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The team identified an issue of concern anThe team identified an issue of concern and an unresolved item related to the effect of electrical system harmonics on safety-related degraded voltage relays. Specifically, in 1993, the licensee identified that harmonic distortions adversely affected the 6.9 kilovolt (kV) bus overvoltage relays by causing them to alarm unnecessarily. The licensee entered this issue into their corrective action program and modified the overvoltage relays to minimize the effects. However, the licensee did not identify (or otherwise evaluate) the adverse effect that harmonics could have on the ability of the degraded voltage relays to perform their safety function, as required by limiting condition for operation 3.3.5 of the plants technical specifications. The Watts Bar degraded voltage protection scheme features three ABB type 27N relays for each 6.9 kV safety bus, arranged in a two out of three tripping scheme. The ABB instruction bulletin 7.4.1.7-7 contained in vendor manual WBN-VTD-AS04-0080 states that (1) the relay employs a peak voltage detector, and (2) harmonic distortion on the AC waveform can have a noticeable effect on the relay operating point and the measuring instruments used to calibrate the relay. The bulletin also notes that the relay is available with an internal harmonic filter for applications where waveform distortion is a factor. The team noted that calculation WBPE2119202001, 6.9kV Shutdown & Logic Boards Under-voltage Relay Requirements/Demonstrated Accuracy Calculation, identified the relay as a model not equipped with a harmonic filter, but did not address the basis for excluding harmonic distortion as a factor which affected relay accuracy. In response to the teams inquiries, the licensee provided PER 930397 that addressed spurious actuations of the ABB type 59H overvoltage relays which are similar in design to the ABB type 27N degraded voltage relays. Troubleshooting tests performed to identify the cause of the 59H spurious actuations revealed that high levels of 6.9 kV system harmonics from sources both external and internal to the station accompanied the spurious operations. The causal factor section of PER 930397 stated that the relays sometimes trip on harmonic distortion although the root mean square voltages are at acceptable levels. Corrective actions consisted of replacing the type 59H overvoltage relays with a model equipped with harmonic filters. The team further noted that the extent of condition section of PER 930397 did not identify or address whether the degraded voltage relays operating point could also be affected by the same harmonics implicated in the mal-operation of the overvoltage relays. The team was concerned that harmonics on the 6.9 kV system could cause the degraded voltage relays to fail to actuate at the set-point specified by technical specifications. Persistent harmonics can be produced by factors external to the nuclear site or by internal phenomena. A typical internal source of harmonics at nuclear power plants is motor defects. The team was also concerned that transient harmonics could cause the relays to spuriously reset during an actual degraded voltage event, thereby delaying the protective function beyond the 10 seconds stipulated in technical specification limiting condition for operation 3.3.5. Specifically, the degraded voltage relays design features an instantaneous reset characteristic that could allow reset of the degraded voltage relay in less than two cycles in the presence of harmonics, thereby reinitiating the external 10 seconds timer. The reset function of the existing degraded voltage relays is identical to the tripping function of the overvoltage relays that actuated due to transient harmonics in 1993. In 1993, transient harmonics were measured at levels of greater than 10% total harmonic distortion during the troubleshooting for PER 930397 versus the 0.3% distortion deemed acceptable by the relay vendor. The transient harmonics documented in PER 930397 were attributed to events that included the trip of the nearby Sequoyah generating station, and to breaker operations at the Watts Bar station. The team noted that similar conditions could exist during an accident scenario when proper performance of the degraded voltage scheme time delay would be critical with respect to satisfying the response time assumptions in the accident analysis. In response to the teams concerns, the licensee provided information regarding condition monitoring of large motors that consisted of periodic measurement and analysis of motor bearing vibration from which various defects that may produce harmonics could be identified. The team noted, however, that there was no written guidance or acceptance criteria for these tests that would prompt engineering to investigate whether suspected motor defects could produce harmonics that would adversely affect the accuracy of degraded voltage relays. Specifically, there was no recognition in design or maintenance documents regarding the susceptibility of the degraded voltage relays to harmonic distortion, or the need to investigate suspected motor defects with respect to this susceptibility. The team further noted that during normal bus voltage conditions when voltage is above the degraded voltage relay reset set-point, harmonics would shift system peak voltage away from the degraded voltage relay operating set-point rather than closer to it, and so the presence of harmful harmonics would not self-reveal by spurious actuations. The overvoltage relays are now equipped with harmonic filters so they will also not reveal the presence of either transient or persistent harmonics. Based on the teams observations, the licensee has entered these concerns into their corrective action program as PER 515413 and PER 546072. The team determined that additional review of information recently received from the licensee regarding Watts Bars design and licensing bases was necessary to determine if the licensees performance constituted a violation of NRC regulatory requirements. Additionally, the team determined that additional consultation with the Office of Nuclear Reactor Regulation was warranted before reaching a final disposition of the unresolved item. This unresolved item is open pending (1) the review of additional information from the licensee regarding the design and licensing basis of the degraded voltage relays and (2) consultation with the Office of Nuclear Reactor Regulation: URI 05000390/2012008-04, Effect of System Harmonics on Degraded Voltage Relay Function. Harmonics on Degraded Voltage Relay Function.  
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05000390  +
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00:47:32, 21 February 2018  +
23:59:59, 30 June 2012  +
Effect of System Harmonics on Degraded Voltage Relay Function  +