ML15146A022

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Qualtech Np - Potential 1O CFR Part 21 Notification on Struthers Dunn Relays
ML15146A022
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 05/07/2015
From: Franchuk T
Curtiss-Wright Corp, Qualtech NP
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15146A022 (31)


Text

QualTech NP CURTISS - Nuclear Division 4600 East Tech Dr. - Cincinnati, OH 45245 WRIGHT Phone: 513.528.7900 - Fax: 513.528.9292 www. quaftechnp.cwfc.corn May 7, 2014 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Potential 10CFR Part 21 Notification on Struthers Dunn Relays

Dear Sir or Madam:

This letter provides notification of a potential 10CFR Part 21 with Struthers -Dunn relays as described in the attached report. QualTech, NP offers recommendations to the industry within the body of the report. We have notified our customers that this 10CRF21 report will be issued.

If you have any questions or wish to discuss this further, please call me at 513-528-7900 x 2176 Respectfully, Tim rnh46 Director of Quality Assurance 4600 East Tech Drive, Cincinnati Ohio 45245 Phone: 513.528.7900 x 2176 Fax: 513.528.9292

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Investigation for Potential Part 21 for Struthers Dunn Relays

Subject:

PSEG reported failures for Struthers Dunn 219BBX200 relays related to greater than 1 ohm contact resistance. Two relays were evaluated by Exelon Power Labs. Of these, one had a failure consisting of a contact resistance greater than one ohm. Struthers Dunn has also provided an evaluation in this regard and does not agree with the failure mode as inferred in the Exelon Power Labs report.

Lab and OEM report key difference:

The Power Labs' Report(s) shows fiberglass fiber(s) embedded into gold plated contacts on one relay believed to result in a contact resistance greater than one Ohm (1.7 Ohm Max). The second relay, from stock, had evidence of fiberglass present but was not considered to have affected functionality.

The Struthers Dunn evaluation suggests that the fiber embedded on the gold contact is not at the mating point of the contacts and should not impact operability. Struthers Dunn also indicates that the relay's application is operating below their minimum current.

Discussion:

The actuator board on the evaluated relays is manufactured from a printed circuit board (PCB) type fiber board. The fibers from the edges of the board could become airborne. The attached design drawing and Struthers Dunn letter indicates that this specific board material was utilized beginning in March 2010.

Since there have been no prior reports of this issue, it is possible that the 2010 material change introduced a foreign materials exclusion (FME) concern. Since then, and solely for those relays manufactured in the USA, the material changed again in November 2014 and was incorporated into the products starting January 2015. The newest version of the actuator board is a molded material that does not contain fiberglass fibers.

Struthers Dunn relays with base part numbers 219, 236, 237, and 255 have the common PCB type fiber board. This fiber board (per the attached Struthers Dunn drawing) was used in relays with date code 1009 through 1452 with or without letter suffix (where the letter indicates made outside of the USA).

Page 1 of 30 Mav 7. 2015 Panel of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays 2010-2014 material USA Manufactured Material starting 2015 Fiberglass Fiber shown in the box ULTEM 2300 material Page 2 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Customer Input:

1 st 219 series relay failed due to contact issue, considered a random failure & discarded.

2nd 219 series relay failed due to contact resistance & sent to Exelon Power Labs Five parts from inventory bench tested. One had high resistance & it was sent to Power Labs Note: All parts provided were 100% functionally tested for contact resistance during dedication process and passed testing at QTNP.

Exelon Power Labs reports on the tested parts are attached herein.

Vendor Input:

Struthers Dunn has, since 2010, experienced only one field complaint (PSE&G) on continuity issues related to fiberglass on these 219 relays. The material change to ULTEM 2300 was considered an ongoing quality/process improvement process to reduce potential defects proactively. Over the four years using this PCB type material, 13,000 relays were sold.

Struthers Dunn has also questioned the application having current below the manufacturer's recommended value of 5OmA, requiring bifurcated contacts. Please see their attached report and current product catalog for details.

Recommendation:

The root cause of the failure is inconclusive. Exelon Power Labs said "The irregular contact surface patterns in conjunction with the presence of the embedded fiberglass fibers are the most likely cause of the excessive resistance. This finding is considered to be a manufacturing defect." While the manufacturer sees the failure as a misapplication of its product and that the fiber "was not located at the

'mating point' of the 2 contacts so therefore has no effect on the performance of the contacts or relay".

QualTech NP recommends an application review for the named relays. A review of the Exelon Power Labs reports and the vendor's report should also be completed by the utility to evaluate the impact on the safety function.

routne Date Tim Franchuk Date General Manager Director of Quality Assurance / Safety QualTech NP, Nuclear Division Curtiss-Wright Corporation Paize 3 of 30 May 7. 2015 Pane 3 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays I

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Investigation for Potential Part 21 for Struthers Dunn Relays Material Change Struthers-Dunn is committed to ensure quality products through its continuous improvement efforts. Therefore the following products have undergone changes to two parts currently used in the following relay series: 219, 236, 237 and 255.

The material change will take affect for all the mentioned relay series that are made in the USA starting January I' 2015.

A environmental analysis qualification has been done by an accredited company in compliance with I OCFR Part 21, 10 CFR Part 50 Appendix B,ASME NAQA-I, ANSI/ASME N45.2-1977 and IEEE Std. 323-1974.

Manager Struthers-Dunn, LLC e 407 E. Smith Street, Suite B e Timmonsville, SC 29161

  • Phone: (843)346-4427 Fax: (843)346-4460 Page 5 of 30 May 7. 2015 Pa~eS of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays STRUTH ERS-DUNN1 407B E Smith Street, Timmonsville, SC 29161 Phone: 843-346-4427 Fax: 843-346-4465 Date: April 30, 2015 To: Curtis Wright

Subject:

Root Cause Analysis of a 219 Series Relay Referenced Documents: Exelon PowerLabs PSE-83022, PSE-72352; S-D Relay Type 219BBXP200 Date code: 1233 To Whom It May Concern, After further review of the Exelon PowerLabs report, PSE-83022 and PSE-72352, Struthers-Dunn feels it is necessary to clarify any concerns with current and future customers.

Struthers-Dunn can make the following systematic conclusions of the failure analysis by Exelon PowerLabs' mentioned reports regarding the failure of a 219 series relay:

Although the situation addressed in this report was the fiber on the contact, Struthers-Dunn cannot agree with the failure mode due to the fact that Struthers-Dunn wasn't able to verify the relay had all the required adjustments (contact pressure, over-travel, etc.) after the incident happened. This is also the first time Struthers-Dunn was notified by any customer of a failed 219 relay with a claimed failure due to fiberglass on the contacts.

The exact root cause in this report points to the fiber being embedded in the contact. However, without knowing whether this fiber being embedded happened while being manufactured or was introduced while the relay was in operation, we cannot give an exact root cause. Although a fiberglass fiber was found on the contact it was not located at the "mating point" of the 2 contacts so therefore has had no effect on the performance of the contacts or relay.

Pa~e 6 of 30 May 7. 2015 Page 6of30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Struthers-Dunn believes this fiber could be from the previous actuator card material. Due to our continuous process improvement done to the 219/236/237/255 production line from 2012 to 2014, we added a new ionized air gun to clean the relays and neutralize any static charge, which can attract dust and particles that could possibly adhere to the relay blades and contacts. The last step of our improvement efforts was the elimination of any potential source contamination inside the relay which resulted in producing the actuator card with a different material.

The actuator card had been previously constructed from a fiberglass composite material (between March 2010 and December 2014). But now we have switched to a new and better material, ULTEM 2300. On the previous material the actuator card was stamped out of a fiberglass sheet. Where the current actuator card is being injection molded and does not have any edges that could have potential fibers breaking off. In order to keep our nuclear grade rating of this relay family series we contracted Curtiss-Wright to do an environmental analysis qualification in compliance with 10 CFR Part 50 Appendix B, ASME NAQA-1, ANSI/ASME N45.2-1977 and IEEE Std. 323-1974. As of January 1St 2015 all U.S.

manufactured 219 family relays are manufactured with the upgraded actuator card.

Furthermore, the PSEG application described in which the 219 relay was used had a load between 16 to 20mA @ 125VDC. This indicates the current being switched is below our specified minimum of 5OmA for non-bifurcated contacts. Struthers-Dunn advises any customer to use bifurcated contacts to switch any current below the mentioned 50mA level. At this time Struthers-Dunn is testing to find out the exact minimum load level for bifurcated contacts, however it would certainly handle PSEG's stated load of 16 to 20mA @ 125VDC. Our current estimation is 10mA@48VDC but we will not publish that information until the testing confirms our findings.

In conclusion, Struthers-Dunn cannot pinpoint the exact mode of failure of this relay, due to the fact that there were various fundamental errors in the application by the customer and in the failure analysis by PowerLabs.

Dan el Heider ore David Mioduski ngineering Manager President Product Marketing Manager Page 7 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays 219 Series - Industrial DPDT, up to 6PST, 10 Versatile. Rugged. Proven. These are but a few words used by customers to describe the 219 series.

Fie No. E13224 When long life and cost of down time / service are important the 219 solves the problem. It's a standard throughout industrial applications which many other relays are measured against. Capable of up to four poles double throw or six poles single throw. Contact arrangements are easily customized for special applications. NUCLEAR versions are available that utilize special platings and materials to minimize wear. All 219s are built with materials that meet the UL 94-VO requirements.

GENERAL SPECIFICATIONS (@ 25° C)

COMM:

Contact Configuration Up to 4PDT or 6PST Contact Material SilverAIIoy-Gold Diffused Contact Rating 120 / 240VAC Resistive 10Amp/5Amp 28VDC Resistive 10Amp Contact Resistance, Initial 50 mllliohms max @ 6vdc Coil, Coils Available AC and DC Menud uaorw Nominal Coil Power AC 5VA DC 1.8-2.5W Input Voltage Tolerance -AC 85% to 110% of nominal Input Voltage Tolerance - DC 80% to 110% of nominal Drop-out voltge 10% of nominal Duty Continuous 7T1W Operate Time (max) 25 mS Release Time (max) 20 mS Across Open Contacts 50OVrms Between mutually insulated point 1500Vrms Insulation resistance 1,000 Mohms min @ 500VDC T111"periOtDm Operating AC = -20 to 60°C (-4 to 140°F)

DC = -20 to 701C (-4 to 158°F)

Storage -40 to 105°C (-40 to 221°F)

LW.e Expecarmwy:

Electrical (full load) 100,000 Mechanical (no load) 10,000,000 Mounting Position Arty Enclosure Clear Potycarbonate Weight 8.5oz (241 grams)

Matned Mating socketwhen used) 12 PIN: 27390 (D) 14 PIN: 33377 (D)

(D) Is option for DIN Rail Mount wwwstruthers-dunn.com (843) 34*-4427 Palze 8 of 30 Mav 7. 2015

Investigation for Potential Part 21 for UL Contact Load Ratings Table Contact nl ,l Current Load Load Frequency nM.- Type of Load 219 10 Amp 120 VAC W5e"G0 RESISTIVE IAImp 240 VAC WeY001z RESISTIVE ConMctArrangement 10 Amp 0.5Amp 28VDC DC RESISTIVE XBX (DPDT) AllSty4e 125 VDC DC RESISTIVE ABA (1 Pole N.O. + DPDT + 1 Pole N.C.) EXCEPT I

Cd 3 I3Amp I lAmp 120 VAC 240 VAC 50I6, - I 5I'6OIz INDUCTIVE INDUCTIVE BBX (2 Pole NO & DPDT)

XDX (4PDT) 3 Amp 28 VDC DC INDUCTIVE FXX (6 Pole-NO) I 1I0.1 Amp I 125VDC I DC I INDUCTIVE DXB (4 Pole - NO & 2 Pole-NC)

OptonalFeatures Permanent Magnet Blowout - CODE 69 Use Code "69" for blowout magnet when switching Polycarbonate covers - CODE P voltages above 4OVDC. (NOT UL OR CSA APPROVED)

Indicator Lamp - CODE L Manual Actuator - CODE M Bifurcated Contacts - CODE 33 Contact Load Load Frequency Configuration Voltage Voltage Type of Load Coil Voltage Single Make 1.5 Amnp i2VDC DC RESISTIVE AC: 1Z 24,120, 240, (Add VAC) Double Make 4 AMP 1VDC DC RESISTIVE DC: 6,12, 24/28, 32, 48,115/125, 250 (Add VDC)

Single Make 0.5 Amp -25VDC DC RESISTIVE Coil voltages and frequencies must be specified DoubleMae 1.5 Amp 2WOVDC DC RESISTIVE Single Make 0.5 Amp 12VDC DC INDUCTIVE DoubleMake 1.5Amp 1VDC DC INDUCTIVE SingleMake 150 mA 2WIVDC DC INDUCTIVE DoublMice 0.6 Amp 20VDC; DC INDUCTIVE Use Code "33" for bifurcated contacts when switching low level current below 5OmA.

219 Coil Specifications AC Coils, 50MHZ DC Coils Nominal Resistance Milliamperes Impedance Nominal Resistance Milliamperes voltage ohms Cold Hot ohms voltage ohms Cold Hot

.10%

I10%

6 1.1 1500 840 7.2 6 15.5 385 304 12 4.2 750 410 27 12 6.S 189 147 24 15.5 375 200 120 24/28* 250 96 77 120 540 75 40 Z700 32 375 88 62 240 2100 32 17 13,400 37.5 375 100 80 48 975 49 39 115/125o 6200 20 16 250 27777 9 7 Note: Stock 24VDC and 115VAC relays have nameplates stamped 24/28VDC and 115/1125VAC respectively These relays operate at 80% of the lovwer voltages and operate within allowable temperature rises at higher voltages.

www.struthers-dunn.com (843) 346-4427 A

Pa~e 9 of 30 Mav 7. 2015 Pane 9 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays 219 Series - Inlustrii DPDT, Up To 6PST, '

Outline Dimenmlons DimmerWonsShown in Incht & (mill stmet) 12 Pin Plug-In 14 Pin Plug-in Optional mamal aduetor 025 OptIonal ma*ual actuator 025 2.52 (63) 3D1 (63)

(.4) 2M5 (657) 268 g I I LOckkV dip !)

4 -I 1,4S (38.8) 1.45

.10 x .43 (2.5 x/<) DIA. TWIolc T / 7 of ld pin dimeuons .10 x .43 (2S5 x11.0) DIA. Tplcd of m pin dmwmlions A www.struthers-dunn.com 1343) 346-4427 Paae 10 of 30 Mav 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relavs 219 Wire Diagram (Top View) 12-Pin 219ABX 219ABA 2I9BBX 219BXB (SPST.N.O. + DPDT) (DPDT4P-NO+IP-NC) (DPDTfr2P- N.O.) (DPDT+2P- N.O.)

65 4 3 2 1]

6 54 3 21 6 5 43 21 7 8 9 1011 12 78 9 101112 7 0!1 72 8 9 101112 Many additional contact combinations and 219XBX 219XCX wiring schematics are available. Contact sales with requirements.

(DPDT) (3PDT) 654321 Standard Diode Suppression Wiring 0 _ (applies to relays with option V". alternative polarityMring is also available as a special) 10111 7 8 9 10 11 12 (12-Pin)

+ -M- 7-219 Wire Diagram (14-Pin)

(Top View) 14-Pin +7 -4w 219BXD 219CXC 219DXB 219EXA (2P-NO04P-NC) (3P-NO03P-NC) (4P-NO42P-NC) (5P-N04IP-NC) 87654321 '76 5 4 3 2 1 7 6 5 4 3 2 1' 76 5 4 3 2 1

$ 9 1112 13 14

ý1* 11 tl4 lf 89 1011121314 219FXX 219KXX 219XDX 219XJX (OP-NO) (3PST4)NQ (4PDT) (DPDT-DIWDB) 7 6 5 4 3 2 1543 765 4 3 2 1* 76543 2 1 S,9 l,°1f 114i

`

UL LISTED whien used with mating sockets 27390 for 12 pin or 33377 for 14 pin www.struthers-dunn.com (843) 346-4427 A

Paize 11 of 30 May 7. 2015 Pa2e 11 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Exelon Power Lab Report PSE-72352 (20 pages)

Page 12 of 30 May 7. 2015 Pane 12 of 30 MaY 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays

" Exelon Generation, Exelon PowerLabs To: Bryan Olmuert, (85) 339-2949, PSEG-Nuclear From: Lance Walls, 610-380-2309 lance.walls(§exelonpowerlabs.com Project: PSE-72352

Subject:

Failure Analysis of a Relay Manufacturer: Struthers Dunn Model: 219BBX200 Stock Code/Cat ID: X400405 Purchase Order No.: 4500850488-0 Quantity Received: I Qualtech Tag#: CJ358602-05 Date: 19 March 2015 STATION DESCRIPTION OF PROBLEM The relay had been installed in service for 6 months at the time of the failure. The failure mode was a consistently excessive (> I ohm) and erratic resistance on contact set 8-9. The expected resistance was < 1 ohm.

CONCLUSIONS The station observation of excessive resistance on the 8-9 contact was verified and duplicated via the testing performed at PowerLabs.

The relay was received free of any thermal, mechanical, or electrical damage, and the only deficiency identified during the functional testing was that of the excessive contact of the 8-9 contact. The 8 and 9 contacts were harvested from the relay for further examination. Both contact surfaces exhibited striation patterns that resembled scratch marks. The marks on the contact 9 surface being more widespread and conspicuous than that of the contact 8 surface.

SEM/EDS Analysis of both contacts revealed the presence of Gold, Copper, and Nickel, with the Nickel being of unknown origin. The 8 contact had the presence of the striation patterns, which are not thought to be due to normal wear through make/break operations and wiping action. The 9 contact surface was comprised of Gold and Copper and also had the striation patterns, but additionally had the presence of several fiberglass strands that were embedded into the contact surface, as opposed to being surface contamination. The fact that they were embedded suggests that they were present during the surface plating process during manufacturing. There were other cavities on the contact surface that were similar in appearance, which increases the likelihood that there were other fibers present at one time, but became disassociated via contact make/break operations. The irregular contact surface patterns in conjunction with the presence of the embedded fiberglass fibers are the most likely cause of the excessive resistance. This finding is considered to be a manufacturing defect.

The Exelon PowerLabs Quality System meets 10CFR50 Appendix B, NQA-I (1994), ANSI N45.2, ANSI/NCSL Z540-1 and IOCFR21/10CFR50.55 (e). Exelon PowerLabs is ISO 9001:2008 Registered and ISO/EC 17025 Accredited.

175 N. Cain Road Coatesville, PA Page 1 of 10 Pa~e 13 of 30 May 7. 2015 Pane 13 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays COMMENTS AND RECOMMENDATIONS No additional comments or recommendations.

REQUIREMENTS If it is determined that a high resistance condition exists, determine the cause of the failure.

TEST PLAN

1. Document Nameplate Data
2. As Received Condition
3. Functional Testing
4. Disassembly / Analysis
5. Material Analysis (if necessary)
6. Discovery STATEMENT OF QUALITY Testing was performed with standard equipment that have accuracies traceable to nationally recognized standards, or to physical constants, by qualified personnel, and in accordance with the Exelon PowerLabs Quality Assurance Program.

Technician(s): Lance Walls Prepared by: Lance T. Walls 18 March 2015 Sr. Engineer Date Reviewed by: Joseph P. Mulcahy 18 March 2015 ANSI Level 11I Date Approved by: Lance T. Walls 19March 2015 Sr. Engineer Date Projectreview and approval are electronicallyauthenticatedin the Exelon PowerLabsprojectrecord.

Exelon PowerLabs, LLC - TECH SERVICES Project Number. PSE-72352 175 N. Cain Road Coatesville, PA Page 2 of 10 Paee 14 of 30 May 7. 2015 Pane 14 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays I OBSERVATIONS AND DATA 1.) Document Nameplate Data Photograph 1: Nameplate Data I Manufacturer: Struthers-Dunn Model#: 219BBX200 Coil Voltage: 24 - 28 VDC Contact Rating: 120 VAC, 10 A N.C. Contacts: 1-2 and 11-12 N.O. Contacts: 2-3, 4-5, 8-9, and 10-11 Date Code: 1233 (Not shown in photo)

Photograph 2: Nameplate Data H QualTech NP Tag#: CJ358602 QualTech NP S/N: 05 PSEG PO#: 4500790578 Exelon PowerLabs, LLC - TECH SERVICES Project Number PSE-72352 175 N. Cain Road Coatesville, PA Page 3 of 10 Pane 15 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays 2.) As Received Condition Photograph 3: As Received Condition

  • There was no outward indication of any thermal, mechanical, or electrical damage.

" All soldered connections on the pins and contact block were microscopically examined and were verified as being acceptable.

" There was no indication of any arcing on any of the pins. There were only expected wear marks present that were associated with routine insertion / desertion operations.

  • Manual manipulation of the assembly yielded no indication of the presence of free-moving or loose internal components or foreign material.
  • There was no indication of coil outgassing on the internal surface of the case.
  • There were no fmdings or observations that prohibit energized testing.

Intentionally Blank Exelon PowerLabs, LLC - TECH SERVICES Project Number PSE-72352 175 N. Cain Road Coatesville, PA Page 4 of 10 Page 16 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays 3.) Functional Testing Pre-Energization Tests (As-Received)

Measured Measurement Comment Parameter Coil Resistance 254.4.2 (Cold) Reasonable per OEM spec. of 1.8 - 2.5 W N.C. 1-2 16.3 mfl Acceptable N.O. 2-3 > 500 MU Expected in de-energized state N.O. 4-5 > 500 MQ2 Expected in de-energized state N.O. 8-9 > 500 MQ Expected in de-energized state N.O. 10-11 > 500 M_2 Expected in de-energized state N.C. 11-12 9.6 m!l Acceptable All of the static measurements in the de-energized state were acceptable or expected.

Energized Testing Coil Characteristics Measured Measurement Comment Parameter Pickup Voltage 13.3 VDC (Cold) Less than OEM-specified 80%

Current at Pickup 54 mA DC Not specified by OEM. For information only Sealed Current @ 24 94 mA DC Not specified by OEM. For information only VDC Sealed Current @ 28 107 mA DC Not specified by OEM. For information only VDC Coil Watts @ 24 2.26 Slightly greater than OEM-specified 1.8 W VDC Coil Watts @ 3.00 Slightly greater than OEM-specified 3.0 W 28VDC Dropout Voltage 6.1 VDC Greater than OEM-Specified 10% of nominal The only reading that exceeded the OEM specification was that of dropout voltage.

Contact Resistance Measured Measurement Comment Parameter N.C. 1-2 > 500 ML2 Expected in energized state N.O. 2-3 9.4 mQ2 Acceptable N.O. 4-5 9.5 m52 Acceptable N.O. 8-9 230 mn - 1.7 5 The station observation of excessive contact resistance was verified N.O. 10-11 12.3 rnf Acceptable N.C. 11-12 > 500 MU2 Expected in energized state The station observation of excessive contact resistance with N.O. set 8-9 was duplicated, although the excessive resistance was not radically excessive.

Exelon PowerLabs, LLC - TECH SERVICES Project Number: PSE-72352 175 N. Cain Road Coatesville, PA Page 5 of 10 Page 17 of 30 May 7. 2015 Pane 17 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Pickup Time Pickup Thmes (3 iterations) I Comment 19.6 ms, 19.3 ms, and 20.0 ms Less than OEM specified 25 ms Release Time Release Times (3 Iterations) I Comment 10.1 ms, 10.1 ms, and 9.9 ms Less than OEM specified 20 ms There was no indication of binding or sluggish armature movement with either the pickup or dropout movements.

The only anomalous observation / test result gleaned through both the de-energized and energized testing was that of the excessive and erratic closed contact resistance measurement associated with normally open contact 8-9.

The focus of the balance of the analysis was placed upon N.O. contact 8-9.

4.) Disasembly / Analysis Photograph 4:8-9 Contact Connection The arrow in this photograph points to the closed 9-9 contact set. They were viewed via stereomicroscope ad there was clear surface - surface engagement in the approximate center areas, with no air gapping observed.

Contact 8 Exelon PowerLabs, LLC - TECH SERVICES Project Number. PSE-72352 175 N. Cain Road Coatesville, PA Page 6 of 10 PaRe 18 of 30 May 7. 2015 Page 18 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Photograph 5: Contact 81 The surface of the 8 contact exhibited pronounced striations in the approximate center of the area. They had the appearance of multiple scratch marks in close proximity and in parallel orientation to one another.

Contact 9 The surface of the 99 contact also had contact also the striation had the striation 4 A closer view of the boxed area of photograph 7.

A closer view of the boxed area of photograph 7.

marks that were observed with contact 8, although they were widespread and severe in nature. They appeared to be random and numerous scratch marks.

The striation / scratch marks observed with both the 8 and 9 contact surfaces are not a normal or expected observation with contacts that have not been mechanically burnished. Mechanically burnishing will produce scratched surface marks due to the inherent cleaning process, however it is not believed that either of these contacts were burnished.

Exelon PowerLabs, LLC - TECH SERVICES Project Number: PSE-72352 175 N. Cain Road Coatesville, PA Page 7 of 10 Paue 19 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays 5.) Material Analysis Both contacts were examined with high magnification and for elemental constitution via SEM / EDS analysis (Scanning Electron Microscope / Energy Dispersive x-ray Spectroscopy).

Contact 8 Photograph 10: Contact 8 Surface - Center A

20K-2OK IRK -

f_Nil ý. 1 Cu L 3. 'I 5 10 15'W 3 10 IS kev CwýoISS9Akýl 21cnt[DmBiI0 2Thlb2 IDPahW Sr CUUN-16jO-1kev 22ctLL Po b2 Vo0=3330 Windoe0005- 40955= 16.4.772-em Val! IM01 11*iuo0.005-40.955149)210 eM Elt. Line Intensity Conc Elt. Line Intensity Cone Ni Ka 5.21 0.877 wL% Ni Ka 6.37 1.055 wt.%

Cu Ka 2.98 0.619 wt.% Cu Ka 4.77 0.976 wt.%

Au La 65.36 98.503 wL% Au La 66.01 97.969 wt.%

Au La Photograph 10 exhibits the striation patterns that were present on the contact 8 surface. Again, these patterns are not a typical wear pattern observed relay contact make/break or wipe operations. Gold was primary elemental constituent in both snapshots, with similar concentrations of Nickel and Copper in both.

Contact 9 Exelon PowerLabs, LLC - TECH SERVICES Project Number. PSE-72352 175 N. Cain Road Coatesville, PA Page 8 of 10 Page 20 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Photograph 11: Contact 9 Surface The contact 9 surface had the striation patterns present both in the contact center area and away from the center area. Gold was the primary constituent, and the presence of Copper was also detected. No Nickel was detected. The boxed area will be better explained in photographs 12 and 13.

Elt. Line Intensity Conc Units Cats Cu Ka 2.42 0.573 wt.%

Au La 58.07 99.427 wt.% 2 2.0K -

1.OK-CC.Mi SCa Au CII CCUM 5 Clurý A A All 10 15 key Cumor--1535SkeV 25 cut ID =Pa1b6 RabW Vefl3000( Wmd~nwvOflfr-40IS5- 118W6cnit Intentionally Blank Exelon PowerLabs, LLC - TECH SERVICES Project Number: PSE-72352 175 N. Cain Road Coatesville, PA Page 9 of 10 Paee 21 of 30 May 7. 2015 Pane 21 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Mi'nOw rS ni is: %-OniA"iY- A Fox. Center Stýccmi7 Jubs 2 Ots 10K -

10K-500O-Au j

ýC-'

~Cu~

-U I C" I Cu A LKL

  • : -- , , , , , , J Au Au Uursor4.435 kcV 15 cul ID r WbAin ia2 C~urw-12'415 kV 7 cn T) - Os le- 71 W, VentI330 Wnmto 0.005 - 40.955- 36.650 cut Elt. Line Intensity Conc The embedded fibers shown in this photograph Cu Ka 2.17 0.508 wt.% were primarily made up of Silicon, Aluminum, Au La 58.66 99.492 wt.% and Calcium. This is consistent with Fiberglass.

The embedded fibers in the contact surface, which are exhibited in photographs 12 and13 had an elemental composition consistent with Fiberglass. The fact that they are embedded into the surface of the contact suggests that they were present at the time of manufacture when the surface was coated. The presence of other similar cavities into the contact surface may suggest that there were other fiberglass fibers present at one time, but that they became disassociated due to contact make I break operations. The irregular patterns in the contact surfaces and the presence of the fiberglass fibers in the approximate center of contact 9 are the most likely cause of the excessive resistance.

6.) Discovery There were no additional items of discovery.

Exelon PowerLabs, LLC - TECH SERVICES Project Number: PSE-72352 175 N. Cain Road Coatesville, PA Page 10 of 10 Paee 22 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Exelon Power Lab Report PSE-830222 (7 pages)

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Investigation for Potential Part 21 for Struthers Dunn Relays a ExeLonGeneration, Exelon PowerLabs To: Joseph Thompson, (856) 339-1177, PSEG Nuclear From: Michael Minicozzi, 610-380-2427 Michae.Minicozzi@exelonpowerlabs.com Project: PSE-83022

Subject:

Scanning Electron Microscope Examination of Relay Contacts Manufacturer: Struthers-Dunn Model: 219BBX200 Purchase Order No.: 4500850488-1 Quantity Received: 2 Date: 4/15/15 DESCRIPTION Highly Magnified Examination of All Contacts in an Effort to Determine if Foreign Material and / or Manufacturing Defects Exist Site Information:

Due to the issues identified under notification 20682668, all of the existing stock associated with X400405 Struthers Dunn relay purchased from Qualtech as part number 219BBX200 has been placed in blocked stock.

To provide an adequate replacement relay for the failed relay in 21CFCU, 2 of the 5 relays purchased under PO 4500850435 have been sent to power labs to assure the sample and by extrapolation the entire batch is free from FM concerns.

CONCLUSIONS All contacts from both relays were harvested and examined under the Scanning Electron Microscope.

Relay I displayed one contact (#2 N/O) with one piece of embedded foreign material (consistent with fiberglass). Similar to what was discovered under PowerLabs project PSE-72352. All the other contacts from Relay 1 did not contain any foreign material, but revealed scratches on the contact surface.

All contacts for Relay 2 revealed scratches on the contact surface, but no embedded foreign material was observed.

The Exelon PowerLabs Quality System meets IOCFR50 Appendix B, NQA-I (1994), ANSI N45.2, ANSI/NCSL Z540-1 and IOCFR21/10CFR50.55 (e). Exelon PowerLabs is ISO 9001:2008 Registered and ISO/IEC 17025 Accredited.

175 N. Cain Road Coatesville, PA Page 1 of 7 Page 24 of 30 May 7,.2015 Pa2e 24 of 30 MaY 7.2015

Investigation for Potential Part 21 for Struthers Dunn Relays TEST PLAN

1. Document Nameplate Data
2. Harvest contacts from Both Relays
3. Highly Magnified Examination (Scanning Electron Microscopy) of all contacts in an effort to determine if foreign material and / or manufacturing defects exist.

STATEMENT OF QUALITY Testing was performed with standard equipment that have accuracies traceable to nationally recognized standards, or to physical constants, by qualified personnel, and in accordance with the Exelon PowerLabs Quality Assurance Program.

Technician(s): Lance Walls, Michael Minicozzi Reviewed by: Lance Walls 4/15/15 ANSI Level Ill / Sr. Engineer Date Approved by: MichaelMinicozzi 4/15/15 ANSI Level II / Sr. Engineer Date Projectreview and approvalare electronicallyauthenticatedin the Exelon PowerLabsprojectrecord.

Exelon PowerLabs, ILC - TECH SERVICES Project Number. PSE-83022 175 N. Cahn Road Coatesville, PA Page 2 of 7 Page 25 of 30 May 7.,2015

Investigation for Potential Part 21 for Struthers Dunn Relays I OBSERVATIONS AND DATA 1.) Document Nameplate Data Photo 1: Nameplate Data I - Relay 1 Manufacturer: Struthers-Dunn Model#: 219BBX200 Coil Voltage: 24 - 28 VDC Contact Rating: 120 VAC, 10 A N.C. Contacts: 1-2 and 11-12 N.O. Contacts: 2-3, 4-5, 8-9, and 10-11 Photo 2: Nameplate Data U - Relay 1 QualTech NP Tag#: CJ471601 QualTech NP SIN: 02 PSEG PO#: 4500850435 Exelon PowerLabs, LLC - TECH SERVICES Project Number PSE-83022 175 N. Caln Road Coatesville, PA Page 3 of 7 Paue 26 of 30 Mav 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays I

Photo 3: Nameplate Data I - Relay 2 Manufacturer: Struthers-Dunm Model#: 219BBX200 Coil Voltage: 24 - 28 VDC Contact Rating: 120 VAC, 10 A N.C. Contacts: 1-2 and 11-12 N.O. Contacts: 2-3, 4-5, 8-9, and 10-11 Photo 4: Nameplate Data II- Relay 2 QualTech NP Tag#: CJ471601 QualTech NP S/N: 03 PSEG PO#: 4500850435 Exelon PowerLabs, LLC - TECH SERVICES Project Number. PSE-83022 175 N. Cain Road Coatesville, PA Page 4 of 7 Paee 27 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays

2. and 3.) Harvest Relay Contacts and Perform Scanning Electron Microscopy of the contact surfaces Photo 5: Scanning Electron Microscope Photo 6: Magnification of Photograph 5 SE inef40ARei - Contact #2 N/O fits 400- Si 300 0

200- A Ca 10 0

  • M Cu .Au I0 ~keY Embedded foreign material was observed on the #2 NIO contact surface. The embedded foreign material in the contact surface had an elemental composition consistent with fiberglass shown in the Energy Dispersive Spectroscopy spectrum shown above (Primary constituents are Si, Ca, Al, 0).

Exelon PowerLabs, LLC - TECH SERVICES Project Number: PSE-83022 175 N. Cain Road Coatesville, PA Page 5 of 7 Paeze 28 of 30 May 7. 2015 Pale 28 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays Photo 7: SEM imae.

Photo 8: SEM in The photographs above are representative of the remaining contact surfaces examined from Relay 1.

All the other contact surfaces did not contain any foreign material, but revealed scratches on the contact surface.

Exelon PowerLabs, LLC - TECH SERVICES Project Number: PSE-83022 175 N. Cain Road Coatesville, PA Page 6 of 7 Paue 29 of 30 May 7. 2015

Investigation for Potential Part 21 for Struthers Dunn Relays rnoto.10:MlyAv hma me= A, Contact FF 11  !

The photographs above are representative of the contact surfaces examined from Relay 2. All of the contact surfaces did not contain foreign material, but revealed scratches on the contact surface.

Exelon PowerLabs, LLC - TECH SERVICES Project Number: PSE-83022 175 N. Cain Road Coatesville, PA Page 7 of 7 Paue 30 of 30 May 7. 2015