ML15134A016

Part 21 Report Regarding Potentially Unqualified Component in Certain Allen Bradley Timing Relays

ML15134A016
Person / Time
Site:	Millstone, Browns Ferry, Perry, Saint Lucie, Grand Gulf, North Anna, River Bend, Ginna, South Texas, Fort Calhoun
Issue date:	05/01/2015
From:	Bolt T Nuclear Logistics
To:	Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4
References
Download: ML15134A016 (7)

Text

0510112015 Paop I 050/5U.S. Nuclear Reeulatrv Commision Onerations Center Event Rennrt Pavep Part 21 (PAR) Event# 51030 Rep Org: 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: 05/01/2015 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 ROBERT ORLIKOWSKI 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 This was an unpublished design change that was implemented to replace an obsolete integrated circuit chip. 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. 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

0510112015 12:29 TAX) P.O0011006 A&AZZ NLIN To:

Fax (301) 816- 5151 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 From:

Tracy Bolt Director of Quality Assurance AZZ INLI Nuclear Logistics, Inc.

7410 Pebble Drive Fort Worth, Texas 76118 817-284-0077 Pursuant to 10CFR 21.21 (d) (3) (1i), AZZINLI is providing in the following letter the written notification of the identification of a potential failure to comply.

Total Pages Including this page: 6 NUCLEAR LOGISTICS INC. www.,n.c*om 7410 Pebble Drive Fort Worth, Texas 76118

• 800.448.4124 Phone W 817.590.0484 Fax

0510112015 12:30 P.0021006.

AAZZ NLI" Date: April 30, 2015 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Part 21 Report No: P21-04302015

Subject:

Report of potential 10CFR Part 21, Allen Bradley Timing Relay Model 700RTC 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 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 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:

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. 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. 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.

Page 1 of 5 NUCLEAR LOGISTICS INC. ,www.azz.cem 7410 Pebble Drive e Fort Worth, Texas 76118 o 800.448.4"124 Phone

• 817.500.0484 Fax

0510112015 12:30 TAN) P.0031006 (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.

Between 2009-2010 Allen 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 w1 the definition of a digital device under the guidance of NEI 01-01. See Figures 1 and 2 below:

Figure 1- Original qualified design (prior to 2009).

Relays supplied prior to 2009 are not affected by this issue.

Page 2 of 5

0510112015 12:30 TAX) P.0041006 Figure 2 - New design circuit board and CPLD / that repiaced 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 reportability of the failure to comply that is the root cause for the event.

Page 3 of 5

4 05101/2015 12:30 TAX) P.0051006 (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 2009 to present are identified below.

Plant Name Purchase order Serial Number Browns Ferry 72923-i 29760-001-00003

/ Ginna Station 6617899 51475-001-00001 and -00002, 52656K1-01-0001 4/ Grand Gulf 10304816 34182-001-00001 9 Grand Gulf 10400205 56319-001-00001 r Invensys 4540224951 39228-001-00001 thru -00017 39407-001-00001 thru -00008, 39407-002-00001 thru -

KHNP Y12-0292-010 00005

_Lungmen 874941 IEO07CO 38486-001-00001 and -00002, 38486-002-00001 Millstone 45735761 31998K1-01-0001

'I Millstone 45735761 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 -

z North Anna 70239037 00003 2- 40033-001-00001 and 40033-001-00002, 40033-002-00001 North Anna 70239037 thru -00003 33846-001-00001 thru -00009, 33846-001-00011 thru 5

OPPD Ft Calhoun 155213 33846-001-00015, 33846-002-00002 & -00003 OPPD Ft Calhoun 163495 35941-001-00001 thru -00004 OPPD Ft Calhoun 164936 35891K1-01-0001 thru -0005 OPPD Ft Calhoun 164936 36888-001-0000 1, -00003 thru -00005 OPPD Ft Calhoun 164936 36888K2-01-0001 OPPD Ft Calhoun 177878 39194-001-00001 thru -00006 OPPD Ft Calhoun 182681 40743-001-00001 thru -00003, 40743-002-00001 17 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 South Texas Project 147962 37204-001-00001 thru -00006 Page 4 of 5

4 0510112015 12:30 (FAX) P.0061006 C' South Texas Project 154172 51592-001-00001 thru -00004 qI South Texas Project 171193 57894-001-00001 thru -00006 Z. St Lucia Bechtel PO: 25486-974-FPA-EMRO-00001 385490l100002 thru -00005 (vii) The corrective action which has been, is being, or will he 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 NLI have been placed on hold until after the units have been qualified for the specific application. NLI will perform EMC qualification testing per the requirements of EPRI TR-102323 Rev. 3 for the following tests, as applicable: CEI01, CE102, RE10I, RE102, RS101, RSl03, CSI01, CSI14, CS115 and CSI16. Estimated completion date is August 28, 2015.

(viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given 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 by AZZ. 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 unevaluated EMI/KFI conditions in the plant.

Please contact me with any questions or comments.

Sincerely, Tracy Bo Director of Quality Assurance Page 5 of 5