Part 21 Report - 1995-059
ACCESSION #: 9503100009 Farwell & Hendricks, Inc. February 24, 1995 United States Nuclear Regulatory Commission Mail Stop M/S 0-9A1 Mail: Washington, DC 20555 Express: 11555 Rockville, Maryland 20852 Telephone #: (301) 415-2995 Telecopy #: (301) 415-2968 ATTENTION: Mr. Steven Alexander SUBJECT: Notification of Identification of a POTENTIAL DEFECT Dear Mr. Alexander; Per our discussion of 02/22/95, Farwell & Hendricks, Inc. (F&H) is forwarding this letter to your attention for advice on a future course of action, beyond F&H notifying its clients of a potential problem. Per our discussion it would appear likely that: o The Siemens/ITE MCCBs generally affected are magnetic style HE3AXXXs and HE3L050 (low setting 50 amp) and HE3H050 (high setting) having a 050191 date code. o HE3 style Molded Case Circuit Breakers (MCCBs), date code 050191, after acceptance would probably not fail in service, but may not relatch. Not relatching may result in rendering the equipment in which it is installed non-operational. Therefore, if installed within a technical specification system, it could potentially degrade the operation of the system. This is beyond the capability of F&H to evaluate. o The specific HE3 style MCCB failure appears to be a PREMATURE event after being processed to an acceptance level of mechanical cycles and adjustable instantaneous high and low trips. This premature failure appears coincidental with poor quality workmanship resulting in stripped screws and holes in the trip bar retaining plate, as discussed. The premature failure is probably caused by a marginal latch trip bar "bit". o The HE3 style MCCBs that are potentially subject to premature failures, even though 050191 date code is approximately four years old, could be in the distribution system today since date codes older than five years have been routinely observed. A potential information notice might be beneficial since multiple suppliers could have or could be supplying these MCCBs. USNRC.ltr 02/24/95 Page 1 of 54 4600 East Tech Drive o Cincinnati, Ohio 45245 o (513) 528-7900 o FAX (513) 528-9292 United States Nuclear Regulatory Commission February 24, 1995 Page 2 o F&H, per 10CFR21.21(b) is informing all prior clients of this condition since, F&H has determined that it does not have the capability to perform the evaluation to determine if a defect exists. This is written notification of the initial identification of a POTENTIAL DEFECT which, per 10CFR21,21.3 Definition (d) (4)..., could contribute to the exceeding of a safety limit, as defined in the technical specification of a license for operation issued pursuant to Part 50 of this chapter. This notification is structured per 10CFR21,21.3 (i) and (ii) written notification to the extent known, as if it was a defect. The following written notification (report) is formatted per 10CFR21, section 21.21, paragraph 4. (i) Farwell & Hendricks, Inc. (F&H) at the address listed below is the organization informing the USNRC. Dr. Charles R. Farwell, Jr., F&H Corporate Officer, of the same address is the specific individual informing the USNRC. (ii) The basic component supplied by F&H which contains the defect is the Siemens/ITE molded case circuit breaker style "HE3". Additional information is provided in Attachment A. (iii) F&H is the identification of the firm that supplied the basic component listed above. (iv) The nature of the defect is provided in Attachment A and a PRELIMINARY safety evaluation is provided in Attachment B, although F&H IS UNABLE TO EVALUATE THE SAFETY HAZARD WHICH COULD BE CREATED BY THE DEFECT AS ANY POTENTIAL EFFECT IS "APPLICATION-SPECIFIC", CONSISTENT WITH 10CFR21,21.3 (d) (4). (v) The date on which the information of the potential defect was obtained is 02/23/95. A chronological history and course of events is provided in Attachment C. (vi) The potential specific number and specific site locations of all such devices supplied by F&H is fully compiled and being evaluated. The total list of prior sales is provided in Attachment D. (vii) The corrective action is per the F&H action plan which is provided in Attachment C. USNRC.ltr 02/24/95 Page 2 of 54 United States Nuclear Regulatory Commission February 24, 1995 Page 3 (viii) Advice related to the defect will be provided to all F&H clients with preliminary conclusions in Attachment E. Please know, based on all preliminary findings, F&H concludes this could only be a concern based on unusual circumstances and misapplications of the molded case circuit breaker. Steve, should F&H send a copy of this report to the Operations Desk for log-in purpose? If you should have any questions please feel free to contact Mr. Roy A. Woeste at the telephone number listed below. Written By: Reported By: Mr. John Hendricks, P. E. Dr. Charles R. Farwell, Jr., P.E. Technical Director Chairman/Chief Executive Officer President Mr. Roy A. Woeste Director of Quality Assurance tmw Attachments FARWELL & HENDRICKS, INC. 4600 East Tech Drive Cincinnati, Ohio 45245 Phone: (513) 528-7900 Fax: (513) 528-9292 USNRC.ltr 02/24/95 Page 3 of 54 TABLE OF CONTENTS Section Description Page No. # of Page Cover Letter Written Notification 1 3 Table of Contents Directory 4 1 Attachment A Nature of Defect 5 2 Attachment B Preliminary Safety 7 2 Evaluation Attachment C Chronology of F&H 9 1 Evaluation and Corrective Action Plan Attachment D Preliminary List of All 10 5 HE3 Style MCCBs Sold by F&H Attachment E Preliminary Advice 15 1 Related to the Defect Attachment F FP&L Seismic Test Letter 16 11 Attachment G Generic Seismic Levels 27 27 and Post Functional USNRC.ltr 02/24/95 Page 4 of 54 ATTACHMENT A Nature of Defect on the HE3 Style Siemens/ITE MCCBs The MCCBs involved are manufactured by Siemens/ITE. The styles are magnetic only: HE3AXXXs HE3L050 and HE3H050 (50 amp low or high setting, respectively). Currently this does not generally appear to affect the thermal magnetic MCCB styles HE3BXXXs or HE3MXXXs (50 degrees C rated). The potential defect is defined as a significantly higher percentage of problems specifically related to a 050191 date code. Although a HE3B015, date code 9103, with no loose case screws and proper function had one screw loose on the tie down bar over the trip bar, thereby requiring on- going analysis. These defects included stripped screw holes in the outer case which holds the cover and internal stripped screw holes in the hold down bar for the trip cam assembly. Both cases involve self tapping screws which are installed by the manufacturer into the 'plastic' material of the breaker housing. The term "stripped screw" describes where the hole's plastic threads were stripped. There are two screws, one each holding down a small bar which forms part of the enclosure in which the trip cam rotates. In several cases one or both of these screw holes were found stripped. Front cover screws: The stripped case screws were noted initially by Florida Power & Light Company (FP&L) during removal of the front cover. There are 4 each #6 x 3/4" screws holding the outer cover in place. FP&L reports that most of the time only one of the four screws was stripped, some had two screws stripped, and in rare cases three of the four cover screws were stripped. These were found under either of two conditions, noting a lack of torque prior to removal, or not being able to re-torque these screws upon reinstallation of the cover. The ITE HE3 type breakers were not meant to be repeatedly opened. Discussions with the site technician indicates that the case screws were not always checked for torque prior to removal. Therefore the number of stripped external case screws may not reflect the condition of the screws prior to removal. FP&L was performing a special MCCBs evaluation which included removing the cover from the case, a task not normally performed by FP&L. Stripped screws on the hold-down bar for the trip cam: The internal stripped screws consisted of two #2 x 5/16" screws installed in the plastic body of the breaker, which hold two small 1/8" x 1/2" metal bars in place. In turn, the metal bars are retainers for the trip cam assembly, and forms part of bearing surface when the trip bar rotates. These stripped screws were found by applying a small amount of torque to the installed screws. FP&L indicated that there may be correlation between stripped screws on the hold down bars for the trip cam, and breakers which exhibit resetting problems. USNRC.ltr 02/24/95 Page 5 of 54 ATTACHMENT A - Continued Breakers which exhibit problems with the reset mechanism: FP&L has noted that a number of the ITE HE3 style breaker exhibit problems with resetting. These include complete inability to reset and/or intermittent difficulty to reset. The resetting problem appears to be related to the latch "bit" with the trip bar being marginal. Date Code Limited: Most of the stripped screw problem breakers display an ITE 0591 date code. Farwell & Hendricks, Inc. (F&H) indicates that the ITE HE3 style breaker was manufactured in Wilmington, N.C. from 1986 through 1991. Manufacturing was moved to Bellefontaine, OH approximately in January, 1992. FP&L had placed a large order for ITE HE3 style breakers which were received in 1991. The large size of the FP&L order and the planned impending facility relocation may have had an effect on the large number of problems seen with breakers manufactured in 1991. Random samples of later date codes by FP&L of 92-01 and 92-02 and F&H samples of 0791, 1291 and early 1992, had no indication of stripped screws. Although only limited examples prior to 1991 are available at F&H and FP&L, there has been minimal indication of stripped screws on breakers with date codes prior to 1991. In addition, FP&L Electrical Maintenance has been testing a percentage of the existing installed breakers on a periodic basis and has not noted any failures of this type in the HE3 style breakers installed in the plant. Discussions with FP&L Electrical Maintenance has not indicated any unacceptable trends with respect to failures of the installed ITE HE3 style breakers. Maintenance has reported that they have experience resetting problems with HE3 breakers during testing but prior to installation. Although specifics are not available for these rejected breakers, most failures were in the 1991 batch of breakers in stock, and shows that the Electrical Maintenance testing practices screen out unacceptable breakers. Also, F&H has had no other utility report similar failures prior to FP&L's issue. Since 1991, at FP&L over 50 breakers have been replaced with only a few being due to breaker problems. It should be noted that one failure characteristic attributed to the 1991 batch, the failure to be able to reset the breaker after tripping, is also a common failure on these breakers at end of life. Thermal magnetic breakers are UL type tested for several thousand operations. F&H and FP&L are continuing to evaluate the HE3 style. Today a potential isolated example has occurred wherein a thermal magnetic HE3B015, date code 9103 operated successfully, no loose case cover screws, although one of the two internal screws was stripped as discussed above. In conclusion, it appears to be premature failures on manual reset after 10-20 minimum cycles which appear to coincide with the loose screws holding the metal bar over the top of the trip bar. These loose metal bars seem to coincide with the loose screws on the molded case circuit breaker case and cover which relate to a specific date code of 050191. USNRC.ltr 02/24/95 Page 6 of 54 ATTACHMENT B Preliminary Safety Evaluation (Not All Inclusive) The following evaluation has been conducted to determine that these molded case circuit breakers DO NOT APPARENTLY CONTRIBUTE TO A SUBSTANTIAL SAFETY HAZARD, although it is not all inclusive and each individual utility must evaluate specific application which is defined by their license commitment unique and/or specific applications that F&H would not be aware of: o The manufacturer performs low-middle-high magnetic calibration on adjustable trip, mechanical operations and continuity checks per NRC Inspection Report 99901177/90-01. o The acceptance as a basic component screens out-all-failures via: o Receipt/Inspection o Dielectric withstand o Mechanical cycles of 5 or 6 manual operations o Magnetic only MCCBs are tested per pole on both a high and a low setting NOTE: ALL MCCBs THAT HAVE BEEN ACCEPTED FOR BASIC COMPONENT APPLICATIONS HAVE BEEN CYCLED 10-20+ TIMES. Most utilities check MCCBs for operability prior to acceptance into the system, for example. FP&L Electrical Maintenance has been functionally testing all breakers received from the warehouse prior to installation as standard practice. Testing includes manual operation of the breakers, and electrically testing the trip functions. Any breakers with loose covers, or breakers which exhibit resetting problems, would have detected and rejected by Electrical Maintenance prior to installation. However, Electrical maintenance does not and should not open molded case circuit breakers. Due to the 'loaded spring' design of the circuit breakers any loose parts, poor tolerances, etc. tend to cause these breakers, to trip rather than interfere with the tripping action. There have been no examples of breakers found with problems related to not tripping. USNRC.ltr 02/24/95 Page 7 of 54 ATTACHMENT B - Continued Thus, prior to installation all MCCBs have demonstrated operability and ability to reset. Additionally, molded case circuit breakers are not normally used as ON/OFF switches although they are used to secure power during maintenance or similar evolutions. The resetting problem will occur when the breaker is OFF (or tripped) and in the process of being turned on (closed). At that time the equipment is already out of service and in the worst case would delay the equipment return to service. There is no evidence that the observed defects which would cause the breaker to fail to trip when called upon. Neither the external stripped cover screw holes nor the internal stripped screw holes on hold down bar for the trip cam affect the ability of the breaker to trip. These screws are the only screws in the breakers which are threaded into the plastic housing. The safety function of the MCCB is usually to maintain electric continuity and to open to protect the safety related equipment from nuisance tripping and short circuit protection. Additionally, when remote control activation is required the starter or relay performs the operation and the MCCB is performing its safety function of remaining closed. Thus, F&H took two MCCBS, HE3A010 and HE3A003, that FP&L indicated with both internal screws stripped and free movement of the bars over the top of the trip bar, with one MCCB having stripped case/cover screws as test samples which were: (1) Baseline Tested (2) Seismic Tested to 5 OBE's and 1 SSE site-specific level (3) Post seismic tested (Attachment F) (4) Generic shake table limits test for 5 OBE's and 1 SSE for SQURTs utilities and F&H clients (5) Post seismic tests (Attachment G); after initially being dedicated by F&H, which performed satisfactorily in fulfilling the above safety functions while in the degraded condition. Additionally, reasonable assurance is demonstrated by: (1) limited number of potential MCCBs, HE3 magnetic only manufactured with a date code of 050191 and a few potential related weeks. (2) Existence of redundant safety systems. Therein, preliminarily after MCCBs are acceptance tested, the specific MCCB should not fail in service; Although, they may not relatch and thereby provide the equipment non-operational. USNRC.ltr 02/24/95 Page 8 of 54 ATTACHMENT C Chronology of F&H Evaluation 02/17/95 Received a telephone call from Florida Power & Light Company (FP&L) concerning loose screws and reset problems on the HE3 style MCCBs 02/21/95 FP&L arrives at F&H with the subject MCCB. FP&L and F&H perform evaluations and determines that the MCCB reset performs the safety function before, during and after an earthquake. 02/22/95 F&H has preliminary discussion with Siemens on the subject MCCB and schedules a visit on 03/01/95 to the Siemens Factory at Bellefontaine to aid in determining the root-cause failure. 02/23/95 F&H Contacted the NRC, Mr. Steve Alexander, to discuss technical information. The result of the phone conversation is to send him a letter on "POTENTIAL 10CFR21" due to uniqueness of premature failures. 02/24/95 Generic seismic satisfactory tested same two MCCBs. Mail the NRC a letter. TO BE DONE PER THE ACTION PLAN 02/23/95 Identification of Potential 10CFR21. 03/01/95 Visit the Siemens factory. 03/02/95 Contact F&H clients of the potential 10CFR21 for their evaluation. Before Issue the final evaluation within F&H's capabilities. 04/14/95 USNRC.ltr 02/24/95 Page 9 of 54 ATTACHMENT D "Preliminary List of all HE3 Style MCCBs Sold by F&H," 5 pages, omitted. ATTACHMENT E Preliminary Advice Related to the Defect (Suggestion, Not All Inclusive) 1. The utility needs to evaluate the number of HE3 style MCCBs installed and in the warehouse with respect to date codes. (F&H will provide its clients with F&H provided date codes. Sample attached.) 2. The specific application: - Safety function - Technical specification application - Effect of not re-setting per system application 3. The date range selected, i.e. such as, March through July, 1991 4. Screen all new orders for the above date range. 5. Establish selection criteria before usage of the MCCBs. 6. Inspection of MCCBs to confirm that date code 050191 is the only problem MCCB. NOTE: THE NRC MAY BE ISSUING AN INFORMATION NOTICE ON THIS ISSUE. F&H would appreciate being the central point of coordination and can keep utilities informed of any additional evaluations, date code data and types of data. All correspondence should be addressed to Mr. Dan Kobida. USNRC.ltr 02/24/95 Page 15 of 54 ATTACHMENT F FP&L Seismic Test Letter USNRC.ltr 02/24/95 Page 16 of 54 Farwell & Hendricks, Inc. February 22, 1995 Florida Power & Light Company Turkey Point Nuclear Plant P.O. Box 3088 Florida City, Florida 33054 Telephone #: (305) 246-7215 Telecopy #: (305) 246-6231 Attention: Raj Kundalkar, Engineering Manager Subject: F&H Seismic Test of Siemens HE3A MCCB's per FP&L Condition Report 95-083 Concerning Stripped Screw Holes for The Trip Bar Retaining Plate Dear Mr Kundalkar: Presented herein is a summary of the seismic testing of Siemens HE3A magnetic only MCCB's by F&H to evaluate FP&L concerns of their Condition Report 95-083. In this report FP&L documented Siemens HE3A MCCB's that would not reset after being tripped or manually transitioned. FP&L removed the cover of the MCCB's and inspected the internal mechanisms of the breakers. FP&L identified that on some samples either one or both of the screws securing the trip bar retaining plates were loose. These screws were able be turned freely with a screw driver. They could not be tightened down completely because their holes in the phenolic were stripped. FP&L personnel demonstrated to F&H this anomaly on two Siemens HE3A samples previously provided to FP&L by F&H (F&H Tag 8005804 S/N 67, Siemens P/N HE3A010 and F&H Tag 8005806 S/N 21, Siemens P/N HE3A003). These two samples were then subjected to seismic testing at FP&L site specific levels with the breakers in the "ON" position. This was done to ensure that breakers with this anomaly would not trip spuriously during a seismic event. Five OBE level and one SSE level test were successfully performed. Neither sample tripped during seismic testing. Both items successfully completed baseline and post seismic functional testing. Attached are the SSE level seismic plots, a summary of the functional data, and photographs of the trip bar retaining plate setup inside the breaker. 4600 East Tech Drive o Cincinnati, Ohio 45245 o (513) 528-7900 FAX (513) 528-9292 USNRC.ltr 02/24/95 Page 17 of 54 Thus it is established that Siemens HE3A MCCB's with stripped screw holes of the trip bar retaining plate will not spuriously trip during a seismic event of the attached SSE levels when the breakers are in the 'ON' position. Please let me know if you need any additional information. Sincerely, FARWELL & HENDRICKS, INC. Timothy A. Geers Mark D. McClung Project Engineer Quality Assurance Specialist Enclosure cc: 80058 MF JRH DBK USNRC.ltr 02/24/95 Page 18 of 54 Enclosures consisting of figures, tables and graphs, pages 19 thru 26 of 54, are omitted. Attachment G Generic Seismic Levels and Post Functional The two MCCBs were retested at generic fragility levels. The SSE energized and SSE de-energized are attached. The post functional data is attached. All acceptance criteria were satisfied. The final report number for EPRI-SQURTS members is 50090.9. USNRC.ltr 02/24/95 Page 27 of 54 Enclosures consisting of figures, tables and graphs, pages 28 thru 40 of 54, are omitted. Table "FUNCTIONAL TESTING DATA SHEET FOR MOLDED CASE CIRCUIT BREAKERS," Pages 41 thru 43 of 54, omitted. Table "SEISMIC OPERABILITY DATA SHEET FOR MOLDED CASE CIRCUIT BREAKERS (MCCB)" omitted. USNRC.ltr 02/24/95 Page 44 of 54 Table "FUNCTIONAL TESTING DATA SHEET FOR MOLDED CASE CIRCUIT BREAKERS," Pages 45 thru 50 of 54, omitted. Table "SEISMIC OPERABILITY DATA SHEET FOR MOLDED CASE CIRCUIT BREAKERS (MCCB)" omitted. USNRC.ltr 02/24/95 Page 51 of 54 Table "FUNCTIONAL TESTING DATA SHEET FOR MOLDED CASE CIRCUIT BREAKERS," Pages 52 thru 54 of 54, omitted. *** END OF DOCUMENT ***
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