ML20138D283
| ML20138D283 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/11/1993 |
| From: | Woodard J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEB-90-001, IEB-90-1, NUDOCS 9302170169 | |
| Download: ML20138D283 (6) | |
Text
Couttmm Nalear Oguating coro,nriy.
Post Of*:c.e Box 12%
Dimunghyn, Alaoama 75001 Tolnhono 205 CSS 5066 L
Suthern Nudear Operating Company ElI ENU Fet'rua ry 11, 1993
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Docket Nos. 50-348 50-364 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Joseph M. Farley Nuclear Plant - Units 1 and 2 Loss of Fill-Oilin Transmitters Manufactured By Rosemount NRC BULLEIlN 90-01. SUPPL..EMEN'l 1 Gentlemen:
NRC Bulletin 90-01, Supplement i entitled " Loss of Fill-Oil in Transmitters Manufactured By Rosemount" was issued December 22,1992 requesting licensees to take actions to address this issue. The requested actions described m the subject bulletin supersede the actions requested by the original bulletin issued on March 9, 1990. The bulletin supplement requested that licensees provide a written response, within 60 days after bulletin receipt.
Southern Ntmlear Operating Company's (SNC's) complete response to NRC Bulletin 90-01, Supplement 1 for Farley Nuclear Plant Units 1 and 2 is provided in the Attachment here:a. The information provided herein is true to the best of our knowledge and belief.
If there are any questions relating to the information provided herein, please advise.
Respectfully submitted, s
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I ATTACHMENT Southern Nuclear Operating Company's Response to j
NRC 13ulletin 90-01, Supplement 1 i
for Joseph M. Farley Nuclear Plant Units 1 & 2 i
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ERC Requg31 i
1.
Review plant records and idemify any Rosemount 1153 Series B, Model 1153 Series D, and Model 1154 transmitters manufactured before July 11,1989, that
.i are used or may be used in the future in either
?cty-related systems ' r systems o
installed in accordance with 10 CFR 50.62 (the ATWS rule), and -
a.
Expediticusly replace, or monitor for the life of the transmitter on a monthly basis using an enhanced surveillance monitoring program, any -
i transmitters tha; have a normal operating pressure greater than 1500 psi and that are installed in reactor protection trip systems, ESF actuation systems or ATWS systems. Action for those transmitters that have not met the Rosemount psi month threshold criterion should be expedited.
At their discretion, licensees may monitor using an enhanced surveillance program at least once evety refueling cycle, but not exceeding 24 'rnonths, l
transmitters in this category if the appropriate psi month threshold o
criterion recommended by Rosemount has been reached, and the monitoring interval is justified based upon transmitter performance in 9
service and its specific safety.tunctionc The justification should show that a sufficiently high level of reliability for the function is provided by the'--
4 redundancy or diversity of applicable instrumentation and control ystems,.
f commensurate with the importance of the funedon, when considered in-l conjunction with the overall performance of the reactor protection trip E
system, ESF actuation systems, or ATWS system. Provide to the NRC a' copy of the licensee justification to. extend the enhanced surveillance.
program beyond the monthly test interval for transmitters that have:
reached the appropriate psi-month threshold criterion recommended by -
' Rosemount.
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SNC Respnag i
L-1, a.
Southern; Nuclear Operating Company has. identified the following.
Rosemount trammitters which perform safety related functions:
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t A'ITACllMENT Response to NRCB 90-01, Supplement 1 Page 2 i
TPNS Emetion
.Mmkl 01B21PT402 RCS Wide Range Pressure 1154GP9RA 02B21PT402 RCS Wide Range Pressure 1154GP9RA 02B21PT403 RCS Wide Range Pressure 1154GP9RA OlP17LT3027C CCW Surge Tank Level 1154DP4RD 01Pl7LT3027D CCW Surge Tank Level 1153DD4RG 01P23FT3229A Auxiliary Feedwater Flow Il54DP6RA--
SNC's review of the above listed transmitters has revealed that none of these transmitters are installed in reactor protection trip systems, ESF actuation systems, or NnVS systems. Therefore, request 1.a does not apply to Farley-Nuclear Plant.
HRC Requni 1.b.
Replace or monitor for the life of the transmitter on a quarterly basis-3 using an enhanced surveillance monitoring program, any transmitters that -
have a normal eperating pressure greater than 1500 psi and that are used in safety related applications but are not installed in reactor protection trip systems, ESF actuation systems, or NnVS systems, At -their discretion,~ licensees may monitor using an enhanced surveillance program at least once ' every refueling. cycle, but not exceeding 24 months, transmitters in this category if the appropriate psi month threshold' criterion. recommended ' by Rosemount has' been reached, and-the monitoring interval is justified based upon transmitter performance in service and its specific function. Provide to the NRC a copy of the licensee justification to extend the enhar.ced surveillance program beyond -
the quarterly test interval for transmitters that - have reached the L
appropriate psi-month threshold criterion recommended by Rosemount.
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SNCBesponse
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1.b.
Of the transmitters listed in SNC's response to.l.a, three have normai opera'ing pressures greater than '1500 psi (01B21PT402,02B21PT402, and Q2B21PT403). 01B21PT402,02B21PT402 along with 3i
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q ATTACllMENT i
Response to NRCl3 90-01, Supplement 1 l
Page 3 i
021321PT403 will be replaced dining the ner.1 refueling outage (Unit.
1 - Spring 1994, Unit 2 - Fall 1993) with. transmitters manufactured monitoring results to-date of these transmitters.
Specifically, this monitorir., has not revealed any concern for fill oil loss for these transmitters. Once these transmuters have been replaced, monitoring
,t (using an enhanced surveillance monitoring program) will cease.
NRC Requcil 1.c.
[For PWRs] Replace, or manhor at least once every refueling cycle, but a
l not exceeding 24 months, using an enhanced surveillance program until _
the transmitter reaches the appropriate psi month threshold. criterion recommended by Rosemount, any-transmitters that have a normal operating pressure greater than 500 psi and less than or equal to 1500 psi and that nre installed in reactor protection trip systems, ESF actuation systems, or ATWS systems.
I
.SNC_E.cananst 1.c.
SNC's review of the transmitters listed in SNC's response to 1.a has revealed that none of these transmitters are installed iri reactor protection trip systems, ESF actuation systems, or ATWS systems. Therefo're, tequest 1.c does not apply to Farley Nuclear _ Plant.
NRC Regunt -
- 1.<l.
Replace, or monitor at least once every refueling cycle, but not exceeding _
24 months, using an enhanced surveillance monitoring program until the.
transmitter reaches the appropriate psi-month..-threshold : Sriterion recommended by lRosemount, any transmitters used in safety-related-systems that hwe a normal operating pressure greater than 500 psi and less than or equal to 1500 psi, and that are; not installed in reactor -
protection trip systems, ESF actuation systems, or. ATWS systems.
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I ATTACHMENT Response to NRCl3 90-01, Supplement 1 Page 4 SNC Resoonse j
1.d.
Of the transmitteis listed in SNC's response to 1.a, one has a normal operating pressure greater than 500 psi and less than or-equal to 1500 psi (01P23173229A). This transmitter will also be-I rephiced -during the next refueling outage (Spring 1994) with a transmitter. manufactured - after ' July 11, 1989.-
Since this' transmitter is installed in an application having a normal opera _ ting q
pressure greater than 500 psi and less than 1500 psi along with the-
- fact that monitoring results to-date have not revealed any concern for fill-oil-loss, monitoring (using an enhanced surveillance monitoring program) will be on a refueling cycle basis. Once this transmitter has been replaced, monitoring (using an enhanced surveillance monitoring progcam) will cease.
NRC Reg;gs t
At licensee discretion, exclude from the enhanced surveillance l regram 1.e.
i any transmitters that have a no'rmal operating preasure greater.than 500 i
psi and less than or. equal to 1500 psi that have reached the_ appropriate -
psi-month threshold criterion _ recommended by Rosemount (60,000 psi-a
- nonths or 130,000 psi months _ depending' on the range code _of the transmitter). A high degree of confidence should be maintahed for detecting failure of these transmitters caused by a loss of fill oil and.a high degree of reliability should be maintained for the function consistent -
with its safety significance.
L SbTXcsponse l
1.e.
See SNC's response 10.1.0.
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l MRC Request 1.f.
At licensee discretion, exclude from the enhanced surveillance program.
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' any transmitters that have a normal operating pressure less than or equal ~'
to 50d psi. - A high degree -of-confidence shouldibe: maintained for R
detecting failure of these transmitters caused 'oy a loss of fill-oil and a'.
- high degree'of reliability should be maintained for the function consistent:
with its safety significance.
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i A'lTACllMENT-Response to NRCH 90-01, Supplement 1 Page 5 SNC Response 1.f.
The two remaining transmitters listed in ' SNC's response to 1.a -
(01P171;13027C and 01P171113027D) have normal operating pressures -
q less than 500 psi.
Therefore, these transmitters do not require replacement and do not require. monitoring (using an enhanced surveillance tuonitoring program),
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ERC Ruutnt 2.
Evaluate the enhanced surveillance monitoring program to ensure that the-program provides measurement data with an accuracy range consistent with that needed for comparison with manufacturer drift data criteria for determining degradation caused by loss of fiil oil.
SNC. Response 2.
The enhanced surveillance monitoring program implemented for Farley-Nuclear Plant Units 1 and 2 involves review of survedlance ' data'. -
specifically, zero shift data. If surveillance reveals a sustained zero shift gremer
. than 1.0% forther evaluations for replacement,. including step time response testing if deemed necessary, would be initiated. Rosemount states in Technical.
N Bulletin Number 4 (December 22,1989) 1. hat trending calibration data (zero shift data) can detect failing units, and identify leaking transmitters before significant-l degradation in response time occurs. Consequently, the enhanced surveillance monitoring program implemented for Farley Nuclear Plant Units 1 and 2, in-response to the original bulletin, provides measurement da:a with an accuracy range consistent with that needed for determining degradation caused by loss of.
fill oil. As stated above, this program will be maintained until those transmitters; mentiimed above are replaced. Once those transmitters have been replaced, the enhanced turveillance monitoring program will cease.
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