ML15205A293

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Potential Part 21 Report Regarding Bradley Failure to Document Design Change, Per Fort Calhoun Station
ML15205A293
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 07/20/2015
From: Hale R
United Controls International
To:
Office of Nuclear Reactor Regulation, NRC/RGN-II
References
Download: ML15205A293 (6)


Text

0712112015 U.S. NuclearRegulatory Commission OperationsCenter Event Report Pa-ve I Part 21 (PAR) Event# 51243 Rep Org: UNITED CONTROLS INTERNATIONAL Notification Date / Time: 07/20/2015 16:48 (EDT)

Supplier: UNITED CONTROLS INTERNATIONAL Event Date / Time: 06/03/2015 (EDT)

Last Modification: 07/20/2015 Region: 1 Docket #:

City: NORCROSS Agreement State: Yes County: License #:

State: GA NRC Notified by: WILLIAM MALLIA Notifications: MICHAEL F. KING R2DO HQ Ops Officer: JEFF HERRERA HEATHER GEPFORD R4DO Emergency Class: NON EMERGENCY PART 21/50.55 REACTORS EMAIL 10 CFR Section:

21.21(a)(2) INTERIM EVAL OF DEVIATION POTENTIAL PART 21 - ALLEN BRADLEY FAILURE TO DOCUMENT DESIGN CHANGE The following information is excerpted from an email received from United Controls International:

"[In] August 2014, United Controls supplied four (4) time delay relays to Omaha Public Power-Fort Calhoun Station. The subject relay was qualified in accordance with IEEE 323-74/83, IEEE 344-1975/1987 and IEEE C37.98-1987, for use in mild environment safety related applications.

"Per NRC Part 21 notifications, UCI was informed that the Allen Bradley relays base model 700RTC contain a Complex Programmable Logic Device (CPLD) which was unpublished. This design change could not be noticed since the external appearance of the relay and the relay part number remained the same. Hence, UCI has qualified the subject relay as solid state relay whereas the presence of the CPLD device elects the item as a digital device which can be affected by EMI/RFI noises.

"At this time, UCI has no sufficient information to determine whether this design change would create a Substantial Safety Hazard as it relates to the plant applications for the subject relay.

"Per the Nutherm Part 21 ML15161A230, Allen Bradley has indicated that a rolling change occurred from mid-2009 with no specific manufacturing date to distinguish between the old and the new configuration. Hence, all units manufactured during 2009 and later are suspect.

"If you have any questions or wish to discuss this matter or this report, please contact:

"Jim Garrison "Engineering Manager

07/21/2015 U.S. NuclearRegulatory Commission Operations Center Event Report Page 2 "jgarrison@unitedcontrols.com "770-496-1406 x 103" Affected facility: Omaha Public Power-Fort Calhoun Station Part Number: 700-RTC-11200U1 Quantity: 4

, UCI DATA TRANSMITTAL DATE: July 20, 2015 TO: NRC OPERATIONS FROM: William Mallia/UCI CENTER FAX: 301-816-5151 FAX: 770-496-1422 EMAIL: HOO.HOC@NRC.GOV EMAIL: wmallia@unitedcontrols.com TEL: 301-816-5100 TEL: 770-496-1406 x 148 cc: Interim letter PAGES: 4 pages with cover page COMMENTS:

PLEASE SEND A MESSAGE OF RECEIPT TO VERIFY THAT THE EMAIL TRANSMITTAL HAS BEEN RECEIVED.

THANK YOU, WILLIAM MALLIA

UNITED CONTROLS INTERNATIONAL 10CFR21 INTERIM LETTER July 20, 2015 U.S. Nuclear Regulatory Commission Document Control Desk Washington D.C. 20555-0001

Subject:

Report of Potential Part 21 on Allen Bradley Time Delay Relay 700-RTC-1 1200U1.

The purpose of this letter is to provide the NRC with a report in general conformity of the requirements of 10CFR Part 21.21. On August 2014, United Controls supplied four (4) time delay relays to Omaha Public Power - Fort Calhoun Station. The subject relay was qualified in accordance with IEEE 323-74/83, IEEE 344-1975/1987 and IEEE C37.98-1987, for use in mild environment safety related applications.

Per NRC Part 21 notifications, UCI was informed that the Allen Bradley relays base model 700RTC contain a Complex Programmable Logic Device (CPLD) which was unpublished. This design change could not be noticed since the external appearande of the relay and the relay part number remained the same. Hence, UCI has qualified the subject relay as solid state relay whereas the presence of the CPLD device elects the item as a digital device which can be affected by EMI/RFI noises.

At this time, UCI has no sufficient information to determine whether this design change would create a Substantial Safety Hazard as it relates to the plant applications for the subject relay.

Required information as per 10CFR Part 21.21 (d)(4) follows:

(i) Name andAddress of the individualor individuals informing the Commission Rob Hale President United Controls International 205 Scientific Drive Norcross, GA 30092 (ii) Identification of the facility, the activity, or the basic component suppliedfor suchfacility or such activity within the United States which fails to comply or contains a defect.

The item was supplied to Omaha Public Power-Fort Calhoun Station under Purchase Order 00205846.

Page 1 of 3

UNITED CONTROLS INTERNATIONAL (iii) Identification of thefirm constructingthe facility or supplying the basic component which fails to comply or contains a defect.

United Controls International 205 Scientific Drive Norcross, GA 30092 (iv) Nature of the defect orfailure to comply and the safety hazard which is created or could be createdby such defect orfailure to comply.

Allen Bradley made an unpublished design change by adding a CPLD device which by nature is a digital device but failed to document this design change. The part number and the outer appearance of the relay remain unchanged which is not indicative of any difference in internal configuration. Per the Nutherm Part 21 ML15161A230, Allen Bradley has indicated that a rolling change occurred from mid-2009 with no specific manufacturing date to distinguish between the old and the new configuration. Hence, all units manufactured during 2009 and later are suspect. UCI has no sufficient information for determining whether this condition could lead to substantial safety hazard as it relates to the plant applications for the subject 700RTC time delay relay.

(v) The date on which the information of such defect orfailure to comply was obtained.

This information was initially obtained on June 3, 2015.

(vi) In the case of a basic component which contains a defect orfails to comply, the number and location of these components in use at, suppliedfor, beingsupplied for, or may be suppliedfor, manufacturedor being manufacturedfor one or morefacilities or activities subject to the regulationsin this Part.

Part number Utility Purchase Order Quantity 700-RTC-1 1200U1 OPPD- Fort 00205846 4 Calhoun Station (vii) The correctiveaction which has been, is being, or will be taken; the name of the individualor organizationresponsiblefor the action; and the length of time that has been or will be taken to complete the action.

At this time, UCI does not have sufficient information for determining whether this condition would have created Substantial Safety Hazard as it relates to the plant application (s) for this relay. OPPD is responsible for evaluating the condition and for determining the necessary corrective actions.

  • (viii) Any Advice relatedto the defect orfailure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasersor licensees.

EMI/RFI tests need to be performed on the relay.

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UNITED CONTROLS INTERNATIONAL (ix) In the case of an early site permit, the entities to whom an early site permit was transferred.

Not Applicable.

If you have any questions or wish to discuss this matter or this report, please contact:

Jim Garrison Engineering Manager jgarrison@unitedcontrols.com 770-496-1406 x 103 Sincerely, Rob Hale President United Controls International Page 3 of 3