ML20080A672

Technical Evaluation Rept,Evaluation of Util Response to Suppl 1 to NRC Bulletin 90-01:Vogtle-1/-2

ML20080A672
Person / Time
Site:	Vogtle
Issue date:	09/30/1994
From:	Udy A EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20080A675	List: ML20080A672
References
CON-FIN-L-1695 EGG-DNSP-11510, TAC-M85457, NUDOCS 9411090176
Download: ML20080A672 (21)

Text

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EGG-DNSP-11510 I

TECHNICAL EVALUATION REPORT

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Evaluation of Utility Response to Supplement I to NRC Bulletin 90-01: Vogtle-1/-2 Docket Nos. 50-424 and 50-425 Alan C. Udy Published September 1994 EG&G Idaho, Inc. ,

Idaho National Engineering Laboratory Idaho Falls, Idaho 83415 -

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

Under DOE Contract No. DE-AC07-76ID01570 FIN No. L1695, Task No. 11a TAC Nos. M85457 and M85458 f

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SUMMARY

This report documents the EG&G Idaho, Inc., review of the Georgia Power Company submittals that respond to Supplement I to NRC Bulletin 90-01 for Unit Nos. I and 2 of the Vogtle Electric Generating Plant. This NRC Bulletin provides information on the loss of fill-oil in certain pressure and differential presuire transmitters manufactured by Rosemount, Inc. This report finds the licensee complies with the requested actions of the Supplement.

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FIN No. Ll695, Task No. 11a B&R No. 320-19-15-05-0 Docket Nos. 50-424 and 50-425 TAC Nos. M85457 and M85458 11

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i 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 Factors, by EG&G Idaho,  !

Inc., DOE /NRC Support Programs Unit.

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CONTENTS

SUMMARY

.............................................................. 11 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 1

4. CONCLUSIONS ..................................................... 12

5. REFERENCES ...................................................... 13 i

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Evaluation of Utility Response to Sucolement I to NRC Bulletin 90-01: Voatle-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 1 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 Reaues11d 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 comitting the licensee to take the NRC Bulletin 90-01, Supplement 1, Reauested Actions or taking exception to those actions. ,

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

a. a list of specific actions, including any

• justifications, to be taken to complete the comitment,

b. a schedule for completion, and 1

c. after completion, a statement confirming the actions comitted 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.

o The Georgia Power Company, the licensee for Unit Nos. I and 2 of the Vogtle Electric Generating Plant, responded to Supplement 1 of NRC Bulletin ,

90-01 with a letter dated February 26, 1993 (Reference 3). The licensee submitted additional information and confirmation that their actions are complete on April 21, 1994 (Reference 4). A typographical error was corrected on July 11, 1994 (Reference 5). This technical evaluation report evaluates -

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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 limit ( 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 I

• Rosemount Model 1153, Series D  :

• Rosemount Model 1154  ;

I 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 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 i 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.

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 the specific safety function of the transmitter. That  ;

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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 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 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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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  !

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.The licensee responded to Supplement 1 of NRC Bulletin 90-01 on February 26, 1993. The licensee provided additional information on April 21, 1994. This was resubmitted on July 11, 1994. Those responses were compared  !

to the Bulletin Reportina Reauirements and Reauested Actions as described I below. The licensee reports, in Reference 3, that they had 24 medium pressure )

Rosemount transmitters that are subject to the Reauested Actions of the Supplement. The licensee states that additional Rosemount transmitters in low j pressure applications are excluded from the enhanced surveillance progra J. i Still other Rosemount transmitters are outside the scope of the Supplement due to replacement, refurbishment, or use in non-safety applications. The Vogtle l Electric Generating Plant consists of 2 PWRs.

3.1 Evaluation of Licensee Response to Reportina Reauirements l

The licensee states, in Reference 3, they will meet the intent of the Reauested Actions detailed in 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 comply with-the Reauested Actions.

References 4 and 5 include a statement that the Reauested Actions are i complete. The licensee submittal conforms with the Reoortina Reauirements of Supplement 1 of NRC Bulletin 90-01.

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3.2 Evaluation of Licensee Response to Reauested Actions Supplement 1 of NRC Bulletin 90-01 requested licensee action to resolve i the issue of fill-oil leakage in Rosemount transmitters. This Technical l Evaluation Report summarizes the Reauested Actions and the associated transmitter criteria in Section 2. The licensee identified no high pressure transmitters that are in the scope of this review. The licensee identified a 7

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I total of 24 medium pressure transmitters that are in the scope of this review. f

- The licensee excluded low pressure application Rosemount transmitters from the ,

i enhanced surveillance program. The scope of the review includes only those  !

Rosemount transmitters manufactured before July 11, 1989. The following  !

sections discuss the licensee response to the Supplement.

3.2.1 Licensee Response to'Reauested Action 1.a i

The licensee states there are no remaining pre-July 11, 1989, Rosemount  ;

transmitters from this transmitter classification at the Vogtle Electric ,

Generating Plant.  !

i 3.2.2 Licensee Resnonse to Reauested Action 1.b  :

The licensee states there are no Rosemount transmitters from this '

transmitter classification at the Vogtle Electric Generating Plant.

l 3.2.3 Licensee Response to Reauested Action 1.c l I

i The licensee states, in Reference 3, that there are 20 remaining pre-  ;

July 11, 1989, Rosemount transmitters from this transmitter classification at l the Vogtle Electric Generating Plant. These 20 transmitters are in the licensee's enhanced surveillance program. Calibration data is taken on an  !

established schedule, with either an 18-month or a 24-month calibration interval. This data is trended and compared to the Rosemount drift data  ;

criteria. It 1 . hat criteria that determines whether a transmitter needs further testing and evaluation of its condition regarding the loss of fill- -l oil.

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l. The licensee notes that these 20 transmitters monitor the auxiliary i feedwater system. Because of this application, the transmitters only operate ,

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at pressure during reactor modes 2, 3, or 4, and for a few hours a month during system surveillance testing that occurs both monthly and quarterly.

The licensee has included these 20 transmitters in an enhanced surveillance program as directed by Recuested Action 1.c. Therefore, the licensee response for this Recuested Action is acceptable.

3.2.4 Licensee Response to Recuested Action 1.d The licensee states, in Reference 3, that there are four remaining pre-July 11, 1989, Rosemount transmitters from this classification at the Vogtle Electric Generating Plant. These four transmitters, used to monitor the main steam system atmospheric relief valves, were in the licensee's enhanced surveillance program. The output signals from these four transmitters was compared to the output signals of redundant, non-Rosemount transmitters monthly. Drift between the redundant signals is a symptom of the loss of fill-oil. The licensee noted that these four transmitters would continae in this program until replaced.

The licensee notified the NRC, in Reference 4, that these transmitters are replaced. Thus, the licensee actions for this transmitter classification are complete and acceptable.

3.2.5 Licensee Response to Recuested Action 1.e The licensee states there are no Rosemount transmitters from this transmitter classification at the Vogtle Electric Generating Plant. Further, .

1 with the replacement of the Rosemount transmitters in classification 1.d. and i the low time at pressure for the Rosemount transmitters in classification 1.c, there will be no transmitters added to this transmitter classification in the immediate future. Thus, there are no licensee actions necessary for this transmitter classification. ,

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i 3.2.6 Licensee Resoonse to Reouested Action 1.f l The licensee states there are Rosemount transmitters from this  !

classification at the Vogtle Electric Generating Plant. The licensee did not  !

identify the quantity of the Rosemount transmitters included in this  !

classification. As permitted by this Reauested Action, the licensee is i excluding these transmitters from the enhanced surveillance program.  :

The Supplement requires the licensee to maintain a high degree of confidence that these transmitters remain highly reliable. The licensee states that this capability is maintained through periodic transmitter calibrations. The transmitters are calibrated every 18-24 months. The l licensee uses a transmitter performance checklist with the transmitter calibrations. If the technician observes sluggish transmitter response, i various actions are taken to address the loss of fill-oil concern. The j licensee may trend past calibration data to determine if a zero shift l indicative of loss of fill-oil is present. The licensee may bench test the ,

transmitter to gauge its performance. The licensee may perform an engineering i evaluation. If the licensee determines that the transmitter has lost fill-f oil, the transmitter would either be replaced, refurbished, or subjected to -

additional bench testing. The licensee's actions maintains a high level of j confidence that a high level of reliability is maintained and that transmitter failure due to loss of fill-oil is detectable.

a 3.2.7 Enhanced Surveillance Monitorina Proaram The licensee has a two-part enhanced surveillance program. The 20 -

transmitters in classification 1.c have calibration data trended. The i licensee states that the accuracy and range of the data are consistent with -

the Rosemount recommendations for comparison with the Rosemount drift data l criteria. Each transmitter is evaluated individually. l The four transmitters in classification 1.d had their output signals  !

compared to the output signals of redundant transmitters monthly. The l l*

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s s redundant transmitter is of non-Rosemount manufacture. The redundant transmitters monitor the same process fluid. This method is also an  :

acceptable means to identify a transmitter with degradation due to the loss of fill-oil. Since these transmitters are replaced, this method was discontinued.

The licensee uses acceptable methodology to detect the loss of fill-oil in their Rosemount transmitters. Further, the licensee states the data has the accuracy that enables them to detect degraded transmitters. Therefore, the licensee's enhanced surveillance program is acceptable.

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4. CONCLUSIONS Based on our review, we find the licensee has completed the reporting requirements of Supplement I of NRC Bulletin 90-01. Further, the licensee  ;

conforms to 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, Georgia Power Company (C. K. McCoy) to NRC, "NRC Bulletin 90-01, Supplement 1, Loss of Fill-Oil in Transmitters Manufactured by Rosemount," February 26, 1993, ELV-05225 003019.

4. Letter, Georgia Power Company (C. K. McCoy) to NRC, ~' Status of Action in Response to NRC Bulletin 90-01, Supplement 1, Loss of Fill-Oil in Transmitters Manufactured by Rosemount," April 21, 1994, LCV-0331.

5. Letter, Georgia Power Company (C. K. McCoy) to NRC, " Status of Action in Response to NRC Bulletin 90-01, Supplement 1, Loss of Fill-Oil in Transmitters Manufactured by Rosemount," July 11, 1994, LCV-0331, Corrected Copy.

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4 CF 335 U.S. NUCLEAR REGLATORY CDPNISSIC3 1. PORT W BER

• 3201, 3202 BIBLIOGRAPHIC DATA SHEET

<see instnetions on the reverse) EGG-DNSP-11510

2. TITLE AND SUDTITLE 3. DATE REPORT PUHLISK D Evaluation of Utility Response to Supplement 1 to Me YEAR NRC Bulletin 90-01: Vogtle-1/-2 September 1994  ;

4. FIN G GRANT NMR L1695

5. AUTHOR (S) 6. TYPE OF REPORT Alan C. Udy Technical Evaluation

7. PERIOD COVERED - n

8. PERFORMING ORGANIZATION - NAK AND ADDRESS n=. - am.. u n.-- .n.,.-,

DOE /NRC Support Programs EG&G Idaho, Inc.

P.O. Box 1625 Idaho Falls, ID 83415-3870

9. SPONSORING ORGANIZATION . NAK AND ADDRESS a e. .-4 .-.mem am..s u m a ,- =>

Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

10. SUPPLE K NTARY NOTES

11. ABSTRACT .

This report documents the EG&G Idaho, Inc., review of the Georgia Power Company submittals that respond to Supplement 1 to NRC Bulletin 90-01 for the Vogtle Electric Generating Plant, Unit Nos. I and 2. This NRC bulletin provides informatio: I 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 s. .- . ,

13. AVAILABILITY STATEE NT Rosemount Transmitters Unlimited Distribution B 11 1 -01, Supplement 1 Unclassified

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Unclassified

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16. PRIE l

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