ML22220A236
| ML22220A236 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/02/2022 |
| From: | Andino K Leonardo DRS |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| DRS-2022-0227 | |
| Download: ML22220A236 (8) | |
Text
~t9 LEDNRRDD DRS In Reply, reference DRS-2022-0227 August 2, 2022 NRC Document Control Desk U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001
Subject:
16-AA T907B Power Supply 10 CFR Part 21 Notification To Whom It May Concern:
DRS Naval Power Systems. Inc.
21 South Street, Danbury, CT 06810 Tel: +1-203-798-3000 This Notification letter is to inform the United States Nuclear Regulatory Commission of a 10 CFR Part 21 reportable condition on NPS Part Number 16-AA T907B, 48 VDC Power Supplies (QTY 11 ), delivered to Wolf Creek Generating Station in August 2018 under Contract Number 775446/5.
Summary:
Plant installed: Wolf Creek Generating Station Unit 1, Burlington, KS Basic Component: 16-AA T907B Serial Numbers: (11) 18-17-015, 18-17-017, 18-17-018, 18-17-019, 18-17-020, 18-17-021, 18-17-022, 18-17-023, 18-17-024, 18-17-025, 18-17-026 Host Component: 8N25-12, 8N28-12, 8N26-13, 8N26-14 Host Cabinet: 9N39-13, 9N39-14, 9N39-15, 9N40-11, 9N40-12 (ESFAS & LSELS)
Nature of Deviation: Failure to meet reliable/consistent operation of cooling fan on power supply 16-AAT907B.
Background:
DRS Consolidated Controls Inc. (Currently Leonardo DRS Naval Power Systems, henceforth referred to as NPS) provided 48 VDC power supply, Part Number 16-AAT907B to Wolf Creek Generating Station in 2018. It was discovered in 2019 by Wolf Creek that there was anomalous fan performance occurring within this power supply after several months of operation. These issues were in the form of the following:
fan noise fan failure to operate The power supplies were replaced by Wolf Creek upon discovery. NPS and the power supply manufacturer were notified of the issue to begin investigation on root cause and remedial actions.
Actions Already Taken NPS has fulfilled an order (Contract Number 789557) for new units of QTY 4, 16-AAT907B. These were delivered to Wolf Creek 3/2021.
NPS has fulfilled an order (Contract Number 792247/2) for repair units of QTY 4, 16-AAT907B from site. These were delivered 3/2022.
NPS has evaluated fan replacement as acceptable (Documented in ER16-0390/02) in maintaining the previous qualification of the 16-AA T907B.
Page 1 of 2
Wolf Creek has informed DRS that they would re-install previous generation of power supply assembly, 8N to accommodate timing for repair of power supplies.
Update of Statement of Work (SOW PR16-0502) to power supply manufacturer to prevent recurrence of component changes prior to evaluation.
Supplier Corrective Action Requests (SCAR) 1922 and 1923 were issued to power supply manufacturer due to failure to notify of potential issues due to fan as per Purchase Order requirements.
Internal Corrective Action Request (CAR) 1893 was opened to analyze root cause of delay in 10 CFR Part 21 evaluation.
Extent of Condition:
Wolf Creek Generating Station is the only power plant affected by this deviation.
Actions to be Taken:
NPS to complete fulfillment of Purchase Order (Contract Number 792497/1) for new units of QTY 3, 16-AAT907B. Delivery in July 2022.
Resolution of SCARs 1922 and 1923 with the power supply manufacturer Resolution of Internal (CAR) 1893 along with root cause and remedial actions.
Kevin Andino Senior Director of Quality Leonardo DRS Naval Power Systems
Attachment:
DQP-SP-048A_Rev4 10 CFR Part 21 Discovery and Evaluation Checklist Cc: Brandon Ma, Evergy Robert Bunz, Evergy Sandy Somerhalder, Evergy Oliver Cueff, DRS Mackenzie Manning, DRS Harry Brooks, DRS James Mena, DRS Paul Stankiewicz, DRS Mei Wu, DRS Page 2 of 2
7~ LEONRRDO DRS 10 CFR Part 21 Discovery and Evaluation Checklist DR and or CPAR Number:
CAR 1893 Discovery Date:
4/13/2022 Initiators:
(DR disposition Date)
Name:
James Mena Department:
Engineering Name:
Harry Brooks Department:
Quality NOTE: This form must be completed within five (5) business days of the date above, which is considered the date of Discovery. (the DR Disposition date)
Description ofNon-compliance (or attach the DR to this):
Question A.
DQP-SP-048A If the issue involves only an item, proceed to Question A.
If issue involves a service, proceed to Question B.
For issues involving only an item, did the item fail in-service in conditions other than the following:
The in-service failure is identified as a normal end of life issue.
The in-service failure is identified as a calibration or instrument tolerance issue.
The in-service failure is due to normal expected usage of a component such as installation, rework, repair, post-maintenance testing, etc.
The in-service failure is environmentally induced where abnormal operational parameters exceed technical requirements (for example, dirt in the system, exceeding temperature, pressure, hydraulic stresses, structural stresses, voltage, amperage, electrical load, etc.).
The in-service failure is identified by normal operational checks, tests, inspections, or due to trouble alarms, provided the failure is not a departure from an item's technical requirements identified in a procurement document (as determined by question C).
Answer If the answer to Question A is "No,"the condition is NOT REPORTABLE by the Company under 10CFR 21.
Check the 'No" box in Question A and document the basis for the determination in Section J, and note on the DR "Part 21 Reporting Not Required".
If the answer to Question A is "Yes, "the issue is potentially subject to 10 CFR 21. Check the "Yes" box in Question A and proceed to Question B.
Revision 4 Page 1 of 5
~~ LEONARDO DR5 10 CFR Part 21 Discovery and Evaluation Checklist Question Answer B.
Does the issue involve a failure to comply that is potentially 0Yes l:8:]No associated _with a substantial safety hazard?
Failure to comply means the manufacture, construction or operation ofa licensed facility or activity, a basic component supplied for such facility or activity, or a design certification or design approval under 10 CFR Part 52; which is not in compliance with the Atomic Energy Act of 1954, as amended, any applicable rule, regulation of 10 CFR, order or license issued by the Commission, or a standard design approval under 10 CFR under 10 CFR Part 52.
A failure to comply is considered to be potentially associated with a substantial safety hazard if the failure to comply affects the performance of a safety function.
If the answer to Question Bis No," proceed to Question C.
If the answer to Question Bis Yes", the issue is a failure to comply that may be reportable under 10 CFR Part 21, and requires an evaluation; check the Yes" box in Question C and document the basis for all Yes" answers in Questions A and B in Section E.
Question Answer C.
Does the issue involve a deviation in a basic component delivered to a
[gjYes 0No purchaser for use in a facility or an activity subject to the regulations in 10 CFR Part 21?
If the answer to Question C is "No," 10 CFR Part 21 does not apply. No further investigation is necessary and an evaluation is not required. Check the "No" box in Question G and document the basis for all NO" answers in Questions Band C in Section D.
If the answer to Question C is Yes, "the issue is a deviation that may be reportable under 10CFR Part 21, and requires an evaluation, check the Yes" box in Question C and document the basis for all Yes" answers in Questions A and C in Section E.
Section D Evaluation is NOT REQUIRED:
Document basis for determining the issue is not a deviation or failure to comply potentially associated with a substantial safety hazard. Attach this form and any supporting documentation to the DR/CAP A (No further action is required once the basis has been documented.)
r---£ion E Evaluation is REQUIRED: YES (See Evaluation at end of report)
Document basis for determining the issue is a deviation or failure to comply potentially associated with a substantial safety hazard, and record the date this documentation was completed. Attach this form and any supporting documentation to the DR/CPAR (This is the point of discovery, and an evaluation is required. Proceed to Question F.)
DQP-SP-048A Revision 4 Page 2 of 5
~~ LEDNRRDD DRS 10 CFR Part 21 Discovery and Evaluation Checklist Part 21 Evaluation Section (If during the course of performing the evaluation, it is determined it cannot be completed within 60 days of the Point of Discovery, as documented in Section J, proceed to Section Mand complete an interim report.)
Question Answer F
Does the responsible officer have actual knowledge that the NRC has 0Yes cgjNo been adequately informed of the defect or failure to comply.
If the answer to Question F is "Yes," evaluation and notification are not required. Check the "Yes" box in Question G and document the basis in Section J.
If the answer to Question F is "No, "the deviation or failur:_e to comply must be evaluated under 10 CFR 21. Proceed to Question G.
G Does the entity have the capability to perform an evaluation of the deviation or failure to comply potentially associated with a substantial cgjYes 0No safety hazard?
For If the answer to Question G is 'No, "the evaluation of the deviation or failure to comply Suppliers potentially associated with a substantial safety hazard must be transferred to the purchaser(s)".
Check the "No" box in Question G, notify the purchaser(s) within five (5) days that the evaluation is being transferred and they now are responsible for performing the evaluation in accordance with 10 CFR 21.21(b), and document this in Section I.
If the answer to Question G is Yes, "the evaluation of the deviation or failure to comply potentially associated with a substantial safety hazard must be performed by the Company under 10 CFR 21. Check the yes box in Question G and proceed to Question H.
For If the answer to Question His "No," assistance is need to perform the evaluation of the Purchasers deviation or failure to comply potentially associated with a substantial safety hazard. Check the "No" box in Question G, obtain assistance to perform the evaluation and proceed to Question H.
If the answer to Question G is Yes," the evaluation of the deviation or failure to comply potentially associated with a substantial safety hazard must be performed by the Company under IO CFR 21. Proceed to Question H Question Answer H
Could the deviation or failure to comply create a substantial safety hazard, cgjYes 0No if it were to remain uncorrected?
If the answer to Question H is 'No," the deviation or failure to comply cannot create a substantial safety hazard, ifit were to remain uncorrected, and is NOT Reportable to the NRC.
Check the 'No" box in Question H and document the basis for the 'No" response in Section J.
If the answer to Question H is Yes," the defect or failure to comply could create a substantial safety hazard if it were to remain uncorrected, and IS REPORTABLE by the Company under 10 CFR 21.
Check the Yes" box in Question Hand proceed to Section K.
DQP-SP-048A Revision 4 Page 3 of 5
~~ LEDNRRDD DRS 10 CFR Part 21 Discovery and Evaluation Checklist Section I (For suppliers only) Transfer of evaluation.
Document the basis for transferring the evaluation and the notification of purchasers, including date. (No further action is required once the basis has been documented and purchaser notification)
Date Purchaser(s) notified:
MM/DDNYYY Section J Notification is NOT REQUIRED:
Document basis for determining the issue is not reportable. i.e., the deviation or failure to comply could not create a substantial safety hazard, if it were to remain uncorrected, or the defect or failure to comply has been previously reported to the NRC. Attach this form and any supporting documentation to the DR/CP AR (No further action is required once the basis has been documented.)
Section K Notification is REQUIRED: YES Document basis for determining the issue is a reportable defect or failure to comply (i.e., it could create a substantial safety hazard, if it were to remain uncorrected), and record the date this documentation was completed. Notify the responsible officer of this determination within five (5) days of the completion of the evaluation and document the date they were notified. Attach this form and any supporting documentation to the DR/CP AR (Proceed to Section M to document the notification and reporting to the NRC.)
Date Evaluation was Completed: 06/09/2022 Date the Director or Responsible Offices was Notified: 06/14/2022 Section M Documentation of notification and reporting to the NRC.
Interim Regort If during the course of performing the evaluation, it is determined it cannot be completed within 60 days of the Point of Discovery, as documented in Section J, an interim report must be submitted to the NRC within 60 days of the Point of Discovery.
Date Interim Report was submitted to the NRC: MM/DDNYYY Interim Report included all required information: D Yes D No Document confirmation the NRC received the Interim Report:
Initial If Notification is required (Section K), then the responsible officer, or their designe_e, must provide the Notification NRC initial notification within two (2) days of the responsible officer or their designee being notified.
Date Initial Notification was provided to the NRC: 08/02/2022 Document method to provide Initial Notification and confirmation the NRC receive it: Fax DQP-SP-048A Revision 4 Page 4 of 5
~~ LEONARDO DR5 10 CFR Part 21 Discovery and Evaluation Checklist Written Re12ort If Notification is required (Section K), then the responsible officer, or their designee, must submit a written report to the NRC within 30 days of the director or responsible officer being notified.
Date Written Report was submitted to the NRC: 08/02/2022 Written Report included all required information: cg] Yes D No Document confirmation the NRC received the Written Report Decision Summary I
We, the undersigned, have evaluated the information provided and have made the followin2 determination(s):
A substantial safety hazard does not exist DRS does not have the capability to determine if a substantial safety hazard exists cg]
A substantial safety hazard exists (Begin Notification Process)
SIGNATURES Department Name Title Date Mena, James DigilallysignedbyMena,James Principal Electrical ON: cn=Mena, James ou=Employee Reason:lamapprovingthisdoeument Engineering Location:
Engineer 06/20/2022 Oate:2022-06-2011:45-04.00 James Mena f Digitally ~igned by Brooks, Harry B
k H
. ON: ema1l=Hany.Br0oks@drs.com, Quality Assurance:
roo S, arry:~~;~~~i:ie~~;z* O=RS Senior Quality Engineer 06/20/2022 1/
Date:2022.0S.2011:53:35-04'00' Harry Brooks Program l),glldy"'gnedt,y!A°"'""ardl,Ro!:><11 Senior Director, Mastronardi, Robert DN:cn=Ma.... !18r<ll,R.,,.,t~RSTo<:tinologlo1.lnc Management g~:::::~
Program Management Robert Mastronardi DQP-SP-048A Revision 4 Page 5 of 5
7~ LEONRROO ORS Safety Evaluation:
10 CFR Part 21 Discovery and Evaluation Checklist Wolf Creek identified instances of abnormal activity on the DRS Part Number 16-AA T907B. installed in host assemblies 8N25-12, 8N28-12, 8N26-13 and 8N26-14.
Extent of Condition:
Wolf Creek is the only affected Power Plant that is subject to this notice.
The abnormal conditions reported were abnormal fan noise (3 total) and fan failure (2 total) as indicated by the Fan Failure LED present on host assembly 8N power supply assembly.
Fan Noise:
- 1. Occurred 09/28/2019
- a. Ran for approximately 2 months prior to abnormal fan noise
- 2. Occurred 06/08/2021
- a. Ran for approximately 2 months prior to abnormal fan noise
- 3. Occurred 01/20/2022
- a. Ran for approximately 9 months prior to abnormal fan noise Fan Failure:
- 1. Occurred 12/14/2021
- a. Ran for approximately 8 months prior to fan failure
- 2. Occurred 02/05/2022
- a. Ran for approximately 9 months prior to fan failure It was noted that voltage output was not significantly affected as such did not lose its safety related function but were replaced with spare units as a precaution.
After further investigation, the manufacturer of the 16-AA T907B power supply identified varying degrees of issues with cooling fan (FAN 1 ). The power supply vendor has decided to discontinue the use of the suspect cooling fans and replace them with fans from another fan supplier that show an increase in the reliability of the cooling fan. Returned 16-AAT907B power supplies are being updated with the new cooling fans (FAN2).
DRS began providing new 16-AAT907B power supplies in 3/2021 which utilized the new fan FAN2 described above. DRS has evaluated FAN2 as acceptable in maintaining the previous qualification of the 16-AAT907B.
It is concluded that this condition is a deviation in a basic component as
- 1. Cooling fan is a necessary part of the design of the power supply.
- a. It was not seen to have degraded the voltage output of the power supply at the site when noise and loss of cooling was found.
- 2. Due to the nature of the FANl failures, DRS cannot provide reasonable assurance that the power supply will perform its safety related function for the intended life of design.
Therefore, all instances of the 16-AA T907B power supply using F ANl need to be updated with a 16-AA T907B power supply with F AN2.
DQP-SP-048A Revision 4 Page 1 of 1