Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
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 ***
