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United States Nuclear Regulatory Commission - Protecting People and the Environment

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                                                    OMB No.:  3150-0011
                                                    NRCB 90-01, Supplement 1

                                 UNITED STATES
                         NUCLEAR REGULATORY COMMISSION
                     OFFICE OF NUCLEAR REACTOR REGULATION
                            WASHINGTON, D.C.  20555

                               December 22, 1992


NRC BULLETIN NO. 90-01, SUPPLEMENT 1:  LOSS OF FILL-OIL IN TRANSMITTERS
                                       MANUFACTURED BY ROSEMOUNT

Addressees

All holders of operating licenses or construction permits for nuclear power
reactors

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this bulletin
supplement to inform addressees of activities taken by the NRC staff and the
industry in evaluating Rosemount transmitters and to request licensees to take
actions to resolve this issue.  This supplement updates information provided
in Bulletin 90-01, "Loss of Fill-Oil in Transmitters Manufactured by
Rosemount."  It is requested that recipients review the information for
applicability to their facilities and modify, as appropriate, their actions
and enhanced surveillance programs as described in this bulletin supplement.

Description of Circumstances

On April 21, 1989, the NRC issued Information Notice (IN) 89-42, "Failure of
Rosemount Models 1153 and 1154 Transmitters," to alert the industry to a
series of reported failures of Models 1153 and 1154 pressure and differential
pressure transmitters manufactured by the Rosemount Inc. (Rosemount). 
Rosemount investigated the cause of the failures and confirmed that the
failure mode was a gradual loss of fill-oil from the sealed sensing module of
the transmitter.  On March 9, 1990, the NRC issued Bulletin 90-01, in which it
requested that licensees promptly identify and take appropriate corrective
actions for Model 1153 Series B, Model 1153 Series D, and Model 1154
transmitters manufactured by Rosemount that may be or have the potential for
leaking fill-oil.  During the summer and fall of 1990, the Nuclear Management
and Resources Council (NUMARC) surveyed the industry to gather data on all
installed Rosemount Model 1153 and 1154 transmitters and safety-related Model
1151 and 1152 transmitters at commercial nuclear facilities.  NUMARC also
requested data on all suspected or confirmed failures of Rosemount
transmitters attributed to a loss of fill-oil from these same facilities.





9212170002.

                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 2 of 14


Discussion

The staff has reviewed the Rosemount transmitter loss of fill-oil issue by
analyzing data gathered from (1) licensee event reports, (2) the licensee's
responses to NRC Bulletin 90-01, (3) technical information provided by
Rosemount, (4) site visits, (5) NUMARC report 91-02, "Summary Report of NUMARC
Activities to Address Oil Loss in Rosemount Transmitters," (Reference 5) and
(6) numerous meetings with representatives from the industry, NUMARC, and
Rosemount.  The NRC became concerned about this complex technical issue
because the failure could occur and remain undetected while the transmitter
was in service and could be a common mode failure.  The manufacturer indicated
that these failures resulted from a failure of a glass-to-metal seal inside
the sensor which allowed fill fluid to leak out of the sensor at a very slow
rate.  When this condition occurs, the transmitter performance gradually
deteriorates and may lead to failure.  The loss of fill-oil failures has not
been traced to a specific time of manufacture, manufacturing lots, or process
conditions for transmitters manufactured before July 11, 1989.  The manufac-
turer performed extensive analyses to thoroughly understand and quantify the
symptoms of the failure and to develop diagnostic guidelines for detecting a
loss of fill fluid.  While performing these analyses and reviewing historical
data on the failed transmitters, the manufacturer found that the issue
involved a number of interacting factors.  These factors are discussed in
references (1) through (5).  These factors include the range code of the
transmitter, the ability of various evaluation methods to detect the
characteristics of a loss of fill fluid, the operating pressure of the
transmitter, and the amount of time that the transmitter had been in service.

Rosemount attributed many of the failures resulting in a loss of fill-oil to
the use of stainless steel "O" rings and the increased stresses on the sensor
module that result.  The manufacturer made improvements to the manufacturing
process and the post-production screening for transmitters and sensors
produced after July 11, 1989.  These improvements included making process
changes to reduce stresses on the sensor modules and pressure testing the
sensors to identify any incipient failures caused by leaking fill fluid.  By
making these improvements, the manufacturer corrected to a large extent the
problem of sensor fill-oil loss, since only one failure attributed to a loss
of fill-oil has been found in transmitters manufactured after that date.

The staff has reviewed licensee individual responses to NRC Bulletin 90-01 and
concluded that the actions taken as a result of the bulletin helped to improve
the safety of operating reactors by reducing the susceptibility to Rosemount
transmitter failures due to a loss of fill-oil.  This was accomplished mainly
by prompting licensees to remove Rosemount transmitters that were installed in
the reactor protection systems (RPS) or engineered safety feature (ESF)
actuation systems that the manufacturer found to have a high failure fraction
resulting from a susceptibility to a loss of fill-oil (i.e., suspect lot 

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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 3 of 14

transmitters).  The licensee also was to evaluate against appropriate
operability acceptance criteria those transmitters that were suspected of
exhibiting symptoms of a loss of fill-oil when reviewing the plant's
historical records on the calibration of these transmitters.  The licensees
established enhanced surveillance programs by considering various diagnostic
procedures for detecting transmitter fill-oil leakage.  These diagnostic
procedures included trending calibration data, trending operational data,
reviewing transmitter performance for sluggish transient response, and
conducting process noise analysis.

However, the staff raised a number of concerns upon reviewing the licensee
responses.  These included the following:

1.    The responses from two licensees indicated that they did not intend to
      replace suspect lot transmitters installed in RPS or ESF actuation
      systems.  These responses were reviewed with the licensees concerned,
      and the staff determined that based on the available monitoring program
      or the specific applications and available backup indications, the
      licensee actions were acceptable.

2.    Using pressure times time-in-service criteria provided in the Rosemount
      Technical Bulletin No. 4 (Reference 4) as a means to identify which
      transmitters should be included in the enhanced surveillance program. 
      In evaluating the industry survey data, the staff has since confirmed a
      relationship, as had been previously found by Rosemount and NUMARC,
      between operating pressure, time-in-service and failure rate, and that
      these parameters were acceptable for identifying which transmitters
      should be included in an enhanced surveillance program.

3.    Eliminating low pressure application (below 250 psi) transmitters from
      the enhanced surveillance program because the low oil pressure was not
      sufficient to cause oil loss.  The staff has since confirmed a
      relationship between operating pressure and transmitter failure.  A high
      operating pressure was the most dominant factor leading to a loss of
      fill-oil.  Transmitters in low pressure applications had low failure
      rates due to a loss of fill-oil.

4.    The difference between the number of transmitters manufactured by
      Rosemount and the total number of transmitters (those installed and
      those in the suspect lots) found from the responses of all licensees,
      and the reasons for this difference.  The staff has since found the
      NUMARC report evaluation and the associated database sufficiently
      account for the difference between the number of transmitters
      manufactured by Rosemount and the total number of transmitters (those
      installed and those in the suspect lots) identified from the responses
      of all licensees to the original Bulletin 90-01.


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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 4 of 14


5.    The adequacy of licensee enhanced surveillance programs to detect failed
      transmitters.  The staff has since completed a review of the NUMARC
      transmitter data and specific modified and additional requested actions
      regarding enhanced surveillance programs are contained within this
      supplement.

During the licensee response period to Bulletin 90-01, NUMARC surveyed all
utilities to collect data on all installed Rosemount Model 1153 and 1154
transmitters, and on Rosemount Model 1151 and 1152 transmitters installed in
safety-related systems.  NUMARC conducted the survey to address the staff
concerns (2) through (4) above, the closure of enhanced surveillance
monitoring activities, and to address concerns regarding the loss of fill-oil
in the Rosemount Model 1151, 1152, and 1153 Series A transmitters.

The staff reviewed the data collected by NUMARC to (1) verify NUMARC
conclusions, (2) evaluate surveillance issues regarding licensee responses in
implementing the enhanced surveillance program requested by the staff in the
bulletin, and (3) determine if other insights could be drawn from this data. 
The Brookhaven National Laboratory (BNL) assisted the staff in evaluating the
data by assessing the failure rates for various types of transmitters by
operating pressure, time-in-service, and suspect or nonsuspect lot
classification.  BNL provided the staff with the report, "Evaluation of
Surveillance and Technical Issues Regarding Rosemount Pressure Transmitter
Loss of Fill-Oil Failures," December 20, 1991 (Reference 6).  The staff
evaluated the effect of the various failure rates to address the staff
concerns (2), (3), and (5) discussed above.  In addition, the staff considered
the effects of the various failure rates on the potential for anticipated
transients without scram (ATWS).  The staff concluded that estimated
unavailabilities and the associated impact on ATWS frequency could be very
sensitive to changes in the transmitter failure rate.

In evaluating this issue, the staff confirmed a relationship, as had been
previously found by Rosemount and NUMARC, between operating pressure, time-in-
service, and the suspect and nonsuspect lot classifications in identifying
where the transmitters would most likely fail.  A high operating pressure was
the most dominant factor leading to a loss of fill-oil.

Second among these factors was time-in-service, with those transmitters having
been in service for less than 60,000 psi-months exhibiting higher failure
rates than transmitters that had been in service for more than 60,000 psi-
months.  Attachment 1 represents the staff estimates of Rosemount transmitter
failure rates based on pressure application and the time in service derived
from the NUMARC survey data.
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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 5 of 14


Third among these factors was the classification of the lot as suspect or
nonsuspect.  All suspect lots as defined by Rosemount contained at least one
confirmed failure and possibly more, depending on the size of the lot.  
However, many confirmed or suspected failures caused by a loss of fill-oil
were identified in nonsuspect lots.  If all other factors were assumed equal,
suspect lots had higher failure rates than nonsuspect lots.  When pressure
application or time-in-service was considered, classification by suspect or
nonsuspect lot was of lesser importance.

Throughout this evaluation period, the staff found several noteworthy items
including the following:

1.    The manufacturer continues to confirm that transmitters are failing
      because of a loss of fill-oil.

      When the NRC issued Bulletin 90-01, the manufacturer confirmed that
      approximately 90 transmitters had failed because of a loss of fill-oil. 
      By taking the actions requested in the bulletin, the licensees would
      have removed from service both those groups of transmitters identified
      as suspect transmitters and those transmitters suspected of oil loss
      based on historical calibration data.  Since that time, Rosemount has
      confirmed approximately 50 additional transmitters as having failed
      because of a loss of fill-oil.  While the number of failures resulting
      from a loss of fill-oil has decreased recently, this condition continues
      to cause transmitters to fail.  However, only one failure attributed to
      a loss of fill-oil has been found in transmitters manufactured after
      July 11, 1989.

2.    The manufacturer continues to classify more transmitters as being
      suspect lots.

      In December 1989, Rosemount issued the initial list of suspect lot
      transmitters which included approximately 1075 transmitters.  Since that
      time, the manufacturer has updated this list with four addenda
      (references 1 through 4), with the most recently issued addendum adding
      approximately 215 transmitters in December 1991.  The current number of
      transmitters found in the suspect lots is approximately 1700.  The staff
      now concludes that the suspect lot classification is of lesser
      importance than operating pressure and time-in-service.
      

3.    At nuclear facilities, Model 1151 and Model 1152 transmitters have
      failed because of a loss of fill-oil.
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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 6 of 14


      The fact that these transmitters failed indicates that the failures are
      not limited to transmitters with stainless steel "O" rings. However, the
      number of Model 1151 and Model 1152 transmitters which have been
      confirmed to have failed due to loss of fill-oil is very small for their
      considerable operating experience.

4.    In November 1991, Rosemount informed the NRC that it was recalling
      approximately 1300 Model 1151 transmitters based on a Rosemount
      engineering analysis which indicated that these transmitters are
      susceptible to a loss of fill-oil.

      Rosemount indicated that it had shipped only a few of these transmitters
      to nuclear facilities and that none had been reported as having failed
      because of a loss of fill-oil.  The staff reviewed information on these
      transmitters and concluded that Rosemount has addressed the issue
      adequately by making a recall.  Rosemount is also improving the post-
      production screening test of Model 1151 transmitters.

The staff concern throughout the evaluation of this issue is the need to
determine whether or not the Rosemount transmitter meets current criteria as a
reliable component for which failures can be readily detected.  The NRC issued
General Design Criterion (GDC) 21, "Protection System Reliability and
Testability" in Appendix A to Part 50 of Title 10 of the 
Code of Federal Regulations (10 CFR 50) to require the protection system to be
designed with high functional reliability and with a capability to permit
periodic testing of its functioning when the reactor is in operation.  The NRC
established this requirement to ensure that the licensee can readily detect
failures of subcomponents and subsystems within the protection system and can
readily detect loss of the required protection system redundancy when it
occurs.  In 10 CFR 50.55a(h), the NRC requires that protection systems meet
the Institute of Electrical and Electronics Engineers Standard, "Criteria for
Protection Systems for Nuclear Power Generating Stations" (IEEE-279).  In
IEEE-279, the Standard states that means shall be provided for checking, with
a high degree of confidence, the operational availability of each system input
sensor during reactor operation.  To achieve a high functional reliability, a
transmitter must have a low probability of failure while it is operating. 
Furthermore, failures should be readily detectable, commensurate with the
safety function, while the transmitter is in operation.  Upon reviewing the
analyses, evaluations, and historical data on the loss of fill-oil, the staff
concludes that actions requested by the previous bulletin are insufficient to
ensure compliance with the regulations requiring that the transmitters achieve
the desired high functional reliability.
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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 7 of 14


The staff concludes the following:

1.    The following Rosemount transmitters are not achieving high functional
      reliability:  Model 1153 Series B, Model 1153 Series D, and Model 1154
      transmitters manufactured before July 11, 1989, that are currently used
      in either safety-related systems or systems installed in accordance with
      10 CFR 50.62 (the ATWS rule), and that:

      a.  have a normal operating pressure greater than 1500 psi, or
 
      b.  have a normal operating pressure greater than 500 psi and less than
          or equal to 1500 psi that have not reached the appropriate psi-month
          threshold recommended by Rosemount (60,000 psi-months or 130,000
          psi-months depending on the range code of the transmitter).

      Since these transmitters are not achieving high functional reliability,
      the transmitters should be replaced or use of an enhanced surveillance
      program should be implemented.  Details are provided in Requested
      Actions below.  The availability of access points to the instrument
      loops and the potential for inadvertent actuation should be considered
      in any decision to implement the enhanced surveillance program option
      rather than replace transmitters.  Plant shutdown solely for the
      purposes of implementing the replacement option of transmitters
      identified in the Requested Actions is not intended.

2.    The following Rosemount transmitters are achieving a high functional
      reliability:  Model 1153 Series B, Model 1153 Series D, and Model 1154
      transmitters manufactured before July 11, 1989, that are currently used
      in either safety-related systems or systems installed in accordance with
      10 CFR 50.62 (the ATWS rule), and that:

      a.  have a normal operating pressure less than or equal to 500 psi, or

      b.  have a normal operating pressure greater than 500 psi and less than
          or equal to 1500 psi that have reached the appropriate psi-month
          threshold recommended by Rosemount (60,000 psi-months or 130,000
          psi-months depending on the range code of the transmitter).

      These transmitters may remain in service and may be excluded from any
      enhanced surveillance program provided that a high degree of confidence
      is maintained for detecting degradation of these transmitters caused by
      a loss of fill-oil and a high degree of reliability is maintained for
      the function consistent with its safety significance.

3.    As a minimum, enhanced surveillance monitoring programs should provide
      measurement data with an accuracy range consistent with that needed for 


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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 8 of 14


      comparison with manufacturer drift data criteria for determining
      degradation caused by a loss of fill-oil.  To achieve the desired
      accuracy, the licensee can determine the trending of zero drift and span
      drift from the calibration data for most Rosemount transmitter range
      codes.  Other methods may include measuring the output of a transmitter
      that is in service using a calibrated instrument and comparing the
      results with redundant channels.

4.    The appropriate enhanced surveillance test interval for each of the
      transmitters in the program should consider the specific safety
      function(s), available diversity, and other factors.  In determining the
      test interval for those transmitters which are to be monitored by an
      enhanced surveillance program, the licensee may find that the normal
      calibration interval may not be sufficient to provide a high degree of
      confidence for detecting degradation caused by a loss of fill-oil.

5.    Replacing a Rosemount transmitter with one manufactured after July 11,
      1989, means installing a transmitter which has been refurbished with a
      sensor module manufactured after July 11, 1989 (sensor module number
      greater than 2182605), or installing a transmitter manufactured after
      July 11, 1989 (a transmitter having a serial number greater than
      500000).

6.    The performance experience and identified failures do not indicate that
      additional licensee action is warranted to address the issue of a loss
      of fill-oil for Rosemount Model 1151, 1152, and 1153 (Series A)
      transmitters.  The number of Model 1151 and Model 1152 transmitters
      which have been confirmed to have failed due to a loss of fill-oil is
      very small given their operating experience, and therefore is
      sufficiently low to be of minimum concern.

7.    The NUMARC report evaluation and the associated database sufficiently
      account for the difference between the number of transmitters
      manufactured by Rosemount and the total number of transmitters (those
      installed and those in the suspect lots) found from the responses of all
      licensees to the original Bulletin 90-01.  The NUMARC survey data
      provided the staff a "snapshot" of the installed population of Rosemount
      transmitters subject to the bulletin, including application by function,
      time-in-service, and operating pressure.  

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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 9 of 14


Requested Actions

Operating Reactors

The NRC requests that all holders of operating licenses for nuclear power
reactors take the following actions: 

1.    Review plant records and identify any Rosemount Model 1153 Series B,
      Model 1153 Series D, and Model 1154 transmitters manufactured before
      July 11, 1989, that are used or may be used in the future in either
      safety-related systems or systems installed in accordance with 10 CFR
      50.62 (the ATWS rule), and

      a.  Expeditiously replace, or monitor for the life of the transmitter on
          a monthly basis using an enhanced surveillance monitoring program,
          any transmitters that 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 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 safety function.  The justification should show
          that a sufficiently high level of reliability for the function is
          provided by the redundancy or diversity of applicable
          instrumentation and control systems, commensurate with the
          importance of the function, when considered in conjunction with the
          overall performance of the reactor protection trip 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.

      b.  Replace, or monitor for the life of the transmitter on a quarterly
          basis using an enhanced surveillance monitoring program, any
          transmitters that have a normal operating 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 ATWS 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 
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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 10 of 14


          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 enhanced surveillance program
          beyond the quarterly test interval for transmitters that have
          reached the appropriate psi-month threshold criterion recommended by
          Rosemount.

      c.  [For BWRs] Replace, or monitor on a monthly basis using an enhanced
          surveillance monitoring 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, that are installed in
          reactor protection trip systems, ESF actuation systems or ATWS
          systems.  On a case-by-case basis except for transmitters that
          initiate reactor protection or ATWS trips for high pressure or low
          water level, licensees may monitor using an enhanced surveillance
          program at least once every refueling cycle, but not exceeding 24
          months, if sufficient justification is provided based upon
          transmitter performance in service and its specific safety function.
          The justification should show that a sufficiently high level of
          reliability for the function is provided by the redundancy or
          diversity of applicable instrumentation and control systems,
          commensurate with the importance of the function, when considered in
          conjunction with the overall performance of the reactor protection
          trip 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 PWRs] Replace, or monitor at least once every refueling cycle,
          but 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 are installed in reactor protection trip
          systems, ESF actuation systems, or ATWS systems.

      d.  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 criterion recommended by Rosemount, any transmitters used
          in safety-related systems that have 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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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 11 of 14


      e.  At licensee discretion, exclude from the enhanced surveillance
          program any transmitters that have a normal operating pressure
          greater than 500 psi and less than or equal to 1500 psi that have
          reached the appropriate psi-month threshold criterion recommended by
          Rosemount (60,000 psi-months or 130,000 psi-months depending on the
          range code of the transmitter).  A high degree of confidence should
          be maintained 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.

      f.  At licensee discretion, exclude from the enhanced surveillance
          program any transmitters that have a normal operating pressure less
          than or equal to 500 psi.  A high degree of confidence should be
          maintained 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.

      Summary tables are included as Attachment 2 to aid in understanding the
      above actions requested in this Bulletin Supplement compared with those
      in Bulletin 90-01.

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 a loss of fill-oil.

The actions described in this supplement supersede the actions requested in
the original bulletin.  Compliance with applicable Commission requirements may
be the subject of NRC audits or inspections in the future.

Construction Permit Holders

All holders of construction permits are requested to complete Items 1 and 2 of
Requested Actions for Operating Reactors before the date scheduled for loading
fuel.

The actions described in this supplement supersede the actions requested in
the original bulletin.  Compliance with applicable Commission requirements may
be the subject of NRC audits or inspections in the future.

Reporting Requirements

Operating Reactors

Provide within 60 days after receipt of this bulletin, a response that
includes the following:

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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 12 of 14


1.    A statement whether the licensee will take the actions requested above.

2.    With regard to the actions requested above that the licensee is taking:

      a.  A list of the specific actions that the licensee will complete to
          meet Item 1 of Requested Actions for Operating Reactors provided in
          this supplement, including justifications as appropriate.

      b.  The schedule for completing licensee actions to meet Item 1 of
          Requested Actions provided in this supplement.

      c.  When completed, a statement confirming that Items 1 and 2 of
          Requested Actions for Operating Reactors provided in this supplement
          have been completed.

3.    A statement identifying those actions requested by the NRC that the
      licensee is not taking and an evaluation which provides the bases for
      not taking the requested actions.

Construction Permit Holders

Before the date scheduled for loading fuel, all holders of construction
permits are required to provide a response that confirms that the Requested
Action for Construction Permit Holders has been completed.

The written reports required above with respect to both operating reactors and
plants under construction shall be addressed to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, D.C. 20555, and shall be
submitted under oath or affirmation pursuant to the provisions of 
Section 182a, Atomic Energy Act of 1954, as amended and 10 CFR 50.54(f).  A
copy shall also be submitted to the appropriate Regional Administrator. 
Because the information sought above is to verify licensee compliance with 
10 CFR 50.55a(h) and GDC 21, which are part of the current licensing basis for
all plants, justification for this information request need not be prepared by
the Commission pursuant to 10 CFR 50.54(f).

Backfit Discussion

The NRC is requesting that the addressees take the actions described herein to
ensure that they promptly detect transmitter failures caused by a loss of
fill-oil.  A loss of fill-oil may result in a transmitter not performing its
intended safety function.

The actions requested in this bulletin supplement represent new positions of
the staff and thus, this request is considered a backfit in accordance with .

                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 13 of 14


the NRC's procedures.  The staff is imposing this backfit to bring facilities
into compliance with existing requirements and did not perform a full backfit 
analysis.  However, the staff performed an evaluation of the type discussed in
10 CFR 50.109(a)(6) including a statement of the objectives of and reasons for
the actions requested and the basis for invoking the compliance exemption.  It
will be made available in the Public Document Room with the minutes of the
228th meeting of the Committee to Review Generic Requirements.  The staff
disposition of comments received on the proposal for this Supplement 1 to
Bulletin 90-01, which was published in the Federal Register on April 7, 1992
will also be made available with those minutes.

This request is covered by Office of Management and Budget Clearance Number
3150-0011 which expires June 30, 1994.  The estimated average number of burden
hours is 2 person-hours for each transmitter for each licensee.  This includes
the time needed to assess the requested actions, review plant records, analyze
the data obtained from plant records, evaluate the existing enhanced
surveillance program, and prepare the required response.  This does not
include the time needed to revise the enhanced surveillance programs or to
replace transmitters.  Send comments regarding this burden estimate or any
other aspect of this collection of information, including suggestions for
reducing this burden, to the Information and Records Management Branch,
Division of Information Support Services, Office of Information Resources
Management, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555; and to
Ronald Minsk, (3150-0011), Office of Management and Budget, Washington, D.C.
20503.

Although no specific request or requirement is intended, the following
information would be helpful to the NRC in evaluating the cost of complying
with this bulletin supplement:

(1)   the licensee staff time and costs to perform requested inspections,
      evaluations, modifications, and associated testing

(2)   the licensee staff time and costs to complete the requested reports and
      documentation

(3)   the additional short-term costs incurred as a result of performing the
      requested actions such as the costs of additional corrective actions or
      costs of down time

(4)   an estimate of the additional long-term costs which will be incurred in
      the future as a result of implementing commitments such as the estimated
      cost of conducting future surveillances or increased maintenance

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                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 14 of 14


If you have any questions about the information in this supplement, please
contact the technical contact listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) project manager.


                                ORIGINAL SIGNED BY


                              James G. Partlow
                              Associate Director for Projects
                              Office of Nuclear Reactor Regulation

Technical contact:  Paul Loeser, NRR
                    (301) 504-2825

Lead Project Manager:  Ngoc Le, NRR
                       (301) 504-1458

Attachments:
1.  Figure 1, Rosemount Transmitter Failure Rates
2.  Comparison of Requested Actions
3.  List of Recently issued NRC Bulletins

References:
1.  Rosemount Technical Bulletin No. 1, May 10, 1989
2.  Rosemount Technical Bulletin No. 2, July 12, 1989
3.  Rosemount Technical Bulletin No. 3, October 23, 1989
4.  Rosemount Technical Bulletin No. 4, December 22, 1989
5.  NUMARC Report 91-02, "Summary of NUMARC Activities to Address Oil Loss in  
      Rosemount Transmitters," April 1991.
6.  BNL Report, "Evaluation of Surveillance and Technical Issues Regarding     
      Rosemount Pressure Transmitter Loss of Fill-Oil Failures," December 20,  
      1991..

                                                Attachment 2
                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 1 of 3

                        COMPARISON OF REQUESTED ACTIONS

   High Pressure      Supplement to Bulletin 90-01    Original Bulletin 90-01
                                                                              
Non-Mature           \Replace or monitor with an     \Replace suspect lot 
RPS/ESF/ATWS         \enhanced surveillance program  \transmitters
                     \on a monthly basis.            \Monitor remainder in an
                     \                               \enhanced surveillance
                     \                               \program                 
Non-Mature           \Replace or monitor with an     \Monitor with an 
Non-RPS/Non-         \enhanced surveillance program  \enhanced surveillance 
ESF/Non-ATWS         \on a quarterly basis.          \program                 
Mature               \Replace or monitor with an     \Replace suspect lot 
RPS/ESF/ATWS         \enhanced surveillance program  \transmitters
                     \on a monthly basis. (24 month  \Monitor remainder in an 
                     \basis with adequate            \enhanced surveillance    
                     \justification.)                \program                 
Mature               \Replace or monitor with an     \Monitor with an 
Non-RPS/Non-         \enhanced surveillance program  \enhanced surveillance 
ESF/Non-ATWS         \on a quarterly basis. (24 month\program
                     \basis with adequate 
                     \justification.)                                         


NOTE:  Non-Mature refers to a transmitter that has not reached the appropriate
psi-month threshold recommended by Rosemount (60,000 psi-months or 130,000
psi-months depending on the range code of the transmitter).  Mature refers to
a transmitter that has met the Rosemount psi-month threshold criterion.
.

                                                Attachment 2
                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 2 of 3


                        COMPARISON OF REQUESTED ACTIONS

 Medium Pressure      Supplement to Bulletin 90-01    Original Bulletin 90-01
                                                                              
Non-Mature           \(BWR) Replace or monitor with  \Replace suspect lot 
RPS/ESF/ATWS         \an enhanced surveillance       \transmitters
                     \program on a monthly basis.(24 \Monitor remainder in an
                     \month basis with adequate      \enhanced surveillance 
                     \justification, except for      \program
                     \transmitters that initiate RPS \
                     \or ATWS trips for high pressure\
                     \or low water level.)           \
                     \                               \
                     \(PWR) Replace or monitor with  \
                     \an enhanced surveillance       \
                     \program at intervals no greater\
                     \than 24 months.                \                        
Non-Mature           \Replace or monitor with an     \Monitor with an 
Non-RPS/Non-         \enhanced surveillance program  \enhanced surveillance
ESF/Non-ATWS         \at intervals no greater than   \program
                     \24 months.                     \                        
Mature               \Enhanced surveillance program  \Replace suspect lot 
RPS/ESF/ATWS         \discretionary. Maintain        \transmitters
                     \ability to detect failures     \Monitor remainder in an 
                     \                               \enhanced surveillance
                     \                               \program                 
Mature               \Enhanced surveillance program  \Monitor with an 
Non-RPS/Non-         \discretionary. Maintain        \enhanced surveillance 
ESF/Non-ATWS         \ability to detect failures     \program                 

NOTE:  Non-Mature refers to a transmitter that has not reached the appropriate
psi-month threshold recommended by Rosemount (60,000 psi-months or 130,000
psi-months depending on the range code of the transmitter).  Mature refers to
a transmitter that has met the Rosemount psi-month threshold criterion.
.

                                                Attachment 2
                                                NRCB 90-01, Supplement 1
                                                December 22, 1992
                                                Page 3 of 3

                        COMPARISON OF REQUESTED ACTIONS

  Low Pressure        Supplement to Bulletin 90-01    Original Bulletin 90-01
                                                                              
Non-Mature           \Enhanced surveillance program  \Replace suspect lot 
RPS/ESF/ATWS         \discretionary. Maintain        \transmitters
                     \ability to detect failures     \Monitor remainder in an 
                     \                               \enhanced surveillance
                     \                               \program                 
Non-Mature           \Enhanced surveillance program  \Monitor with an 
Non-RPS/Non-         \discretionary. Maintain        \enhanced surveillance 
ESF/Non-ATWS         \ability to detect failures     \program                 
Mature               \Enhanced surveillance program  \Replace suspect lot 
RPS/ESF/ATWS         \discretionary. Maintain        \transmitters
                     \ability to detect failures     \Monitor remainder in an
                     \                               \enhanced surveillance
                     \                               \program                 
Mature               \Enhanced surveillance program  \Monitor with an 
Non-RPS/Non-         \discretionary. Maintain        \enhanced surveillance 
ESF/Non-ATWS         \ability to detect failures     \program                 


NOTE:  Non-Mature refers to a transmitter that has not reached the appropriate
psi-month threshold recommended by Rosemount (60,000 psi-months or 130,000
psi-months depending on the range code of the transmitter).  Mature refers to
a transmitter that has met the Rosemount psi-month threshold criterion.
.

 

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