ML16252A274
| ML16252A274 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Browns Ferry, Nine Mile Point, Perry, Saint Lucie, Grand Gulf, North Anna, River Bend, Ginna, South Texas, Fort Calhoun  |
| Issue date: | 08/29/2016 |
| From: | Bolt T AZZ / NLI Nuclear Logistics |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 51030 P21-04302015, Rev 4 | |
| Download: ML16252A274 (6) | |
Text
Date: August 26, 2016 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Part 21 Report No: P21-04302015, Rev. 4 hAZZ
Subject:
Update - Report of potential I OCFR Part 21, Allen Bradley Timing Relay Model 700RTC - NRC Event 51030, Accession Number ML15134A016 Revision 2, corrections:
- 1. Page 5 (vii), 2nd paragraph: changed EPRJ TR-102323 Rev. 3 to Rev. 4. -
- 2. Page 5 (vii), 3rd paragraph: changed 'timing' contacts to 'instantaneous' contacts.
Revision 3 correction: The date the change occurred is October 2008.
Revision 4 correction: Page 5 (vii), changed "Instantaneous" back to "Timing" contact.
Pursuant to 10CFR 21.21 (d) (3) (ii), AZZINLI is providing written notification of the identification of a potential failure to comply.
On the basis of our evaluation, it is determined that AZZINLI does not have sufficient information to determine if the subject condition would, or has, created a Substantial Safety Hazard or would have created a Technical Specification Safety Limit violation as it relates to the subject plant applications.
The following information is required per 1 OCFR 21.21 ( d) ( 4 ).
(i) Name and address of the individual or individuals informing the Commission.
Tracy Bolt, Director of Quality Assurance Nuclear Logistics, Inc 7410 Pebble Drive Ft. Worth, TX 76118 (ii) Identification of the facility, activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or contains a defect.
The specific part which fails to comply or contains a defect:
L I' As of October 2008, Allen Bradley relays base model 700RTC, contain a CPLD (Complex Programmable Logic Device). This was an unpublished design change that was impleme11ted to replace an obsolete integrated circuit chip. The undocumented design change did not result in a part number change from Allen-Bradley. There was no change to the appearance of the relay that would Page 1of6 NUCLEAR LOGISTICS INC.
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identify any design changes were made to the relay configuration.
The timing relay model 700RTC has been dedicated/qualified for multiple applications for various plants.
(iii)
Identification of the firm constructing or supplying the basic component which fails to comply or contains a defect.
NLI procured the commercial grade relays, dedicated, qualified and supplied the subject relays as Safety Related.
(iv)
Nature of defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply.
In October 2008, Allen Bradley made a design change without changing the pa1t number of the commercial relay or providing any documented evidence of a design change. The manufacturer specification data sheets maintain the classification that the relays are "solid state", which would imply that there are no digital devices installed in the relay. However, after inspection of the internals of the timing relay (Figure 2), it has been identified that the unit does contain a CPLD which meets the definition of a digital device under the guidance ofNEI 01-0 I. See Figures 1 and 2 below:
Figure 1-Original qualified design (prior to October 2008).
Relays supplied prior to October 2008 are not affected by this issue.
Part 21 Report No: P21-04302015, Rev. 4 Page 2of6
Figure 2 - New design circuit board and CPLD that replaced the original component.
(v)
The date on which the information of such defect or failure to comply was obtained.
On April 27, 2015, enough information was gathered from the evaluations being performed to determine the repo1tability of the failure to comply that is the root cause for the event.
Part 21 Report No: P21-04302015, Rev. 4 Page 3 of 6
(vi)
In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for being supplied for, or may be supplied for, manufactured or being manufactured for one or more facilities or activities subject to the regulations in this part.
Relays that have been procured and dedicated from October 2008 to present are identified below.
Plant Name Purchase order Browns Ferry 72923-1 Ginna Station 6617899 Grand Gulf 10304816 Grand Gulf 10400205 Invensys 4540216542 KHNP y 12-0292-010 Lungmen 8749411E007CO Millstone 45735761 Millstone 45735761 Nine Mile Point 530734 North Anna 70239037 North Anna 70239037 North Anna 70239037 OPPD Ft Calhoun 155213 OPPD Ft Calhoun 163495 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 164936 OPPD Ft Calhoun 177878 OPPD Ft Calhoun 182681 OPPD Ft Calhoun 187625 Perry Station 45354401 River Bend Station 10349942 River Bend Station 10362573 River Bend Station 10378904 South Texas Project 134783 Serial Number 29760-001-00003 51475-001-00001 and -00002, 52656Kl-01-0001 34182-001-00001 56319-001-00001 39228-001-00001 thru -00017, 39228-001-00158 thru 39228-001-00166, 39228-001-00170 thru 39228-001-00177 39407-001-00001 thru -00008, 39407-002-00001 thru -
00005 38486-001-00001 and -00002, 38486-002-00001 31998Kl-O 1-0001 31391-001-00001 63245-001-00001 thru -00018 55133-001-00001 &-00002 39602-001-00001and-00002,39602-002-00001 thru -
00003 40033-001-00001 and 40033-001-00002, 40033-002-00001 thru -00003 33846-001-00001 thru -00009, 33846-001-00011 thru 33846-001-00015, 33846-002-00002 & -00003 35941-001-00001 thru -00004 35891Kl-Ol-0001 thru -0005 36888-001-00001, -00003 thru -00005 36888K2-01-0001 39194-001-00001 thru -00006 40743-001-00001 thru -00003, 40743-002-00001 51477-001-00001 thru -00004 33357-001-00001 thru -00003 38585-001-00001 thru -00004 40077-001-00001 51627-001-00001 33750-001-00001 & -00002 Part 21 Report No: P21-04302015, Rev. 4 Page 4of6
South Texas Project 147962 37204-001-00001 thru -00006 South Texas Project 154172 51592-001-00001 thru -00004 South Texas Project 171193 57894-001-00001 thru -00006 St Lucie Bechtel PO: 25486-974-38549-001-00002 thru -00005 FP A-EMR0-00001 (vii)
The corrective action which has been, is being, or will be taken; the name of the individual or organization responsible for the action; and the length of time that has been or will be taken to complete the action.
NLI has completed the EMC qualification testing per the requirements ofEPRI TR-102323 Rev. 4 for the following tests, as applicable: CElOl, CE102, RElOl, RE102, RSlOl, RS103, CSIOI, CSl 14, CSI 15 and CS116.
The results were satisfactory with exception of the following condition: During Conducted Susceptibility CS 114 onto the power lines, with the timing circuit in operation, the Normally Open Timing contact exhibited chatter (changed state) in the range of 3.3 MHz to 24.0 MHz.
Supplemental testing was conducted to confirm the Timing contact was susceptible to the condition. The unit requires a ferrite to be installed onto the input power lines of the relay with 3 turns through the ferrite core.
In this modified configuration, the relay was not susceptible to Conducted Susceptibility and successfully passed the required test per CSl 14.
In addition to the EMC testing that was performed, the Verification and Validation I Dedication activities for the digital device was also completed. The results of the dedication activity are contained in NLI Verification and Validation/Dedication report VVR-700RTC-Ol, Rev. l. The results of the V &V/dedication activity are satisfactory. The firmware version verified is the only version that has been released since the change was implemented.
Part 21 Report No: P21-04302015, Rev. 4 Page 5of6
(vini)
Any advice related to the defect or fai1ure to comply about the facility, activity, or basic com~onent that has been, is benl!llg, Oll:' wm be given to purchasers Or licensees.
The f\\J.nctions of the relays supplied by NLI were tested for the following critical characteristics:
Pick-up at rated voltage Drop-out when the voltage is removed Pick-up at degraded voltage Over-Voltage operation Insulation resistance Off delay settings are adjustable from 2-120 seconds Pick..:up voltage Drop-out voltage Dimensions and Configuration The relays are dedicated for generic application usage in timing applications. The specific plant application(s) is unknown by NLI. The EMC qualification of the relay is dependent on the installed configuration and location in the plant. The plant should evaluate whether the installed relays are subjected to the specific EMl/RFI condition Conducted Susceptibility CS 114 between the frequencies of 3.3 to 24.0 MHz identified above.
Please contact me with any questions or comments.
Part 21 Report No: P21-04302015, Rev. 4 Page 6of6