United States Nuclear Regulatory Commission - Protecting People and the Environment


ACCESSION #: 9703120404



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United Controls

International, Inc.



1554 Litton Drive

Stone Mountain, GA 30083-1302

Phone: (770) 496-0884

FAX: (770) 496-7097



March 7, 1997



Nuclear Regulatory Commission

Document Control Desk

Washington, D.C.  20555



Reference:     Docket No. 50-46 1, 10CFR21 Final Report 21-97-004:

               Phoenix Power Systems Regulated Power Transformer Supplied

               and Qualified by United Controls International



Subject:  United Control Internationals response to the referenced filing



Dear Madam or Sir:



United Controls International (UCI) has carefully reviewed the referenced

10CFR, Part 24 filing, along with the applicable Illinois Power purchase

order (PO552512) and associated specification.  The following comments

are offered in an effort to provide you with information which Illinois

Power failed to report which Illinois Power failed to report.



1.   The referenced document states: "the purchase specification for the

power transformer supplied requires voltage control from the no load

condition to unit rating.  Contrary to this requirement, IP has found

that the transformer is not stable in the no load condition and trips

when lightly loaded under various plant conditions."



     A.  This statement is partially true in that the specification

     (applicable excerpts included as Attachment 1 to this letter, along

     with the purchase order) states in division 3, section 301 that:

     "the transformer shall have a guaranteed output voltage of 117 volts

     +/- 3% over an output power range of 0 to 15 KVA." The transformer

     provided is a Phoenix model P3C015C6/EAN which has operating

     specifications which require it to have a guaranteed output voltage

     of 117 volts +/- 3% over an output power range of 0 to 15 KVA.  The

     transformer is however reliable in the no load condition.  In fact,

     this has been stated in a letter from Phoenix design engineer Todd

     Desiato (see Attachment 2 to this letter). In addition, enclosed is

     a copy of documented functional tests (Attachment 3), for each of

     the transformers supplied, which demonstrates that the transformer

     did perform reliably, within spec. requirements at no load.



Page Two



2.  The referenced document states: "IP has been advised by the

manufacturer that the transformer units require a minimum load of 2 amps

per phase to remain stable." This statement is misleading in that the

transformer does skip from one tap to another, basically hunting for a

load, when it is unloaded; however, the transformers input circuit

breaker does not trip under these conditions.  The transformer does

perform reliably and provide the required output while under no load

conditions as discussed in point 1, above.  What is not mentioned by

Illinois Power in the referenced Part 21 filing is that it was determined

that the problem occurring, at Clinton Power Station, with these

transformers was an EMI/RFI susceptibility problem.  When the

manufacturer of the transformer (Phoenix Power Systems) was contacted,

Illinois Power had provided them with a recorded output waveform that

identified some type of spikes or noise occurring on the output of one

phase of the transformer, just prior to the transformers input breaker

tripping.  Phoenix, upon review of this waveform, recommended to Illinois

Power to apply a minimum load (approximately 5% of full load) in order to

provide stable operation.  Phoenix made an assumption that the increased

output current would decrease the affects of the apparent noise and

therefore "stabilize" transformer operation.  This approach did not

reliably fix the problem; therefore, Illinois Power requested United

Controls via Purchase Order PO704980 (Attachment 4) to perform EMI/RFI

testing on the transformer in order to determine problem frequencies and

resolve the tripping problem.



3.   The referenced document states on page 2 section vii that: "IP and

representatives of United Controls are working on a network of

filters/surge suppressors and minimum load resistors to eliminate the

tripping problem." This is true; however, the effort has been temporarily

hatted by Illinois Power.  Again the purpose of this "network" is to

resolve the EMI/RFI susceptibility problem with the transformers as

stated in point 2, above.  It should be noted that the original purchase

order and specification to United Controls (see Attachment 1) did not

request EMI/RFI testing to be performed.



United Controls International believes that the above comments as well as

the attached documentation of the involved purchase order and

specifications provides documented evidence that all transformers

provided to Illinois Power meet the requirements of the applicable

purchase order.  If you have any further questions in regard to this

issue or need any additional information, please feel free to contact

Mike LeBlanc, Director of Nuclear Engineering, Deborah Butler, QA Manager

or me (Ben Camp).



Sincerely;



Ben Camp

President, United Controls International



cc:  Mike LeBlanc (UCI)

Deborah Butler (UCI)



                              ATTACHMENT 1



Attachment "Purchase Order Forms, 4 pages" omitted.



                  DRY TYPE REGULATED POWER TRANSFORMERS



DIVISION 3 - Technical Requirements



301  Each transformer shall be a self contained, dry type regulating

     transformer, three phase, 60 Hertz 15 KVA with input voltage of 480

     volts +/- 15%, and a guaranteed output voltage of 117 volts +/- 3%

     over an output power range of 0 to 15 KVA.  The regulating

     transformers shall be qualified 1E per IEEE 323 and Clinton Form

     1999-D.  The Vendor must supply, supporting documentation and test

     results prior to shipment.



302  The environmental and radiation qualification conditions are

     specified as follows:



                           NORMAL            ABNORMAL            LOCA

     a.   Temperature:    50-90 degrees F   104 degrees F   104 degrees F

     b.   Pressure:      Atmosphere       +/-0.5 in W.G.   +/-0.5 in W.G.

     c.   Relative         30-90%            5-90%              5-90%

          Humidity:

     d.   Radiation

          Integrated

          radiation

          exposure for

          Gamma and

          Beta:           1X10**84 Rads    1X10**4 Rads     1X10**4 Rads

          Neutron:         Negligible       Negligible       Negligible



303  Transformer conduit entrance shall be furnished to allow back and

     top entry for incoming 3/C - #19/22 1KV Cable and outgoing 3/C - #2

     1KV Cable.



     The maximum conduit size to be used is 3 in.



304  Transformers shall be designed for floor mounting.  The floor

     dimension's shall be 21" X 19" d and must not be altered without

     approval of the purchaser.  The transformers must be seismically

     qualified so the Purchaser can choose to mount the transformer to

     the floor using bolting or welded connection.  The Contractor must

     supply the purchaser with the mounting detail used to qualify the

     transformers.



305  The transformer shall include an over voltage protection device

     which will trip the transformer, if the output exceeds a preset

     valve.  The trip device must be suitable between 120 and 125 volts.



     The Vendor must supply accuracy data so the Purchaser can perform a

     set point calculation per Instrument Society of America standard

     S67.04-88 "Set Points for Nuclear Safety Related Instrumentation."



haumann/183/11r



The revisions to section 301 and 305 of the specification for DRY TYPE

REGULATING TRANSFORMERS that is part of Illinois Power Company's purchase

order PO552512 with United Controls International are being made so that

United Controls can deliver a product that will meet IP's needs.  These

changes are at the request of United Controls and are, therefore, not in

addition to the original IP order. There will be no additional charge

associated with these changes.  The revised Sections 310 and 305 are to

read as follows:



                  DRY TYPE REGULATED POWER TRANSFORMERS



     DIVISION 3 - Technical Requirements



301  Each transformer shall be a self contained, dry type regulating

     transformer, three phase, nominal 480V delta 202/117V wye, 60 Hertz,

     15 KVA, The transformer shall be capable of operating with an input

     voltage between 530.4 and 414 volts, while maintaining a guaranteed

     output voltage between 113.5 and 121 volts over an output power

     range.  The regulating transformers shall be qualified 1E per IEEE

     323 and Clinton Form 1999-D. The Vendor must supply supporting

     documentation and test results prior to shipment.



305  The transformer shaH include an over voltage protection device that

     will protect the 120 volt level equipment from extended periods of

     over voltage.  The over voltage protective device must trip (shut

     down) the transformer if the output exceeds a pre-set value.  The

     Transformer over voltage trip must be manually reset.  The

     protective device must trip prior to the output exceeding 124.5

     volts, but not less than 121.  It shall have a time delay of

     sufficient duration to allow the regulator to ride through both

     supply voltage transients and low side step load changes.  The

     transient is expected to last between 10 and 60 cycles.  Therefore,

     the over voltage trip device shall have a delay of about 1 second.



     The transformer may have an under voltage trip (due to low input

     voltage) provided the trip a resets prior to the input voltage

     reaching 408 volts



                                   3-1



                              ATTACHMENT 2



PHOENIX POWER SYSTEMS



Innovation and Excellence in Power Protection



10547 Viper Way, San Diego, California 92121

619/ 450-9820 Fax 619/ 450-9662 Web Page: http:f/www.phoenixpower.com



FACSIMILE COVER SHEET



To: Mike LaBlanc                        From: Todd Desiato



Fax: 770-496-7097                       No. Pages: 1



Date: 03/07/97 1:05 PM                  CC: A/ Bagherian



Re: 15kVA Regulating Transformer



Dear Mr. LaBlanc,

This is a summary of our conversation of 3/7/97.  The 15kVA Regulating

Transformers provided by Phoenix Power will operate within the specified

117 Vac +/- 3% for an output load of zero to 15KVA. Having no liked

applied will not cause the circuit breaker to trip.  Our investigation

has shown that the circuit breaker trips due to EMI being fed back from

the low, and a filter applied to the output if the transformer will solve

the problem.  When we were informed that Illinois Power was having a

Problem with the circuit breaker tripping, it was suggested that a

minimum resistive load be applied to determine if the poor quality output

load waveform that we were shown was the cause of the problem.  The

result was that the minimum load helped delay the tripping but the unit

still tripped.  I hope this clarifies your situation.  Please call me if

you need further assistance.



Sincerely,



Todd Desiato

Chief Engineer



                              ATTACHMENT 3



Attachment "DATA SHEET FOR FUNCTIONAL TESTING OF POWER TRANSFORMER,

[20

pages]" omitted.



                              ATTACHMENT 4



                             Fax Cover Sheet



ILLINOIS POWER COMPANY



CLINTON POWER

STATION



POST OFFICE BOX 678

CLINTON, ILLINOIS 61727



DATE                               TIME:



ATTENTION



COMPANY



TELECOPY:



FROM:     LINDA DEGROFFT           PHONE: 217-935-8881, EXT 3839

                                   FAX:  217-935-4258



NUMBER OF PAGES          + COVER SHEET



NOTES:



Attachment "Purchase Order Forms, [10 pages]" omitted.



             EXAMPLE OF DOCUMENTATION CODE [ILLEGIBLE PRINT]



                 CERTIFICATE OF CONFORMANCE REQUIREMENTS

                  (COMPONENT PURCHASES THAT DO NOT HAVE

                 ALL NECESSARY CHARACTERISTIC SPECIFIED



Your each heat of materials, lot of material, or item delivered, the

supplier shall provide a certification that the item conforms to all of

the requirements of the Purchase Order for that item.  The certification

shall identify the part number(s), serial number(s), lot number(s), etc.

(when used), as well as the drawings, specifications, codes, and

standards, to which that item conforms.  The date, title, and signature

of the responsible individual in the supplier's organization shall appear

indicating acceptance of the document(s).  The document(s) shall

reference the IP Purchases Order Number (and item number, if required, to

assure traceability), or other traceable identification number.



The vendor shall certify that the part being supplied meets the

requirements for form, fit, function, material, and manufacturing process

identified by the vendor's drawing/part numbers specified on this

Purchase Order.



                                                        [Illegible print]



                                   March 18, 1996



ILLINOIS

     POWER



To:  All Vendors and Suppliers



     The message at the beginning if this Order contains come very

important information, designed to help you process our requirements.



     Items two (2) through four (4) are self-explanatory and generally do

not pose a problem with filling orders.



     Item one (1) and its intent is the purpose of this notice.



     "Ship no substitutions without prior approval" is the paragraph  you

need to understand.



     If what you intend to ship to us is not and EXACT MATCH to the

description and the part number in the purchase Order DO NOT SHIP IT.



     Please call the Buyer shown on the last page of the Order

immediately and notify him/her of the discrepancy.  You will receive

further instructions at that point.



     WITH FEW EXCEPTIONS, IF WHAT YOU SHIP DOES NOT MATCH THE

DESCRIPTION

ON THE ORDER, PAYMENT OF YOUR INVOICE WILL BE DELAYED.



     We don't want that  and neither do you.



     Thank you for your cooperation.



                                        Regards,



                                        Nuclear Purchasing Team



Form "SELLER QUALITY ASSURANCE PROGRAM REQUIREMENTS, PURCHASE

ORDER [2

pages]" omitted.



*** END OF DOCUMENT ***



Page Last Reviewed/Updated Thursday, March 29, 2012