ML24281A066
| ML24281A066 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/04/2024 |
| From: | Dunkelberger M MPR Associates |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 57363 | |
| Download: ML24281A066 (1) | |
Text
10/04/2024 FRI llo 38 FAX Date:
From:
To;
(+]MPR Company; CELEBRATING6QYEARS Fax; Phone:
Subject:
October 4, io24 Michael K. Dunkelberger, MPR qA Director Document Control Desk U.S. Nudear Regulatory Commission (301) 816-5151 N/A 10 CFR Part 21 Report Submittal
- rota I Pages: s pages including cover sheet Message:
li.l]0 0 1/00 5 The purpose of this fax Is to submit a 10 CFR Part 21 Report in accordance with the requirements of 10 CFR Part 21.
This 10 CFR Part 2-1 Report provides the required information regarding incomplete dedication activities performed on contactors supplied as basic components.
The details regarding this submittal are provided In the pages attached.
If you have any questions, please contact the undersigned identified in this report.
320 KING STREET ALEXANDRIA, VA 22314-3230 703,519-0200 FAX: ra:,.SHl-0224 www.mpr.QQm
10/04/2024 FRI llo 38 FAX Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
- MPR
Subject:
Report in Accordance with 10 CFR Part 21
Dear Sir or Madam:
October 3, 2024 0321-PRT21-RPT-001, Rev. 0 The attached 10 CFR Part 21 Report provides the required information regarding incomplete dedication activities performed on contactors supplied as basic components.
If you have any questions, please contact the undersigned.
Sincerely, IL Robert Coward Principal Officer Attachment li.l]002/005 320 KING STREET AleXANO~IA, VA 22314-3230 703-519-0200 FAX: 703-519-0224 http://www.mpr.com
10/04/2024 FRI llo 38 FAX llaMPR Attachment to MPR Letter dated October 3, 2024 0321-PRT21-RPT-001, Rev. 0 10 CFR Part 21 Report on Incomplete Dedication of Contactors Supplied as Basic Components This attachment provides the infonnation required for reporting a failure to comply in accordance with 10 CFR Part 21.
- 1.
Reporting Individual Robert Coward, Principal Officer MPR Associates, Inc.
3 2 0 King Street Alexandria, VA 22314
- 2.
Identification of the Basic Components that Fail to Comply The basic components that fail to comply are contactors with the following manufacturer part numbers from ABB.
AFI 16-30-11-13 AFS0-30-11-13 li.l]003/005 These contactors were supplied by MPR for use as replacement Kl and K2 contactors in the emergency diesel generator (EOG) excitation systems installed at Beaver Valley Power Station and Davis-Besse Nuclear Power Station.
- 3.
Identification of the Supplier MPR Associates (headquarters in Alexandria, VA) performed commercial grade dedication to supply the contactors as basic components.
- 4.
Nature of the Failure to Comply 4.1. Nature of the Fa/lure to Comply MPR was not aware that the contactor design includes a microcontroller in the circuit that energizes the contactor coil and did not verify critical characteristics associated with software dependability when the commercial grade dedication activities were perfonned. Once aware of the microcontroller, MPR attempted to obtain information from the commercial manufacturer to verify the software critical characteristics but was unsuccessful.
10/04/2024 FRI llo 38 FAX li.l]004/005 4.2. The Safety Hazard Created by the Failure to Comply MPR is not aware of any design deficiency that would prevent the contactor from functioning properly. The critical characteristics associated with the physical and functional attributes of the contactors were verified as part of the MPR commercial grade dedication process. However, the inability to verify the critical characteristics for sotlware dependability prevents the items from being fully dedicated as basic components. As a result, the ability of the contactor to perform reliably throughout its service life is uncertain.
The safety function of the KI contactor at Beaver Valley is to permit excitation during EDG start-up and operation by not being in an energized state. The primary function of the K 1 contactor is to change state to short the input to the rectifier upon an EOG shutdown signal for shutting down the excitation system.
The safety function of the Kl contactor at Davis-Besse is to permit excitation during EOG start-up and operation and field flashing during EDG start by not being in an energized state. The primary function of the Kl contactor is to change state to short the input to the rectifier upon an EDG shutdown signal for shutting down the excitation system. Additionally, the KI at Davis-Besse includes an electrical interlock to prevent field flashing when the excitation system is shut down and to permit field flashing when the excitation system is in standby.
The safety function of the K2 contactor at both plants is to enable battery voltage to be applied to the generator field during an EOG start. Additionally, the K2 contactor isolates the station or diesel batteries from the excitation system output and the generator field during nom1al operation and shutdown.
- 5.
Date the Information was Obtained On August 9, 2024, MPR received an email from an ABB representative, which indicates the AF80 and AF 116 contactors use a microcontroller. This infonnation was different from what was obtained when the contactors were originally supplied by MPR. MPR initiated Condition Report CR-24-052 on August 9, 2024. On August 21, 2024, MPR disassembled an AF80 contactor and confirmed there is a microcontroller in the design.
- 6.
Number and Location of these Basic Components Supplied MPR supplied two (2) ABB AF 116-30-11-13 contactors to be utilized as Kl contactors and two (2) ABB AF80-30-1 I-L3 contactors to be utilized as K2 contactors in the emergency diesel generator excitation systems at Beaver Valley Power Station. The plant indicates that one set of K 1 and K2 contactors was installed in the excitation system for one EDG at one u11it.
MPR supplied five (5) ABB AFl 16-30-11-13 contactors to be utilized as Kl contactors in the emergency diesel generator excitation systems at Davis-Besse Nuclear Power Station. The plant indicates that none of these contactors were installed.
- 7.
Corrective Action Plan MPR notified the affected plants of the situation. MPR attempted to obtain information from the commercial manufacturer to verify the software critical characteristics but was unsuccessful.
10/04/2024 FRI llo 39 FAX MPR is currently working to provide information to support continued use of the installed contactors. MPR is also working to identify a replacement contactor that is suitable for the application.
- 8.
Advice Given to Purchasers or Licensees li.l]005/005 Digital technologies are being introduced in commercial devices that were previously analog.
Commercial suppliers may not be willing to share design information needed to support commercial grade dedication activities or to understand the extent of design changes i11troduced in new models. Purchasers and licensees must maintain a questioning attitude and may need to disassemble a commercial item to ensure information obtained from commercial suppliers is accurate.
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