ML20054C857
| ML20054C857 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1981 |
| From: | Rutherford W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Agee J, Bennett A, Naidu L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML19250H613 | List: |
| References | |
| FOIA-82-125 NUDOCS 8204220031 | |
| Download: ML20054C857 (7) | |
Text
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MAR 1. 0 1991 MEMODANDUM FOR:
See Distribution FROM:
W. R. Rutherford, Vendor and Special Projects Branch, Division of Resident and Regional Reactor Inspection, IE
SUBJECT:
INDEPENDENT VERIFICATION INSPECTION NUMBER 2, EQUIPMENT SET 1 -
ROSEM0UNT TRANSMITTERS Independent Verification Inspection Number 2 includes two equipment sets; set 1 covers Rosemount 1153 Series D Pressure Transmitters and set 2 covers Foxboro N-E10 Series Pressure Transmitters.
The primary subject of this memorandum is Equipment Set 1 which consists of five different models of Rosemount 1153 Series D Pressure Transmitters.
The Wisconsin Electrical Power Company (WEP) has provided NRC a copy of the Utility Group's Qualification Plan (Wyle No.) 45352-2 dated January 15, 1981 for review and evaluation.
The inspection team identified on the distribution list has reviewed the qualification plan and our comments to the plan are provided in Enclosure 1. is to be used as the agenda for a March 10, 1981 meeting between NRC and the Utilities Technical Review Subgroup.
When adequate resolution of the coments in Enclosure 1 are reached the qualification plan will be accepted by the NRC Equipment Qualification Inspection Team.
IE selected the WEP Utility Group's Transmitter Qualification Program because the equipment is sensitive to a harsh environment, the equipment is intended to be used in safety significant applications and the equipment will, if it passes the 'q::alification test, be used extensively in several safety related systems in many nuclear plants.
W. R..Ru he Vendor and Special Projects Branch Division of Resident and Regional Reactor Inspection Office of Inspection and Enforcement
Enclosure:
As stated l
8204220031 820318 PDR FOIA PHILIPS82-125 PDR
6istribution MAR 101981 DISTRIBUTION:
IVI #2 Inspection Team:
A. B. Bennett, IE J. R. Agee, RIV L. Naidu, RIII D. Mcdonald, LASL K. D. Desai, NRR L. L. Bonzon, Sandia L. Bustard, Sandia Wisconsin Electrical Power -
Utility Transmitter Qualification Group:
R. K. Hanneman, WEP cc/w enclosure:
J. H. Sniezek, IE E. L. Jordan, IE G. W. Reinmuth, Id V. N60 nan, NRR Z. Rosztoczy, NRR T
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ENCLOSURE 1 0
NRC COMMENTS TO THE UTILITY TRANSMITTER OUALIFICATION GROUP'S QUALIFICATION PLAN FOR ROSEMOUNT 1153 SERIES D PRESSURE TRANSMITTERS, WYLE LABORATORIES DOCUMENT 45352-2 DATED JANUARY 15, 1981 A.
Coments relevant to the qualification plan defined in the title document mentioned above.
l.
Under Section 1.1 replace the word " intent" with " requirements."
If there are any known deviations from IEEE 323-1974 they should be identified.
2.
Under Section 1.3 clarify the statement relative to qualifying the five units tested and reported in Rosemount Report 10B051.by similarity.
If models other than those identified are to be qualified by the test plan under review they should be identified.
3.
Maintenance requirements are implied, but not definitively stated in c
the test plan.
For example (Section 1.3.1), stability is listed as
+0.25% of upper range limit for 6 months.
Does this imply a 5 month maintenance requirement?
4.
Will the ethylene propylene rubber (EPR) cover 0-Rings (Section 1.3.3) used in the transmitter assembly be exposed to beta radiation? Will non-metallic parts of the Conax Electrical Seal Assembly (Section 3.2.1.2) be exposed to beta radiation? A description of this exposure should be included in the test plan.
5.
Justification for the test sequence (Section 1.4) is not provided.
The discussion of synergistic effects (Section 1.4) during aging is inadequate.
Justification for the aging radiation dose rate (Section 3.2.1.1) is not given.
6.
The normal conditions (Section 2.1.1) ignore electrical, vibration, and mechanical stresses.
7.
The qualification report is inconsistent concerning nonnal operating conditions.
Section 2.1.1 indicates a maximum normal service temperature of 122 F while Section 3.3.3 mentions 120 F.
Also, Eq. 29 (Section 3.3.3) identifies the worst-case normal service temperature as 37.8 C (100 F).
8.
Verify that the accident radiation dose is adequate to cover all plants that will be using this equipment qualification.
T Beach plant SAR indicates an accident radiation dose of 10ge Point rads total integrated dose.
1
9.
The test plan repeatedly allows adjustrer.t of the transmitter zere "when the maximum transmitter error exceed +5% of the calibrated span after transporting from one test location to another." This might result in a loss of information concerning gradual degradation of the transmitter during the implementation of the qualification test.
The acceptance criteria (Section 2.2.2) are unclear.
Does the plan allow the transmitter to have an error tolerance of +5% during transportation, an additional +5% tolerance during radiation exposure, etc.? The test sequence of paragraph 1.4 lists two thermal aging exposures.
Is the +5% tolerance pennitted for both exposures, or only for the combined exposure? How are errors from a sequential test sequence combined to predict the error during a simultaneous exposure?
NRC's comment regarding allowable adjustments during the test is as follows:
1 The only allowable adjustments are those that result from transportation.
Adjustments are allowed if the test aging sequence is such that adjustments made after aging can be repeated through periodic adjustment during a plant maintenance program.
The test sequence under review combines the aging and the accident radiation dose and therefore does not permit readjustment of the instrument to zero following exposure to the accident dose.
Adjustments that return the transmitter error to its value prior to transportation are allowed.
10.
The acceptance criteria (Section 2.2.2) does not mention many implied acceptance tests during the test program.
For example, Section 3.4 l
states:
"The electronic components shall be functionally tested prior to an after thermal aging (of the components) to determine if the results are acceptable to the system requirement." What happens if unacceptable performance is encountered at this stage of aging?
Similarly, some resistors and potentiometers (Section 3.4.1) will be aged at 175*C, others at 150*C.
This "will ensure that an aged component shall be available if aging at the higher temperature,175 C, introduces atypical failure mechanisms in the subject equipment."
The criteria to define " atypical failure mechanisms" is never provided.
More iraportantly, the impact that such a failure would have on the remainder of the qualification test program and its conclusions is never mentioned.
Also, pressure testing (Sections 3.1.2.1 and 3.3.1.3.7 is performed as part of the test plan but acceptance criteria are never )
provided.
J
- 11. The acceptance criteria are not firmly established prior to the test.
i' Repeatedly, the test plan makes vague statements.
For example (Section 3.1.2.1), "Any leakage of the seals of the transmitters shall be evaluated by the lead customer in consultation with the equipment supplier and customers."
Leakage acceptance criteria should be included in the test plan.
f
- 12. The discussion of capacitor aging (Section 3.4.2) is not convincing.
The correct aging program would be based on the following equation:
(total ' degradation) 40 yrs. equiv. 4 (v ltage st "ss) 40 yrs. equiv.
4
+ (thermal stress) 40 yrs. equiv. + (synergistic effects) 40-yrs. equiv.
However, the test plan assumes:
(total degradation) 40 yrs. equiv. = (therinal stress) 10 yrs. equiv.
+ (voltage stress) 4.6 yrs. equiv. + (thermal-stress) 1 yr. equiv.
(The voltage stress and 1 yr. equiv. thermal stress were simu?taneous)
There is no foundation for this assumption.
- 13. The description (Sections 3.2.2 and 3.5.5.1.1.1) of the test fixtures does not provide sufficient information concerning the test fixtures i
to allow an auditable link between the test setup and the installation procedures.
A description is not given for the Raychem splices, the Conax Electrical Seal Assemblies, and the cable used during the test.
All interface materials and components included in the assembly should be described and included in the material / component list.
14.
The use of thennoccuples connected in parallel to monitor test chamber temperature does not provide a method to measure test chamber temperature uniformity.
If superheat conditions are present, non-uniformities may be present.
A sketch of the thermocouple locations should be provided in the test plan.
- 15. The test plan (Section 3.3.4) does not indicate how it will demonstrate "the ability of the pressure transmitters to perform within their relative humidity environment."
16.
Is the silicone oil fill fluid used in the sensing diaphragm the diffusion pump fluid (Section 3.4.4) mentioned in Table IV?
If not, radiation and thennal. aging of silicone oil needs to be considered in the test program.
17.
The sealant, item 2.3.1 on Table IV is shown to have an activation energy of 0.72 ev.
How will this material be justified relative to the qualification of the assembly?
B.
Comments relevant to specific plant applications of the qualification plan.
Each licensee using the qualification plan will be required to respond to the following concerns unless the concerns are covered by a generic response.
1.
The maximum gamma dose rate (Section 3.2.1.1) of 1.5 x 106 rads / hour may be too low for some nuclear applications.
Appendix D of NUREG-0588 provides a sample calculation yielding an initial dose rate of 4.9 x 106 rad / hour.
Some nuclear power plants using Rosemount transmitters may experience larger dose rates than provided for in this test plan.
2.
The choice of radiation levels (Section 2.1.2.2) for qualification is unusual.
The ratio of the allowable beta radiation to the allowable gamma radiation is a factor of twenty.
Appendix D of NUREG-0588 provides estmates much lower than this.
3.
The test program does not identify margins used during the development of the test plan.
Rather, it states (Section 2.1):
Adequate margins have been included in the lead customer's specifications to account for normal variations in comercial production of equipment and variations in service conditions.
Therefore, the levels herein specified shall be the qualification levels and ne further conservatisms shall be applied.
4.
The test plan ignores the effect of beta radiation on the operation of the transmitter.
Justification for this approach is to be provided.
5.
If the interfaces in the actual plant differ from the interfaces described in this qualification plan the licensee must provic'c justification.
6.
Extreme care must be used in comparing the acceptance criteria of i
this test plan to system requirements for a nuclear application.
The test plan does not indicate how errors during a sequential test are to be combined to predict the error during a simultaneous exposure.
Monitoring of accumulated error under simultaneous exposure in the plant may be required to support the qualification.
D.
Members of the Utility Transmitter Qualification Group are requested to discuss the following items:
1.
Results of the Phase I transmitter tests.
2.
The maximum dose rate applied during the test (Section 3.2.1.1) and thetotaldose(Section2.1.2.2)havebeenchanged.
Phase I testing included an initial two hour exposure at 3 x 10 rads per hour.
Phase II testing will use an initial two hour exposure of 1.5 x 106 rads per of 4 x 10 pour.
Also, Phase I testing was for a total integrated dose rads gamma (air equivale t) while Phase II is for a total (air equivalent) exposure of 5 x 10 rads gamma.
3.
Phase I qualification included superheat application during the LOCA/HELB simulation.
The Phase II test plan does not mention the pressures to be used during the LOCA/HELB simulation.
It is not clear if superheat conditions will be applied.
'4.
Provide the names of those nuclear plants where the Rosemount Transmitters (models covered by the qualification plan) will be installed.
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