ML20083A321
| ML20083A321 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/30/1993 |
| From: | Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20083A300 | List: |
| References | |
| CON-FIN-L-1695 EGG-RTAP-10825, IEB-90-001, IEB-90-1, TAC-M85378, NUDOCS 9505100167 | |
| Download: ML20083A321 (16) | |
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EGG-RTAP-10825 June 1993 TECHNICAL EVALUATION REPORT idaho EVALUATION OF UTILITY RESPONSE TO SUPPLEMENT 1 TO NRC BULLETIN National 90-01: C00PER Engineering Laboratory Managed A. C. Udy av the U.S.
Decartment of Energy 9
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U S. NUCLEAR REGULATORY COMMISSION A'Ork C0!10rm05 v!MFer DOE Con:rset No. DE-4Cn7-MctS70 ENCLOSURE 2 9505100167 930630 PDR ADOCK 05000298
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^l NOTICE This repost 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 wartaaty, expressed or imp'ied, or assumss 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 l
not infringe privately owned rights.
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EGG-RTAP-10825 TECHNICAL EVALUATION REPORT Evaluation of Utility Response to Supplement I to NRC Bulletin 90-01: Cooper Docket No. 50-298 Alan C. Udy Published June 1993 EG&G Idaho, Inc.
Idaho National Engineering Laboratory Idaho Falls, Idano 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761D01570 FIN No. L1695, Task No. 11 TAC No. M85378 j
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SUMMARY
This report documents the EG&G Idaho, Inc., review of the Cooper Nuclear Station submittal that responds to Supplement 1 to NRC Bulletin 90-01.. This NRC Bulletin provides information regarding the loss of fill-oil in certain pressure and differencial 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.
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FIN No. L1695, Task No. 11 B&R No. 320-19-15-05-0 Docket No. 50-298 TAC No. M85378 11 s
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I 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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CONTENTS 6
SUMMARY
ii PREFACE...............................................................
iii 1.
INTRODUCTION....................................................
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NRC SPECIFIED REQUESTED ACTIONS.................................
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3.
EVALUATION......................................................
7 3.1 Evaluation of Licensee Response to Reporting Requirements.
7 3.2 Evaluation of Licensee Response to Requested Actions......
7 4.
CONCLUSIONS.....................................................
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REFERENCES......................................................
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Evaluation' of Utility Resoonse to Suoolement-I to-i NRC Bulletin 90-01: CooDer 1.
INTRODUCTION' The NRC issued Bulletin 90-01 on March 9, 1990 (Reference 1).
That j
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-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 j
identified transmitters were either installed in or held in inventory for e
later installation in a safety-related system, actions were detailed for r
licensee implementation.
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 f
mechanism. This increases the potential for a common mode failure.
- Thus, t
this potential failure mechanism raised concern for the reliability of reactor protection systems (RPS), engineered safety teatures (ESF) actuation systems, j
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 regarding the subject transmitters, and noted continuing reports of f
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 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 1 to NRC Bulletin 90-01, the licensee is directed to address three items.
1.
A statement either committing the licensee to take the NRC l
Bulletin 90-01, Supplement 1 Reauested Actions or taking i
exception to those actions.
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2.
Addressing the actions committed to in the above statement, l
provide-i a.
a list of specific actions, including any justifications, to be taken to complete the commitment, i
b.
a schedule for completion, and c.
after completion, a statement that confirms the l
actions committed to have been completed.
3.
A statement identifying tt? 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.
The Nebraska Public Power District, the licensee for the Cooper Nuclear 4
Station, responded to Supplement 1 of NRC Bulletin 90-01 with a letter dated March 5, 1993 (Reference 3). This technical evaluation report evaluates the completeness of that submittal.
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 2
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I of surveillance proposed by the licensee'for any transmitters included in the L
enhanced surveillance program.
5 Many transmitter failures were attributed to the use of stainless steel
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"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 l
the flange bolts.
This limits the stress caused in~the sensing module by the f
"0"-ring.
Post-production screening, including pressure. testing of the i
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 I
Rosemount transmitters manufactured after July 11, 1989, are not subject to j
this review, if so identified by the licensee.
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2.
NRC SPECIFIED REQUESTED ACTIONS The NRC staff specified the following Reauested Actions of licensees of operating reactors, j
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Review plant records and identify the following Rosemount transmitters
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(if manufactured before July 11,1989) that either are used in or may be-used in either safety-related or ATWS mitigating systems.
i Rosemount Model 1153, Series B Rosemount Model 1153, Series D l
e 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 i
an enhanced surveillance program.
If the identif,ed 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 i
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.
i 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, i
using an enhanced surveillance program.
If the identified transmitter exceeds the 60,000 psi-month or the L
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.
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this option, justification must be based on the service record and the specific safety function of the transmitter.
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i 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 with an enha'nced 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 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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.Those; transmitters (o'her than BWR high pressure or low water.
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level trips' for RPS or ATWS actuation) 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 j
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 leve1Lof' reliability is maintained and that transmitter. failure due' to loss of fill-oil is detectable.
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Those transmitters having a' normal operating pressure less than or i
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.
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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 l
criteria.
It is this comparison that determines the degradation
-i 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 l 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.
That response was compared to the Bulletin Reportina Reauirements and Reauested Actioni as described below.
The licensee reports they still have 18 Rosemount model 1153, series B, transmitters with sensing modules that were manufactured before July 11, 1989.
The licensee states there are no safety-related Rosemount model 1153, series D, or model 1154 transmitters installed at the station or held in spare parts inventory..
Further, the licensee states there are no Rosemount transmitters utilitod in the ATWS mitigating system.
3.1 Evaluation of licensee Response to Reoortino Reauirements The licensee states they have completed the Reauested Actions detailed in Supplement 1 of NRC Bulletin 90-01 with no exceptions.
That statement included clarification and interpretation. The licensee described the
,pecific actions taken to implement the Reauested Actions.
As all items have been completed, no schedule for completion is needed, nor is further documentation that the Reauested Actions are complete.
The licensee submittal conforms with and completes the Reportina Reauirements of Supplement 1 of NRC Bulletin 90-01.
3.2 Evaluation of 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 response is discussed in the following sections.
The licensee identified a total of 37 transmitters that were in the scope of review of the original Bulletin 90-01.
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Of these,- 19 have been replaced or refurbished with sensing modules f
manufactured _after July 11, 1989. The remaining 18 Rosemount transmitters manufactured'before July. 11, 1989, are discussed.in the following sections.
t 3.2.1 ' Licensee Resoonse to Reauested Action 1.a.
J The licensee states there are no Rosemount transmitters from this l
classification installed at the Cooper Nuclear Station.
i 3.2.2 Licensee Resoonse to Reauested Action 1.b.
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l The licensee states there are no Rosemount transmitters from this j
classification installed at the Cooper Nuclear Station.
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3.2.3 Licensee Response to Reauested Action 1.c.
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The licensee states there are no Rosemount transmitters from this f
classification installed at the Cooper Nuclear Station.
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3.2.4 Licensee Response to Reauested Action 1.d.
I The Cooper Nuclear Station has 9 Rosemount transmitters from this q
classification.
Four of these transmitters have exceeded the 60,000 psi-month i
criterion established by Rosemount and endorsed by the NRC.
Thus, these four transmitters are no longer included in an enhanced surveillance monitoring' l
program. An enhanced surveillance program is not required by the Supplement
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for these four transmitters.
4 The five remaining transmitters from this classification are part of the l
Boiling Instrument System and have not reached the identified psi-month l
criterion. These transmitters have been trended, using surveillance data, 8
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every refueling cycle (12-and 18-month duration) since 1988. This interval conforms with the Reauested Actions. This data trending will continue for these five transmitters until the psi-month criterion is exceeded or the transmitters have been replaced. The licensee states the drift data for these transmitters since 1988 indicates that no loss of fill-oil has occurred.
3.2.5 Licensee Resnonse to Reauested Action 1.e.
t The licensee includes the four transmitters described in Section 3.2.4, above, in this' classification.
Thus, these four transmitters are acceptable l
without an enhanced surveillance monitoring program, i
The licensee states that normal calibration and surveillance procedures will provide continued confidence in the reliability of these transmitters.
Further, the licensee states that a loss of fill-oil is detectable using these procedures and drift data.
3.2.6 Licensee Response to Reauested Action 1.f.
The Cooper Nuclear Station has 9 Rosemount transmitters from this classification.
An enhanced surveillance program is neither required by the Supplement nor provided by the licensee for these nine transmitters.
These transmitters have been trended, using surveillance data, every refueling cycle (12-and 18-month duration) since 1988. This data trending will continue for these nine transmitters until the psi-month criterion is exceeded or the transmitters have been replaced. The licensee states the drift data for these transmitters since 1988 indicates that no loss of fill-oil has occurred.
3.2.7 Enhanced Surveillance Monitorina Procram The licensee uses current surveillance and calibration procedures to j
obtain transmitter operational data for their enhanced surveillance monitoring 9
program.
This data is trended to identify any sustained drift that would indicate a loss of fill-oil. The licensee states the appropriate personnel have been trained in recognizing symptoms of fill-oil leakage.
The licensee also states that the data accuracy meets the recommendations of the I
manufacturer.
This enhanced surveillance monitoring program will continue for each transmitter until it exceeds the psi-month criterion or is replaced.
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CONCLUSIONS Based on our review, we find the licensee has completed the reporting requirements of Supplement 1 of NRC Bulletin 90-01.
Further, the licensee conforms to the requested actions of Supplement 1 to NRC Bulletin 90-01.
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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, Nebraska Public Power District (G. R. Horn) to NRC, " Loss of Fill-0il in Transmitters Manufactured by Rosemount," March 5, 1993, NSD 930924.
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