functional reliability provided i
by redundancy or diversity.
c.
For boiling water reactors (BWR) --
For those identified transmitters having a normal operating l
pressure greater than 500 psi and less than or equal to i
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 monthly.
with an enhanced surveillance monitoring program, until the transmitter reaches the designated-(by Rosemount) psi-month i
criterion (60,000 psi-month or 130,000 psi-month, depending on the transmitter range code).
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For transmitters that provide signals to the RPS or ATWS trips for high pressure or low water level, the enhanced.
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surveillance must be monthly.
For other transmitters in this classification, 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 i
justification can be based on high functional reliability l
provided by redundancy or diversity..
i For pressurized water reactors --
For those identified transmitters having a normal. operating 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 N
transmitter reaches the designated (by Rosemount) psi-month criterion (60,000 psi-month or 130,000 psi-month, depending on the transmitter range code) on a refueling.(not exceeding 24 months) basis.
d.
For those identified transmitters having a normal operating -
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.
systems, either replace the transmitter or monitor with an-enhanced surveillance 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) on a refueling (not exceeding 24 months) basis.
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e.
Those transmitters (utner d.. 02 't;h p-r tc; or ipw - i.. '
le. 1 1.-:;: f;r nr: er ATU actu:tient 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 exceed the criterion established by Rosemount, may be excluded from the enhanced surveillance monitoring program at the l
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.
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f.
Those transmitters having a normal operating pressure less than or equal to 500 psi may be excluded from the' enhanced surveillance 4
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 cf the subject transmitters.
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The Supplement also states the NRC may conduct audits or inspections in f
the future to verify compliance with the established requirements.
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3.
EVAL.UATION i
The licensee provided responses to Supplement I to NRC Bulletin 90-01 on January 8,1993, and January 26, 1993. These responses were compared to the Bulletin Reoortino Reauirements and Reauested Actions as described below. The licensee reports they have ten Rosemount transmitters that.are subject to the Reouested Actions of the Supplement.
3.1 Evaluation of Licensee Response to Reportina Raouirements The licensee states the Recuested Actions detailed in Supplement 1 of l
NRC Bulletin 90-01 are not necessary, except replacing the sensing module of a spare transmitter.
Included with that statement is clarification, interpretation, and constraints placed on that' commitment. The licensee described the specific actions taken to implement the Reauested Actions and verified the actions were compiete.
The licensee states that the Reauested Actions are complete. The submittal identifies where no licensee action is taken.- The licensee provides i
evaluation and justification supporting the position that an enhanced surveillance program is not necessary.
The licensee submittal conforms with the Reoortino Reauirements'of Supplement 1 of NRC Bulletin 90-01.
l 3.2 Evaluation of Licensee Response to Reauested Actions
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Supplement 1 of HRC Bulletin 90-01 requested licensee action to resolve j
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 response is discussed in the following sections. The licensee identified a total of ten transmitters that are in the scope of this review. The licensee has no 7
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Rostmount model 1154 transmitters included in the scope of this review, only model 1153, type D.
3.2.1 Licensee Resoonse to Recuested Action 1.a.
Big Rock Point has a nominal operating pressure of 1350 psia.
Therefore, there are no Rosemount transmitters from this classification at, Big Rock Point.
3.2.2 Licensee Resoonse to Recuested Action 1.b.
Big Rock Point has a nominal operating pressure of 1350 psia.
Therefore, there are no Rosemount transmitters from this classification at Big Rock Point.
3.2.3 Licensee Response to Recuested Action 1.c.
Four steam drum level transmitters are included in this classification by the licensee. These transmitters are part of the reactor depressurization system and provide both indication and trip functions. All four transmitters have exceeded the 60,000 psi-month criterion established by Rosemount and endorsed by the NRC. Thus, these four transmitters are no longer included in an enhanced surveillance program. An enhanced surveillance program is neither required by the supplement nor provided by the licensee for these four transmitters. Static alignment checks, a part of the transmitter calibration program, have revealed no indication of loss of fill oil since installation of the transmitters in 1985. Static alignment checks are capable of detecting transmitter degradation caused by the loss of fill oil.
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3.2.4 Licensee Response to Reouested Action 1.d.
1 There are no Rosemount transmitters from this classification at Big Rock i
Point.
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3.2.5 Licensee Resnonse,to Reauested Action 1.e.
i The Big Rock Point Plant considers the four transmitters discussed in I
response to action 1.c that have exceeded the psi-month criterion (discussed f
in Section 3.2.3) and a spare transmitter for that application as not subject to an enhanced surveillance monitoring program.
Reference 4 reports the spare transmitter had its sensing module replaced by Rosemount in August 1991.
Therefore, no enhanced, surveillance monitoring program is needed for.this I
spare transmitter. Thus, these five Rosemount transmitters are acceptable without an enhanced surveillance program.
i 3.2.6 Licensee Response to Reauested Action 1.f.
S The Big Rock Point Plant has five Rosemount transmitters in this classification. Two redundant transmitters monitor the core spray flow. Two I
redundant transmitters monitor the containment spray flow. - They provide i
indication only. A fifth transmitter is held as a spare for either of these two applications. The spare transmitter was refurbished by Rosemount in j
August 1991. These installed Rosemount transmitters have static alignment checks as part of their calibration procedures. Static; alignment checks are capable of detecting transmitter degradation caused by the loss of. fill oil, i
f No enhanced surveillance is required by the Supplement for this l
classification of transmitters. Thus, these five Rosemount transmitters are acceptable without enhanced surveillance.
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t' 3.2.7 Enhanced Surveillance Procram The licensee has justified not establishing an enhanced surveillance program for the subject Rosemount transmitters. Therefore, no evaluation of measurement data accuracy is possible or necessary. Static alignment checks are capable of detecting transmitter degradation caused by.the loss of fill oil. These static alignment checks, which are performed as part of the refueling basis transmitter calibrations, provide a high level of confidence 1
that a high level of transmitter reliability is maintained.
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CONCLUSIONS Based on our review, we find that the licensee has completed the l
Reoortino Reauirements and the Reauested Actions of Supplement 1 of NRC Bulletin 90-01.
Further, the licensee either conforms to or has adequate justification for deviating from the requested actions of Supplement I to NRC l
Bulletin 90-01. No enhanced surveillance program is necessary for the Rosemount transmitters at Big Rock Point.
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BIBLIOGRAPHIC DATA SHEET
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Evaluation of Utility Response to Supplement I to NRC 3
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P. O. Box 1625 Idaho Falls, ID 83415
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Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington D. C.
20555
- 10. SUPPLEMENT An v NOTES
- 11. ABsT R ACT :200-e en e, arm, This report documents the EG&G Idaho Inc., review of the Big Rock Point Plant submittal 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 Rosemont, Inc.
This report identifies areas of non-conformance to the requested actions and the reporting requirements. Exceptions to the requested actions and the 4
reporting requirements are evaluated.
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NRC Bulletin 90-01, Supplement 1 Unclassifind '
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- 16. PRICE esRC 80*id 235 '249'
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REFEkENCES r
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-cil in Transmitters Manufactured by Rosemount," December 22, 1992, DMB No. 3150-0011.
3.
Letter, Consumers Power Company (W. L. Beckman) to NRC, " Response to NRC Bulletin 90-01, Supplement 1 - Loss of Fill-0il in Transmitters Manufactured by Rosemount," January 8,1993.
4.
Letter, Consumers Power Company (W. L. Beckman) to NRC, " Revised Response to NRC Bulletin 90-01, Supplement 1,. Loss of Fill-Oil in Transmitters Manufactured by Rosemount," January 26, 1993.
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