ML20080B493

Evaluation of Utility Response to Suppl 1 to NRC Bulletin 90-01:Arkansas Nuclear One-1/-2, Dtd Nov 1994

ML20080B493
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/30/1994
From:	Udy A IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20080B497	List: ML20080B493
References
CON-FIN-L-1695 IEB-90-001, IEB-90-1, INEL-94-0169, INEL-94-169, TAC-M85352, TAC-M85353, NUDOCS 9412050059
Download: ML20080B493 (17)

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Evaluation of Utility Response to supplement 1 to NRC Bulletin 90-01:

Arkansas Nuclear One-1/-2 l

l idaho National .~'

Engineering Laboratory ENCLOSURE 2

&Lockheed /daho Techno/og/es Company

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INEL-94/0169-l TECHNICAL EVALUATION REPORT Evaluation of Utility Response to Supplement I to NRC Bulletin 90-01: Arkansas Nuclear One-1/-2 -

Docket Nos. 50-313 and 50-368 Alan C. Udy Published November 1994 Lockheed Idaho Technologies Company Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 and for the U.S. Department of Energy Under DOE Idaho Operations Office Contract DE-AC07-94ID13223 FIN No. Ll695, Task No. 11a TAC Nos. M85352 and M85353 1

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SUMMARY

This report documents the Lockheed Idaho Technologies Company review'of .

the Entergy Operations, Inc., submittals responding to Supplement I to NRC l Bulletin 90-01 for Unit Nos. I and 2 of Arkansas Nuclear One. 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. This report finds the licensee conforms to-

-the requested actions and the reporting requirements of the Supplement.

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i FIN No. Ll695, Task No. Ila B&R No. 320-19-15-05-0 Docket Nos. 50-313 and 50-368 TAC Nos. M85352 and M85353 ii

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6 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 Regulation, Division of Reactor Controls and Human Factort, by Lockheed Idaho Technologies Company, National Nuclear Operations Analysis Department.

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[ CONTENTS  ;

SUMMARY

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

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

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

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3. EVALUATIOE ........................................................ 7 l

3.1 Evalt ation of Licensee Response to Reporting Requirements ... 7 ,

3.2 Evaluation of Licensee Response to Requested Actions ........ 8

4. CONCLUSIONS ....................................................... 10

5. REFERENCES ........................................................ 11 9

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Evaluation of Utility Response to Sucolement I to BRC Bulletin 90-01: Arkansas Nuclear One-1/-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 certain identified transmitters 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 safety function. Further, this condition could go undetected over a long 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.

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. The 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 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 90-01 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.

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

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

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, Reauested Actions not taken, along with an evaluation providing the basis for exemption.

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 required.

Entergy Operations, Incorporated, the licensee for Unit Nos. I and 2 of Arkansas Nuclear One (AN0), responded to Supplement 1 of NRC Bulletin 90-01 with a letter dated March 5, 1993 (Reference 3). Additional information was provided on April 15, 1994 (Reference 4). The licensee notified the NRC of the completion of their Unit 2 actions and provided additional details on those actions on June 22, 1994 (Reference 5). This technical evaluation 2

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

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2. NRC SPECIFIED REQUESTED ACTIONS The NRC staff specified the following Reauested 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 l pressure greater than 1500 psi, and are installed as part of  !

reactor protection trip systems, ESF actuation systems, or_ATWS l mitigating systems, either replace the transmitter in an expedited '

manner, or monitor monthly, for the life of the transmitter, using .

an enhanced surveillance monitoring program.  !

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 '

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 -i by redur.dancy 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 monitoring 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 I the specific safety function of the transmitter. That 4

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justification can be; based on high functional reliability provided

, by redundancy or.. diversity. '

a 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

.o 1500 psi, and are installed as part of reactor protection trip systems, ESF actuation systems, or ATWS mitigating.

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systems, either replace the transmitter, or monitor. monthly 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 u 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 l 24 months) basis.

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d. For those identified transmitters having a normal operating t 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 i reaches the designated (by Rosemount) psi-month critarion (60,000 psi-month or 130,000 psi-month, depending on the transmitter range ,

code) on a refueling (not exceeding 24. months) basis. j i

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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 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 tne 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 i threshold for loss of fill-oil failures of the subject transmitters.

l The Supplement also states the NRC may conduct audits or inspections in  !

the future to verify compliance with the established requirements. l 6

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3. EVALUATION The licensee provided a response to Supplement 1 of NRC Bulletin 90-01 on March 5, 1993. The licensee provided additional information on April 15, 1994. The licensee notified the NRC of the completion of their Unit 2 actions and provided additional details on those actions on June 22, 1994. Those responses were compared to the Bulletin Reportina Reauirements and Reauested Actions as described Selow. The licensee states they evaluated 197 Rosemount transmitters against the Egg 2ested Actions of the Supplement at ANO. Also affected were 18 spare transmitters. The licensee states there are 53 installed safety-related Rosemount transmitters in either high pressure applications or manufactured before July 11, 1989.

3.1 Evaluation of Licensee Response to Reportina Reauirements The licensee states, in Reference 3, that they intend to follow the Reauested Actions detailed ~in Supplement 1 of NRC Bulletin 90-01. Included with that statement is a schedule the licensee will follow in-implementing the Reauested Actions. The licensee described the scheduled steps to implement the Reauested Actions. References 4 and 5 provide details on the licensee commitments and actions.

Reference 5 states that the Reauested Actions are complete for Unit 2.

The licensee committed to submit a statement that the Reauested Actions are complete for Unit I separately, within 90 days of the completion of the scheduled items. The licensee scheduled these actions for completion in the spring of 1995. The licensee removed 18 spare transmitters manufactured before July 11, 1989, from inventory. Rosemount refurbished 13. The licensee disposed of the remaining 5 transmitters.

The licensee submittals conform to the Reportina Reauirements of Supplement 1 of NRC Bulletin 90-01.

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3.2 Evaluation of Licensee Response to Reauested Actions 1

I 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. The licensee response to the Supplement is discussed in the following sections. I i

3.2.1 Licensee Response to Reauested Action 1.a and 1.b Unit I l The licensee states there are 15 Rosemount transmitters from these two transmitter classifications at ANO-1. One exceeds the maturity threshold, established by Rosemount. The licensee scheduled these 15 transmitters for replacement during refueling outage IR12, in the spring of 1995. The licensee will perform an on-line cross channel check between redundant transmitters each operating shift until transmitter replacement. Once replaced, the Supplement does not require an enhanced surveillance monitoring program.

Unit 2 The licensee states there were 10 Rosemount transmitters from these two transmitter classifications at ANO-2. Each is now replaced. The replacement was complete on April 24, 1994. Thus, the Supplement does not require an I enhanced surveillance monitoring program for these transmitters.

3.2.2 Licensee Response to Reauested Action 1.c and 1.d The licensee states there are 6 non-mature Rosemount transmitters in these two transmitter classifications at ANO. Unit 1 and Unit 2 each has three. The licensee is not replacing these transmitters. The licensee committed to keep these transmitters in an enhanced surveillance monitoring 8

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program,;with a refueling outage frequency. This commitment satisfies the -

Reauested Actions of the Supplement and is acceptable.

3.2.3 Licensee Response to Reauested Action 1.e {

The licensee states there no Rosemount transmitters from this  ;

transmitter classification at ANO. Medium-pressure transmitters will remain in the enhanced surveillance monitoring program after reaching the psi-month maturity threshold. ,

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3.2.4 Licensee Response to Reauested Action 1.f The licensee indicates there'are 22 Rosemount transmitters from this '

transmitter classification at ANO. The Supplement requires the licensee to maintain a high degree of confidence that these transmitters remain hijhly reliable. The licensee states these transmitters will continue participation in the enhanced surveillance monitoring program. This provides the confidence  :

in these transmitters regt ired by the Supplement. l l

3.2.5 Enhanced Surveillance Monitorina Proaram The licensee states their enhanced surveillance monitoring program uses calibration data obtained at an outage-frequency. The licensee compares the zero-shift trend to the limits established in Rosemount Technical Bulletin

~No. 4. The licensee's description of their enhanced surveillance monitoring program meets the basic requirements of the Supplement and is acceptable. .The licensee also committed to monitor, with channel checks every operating shift, the ANO-1 high pressure Rosemount transmitters until replacement.

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?; 4. CONCLUSIONS Based on our review, we find that the licensee has completed the reporting requirements of Supplement 1 of NRC Bulletin 90-01 except notification that the Unit I actions are complete. The licensee committed to notify the NRC within 90 days of the completion of these actions. The actions are scheduled for completion in the spring of_1995. Further, the licensee conforms to the requested actions of Supplement I to NRC Bulletin 90-01.

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5. REFERENCES

.l. 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, Entergy Operations, Incorporated (J. J. Fisicaro) to NRC,

" Response to NRC Bulletin 90-01,. Supplement 1," March 5, 1993, OCANO39302.

4. Letter, Entergy Operations, Incorporated (D. C. Mims) to NRC, "NRC Bulletin 90-01 Supplement 1 Update," April 15, 1994, OCAN049401.

5. Letter, Entergy Operations, Incorporated (D. C. Mims) to NRC, " Unit 2 Final Response To NRC Bulletin 90-01, Supplement 1," June 22,1994, 2CAN069402.

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1 SWIC FORM 335 U.S. NUCLEAR RE00LATOMY COtHeSetON 1. REPORT NUMBER

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BIBLIOGRAPHIC DATA SHEET INEL-94/0169 .

S in. ems, n. e. r .i l

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED Evaluation of Utility Response to Supplement I to MM YEAR November 1994 NRC Bulletin 90-01: Arkansas Nuclear One-1/-2

4. FIN OR GRANT NUMBER Ll695

5. AUTHOR (S) 8. TYPE OF REPORT Alan C. Udy Technical Evaluation

7. PEHlOD COVERED e

8. PERFOfE41NG ORGANIZATION . N AME AND ADDRESS w=e. om.. es ,- .. m s - w -i National Nuclear Operations Analysis Lockheed Idaho Technologies Company P.O. Box 1625 Idaho Falls, ID 83415 3870

9. SPONSORING ORGANIZATION . NAME AND ADDRESS w ec,  %. e - e . um ,- w 6. -i Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

10. SUPPLEMENTARY NOTES

11. ABSTRACT se. .

This report documents the Lockheed Idaho Technologies Company review of the Entergy Operations, Inc., submittals that respond to Supplement I to NRC Bulletin 90-01 for Arkansas Nuclear One, Unit Nos. I and 2. This NRC bulletin provides information regarding the loss of fill-oil in certain pressure and differential pressure transmitters manufactured by Rosemount, Incorporated. This report finds the licensee conforms to the requested actions and the reporting requirements of the supplement.

12. KEY WORDS/DESCRIPTORS n. .- . . 13. AVAILABILITY STATEMENT

, Rosemount Transmitters Unlimited Distribution Bull in -01, Supplement 1 (N Pge Unclassified l

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Unclassified

15. NUMBER OF PAGES l

18. PRICE l

NRC FORM 33512-896