ML20085K467
| ML20085K467 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/30/1995 |
| From: | Udy A IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20085K470 | List: |
| References | |
| CON-FIN-L-1695 IEB-90-001, IEB-90-1, INEL-95-0268, INEL-95-268, TAC-M85359, TAC-M85360, NUDOCS 9506230387 | |
| Download: ML20085K467 (17) | |
Text
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INEL-95 0268 i
June 1995 Idaho National Engineering Evaluation of Utility Response to Laboratory Supplement 1 to NRC Bulletin 90-01:
Braidwood-1/-2 Alan C. Udy i
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TECHNICAL EVALUATION REPORT-Evaluation of Utility Response to Supplement I to NRC Bulletin 90-01: Braidwood-1/-2 Docket Mos. 50-456 and 50-457 i
l Alan C. Udy Published June 1995 Lockheed Martin Idaho Technologies i
Idaho National Engineering Laboratory Idaho Falls, Idaho 83415
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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-AC07-941013223 JCN No. L1695, Task No.11a TAC Nos. M85359 and M85360 l
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SUMMARY
This report documents the Lockheed Martin Idaho Technologies review of the Commonwealth Edison Company submittals that resoond to Supplement I to NRC Bulletin 90-01 for Unit Nos. I and 2 of the Braidwood Station.
This NRC Bulletin provides information regarding the loss of fill-oil in certain pressure and differential pressure transmitters manufactured by Rosemount, Inc.
This report finds the licensee complies with the requested actions and the reporting requirements of the Supplement.
JCN No, L1695, Task No. lla B&R No. 320-19-15-05-0 Docket Nos. 50-456 and 50-457 TAC Nos. M85359 and M85360 ii
l' 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 1.ockheed Martin Idaho Technologies, National Nuclear Operations Analysis Department.
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CONTENTS
SUMMARY
ii PREFACE...............................................................
iii 1.
INTRODUCTION......................................................
1 2.
NRC SPECIFIED REQUESTED ACTIONS..................................
4 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......................................................
11 5.
REFERENCES 12 i
l 1
l 2
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l Evaluation of Utility Resoonse to Sucolement 1 to NRC Bulletin 90-01:
Braidwood-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 sa'fety 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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respond to the NRC.
The Requested Actions in Supplement I to NRC Bulletin 90-01 supersede the original NRC Bulletin 90-01 Requested Actions.
In responding to Supplement 1 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, Requested Actions or taking exception to those actions.
2.
Addressing the actions committed to in the above statement, I
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.
l 3.
A statement identifying the NRC Bulletin 90-01, Supplement 1, Requested Actions not taken, along with an evaluation providing the basis for exemption.
in implementing the replacement option of the NRC Requested 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 Commonwealth Edison Company, the licensee for Unit N,os. I and 2 of the Braidwood Station, responded to Supplement 1 of NRC Bulletin 90-01 with a letter dated March 5, 1993 (Reference 3). The licensee provided additional information in a submittal dated October 14, 1994 (Reference 4).
A licensee submittal dated May 11, 1995 (Referance 5), replaces Reference 4 in its entirety.
This technical evaluation report evaluates the completeness of i
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L those submittals.
It also determines whether proposed surseillance methods are adequate to determine fill-oil loss-caused degradation of the transmitter.
5 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.
l Rosemount improved the manufacturing process for transmitters manufactured
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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, j
those Rosemount transmitters manufactured after July 11, 1989, are not subject to.this review.
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l 2.
NRC SPECIFIED REQUESTED ACTIONS t
The NRC staff specified the following Requested Actions of licensees of operating reactors.
p 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 e',ther 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:
l 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.
l If the identified transmitter exceeds the 60,000 psi-month or the r
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 t
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, I
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 l
this option,- justification must be based on the service record and the specific safety function of the transmitter.
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IL justification can be baseo on high functional reliability provided by redundancy or diversity.
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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 l
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 i
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 i
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)--
J 1
For those identified transmitters having a normal operating pressure greater than 500 psi and less than or equal to i
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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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.
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3.
EVALUATION The licensee responded to Supplement 1 of NRC Bulletin 90-01 on March 5.
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1993.
That response and supplemental information dated May 11, 1995, were compared to the Bulletin Reporting Requirements and Requested Actions as I
described below. The licensee reports having 42 Rosemount transmitters subject to the Requested Actions of the Supplement. Other Rosemount transmitters are outside the scope of the Supplement due to replacement or l
refurbishment.
The licensee shipped ten Rosemount transmitters held in the Braidwood spare parts inventory to Rosemount in September 1990 for refurbishment.
The licensee has not procured additional Rosemount transmitters since that time.
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3.1 Evaluation of licensee Response to Reportino Reauirements l
In Reference 3, the licensee states they agree to follow the applicable Requested Actions of Supplement 1 of NRC Bulletin 90-01.
Included with that statement is clarification, interpretation, and the limits placed on that commitment.
The licensee described the specific actions taken to fulfill the Requested Actions of the Supplement.
The licensee included a statement that the Requested Actions are complete in the Reference 3 submittal.
The licensee states that their actions satisfy the Supplement recommendations.
Reference 5 provides details of the j
enhanced surveillance monitoring program.
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The licensee submittals conform with the Reporting Requirements of Supplement 1 of NRC Bulletin 90-01.
3.2 Evaluation of Licensee Response to Reouested Actions Supplement 1 of NRC Bulletin 90-01 requested licensee action to resolve the issue of fill-oil leakage in Rosemount transmitters.
This Technical 7
Evaluation Report summarizes the Requested Actions and the associated transmitter criteria in Section 2.
The licensee identified a total of 42 transmitters that are in the scope of this review.
The licensee changed their procurement specification to prevent purchase of Rosemount transmitters with serial numbers less than 500,000 unless supplied with a refurbished sensing module.
The licensee acted to refurbish all transmitters held in spare parts inventory.
Thus, any additional ~Rosemount transmitters will be outside the scope of the required actions of the Supplement.
The licensee response to the Supplement is discussed in the following sections.
3.2.1 Licensee Response to Reouested Action 1.a l
l The licensee states there are no Rosemount transmitters from this transmitter classification at the Braidwood Station.
3.2.2 licensee Response to Reouested Action 1.b l
l The 1,censee states there are no Rosemount transmitters from this transmitter classification at the Braid, wood Station.
i 3.2.3 Licensee Response to Reouested Action 1.c The licensee states there are eight Rosemount transmitters from this transmitter classification at the Braidwood Station.
These transmitters have not reached their maturity threshold as of October 1994.
The Unit 1 transmitters have accrued about 38,000 psi-months of operating history.
The Unit 2 transmitters have accrued about 41,400 psi-months of operating history.
The licensee states these transmitters participate in, and will continue participation in, an enhanced surveillance monitoring program.
The licensee
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performs surveillance every refueling outage.
This satisfies the requirements of the Supplement and is acceptable.
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3.2 4 !.icensee Response to Reouested Action 1.d
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The licensee states there are no Rosemount transmitters from this l
transmitter classification at the Braidwood Station.
3.2.5 'ticensee Response to Reouested Action 1.e The licensee states there are no Rosemount transmitters from this transmitter classification at the Braidwood Station.
3.2.6 Licensee Response to Reouested Action 1.f The licensee states there are 34 Rosemount transmitters from this transmitter classification at the Braidwood Station.
The licensee states, in Reference 5, that they calibrate these transmitters every 18 months.
The transmitter zero calibration shift surveillance data is tracked and trended in the enhanced surveillance program.
Transmitter performance suspect of fill-oil loss is the cause for writing a work request to troubleshoot the transmitter.
Transmitters suspected of fill-oil loss by this process are replaced.
This maintains a high degree' of confidence that these transmitters remain highly reliable.
3.2.7 Enhanced Surveillance Monitorina Proaram The licensee states, in Reference 3, that their enhanced surveillance monitoring program monitors the parameters that show a loss of fill-oil with the required accuracy.
The licensee described their enhanced surveillance
.1 monitoring program in Reference 5.
j The Braidwood Station uses the Operability Acceptance Criteria of Rosemount Technical Bulletin No. 4, Table A1.
The licensee uses zero drift trending software to record and project trends from the as-left/as-found zero 9
t value from calibrations.
The software projects when a transmitter will reach the acceptance limit based on a projection from the zero drift documented
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during the calibrations.
The licensee takes the following actions.
If no trend is clear and the cumulative drift versus time plot coincides, there is no licensee action.
If the trend shows an approach (based on the most recent drift rate) to the limit beyond the next scheduled calibration, and the cumulative i
drift versus time plot coincides, there is no licensee action.
If the trend shows an approach (based on the most recent drift rate) to the limit before the next scheduled calibration, the licensee schedules a separate calibration before the predicted approach to the limit.
if trending shows the transmitter beyond the operating limit, the licensee writes a work request to determine the cause of the drift.
The results of the investigation determines whether the licensee repairs or replaces the transmitter.
If the licensee finds no cause for the noticed drift other than i
loss of fill-oil, the licensee replaces the transmitter.
The described surveillance methodology is acceptable.
Rosemount Technical Bulletin No. 4, Table A1, provides maximum allowable accumulative drift limits for all Rosemount transmitter range codes.
The licensee schedules transmitter replacement after evaluating the transmitter and determining the cause of the drift.
If suspected of fill-oil loss, the licensee replaces the transmitter.
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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.
Further, the licensee conforms with the requested actions of Supplement I to NRC Bulletin 90-01.
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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, Comonwealth Edison Company (D. J. Chrzanowski) to NRC (T. E.
Murley), "NRC Bulletin 90 01 Supplement 1, ' Loss of Fill Oil in Transmitters Manufactured by Rosemount', dated December 22, 1992,"
March 5, 1993.
4.
Letter, Commonwealth Edison Company (D. M. Saccomando) to NRC,
" Additional Information Regarding Braidwood Station's Response to Bulletin 90-01, Supplement 1," October. 14, 1994.
5.
Letter, Commonwealth Edison Company (D. M. Saccomando) to NRC,
" Additional Information Regarding Braidwood Station's Response to Bulletin 90-01, Supplement 1," May 11, 1995.
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