ML16232A604

Potentially Unqualified Component in Certain Allen Bradley Timing Relays

ML16232A604
Person / Time
Site:	Millstone, Browns Ferry, Nine Mile Point, Perry, Saint Lucie, North Anna, River Bend, Ginna, South Texas, Fort Calhoun
Issue date:	08/15/2016
From:	Bolt T AZZ / NLI Nuclear Logistics
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
51030
Download: ML16232A604 (9)

Text

0811512016 U.S. Nuclear Regulatory Commission Operations Center Event Report Pagel Part 21 (PAR) Event# 51030 Rep,Org: AZZ/NLI NUCLEAR LOGISTICS, INC Notification Date I Time: 05/01/2015 13:32 (EDT)

Supplier: ALLEN BRADLEY Event Date I Time: 04/30/2015 (CDT)

Last Modification: 08/15/2016 Region: 4 Docket#:

City: FORT WORTH Agreement State: Yes County: License #:

State: TX NRC Notified by: TRACY BOLT Notifications: MEL GRAY R1DO HQ Ops Officer: DANIEL MILLS FRANK EHRHARDT R2DO.

Emergency Class: NON EMERGENCY ROBERTORLIKOWSKI R3DO 10 CFR Section: GEOFFREY MILLER R4DO 21.21(d)(3)(i) DEFECTS AND NONCOMPLIANCE PART 21/50.55 REACTORS EMAiL POTENTIALLY UNQUALIFIED COMPONENT IN CERTAIN ALLEN BRADLEY TIMING RELAYS The following is an excerpt from a document received from the licensee via email:

"Report of potential 10 CFR Part 21, Allen Bradley: Timing Relay Model 700RTC "Pursuant to 10 CFR 21.21 (d)(3)(ii), AZZ/NLI is providing written notification of the identification of a potential failure to comply.

"On the basis of our evaluation, it is determined that AZZ/NLI 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 specific part which fails to comply or contains a defect:

"As of 2009-2010, Allen Bradley relays base model 700RTC, contain an unevaluated CPLD (Complex Programmable Logic Device). This was an unpublished design change that was implemented to replace an obsolete integrated circuit chip. Th13 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 identify any design changes were made to the relay configuration. Therefore, NLI qualification/dedication of the relays after 2009 have not included additional testing for the new CPLD component.

"The timing relay model 700RTC has been dedicated/qualified for multiple applications for various plants.

"Between 2009-2010 Allen Bradley made a design change without changing the part number of the commercial .

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0811512016 U.S. Nuclear Regulatory Commission Operations Center Event Report Page 2 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 of NEI 01-01."

Potentially affected plants include Browns Ferry, Ginna, Millstone, Nine Mile Point, North Anna, Ft. Calhoun, Perry, River Bend, South Texas Project, and St. Lucie.

• • • UPDATE FROM TRACY BOLT TO JOHN SHOEMAKER AT 1744 EDT ON 4/8/16 * *

• AZZ/NLI Nuclear Logistics provided additional information regarding Part 21 Report No: P21-04302015, Rev. 1.

Notified R1 DO (Rogge), R2DO (Nease), R3DO(Skokowski), R4DO (Kellar), and PART 21/50.55 REACTORS via email.

• • • UPDATE FROM LES TAGGART TO BETHANY CECERE AT 0951 EDT ON 5/26/16 * *

• AZZ/NLI Nuclear Logistics provided Revision 2 to Part 21 Report No: P21-04302015 to correct the referenced EPRI TR-102323 Rev. 3 to Rev. 4 and change 'timing' contacts to 'instantaneous' contacts as shown below:

"(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.

"The relays that are currently in stock at NU have been placed on hold until after the units have been determined to be qualified for the specific application. NU has completed the EMC qualification testing per the requirements of EPRI TR-102323 Rev. 4 for the following tests, as applicable: CE101, CE102, RE101, RE102, RS101, RS103, CS101, CS114, CS115 and CS116.

"The results were satisfactory with exception of the following condition: During Conducted Susceptibility CS114 onto the power lines, with the timing circuit in operation, the instantaneous contacts exhibited chatter in the range of 2.6 MHz to 20.3 MHz. 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 CS114."

Notified R1 DO (Lilliendahl), R2DO (Guthrie), R3DO(Kunowski), R4DO (Werner), and PART 21/50.55 REACTORS via email.

• • • UPDATE FROM TRACY BOLT TO DONG PARK AT 1807 EDT ON 8/15/16 * *

• AZZ/NLI Nuclear Logistics provided additional information regarding Part 21 Report No: P21-04302015, Rev. 3, correcting the date the change occurred to October 2008.

Notified R1 DO (Jackson), R2DO (Shaeffer), R3DO (Riemer), R4DO (Proulx), and PART 21/50.55 REACTORS via email.

08/15/2016 ' 17:04 c,FAX) P.001/007

)a AZZ .___N_L I' Date: August 15, 2016 To:

FAX (301) 816-5151 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 205.55 From:

Tracy Bolt Director of Quality Assurance AZZ I Nuclear Logistics 7410 Pebble Drive Fort Worth, Texas 76118 UPDATE - Report of potential 10CFR Part 21, Allen Bradley Timing Relay Model 700RTC Report No: P21-04302015, Rev. 3 Previous NRC Event number 51030 Previous Accession No: ML15134A016 Total pages including this page: 1 NUCLEAR LOGISTICS INC. www.azz:.com 7410 Pebble Drive

• Fort Worth, Texas 76116

• 800.448.4124 Phone

• 817.590.0464 Fax

08/15/2016 17:04 P.002/007 NL I' Date: August 15, 2016.

Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Part 21 Report No: P21-04302015, Rev. 3

Subject:

Update - Report of potential 10CFR Part 21, Allen Bradley Timing Relay Model 700RTC-NRC Event Number 51030, Accession Number ML15134A016 Revision 2, corrections:

1. Page 5 (vii), 2nd paragraph: changed EPRI TR-102323 Rev. 3 to Rev. 4.

2. Page 5 (vii), 3rd paragraph: changed itiming1 contacts to 'instantaneous, contacts.

Revision 3 correction: The date the change occurred is October 2008.

Pursuant to 10CFR21.21 (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 deterinine 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 10CFR 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 faclltty 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:

As .of October 2008, Allen Bradley relays base model 700RTC, contain a CPLD (Complex I Programmable Logic Device). This was an unpublished design change that was implemented 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 identify any design changes were made to the relay configuration.

Page 1 of6 NUCLEAR LOGISTICS INC. www.azz.com 7410 Pebble Drive

• Fort Worth, Texas 76118

• 800.448.4124 Phone

• Si 7.590.0464 Fax

08/15/2016 17:05 P.003/007 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, AIIen Bradley made a design change without changing the part 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 of NE I 01-01. 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: P21-04302015t Rev. 3 Page 2 of6

0811512016 17:05 P.0041007 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 ~om ply was obtained.

On April 27, 2015, enough information was gathered from the evaluations being performed to determine the reportability of the failure to comply that is the root cause for the event.

Part 21 Report No: P21-04302015, Rev. 3 Page 3 of6

08/15/2016 17:05 (FAX) P.005/007 (vi) In the case of a basic compommt which contains a defect or fails to comply, the number and location of these components in use at, supplied for being supplied for9 or may be supplied for, manufactured or being manufactured for one or more facilities or activities subject to the regulations in this pad.

Relays that have been procured and dedicated from October 2008 to present are identified below.

Plant Name Pnrchase ord.er Serial Number -

Browns Ferrv 72923-1 29760-001-00003 .

Ginna Station 6617899 51475-00I-00001 and-00002, S2656Kl~Ol..0001 Grand Gulf 10304816 34182-001-00001 Grand Gulf 10400205 56319-001-0000 I 39228-001-00001thru-00017,39228-00lu00158 thru Invensys 4540216542 39228-001-00166, 39228..001-00170 thru 39228-001-00177 39407-001-00001 thru -00008, 39407-002-00001 thru -

KHNP Y12-0292-010 00005 Lunamen 8749411E007CO 38486-001-00001and-00002,38486-002-00001 Millstone 45735761 31998Kl-Ol-0001 Millstone 45135161 31391-001*00001 Nine Mile Point 530734 63245-001-00001 thru -00018 North Anna 70239037 55133-001-00001 &-00002 39602-001-00001 and -00002, 39602-002-00001 thru-North Anna 70239037 00003 40033-001-00001 and 40033-001-00002, 40033-002-00001 North Anna 70239037 thru -00003 33846-001-00001 thru-00009, 33846-001-00011 thru OPPD Ft Calhoun 155213 33846-001-00015. 33846-002-00002 &-00003 OPPD Ft Calhoun 163495 35941-001-00001 thru-00004 OPPD Ft Calhoun 164936 35891Kl-01-0001 thru -0005 OPPD Ft Calhoun 164936 36888-001-00001, -00003 thru -00005 OPPD Ft Calhoun 164936 36888K2-01-0001 OPPD Ft Calhoun 177878 39194-001-00001 thru -00006 OPPD Ft Calhoun 40743-001-00001 thru -00003, 40743-002-00001 182681 OPPD Ft Calhoun 187625 51477-001-00001 thru-00004 Perry Station 45354401 33357-001-00001 thru -00003 River Bend Station 10349942 38585-001-00001 thru -00004 River Bend Station 10362573 40077-001-00001 River Bend Station 10378904 51627-001-00001 South Texas Project 134783 33750-001-00001 & -00002 Part 21 Report No: P21-04302015~ Rev. 3 Page 4 of6

08115/2016 17:05  !,FAX) P.006/007 South Texas Project 147962 37204-001-00001 thru -00006 South Texas Project 154172 51592-00 I"0000 I thru -00004 South Texas Project 171193 57894-001-00001 thru -00006 Bechtel PO: 25486-974-St Lucie 38549-001-00002 thru-00005 FPA-EMR0-00001 (vii) The correcti\'e action which bas been, is being, or wlll be taken; the name of the individual or organization responsible for the action; and the length of time that h1u; been or will be taken to

~omplete the action.

The relays that are currently in stock at NLI have been placed on hold until after the units have been determined to be qualified for the specific application. NLI has completed the EMC qualification testing per the requirements of EPRI TRM102323 Rev. 4 for the following tests, as applicable: CElOl, I

CEI02, REIOl, RE102, ltSIOl, RS103, CSlOl, CSl 14, CSl 15 and CSl 16.

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 instantaneous I

contacts exhibited chatter in the range of 2.6 MHz to 20.3 MHz. 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 perfonned, 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-01, Rev. 1. 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. 3 Page 5 of6

08/15/2016 17:06 1,FAX) P.007/007 (viii) Any advice related to the defect or failure to comply abont the facility, activity, or basic component that bas been, is being, or will be gil'en to purchasers or licensees.

The functions 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 byNLI. 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 EMIIRFI condition Conducted Susceptibility CS 114 between the :frequencies of2.6 MHz to 20.3 MHz identified above.

Please contact me with any questions or comments.

Sincerely, Tracy Bolt Director of Quality Assurance Part 21 Report No: P21-04302015~ Rev. 3 Page 6 of6