ML20046A361
| ML20046A361 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1993 |
| From: | Zimmerman R Office of Nuclear Reactor Regulation |
| To: | Ballintine R ROSEMOUNT, INC. |
| References | |
| REF-QA-99900271 NUDOCS 9307280002 | |
| Download: ML20046A361 (8) | |
Text
b $JWL Fl L8c. PAR June 24, 1993 Docket No. 99900271 Mr. Richard G.
Ballintine Vice President Government Relations and Administration Rosemount Aerospace, Inc.
14300 Judicial Road Burnsville, Minnesota 55337
Dear Mr. Ballintine:
SUBJECT:
CONFIRMATION OF NRC VISIT This letter confirms the upcoming Nuclear Regulatory Commission (NRC) visit on June 30 and July 1, 1993, as discussed'during a June 23, 1993, conversation between Mr. Ken Ewald of Rosemount and myself.
The purpose of the visit is to discuss various technical matters associated with the NRC Rosemount Issues Group's charter that was forwarded to you on June 1, 1993. to this letter provides a listing of items we would like to discuss during our visit. is a listing of itens that we wisn to discuss with you if time permits, but more likely will be pursued with Rosemount subsequent to our visit.
Your cooperation concerning this matter is appreciated.
If you have any questions, please contact me at (301) 504-2969.
Sincerely, (s) original signed by Roy P. Zimmerman, Deputy Director 9307280002 930624 Division of Reactor Inspection and PDR GA999 EMVROSM Licensee Performance 99900271 PDR Office of Nuclear Reactor Regulation
Enclosures:
As stated
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June 24, 1993 o,
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Docket No. 99900271 Mr. Richard G.
Ballintine Vice President Government Relations and Administration Rosemount Aerospace, Inc.
14300 Judicial Road Burnsville, Minnesota 55337
Dear Mr. Ballintine:
SUBJECT:
CONFIRMATION OF NRC VISIT This letter confirms the upcoming Nuclear Regulatory Commission (NRC) visit on June 30 and July 1, 1993, as discussed during a June 23, 1993, conversation betweer Mr. Ken Ewald of Rosemount and myself.
The purpose of the visit is to discuss various technical matters associated with the NRC Rosemount Issues Group's charter that was forwarded to you on June 1, 1993. to this letter provides a listing of items we would like to discuss during our visit. is a listing of items that we wish to discuss with you if time permits, but more likely will be pursued with Rosemount subsequent to our visit.
Your cooperation concerning this matter is appreciated.
If you have any questions, please contact me at (301) 504-2969.
Sincerely, 73 P.
. merman, Deputy Director s=
visi of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation
Enclosures:
i As stated cc:
Kenneth E.
Ewald Business Unit Manager, Nuclear Rosemount Aerospace, Inc.
1256 Trapp Road i
Eagan, Minnesota 55121 l
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Jay E.
Silberg, Partner l
Shaw, Pittman, Potts &
Trowbridge 2300 N Street, N.W.
Washington, D.C.
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4 I.
Testina Practices 1.
Describe the evolution of test methods and acceptance criteria'for Models 1151, 1152, 1153,c(a,~b,--& d), and 1154'
-transmitters and include in your discussion the following:
.j (a)
Test methods and acceptance criteria used prior to July 11, 1989; on July 11, 1989; andLchanges from July 11, 1989, through current testing practices; (b)
Hold times and pressures for the various' aging tests; (c)
Other tests such as Response Time Testing; and (d)
Use of sampling during testing.
2.
Has Rosemount formally evaluated and documented the analysis for:
(a)
The effects on the-integrity of the glass / metal interface resulting from subjecting the sensor cell to pressures up.to 6000 psi?
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(b)
The effects that the increased pressure:during testing may have on the published. qualified life of the transmitter (15 years.at 120*F for some; models)?- It is noted that data' sheets do not I
appear'to have changed even.though test-pressures have increased?
(c)
Please discuss a & b above in detail.
3.
P29 vide a general discussion on the acceptability of oil loss during various tests and also address the following:
(a)
What is the method (s) used (a calculation, analysis,.etc.) to determine how much oil has leaked during testing?
(b)
Why is any oil loss acceptable?
(c)
It is our understanding that_the. sensor cell may i
only be partially filled with oil and then the unit sealed.
Is this correct?
Is there any way to determine how much oil is in a' sensor cell?
(d)
If a sensor cell is partially full of oil, is 4
there a separate acceptance criteria.for the amount of oil leakage during the pressure test or would the acceptance criteria be the same for a cell which is essentially full of oil?
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2 (e)
During response time testing can you distinguish between a cell about 40% full vs a cell that is about 80% full of oil?
(f)
Does the amount of fill oil in a sensor cell affect the qualified life of the transmitter (with respect.to having the ability to have sufficient oil-fill for the rated life of the transmitter)?.
II.
Desian Describe the evolution of the design for Models 1151, 1152, 1153 (a, b,
& d) and 1154 transmitters and include in your discussion the following:
(a)
Designs prior to July 11, 1989; on July 11, 1989; and changes from July 11, 1989, through current design.
(b)
Changes over the years for the "O"-Ring groove and the "O" Ring dimensions and dimensional tolerances.
(c)
Torque requirements for fasteners and changes over the years and the resulting effects on stresses applied to the sensor cell.
(d)
Effects that these changes have had on maintaining the integrity of the glass / metal interface in the cell.
III. Manuf act'1rina Process Describe the evolution of the manufacturing process for Model 1151, 1152, 1153 (a, b & d), and 1154 transmitters and include in your discussion the following:
(a)
Manufa cturing process used prior to July 11, 1989; on Ju'.y 11, 1989; and changes from July 11, 1989, thro.gh current manufacturing process; (b)
Sensor cell glassing and assembly; (c)
Transmitter assembly; and (d)
Quality requirements (for nuclear and non-nuclear transmitters.
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3 IV.
General 1.
We understand that in November 1991, Rosemount recalled several hundred 1151 transmitters because of the high test reject rate for nuclear transmitters over a three month period.
What was the root cause for the high reject rate during this period?
2.
For Model 1151, 1152, 1153, and 1154 transmitters, what were the in-house HP Aging 1, HP Aging 2, and Response Time Testing reject rates for the years 1987 through present (6/93)?
1 3.
Explain the low loss of fill-oil failure rates for the Model 1152 transmitters?
4.
We understand that Rosemount supplies transmitters to international nuclear power plants (Canada, Japan, Korea, Taiwan, Europe, etc.).
Have these plants reported failures due to loss of fill-oil?
If yes, is this data compiled?
Does Rosemount rework nuclear transmitters sold internationally?
(a)
In preparing the failure analysis for its loss of fill-oil Part 21, did Rosemount solicit input from the international nuclear community?
If not, why?
(b)
How many Model 1151, 1152, 1153, and 1154 transmitters, manufactured after July 11, 1989, have been sold to international nuclear facilities and how many confirmed or suspected loss of fill-oil failures is Rosemount aware of?
1 5.
How many Model 1151, 1152, 1153, and 1154 transmitters, manufactured after July 11, 1989, supplied to U.S.
nuclear plants has Rosemount confirmed as failing due to oil loss?
6.
How many Model 1151, 1152, 1153, and 1154 transmitters manufactured after July 11, 1989, has Rosemount been informed of by its U.S.
nuclear customers, and which may have failed because of oil loss?
7.
Does Rosemount supply Models 1151, 1152, 1153, and 1154 transmitters to other U.S. government agencies such as the Department of Defense, Department of Energy, etc.?
Have the agencies identified to Rosemount any oil-loss i
problems?
8.
Did Rosemount perform a root cause of failure analysis on a Palo Verde 1152 transmitter (NPRDS RMA 76532d) about June 1988?
Results?
9.
Briefly, provide details associated with a 10 CFR Part 21 notification on May 27, 1993 associated with 1154 Series H
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4 transmitters.
Discuss any impact on loss of oil compensatory actions, such as enhanced monitoring.
- 10. Discuss Rosemount's position on adequacy of white noise testing to detect loss of oil.
What is Rosemount's 4
position on the most effective enhanced monitoring methods?
Least Effective?
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ENCLOSURE 2 ROSEMOUNT TECHNICAL BULLETINS No. 1 - 4 1.
Technical Bulletin (TB) No.1 provided results of tests apparently conducted with only one Range Code 5 transmitter. What is the basis for' extending the results of these tests to all Range Code 5 transmitters?
How many transmitters were used for each of the other range codes?
If only one test transmitter was used, how dependable are the results obtained, particularly those identified in Appendix D to TB 47 2.
The tbs imply that the test results can be used as a guideline to diagnose incipient transmitter failures and to predict the time when degraded performance will begin to occur (TB-4, page A5).
A review of these results show the zero and span shifts to be similar except for their magnitude. To what extent can the similarities and dissimilarities of the test results be attributed to the physical differences among sensors used in different ranges? Why are the results for range code 4 different from range codes 3 and 57 Can these results i
be anomalous?
3.
The Technical Bulletins (e.g., TB-4, page A2) state that the zero shift is amplified by the range down factor. As an example, for a range code 5 transmitter calibrated from 0 to 125 inches of water, the tbs state that the zero shift would be amplified by a factor of 6.
Did Rosemount conduct any tests to verify the accuracy of the statement? Why isn't i
the span shift similarly affected?
4.
Tests indicate that, for all transmitters, the zero shift is negative if i
oil is lost from the high side G the sensor and positive if the loss occurs on the low side. Curves also show that the span shift is I
similarly affected. Would the zero shift be the algebraic sum of the two components, if oil were lost from both sides of the sensor? Were tests conducted to evaluate this possibility? How is detectability affected if the loss of oil on both sides is such that the combined effects cause only small zero and span shifts?
How is calibration affected when a significant amount of oil is lost from either or both sides of the sensor?
5.
Given that zero and span shifts are also affected by conditions other than oil loss, is it possible to take direct measurements of capacitance, rather than measuring transmitter output? Would a measurement of the cell capacitance or of a signal somewhere within the transmitter more accurately identify loss of oil, particularly if oil is lost from both sides of the cell?
6.
TB 3 (page 5) states that temperature affects the viscosity of the fill fluid and, hence, the response time.
Doesn't a change in viscosity also affect sensor capacitance? If so, how are the transmitter zero and span shifts affected? How are measurements affected if the transmitter is located in a warmer environment, as in certain areas of the plant?
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7.
The Bulletins (e.g., TB-3, page 5) state that, because of other influences (temperature, line pressure, etc), an output shift does not conclusively indicate fill fluid loss. What is the approximate magnitude of the zero and span shift due to other influences? How do these impact the detectability of the loss of fill oil? How is detectability impacted if the transmitter calibration is other than the upper range limit? How is the magnitude of normal drifts affected by the range down? How does radiation aging (assume less than 1 MR total integrated dose at low dose rates) affect the output stability of the transmitter (operating point, zero and span. shift) ?
Rosemount Report D8900115, Rev A Leak Rate Model and Risk Assessment 1.
Figure 1 (page 3) shows a graph of failure rates vs months at pressure.
.fow was the data obtained?
2.
The report (page 3) estimates that over 30% of the transmitters service hours are from transmitters that have been in service for over 48 months. Was this estimate verified based on confirmed failures?
3.
The report (page 4) states that there have been 21 failures in-application at or above 2000 psi. These failure were used to test the mathematical model the results of which were reported in the table of page 8.
How accurate is the estimated number (750) of transmitters at above 2000 psi used in generating the table? Was the model tested at lower pressures?
Rosemount Report D8900023, Rev A Description of Process Improvements 1.
The failure breakdown by pressure range (Section II) shows that the percentage of failures for range code 5 (1.3%) is nearly three times that of the closest range code (9) which shows a failure of 0.48%.
Does Rosemount have a technical explanation for this difference?
2.
During the screening test, actual pressures are applied to the sensors and leakers are identified. The report (Section IV) appears to indicate that a small amount of oil can be lost without rejection of the sensor.
If so, what is Rosemount's basis?
How were the lifetime extrapolations made? If Rosemount assumed constant leak rates, what is the basis?
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