ML20069H139

Technical Evaluation Rept Evaluation of Utility Response to Suppl 1 NRC Bulletin 90-01:Feri-2

ML20069H139
Person / Time
Site:	Fermi
Issue date:	06/03/1994
From:	Udy A EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20069H123	List: ML20069H139
References
CON-FIN-L-1695 EGG-ERTP-10865, IEB-90-001, IEB-90-1, TAC-M85388, NUDOCS 9406100330
Download: ML20069H139 (16)

Text

ENCLOSURE 2  !

EGG-ERTP-10865 +

TECHNICAL EVALUATION REPORT ,

Evaluation of Utility Response to Supplement I to '

NRC Bulletin 90-01: Fermi-2 t Docket No. 50-341 Alan C. Udy t Published March 1994 i

EG&G Idaho, Inc.

Idaho National Engineering Laboratory i Idaho Falls, Idaho 83415 i

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Prepared for the U.S. Nuclear Regulatory Comission i Washington, D.C. 20555 i Under 00E Contract No. DE-AC07-761D01570 FIN No. Ll695, Task No. 11 TAC No. M85388 l

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9406100330 940603 PDR ADOCK 05000341 p PDR

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SUMMARY

This report documents the EG&G Idaho, Inc., review of the Detroit Edison submittsis that respond to Supplement I to NRC Bulletin 90-01 for Fermi-2.

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.

I FIN No. Ll695, Task No. 11 B&R No. 320-19-15-05-0 i Docket No. 50-341 TAC No. M85388 11

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PREFACE l

l 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, l Inc., DOE /NRC Support Programs Unit.

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Evaluation of Utility Resoonse to Sucolement I to NRC Bulletin 90-01: Ferini-2 l

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. l Actions were detailed for licensee implementation for certain identified transmitters presently installed in a safety-related system. These same  !

actions apply to those identified transmitters presently held in inventory for later installation in a safety-related system.

With the gradual leakage of fill-oil, the transmitter would not have the long term accuracy, time response, and reliability needed for its intended 1 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 comon mode failure. Thus, this potential failure anchanism 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 j 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 regarding the subject transmitters, and noted continuing reports of '

transmitter failures. The NRC requested licensee action to resolve the issue. 1 The Supplement also updated the information contained in the original bulletin. The licensee was requested to review the information and determine

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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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F CONTENTS

SUMMARY

............................................................... ii PREFACE ..................................<............................ iii

1. INTRODUCTION .................................................... 1

2. NRC SPECIFIED REQUESTED ACTIONS ................................. 4

3. EVALUATION ...................................................... 7

's .1 Evaluation of Licensee Response to Reporting Requirements . 7 3.2 Evaluation of Licensee Response to Requested Actions ...... 7  ;

4. CONCLUSIONS ..................................................... 11

5. REFERENCES ...................................................... 12 a

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

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

1. A statement either comitting the licensee to take the NRC Bulletin 90-01, Supplement 1, Reouested Actions or taking exception to those actions.

2. Addressing the actions comitted to in the above statement, provide:

a. a list of the specific actions, including any justifications, to be taken to complete the comitment,

b. a schedule for completion, and

c. after completion, a statement confirming the actions comitted to are complete.

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

In implementing the replacement option of the NRC Reouested Actions, plant shutdown exclusively for replacing the transmitters is not required.

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

Detroit Edison, the licensee for Fermi-2, responded to Supplement 1 of NRC Bulletin 90-01 with a letter dated March 5, 1993 (Reference 3). The licensee provided additional information on December 20, 1993 (Reference 4).

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 degradation of the transmitter.

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Finally, this report addresses the interval of surveillance proposed by the licensee for any transmitters included in the enhanced surveillance monitoring program.

Many transmitter failures were attributed to the use of stainless steel "0"-rings between the sensing module and th'e 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 " - r i.ng . 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, those Rosemount transmitters manufactured after July 11, 1989, are no.t subject to this review, if so identified by the licensee.  ;

The licensee has chosen to replace their at-risk Rosemount transmitters rather than implement an enhanced surveillance monitoring program.

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Finally, this report addresses the interval of surveillance proposed by the licensee for any transmitters included in the enhanced surveillance monitoring program.

Many transmitter failures were attributed to the use of stainless steel "0"-rings between the sensing module and th'e 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 " - r i.ng . 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, those Rosemount transmitters manufactured after July 11, 1989, are no.t subject to this review, if so identified by the licensee.

The licensee has chosen to replace their at-risk Rosemount t ansmitters rather than implement an enhanced surveillance monitoring program.

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2. NRC SPECIFIED REQUESTED ACTIONS The NRC staff specified the following Reauested Actions of licensees of j

operating reactors.

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1. Review plant reords and identify the following Rosemount transmitters i I

(if manufactured before July 11,1989) that either are used in or may be i used in either safety-related or ATWS mitigating systems. '

• Rosemount Model 1153, Series B  !

• Rosemount Model 1153, Series D Rosemount Model 1154 f

Following identification, the licensee is to establish the following: l

a. For those identified transmitters having a nomal. operating  !

pressure greater than 1500 psi, and are installed as part of l

' reactor protection trip systems, ESF actuation systems, or ATWS j mitigating systems, either replace the transmitter in an expedited  ;

manner, or monitor monthly, for the life of the transmitter, using an enhanced surveillance program. l 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 l 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. l

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 l transmitter or monitor quarterly, for the life of the transmitter,  !

using an enhanced surveillance program.  !

5 If the identified transmitter exceeds the 60,000 psi-month or the i 130,000 psi-month criterion (depending on the range code of the i 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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justification can be based on high functional reliability provided by redundancy or diversity.

c. For boiling water reactors (P"R)--

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 monthly with an enhanced surveillance monitoring program, until the transmitter reaches the designaamd (by Rosemount) psi-month criterion (60,000 psi-month or 130,000 psi-month, depending-on the transmitter range code).

For transmitters that provide signals to the RPS or ATWS trips for high pressure or law 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 '

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 i provided by redundancy or diversity, i For pressurized water reactors (PWR)--

i 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  !

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 l 24 months) basis. i

d. For those identified transmitters hasing 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 l l

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 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 i established by Rosemount, 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.

f. 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. EVALUATION ,

The licensee provided a response to Supplement 1 of NRC Bulletin 90-01 on March 5, 1993. Additional information was prov Wed on December 20, 1993.

l Those responses were compared to the Bulletin Reoortina Reauirements and i Reauested Actions as described below. The licensee response (Reference 3) l lists 130 safety-related and non-safety-related Rosemount transmitters. The j licensee, in References 3 and 4, reports having 39 Rosemount transmitters that  ;

are subject to the Reauested Actions of the Supplement. These transmitters-  !

are all model 1153, series B, in safety-related applications, that were manufactured before July 11, 1989.

l 3.1 Evaluation of Licensee Response to Reportina Reauirements l

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The licensee described the specific actions taken to implement the

• Reauested Actions and the associated schedule for completion. The licensee reported having 130 Rosemount transmitters that were evaluated for inclusion in their Reference 3 response. Those transmitters included safety-related and non-safety-related applications. The licensee listed those 130 transmitters,  !

with model number and manufacturing date. Of the 130 transmitters, 39 are  ;

subject to the Reauested Actions of the Supplement. These 39 transmitters i have safety-related applications and were manufactured before July 11, 1989. l A statement that the Reauested Actions are complete will be submitted i i

separately af ter the scheduled items are complete. The licensee submittals i conform to the Reportino Reauirements of Supplement 1 of NRC Bulletin 90-01.

3.2 Evaluation of Licensee Response to Reauested Actions  ;

i Supplement 1 of NRC Bulletin 90-01 requested Jicensee action to resolve -l the issue of fill-oil leakage in Rosemount transmitters. In this Technical .

Evaluation Report, the Reauested Actions and associated transmitter criteria are summarized in Section 2 of this report. The licensee has no Rosemount 7 i

1 model 1154 transmitters included in the scope of this review. The licensee identified a total of 39 Rosemount model 1153 transmitters that are included in the scope of this review.

l 3.2.1 Licensee Response to Reouested Action 1.a The licensee indicates there are no Rosemount transmitters from this classification at Fermi-2.

3.2.2 Licensee Response to Reauested Action 1.b The licensee incicates there are no Rosemount transmitters from this classification at Fermi-2.

3.2.3 Licensee Response to Reauested Action 1.c The licensee lists and discusses nine transmitters from this classification. Each will be replaced by the end of the fourth refueling outage, scheduled to begin in March, 1994. The licensee presented justification for not placing these transmitters in an interim enhanced surveillance monitoring program.

Four of the transmitters are part of a trip circuit for the high pressure coolant injection system pump turbine. The trip occurs as the steam pressure decreases through 100 psi. The fill-oil loss mechanism does not cause a delayed response on decreasing pressure. The transmitters are normally saturated off-scale, preventing a monthly check. These transmitters will be replaced under work requests WR #000Z923080 and #000Z923081.

The signals from the other five transmitters are processed to provide permissives for the main steamline isolation valve. leakage control system.

These transmitters will be replaced under work request WR #000Z923082. Four 8

j of these are normally saturated off-scale, preventing a monthly check. The other transmitter is a-differential pressure unit, and is normally at zero differential pressure. Premature operation (caused by transmitter offset) of the trips associated with these transmitters does not prevent system operation. The system is manually armed and another pressure permissive is necessary before system operation. A redundant division also assures system operation.

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All nine transmitters will exceed their psi-month criterion before j replacement. At that point, those transmitters could be exempted from an enhanced surveillance monitoring program. Reference 3 indicates there is no i drift that suggests of a loss of fill-oil for any of these transmitters. A l loss of fill-oil failure is a gradual deterioration. The potential for the -

1 failure mechanism occurring is largely over as the transmitter reaches this accumulation of operating history. Therefore, replacing these transmitters I without an interim enhanced surveillance monitoring program is acceptable.

3.2.4 Licensee Response to Recuested Action 1.d The licensee indicates there are no Rosemount transmitters from this classification at Fermi-2.

3.2.5 Licensee Response to Recuested Action 1.e The licensee indicates there are no Rosemount transmitters from this classification at Fermi-2. Further, with all at-risk medium pressure Rosemount transmitters replaced, there will be no Rosemount transmitters added to this classification in the future.

3.2.6 Licensee Response to Recuested Action 1.f The Itcensee indicates there are 30 Rosemount transmitters from this classification at Fermi-2. Of these 30 transmitters,18 do not normally 9

. .s operate at pressure. Reference 4 identifies the systems these transmitters monitor and the normal system operating pressure. These transmitters are grouped properly in response to Reauested Action 1.f based on either normal pressure or system operating pressure. None are exposed to more than 300 psi.

No enhanced surveillance monitoring program is required by the Supplement for this transmitter classification. The Supplement requires the licensee to maintain a high degree of confidence that these transmitters remain highly reliable. The licensee maintains this confidence by checking for symptoms of fill-oil loss when performing routine surveillance tests.

i 3.2.7 Enhanced Surveillance Monitorina Procram i

There is no enhanced surveillance monitoring program at Fermi-2. All Rosemount transmitters that would be subject to an enhanced surveillance monitoring program are being replaced with transmitters manufactured after July 11, 1989. The replacement is to coincide with refueling outage 4 in the spring of 1994.  !

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4. CONCLUSIONS Based on our review, we find the licensee has completed the reporting ,

requirements of Supplement 1 of NRC Bulletin 90-01, except notification that the scheduled replacement of nine transmitters is complete. The licensee committed to notify the NRC that the replac'Ement is complete, after the work.

is finished. As described by the licensee, an enhanced surveillance .

monitoring program is not necessary at Fermi-2.

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5. REFERENCES

1. NRC Bulletin No. 90-01: " Loss of Till-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.

3. Letter, Detroit Edison (W. S. Orser) to NRC, " Detroit Edison Response to NRC Bulletin 90-01, Supplement 1," March 5, 1993, NRC-93-0037.

4. Letter, Detroit Edison (D. R. Gipson) to NRC, " Formal Response to NRC Questions on Detroit Edison's Response to Bulletin 90-01, Supplement 1," -

December 20, 1993, NRC-93-0146.

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