ML20080J075

TER EGG-ERTP-11265, Evaluation of Util Response to Suppl 1 to NRC Bulletin 90-001:River Bend

ML20080J075
Person / Time
Site:	River Bend
Issue date:	04/30/1994
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20080J079	List: ML20080J075 ML20080T668 ML20080T685
References
CON-FIN-L-1695 EGG-ERTP-11265, IEB-90-001, IEB-90-1, NUDOCS 9502270074
Download: ML20080J075 (17)

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EGG-ERTP-11265 April 1994

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TECHNICAL EVALUATION REPORT idaho EVALUATION OF UTILITY RESPONSE TO Nationa/

SUPPLEENT 1 TO NRC BULLETIN 90-01:

RIVER BEND Engineering Laboratory Managcd E' *" C ' MY by the U.S.

Depanment ofEnergy I

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Prepared for the 0 EGzG.a.

U.S. NUCLEAR REGULATORY COMMISSION 44 Wewt pedonned under DOE Contract Na DE-AC01-MID01Sm

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ENCLOSURE 2

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-EGG-ERTP-ll265 I

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.f Evaluation of Utility Response to Supplement 1 to NRC Bulletin 90-01: River Bend l

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Docket No. 50-458

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EG&G Idaho, Inc.

I Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 t

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Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

Under DOE Contract No. DE-AC07-76ID01570 FIN No. Ll695, Task No. 11 TAC No. M85434:

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SUMMARY

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This report documents the EG&G Idaho, Inc., review of the Gulf States Utilities company submittal that responds to Supplement I to NRC Bulletin 90-01 for the River Bend Station.- This NRC Bulletin provides information i

regarding the loss of fill-oil in certain pressure and diffarential pressure transmitters manufactured by Rosemount Inc. ;This report examines the.

licensee response to the requested actions and the reporting requirements.

Exceptions to the requested actions and the reporting _ requirements are evaluated.

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FIN No. Ll695, Task No. 11 B&R No. 320-19-15-05-0 Docket No. 50-458 i

TAC No. M85434

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PREFACE 3

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:

Regulatten, Division of Reactor Controls and Human factors, by EG&G Idaho,

-Inc., DOE /NRC Support Programs Unit.

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' CON' TENTS,-:

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SUMMArp..............................................................

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' PREFACE.......,......................................................

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LINTRODUCTION....................................................

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

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

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' 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 Supolement 1 to NRC Bulletin J.0-01: River Bend.

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 reeded 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 ;*tential 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.cliability, 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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' respond to'th'e.NRC.' 'The Recuested 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 l'icensee '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 exc2ption to'those actions.

2.

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

a list of specific actions, including any a.-

justifications, to be taken to complete the commitment, b.

a schedule for. completion, and after completion, a statement confirming the actions c.

1 committed to are complete.

3.

A statement identifying the NRC Bulletin 90-01, Supplement -1, i

Reauested Actions not taken, along with an evaluation providing.

the basis for exemption.

In implemer.'.ing the replacement option of the NRC Reauested ActionL 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.

The Gulf States Utilities Company, the licensee for Unit No.1 of the River Bend Station, responded to Supplement 1 of NRC Bulletin 90-01 with a letter dated March II, 1993 (Reference'3). This technical evaluation report' j

evaluates the completeness of that submittal.

It airo determines whether proposed surveiliance methods are adequate to determine fill-oil loss-caused degradation of the transmitter. Final.ly, this report addresses the interval 2

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_ of) surveillance. proposed by-the licensee for.any transmitters included in;the-

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I enhanced surveillance monitoring program.

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

stainle'ss steel. "0"-rings' between. the sensing module and.the ' process: flanges.

LRoserount improveduthe manufacturing process.for transmitters manufactured.

after July.11, 1989.: Those imp'rovements included a limit of the' torque-applied to the flange bolts. This limits.the stress caused.in the sensing module byf the "0"-ring.. Post-production screening,' including pressure testing L

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.cfter July 11, 1989, are not subject to this review.

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NRC SPECIFIED REQUESTED ACTIONS 6

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 i

used in either safety-_related or ATWS mitigating systems.

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 a.

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 j

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 oi 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 of1 the transmitter, 1

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.

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.by redundancy or. diversity..

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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 i

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 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

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trips for high pressure or low water level, the enhanced.

surveillance must be monthly.

For other transmitters in.

i 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 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 I

systems, either replace the-transmitter, or monitor with an~

enhanced surveillance monitoriag program, until the transmitter reaches the designated (by Rosemount) psi-month j

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

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

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LThose' 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.

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.However, the licensee should' retain a high level of confidence that a high level of reliability is maintained and that.

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transmitter failure 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 l

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 ccmparison 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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EVALUATION

'The licenseo provided a response to Supplement I of NRC Bulletin 90-01 on_ March.ll, 1993. That response was compared to the Bulletin Reportina Reautrements and Reauested Actions as described below. The licensee reports they have 93 Rosemount transmitters that are subject to the Reauested Action _

of the~ Supplement. Nine other Rosemount transmitters are outside the_ scope-of the Supplement due to replacement or refurbishment of the transmitter with a o

sensing module manufactured after July 11, 1989.

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3.1 Evaluation of Licensee Response to Reporti'.ia Reauirements The licensee states they have taken steps to implement the Reques.ind Actioni detailed in Supplement 1 of NRC Bulletin 90-01.

Included with that staternent is clarification, interpretation, and the limits placed on that commitment. The licensee described the specific actions taken to implement the Reauested Actions. All Rosemount model 1153 and 1154 transmitters held in spare parts inventory have been upgraded with sensing-modules manufactured L 5ter July 11, 1989.

As a transmitter is to be replaced in' the spring of-1994, a statement that the Reauested Actions are complete will need to be submitted separately when the scheduled replacement is complete. The March 11, 1989, submittal identifies where no licensee action is taken and provides evaluation and justification supporting the position that the. action is not necessary.

The licensee submittal conforms with the Reportino Reauirements'ef Supplement 1 of NRC Bulletin 90-01, except for the lack of commitment to notify the NRC that the transmitter has been replaced. This action is required by Reportino Reauirement 2.c of the Supplement.

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3.2 Evaluation of Licensee Response to Reauested Actions 4

t Supplement 1 of NRC Bulletin 90-01 requested licensee 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 identified a total of 102 Rosemount transmitters. Of that number, 93 are in the scope of this review.

The licensee response to the Supplement is discussed.in the following

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3.2.1 Licensee Response to Reauested Action 1.a I

The licensee states there are no Rosemour.t transmitters from this classification at the River Bend Station.

3.2.2 Licensee Response to Reauested Action 1.b i

The licensee states there are no Rosemount transmitters from this

,j classification at the River Bend Station.

P 3.2.3 Licensee Response to Reauested Action 1.c The licensee reports there is one Rosemount transmitter remaining at the River Bend Station that is subject to the Reouested Actions of the Supplement.

That transmitter, IE31*PDTN088A, is one of four transmitters that monitor the steam flow in one of the four main steamlines.

It is scheduled. to be replaced during the next refueling outage (Spring of 1994).

The licensee reported an operational history free of fill-oil leakage and a design that includes redundancy.

Technical Specifications require only two of the four i

transmitters per main steamline to be operational.

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' Based on the licensee description and commitment,-the scheduled

' replacement of. thiss transmitter satisfactorily' resolves the Supplement f

concerns.c.However, Reoortina Reauirement 2.c= requires the licensee to notifyy j

- the' NRC thaty the 'reolacement is complete.

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3.2.4 Licensee Response to Reauested Action 1.d p"

The licensee indicates there are no Rosemount transmitters from this.

U classification at-the River Bend Station.

1 3.2.5 Licensee Response to Reauested' Action 1.e Tne licensee has four Rosemount transmitters that meet-the classification requirements for Recuested Action ).d, and exceed the. psi-month maturity threshold. -At the discretion of the licensee, these four transmitters are not-part of an enhanced surveillance monitoring program.

This is permitted by the Supplement.

The Supplement' requires the licensee to maintain a high degree of-L confidence that.these transmitters remain highly reliable..The; licensee

' trains operators and instrument technicians to recognize symptoms that.

-indicate the lo-Of fill-oil.

Scheduled preventive maintenance and normal surveillance, coupled with operator and technician training, gives the licensee confidence that any future transmitter failure caused by the loss of fill-oil can be detected.

3.2.6 Licensee Response to Reauested Action 1.f The licensee states there are 89 Rosemount transmitters from this classification at the River Bend Station. One transmitter has been L

refurbished with a replacement sensing module that was manufactured after July.11, 1989. All transmitters from this classification are excluded from an n

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enhanced. surveillance monitoring program by the licensee. This is permitted m

k by.the Supplement for low pressure application transmitters.

i The Supplement requires the'llcensee to maintain ~a high degree of confidence that these transmitters remain' highly reliable.

The licensee

. trains operators and instrument technicians to recognize' symptoms that

.i indicate the loss of~ fill-oil. Scheduled preventive maintenance and normal

. surveillance, coupled with operator and technician training, gives the licensee confidence that any future transmitter failure caused by the loss of fill-oil can be detected.

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4. ' CONCLUSIONS --

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Based'on our review,.-we find' that the 1.icensee has. completed the -

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4 Jreporting requirements'of. Supplement'l'of NRC.Bulletin 90-01, except.

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notification,that transmitter IE31*PDTN088A has been replaced.. See-Section'3.1.

Further, the licensee either conforms to'or has adequate-q justification _for deviating from the' requested actions of Supplement I to NRC-1 Bulletin 90-01. No enhanced surveillanc'e monitoring program is necessary at q

Unit No. l'of the River Bend Station.

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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, Gulf States Utilities Company (J. E. Booker) to NRC, March 11, 1993, RBG-38,223, File Nos. G9.5, G9.33.1.

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