ML20071J424
| ML20071J424 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/31/1994 |
| From: | Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML17291A310 | List: |
| References | |
| CON-FIN-L-1695 EGG-DNSP-11401, IEB-90-001, IEB-90-1, TAC-M85462, NUDOCS 9407280149 | |
| Download: ML20071J424 (19) | |
Text
.. . _ _ .. .- -. .-
E nu o v ec 2.
'\
EGG-DNSP 11401 July 1994 Idaho EVALUATION OF UTILITY RESPONSE TO National SUPPLEMENT 1 TO NRC BULLETIN 90 01:
Engineering uNp.2
. Laboratory ,
Managed by the U. S.
DeNeent ofEnergy Alan C. Udy l 1 I
~ ~a=
m D( A@7 ?l%1D015N
~ - - - .
N -
t
'n .
i
,t I
I l
I i
l i
?
i i
i NOTICF This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United Sates Government nor any agency thereof, nor any of their employees, makes any warranty, expressed
- or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, apparatus, product or proc. ,
i ess disclosed in this report, or represents that its use by such third party would '
not infringe privately owned rights.
f i
i 1
1 t
I
EGG-DNSP-Il401 TECHNICAL EVALUATION REPORT Evaluatior, of Utility Response to Supplement I to NRC Bulletin 90-01: WNP-2 Docket No. 50-397 Alan C. Udy Published July 1994 EG&G Idaho, Inc.
Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761001570 FIN No. L1695, Task No.11 TAC No. M85462
SUMKARY This report documents the EG&G Idaho, Inc., review of the Washington Public Power Supply System submittals that respond to Supplement I to NRC Bulletin 90-01 for WNP-2. This NRC Bulletin provides information regarding the loss of fiil-oil in certain pressure and differential pressure transmitters manufactured by Rosemount, Inc. This report finds the licensee conforms to the requested actions and the reporting requirements of the Supplement.
FIN No. Ll695, Task No. 11 B&R No. 320-19-15-05-0 Docket No. 50-397 TAC No. M85462 ii
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 Comission, Office of Huclear Reactor Regulation, Division of Reactor Controls and Human f actors, by EG&G Idaho, ;
Inc., 00E/NRC Support Programs Unit.
1 i
iii 1
l
CONTENTS
SUMMARY
...................................... ....................... ii PREFACE .............................................................. iii
- 1. INTRODUCTION .................................................... 1
- 2. NRC SPECIFIED REQUESTED ACTIONS ................................. 4
- 3. EVALUATION ...................................................... 7 3.1 Evaluation of Licensee Ree.ponse to Reporting Requirements . 7 3.2 Evaluation of Licensee Hesponse to Requested Actions ...... '7
- 4. CONCLUSIONS ..................................................... 11
- 5. REFERENCES ...................................................... 12 i
iv
Evaluation of Utility Response to Supplement 1 to NRC Bulletin 90-01: WNP-2
- 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 implementation for identified transmitters installed in a safety-related system. These same actions apply to 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 safety function. Further, this condition could go undetected over a long period. Redundant instrument channels are subject to the same degradation mechanism. lhis increases the potential for a common mode failure. Thus, l this potential failure mechanism raised concern for the reliability of reactor protectioa 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 f ailure while operating, with any failures readily detectable.
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.
The Supplement also updated the information contained in the original bulletin. Ihe licensee was requested to review the information and determine if it was applicable at their facility. Further, the licensee was requested to modify their actions and enhanced surveillance monitoring programs to 4 conform with the direction given. Finally, the licensee was instructed to 1
respond to the NRC. The Reauested Actions in Supplement I to NRC Bulletin 90- -:
01 supersede the original NRC Bulletin 90-01 Reauested Actions. !
In responding to Supplement I to NRC Bulletin 90 01, the licensee is directed to address three items.
I
- 1. A statement either committing the licensee to take the NRC Bulletin 90-01, Supplement 1, Reauested Actions or taking exception to those actions. i
- 2. Addressing the actions committed to in the above statement, '
provide: l
- a. a list of the specific actions, including any justifications, to be taken to complete the '
commitment, ,
- b. a schedule for completion, and ,
- c. after completion, a statement confirming the actions ,
committed to are complete. '
- 3. A statement identifying the NRC Bulletin 90-01, Supplement 1, i Recuested Actions not taken, along with an evaluation providing the basis for exemption.
i In implementing the replacement option of the NRC Reauested 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 l required.
( The Washington Public Power Supply System, the licensee for the i Washington Nuclear Project-2 (WNP-2), responded to Supplement 1 of NRC Bulletin 90-01 with a letter dated March 8, 1993 (Reference 3). The licensee i
provided additional information on May 23, 1994 (Reference 4). This technical j evaluation report evaluates the completeness of these submittals. It also I determines whether proposed surveillance methods are adequate to determine ;
l 2 !
. . . . -. . - , _ _ _ ~ _ - - _ . _ _ . , . - _ _ . _ . . _ _ _ _ _ . _ . _ .
fill-oil loss-caused degradation of the transmitter. Finally, this report addresses the interval of surveillance proposed by the licensee for any transmitters included in the enhanced surveillance program.
Many Rosemount transmitter failures have been 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, 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 not subject to this review.
l 3 l
~
- 2. NRC SPECIFIED REQUESTED ACTIONS The NRC staff specified the following Recuested 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
- 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 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 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 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 s
4
l l
justification can be based on high functional reliability provided by redundancy or diversity.
- c. For boiling water reactors (BWR)--
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 I
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).
For transmitters that provide signals to the RPS or ATWS trips for high pressure 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 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.
For pressurized water reactors (PWR)--
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 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 I psi-month or 130,000 psi-month, depending on the transmitter range code) on a refueling (not exceeding 24 months) basis.
l
9
- 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 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.
l l
I l
l
- 3. EVALUATION The licensee provided a response to Supplement 1 of NRC Bulletin 90-01 on March 8, 1993. The licensee provided additional information on May 23, 1994. Those responses were compared to the Bulletin Reoortina Reauirements and Reauested Actions as described below. The licensee indicates they have 64 Rosemount transmitters that are subject to the Reauested Actions of the Supplement.
3.1 Evaluation of Licensee Response to Reportina Reauirements In Reference 3, the licensee describes how they will take the Reauested Actions detailed in Supplement 1 of NRC Bulletin 90-01. Included with those statements are clarification, interpretation, and the limits placed on those commitments. The licensee described the specific actions taken to implement the Reauested Actions and the associated schedule for completion.
In Reference 4, the licensee stated that the Reauested Actions are complete. This included the replacement of two Rosemount transmitters during the spring of 1993. Together, the licensee submittals conform with the Reoortina Reauirements of Supplement 1 of NRC Bulletin 90-01. The submittals identify where no licensee action is taken and provides evaluation and justification supporting the position that the action is not necessary.
3.2 Evaluation of Licensee Response to Reauested 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 Reauested Actions and associated transmitter criteria are summarized in Section 2 of this report. The licensee identified a total of 64 Rosemount transmitters that are in the scope of this review. The licensee response is discussed in the following sections.
7
i o
3.2.1 Licensee Response to Reauested Action 1.a .
The licensee states there are no Rosemount transmitters from this ;
transmitter classification at WNP-2.
3.2.2 Licensee Response to Reauested Action 1.b ,
The licensee states there are no Rosemount transmitters from this transmitter classification at WNP-2. e 3.2.3 Licensee Response to Reauested Action 1.c in Reference 3, the licensee states there are two Rosemount transmitters ,
from this transmitter classification at WNP-2. The licensee notes that these transmitters, RRC-FT-14A dnd RRC-FT-14C, are scheduled for replacement during refueling outage 8 (Spring 1993). In Reference 4, the licensee informed the NRC that this replacement is complete.
3.2.4 Licensee Response to Reauested Action 1.d The licensee states there is one Rosemount transmitter from this transmitter classification at WNP-2. This transmitter, RFW-DPT-4B, provides a signal representing the reactor pressure vessel level to the reactor feedwater ,
control system. The licensee states this transmitter will continue under the enhanced surveillance program. The frequency for monitoring this transmitter l is every refueling outage (24 months). ,
t This commitment fulfills Reauested Action 1.d of the Supplement and is acceptable.
8 F
3.2.5 Licensee Resoonse to Reauested Action 1.e The licensee states there are 16 Rosemount transmitters from this classification at WNP-2. All have exceeded the 60,000 psi-month maturity criterion established by Rosemount and endorsed by the NRC. The licensee states these transmitters will remain part of the enhanced surveillance monitoring program. This gives continued assurance that these transmitters remain highly reliable, as required by the Supplement.
3.2.6 Licensee Response to Reauested Action 1.f The licensee states there are 45 Rosemount transmitters from this classification at WNP-2. The licensee states these transmitters will remain part of the enhanced surveillance monitoring program. This gives continued assurance that these transmitters remain highly reliable, as required by the Supplement.
These 45 transmitters include some transmitters that observe pressure beyond 500 psi during system testing, yet are normally not subject to pressure. These transmitters include transmitters associated with the high pressure core spray system and the standby liquid control system. The accumulated psi-month operational history is small. The total number of transmitters included in this sub-classification was not identified by the licensee. With minimum time at pressure, these transmitters will not soon exceed the established Rosemount psi-month criteria that establishes the transmitter is at risk of losing sufficient fill-oil to degrade the output signal. Rosemount Technical Bulletin No. 4 notes that transmitters in this type of ' standby' service are acceptable without enhanced surveillance. As the licensee includes these ' standby' service transmitters in their enhanced surveillance monitoring program, the licensee's actions regarding these transmitters is acceptable.
9
1 3.2.7 Enhanced Surveillance Monitorino Procram The licensee determined, in consultation with Rosemount, that calibration data taken to two decimal places provides the required data accuracy for comparison to the Rosemount drift data criteria. The licensee states their calibration instrumentation has an accuracy meeting this requirement.
l In Reference 4, the licensee notes that their enhanced surveillance l
l monitoring program uses transmitter calibration data. This data comes from the performance of normal calibration procedures. A computer is programmed to chart the historical cumulative zero and span shifts. These shifts are compared to the drift limits established by Rosemount for each transmitter, based on the transmitter range code. This program methodology is based on the technical information described in Rosemount Technical Bulletin No. 4. .
Based on the licensee description of their enhanced surveillance monitoring program, we find the enhanced surveillance monitoring program for WNP-2 acceptable.
l 10
- j I
- 4. CONCLUSIONS l
l Based on our review, we find that the licensee has completed the reporting requirements Supplement 1 of NRC Bulletin 90-01. Further, the licensee conforms to t'a " quested actions of Supplement I to NRC Bulletin 90-01.
1 l
l 1
l l
11 l
l l
1
- 5. REFERENCES
- 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.
- 3. Letter, Washington Public Power Supply System (G. C. Sorensen) to NRC,
" Response to IEB 90-01, Supplement 1," March 8,1993, G02-93-055.
- 4. Letter, Washington Public Power Supply System (J. V. Parrish) to NRC,
" Response to Request for Additional Information," May 23, 1994, GO-94-124.
I 12 I
+.
ENCLOSURE 3 SALP INPUT FACILITY NAME: WNP-2
SUMMARY
OF REVIEW The staff completed its review of the licensee's response to Nuclear Regulatory Commission Bulletin 90-01, Supplerant 1, submitted by Washington Public Power Supply System for WNP-2. We find the licensee's response for this item acceptable.
NARRATIVE DISCUSSION OF LICENSEE PERFORMANCE - FUNCTIONAL AREA The initial response provided to the staff was supplemented with additional l information to meet the requested actions.
Author: D. Spauldirg ,
Date: July 18, 1994 I
l I
l