IR 05000416/1979015

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IE Insp Repts 50-416/79-15 & 50-417/79-15 on 790724-0824. Noncompliance Noted:Current GE QA Program Onsite Did Not Meet Requirements of ANSI N45.2-1971
ML19260D610
Person / Time
Site: Grand Gulf  
Issue date: 10/16/1979
From: Conlon T, Walters D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19260D572 List:
References
50-416-79-15, 50-417-79-15, NUDOCS 8002110505
Download: ML19260D610 (15)


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UNITED STATES 8

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NUCLEAR REGULATORY COMMISSION

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ATLANTA. GEORGIA 30303

OCT 181979 IE Inspection Report Nos. 50-416/79-15 and 50-417/79-15 Subject: Mississippi Power and Light Grand Gulf Nuclear Plant Docket Nos. 50-416 and 50-417 Concerns regarding inspection of Power Generation Control Complex cable assemblies.

Period of Inspection: July 24-August 24, 1979

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D. K. Walters,(Reactor Inspector, Daf.e Signed Reactor Construction & Engineering Support Branch Accompanying Personnel:

N. Merriweather, Intern, Reactor Construction & Engineering Support Branch Approved by.

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/o-/6-77 T. E. Conlon, Section Chief Date Signed Reactor Construction & Engineering Support Branch 5 n8 1 10)

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TABLE OF CONTENTS I. INTRODUCTION II. SCOPE OF INSEECTION III. CONCLUSIONS IV. DETAILS OF INSPECTION A.

Persons Contacted B.

Exit Interview C.

Concerns, Discussion and Findings I.

Concerns 2.

Discussion 3.

Findings 1, O K.

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I.

INTRODUCTION On February 23, 1979, Mississippi Power and Light (MP&L) Company notified region II by telephone of a Potentially Reportable Deficiency (PRD) regarding General Electric (GE) supplied Power Generation Control Complex (PGCC)

cable assemblies. MP&L PRD number 79-04 identified inadequate crimping of pins in the connectors of PGCC cable assemblies.

In February, 1978, GE initiated an on-site inspection program at Grand Gulf to identify and correct inadequately crimped connector pins and nicked, cut conductor insulation in PGCC cable assemblies.

The initial inspection procedures requred 100 percent disassembly of the connectors to inspect for defi-ciencies.

In June 1979, GE revised the on-site inspection program which significantly reduced inspr w 1 requirements.

GE's revised inspection program was discussed with MP&L QA representatives, and Bechtel engineering and QA representatives.

Although MP&L expressed concerns about the program which are documented in MP&L letter GEMP-79/70 and requested GE resolution, the revised program was implemented.

On July 5, 1979, MP&L met with site electricians who expressed concerns about the PGCC cable inspection and repair program. MP&L documented thes-concerns and initiated ef forts to have each item evaluated and resolved.

On July 19, 1979, NRC Region II received a letter from an individual expressing concerns (identified in paragraph IV.d) regarding General Electric's cable inspection program at Grand Gulf.

An inspection was initiated on July 24, 1979, into the concerns.

During the periods of July 24-27, 1979, and August 21-24, 1979, the inspectors were on site and contacted five MP&L QA representatives, six GE representatives, three GE QC inspectors, three Bechtel representatives and 6 electricians of a GE sub-contractor.

In addition, the inspectors examined PGCC cable inspection procedures and records and observed work and work activities associated with inspection, test and repair of PGCC cable assemblies.

At the conclusion of each on-site inspection effort, the inspectors met with representatives of MP&L, GE and Bechtel and discussed the preliminary results of the inspection.

This inspection was conducted under the authority provided by Part 1.6.4, Title 10, of the Code of Federal Regulations and required a total of 108 man-hours of onsite inspection effort.

II.

SCOPE OF INSPECTION The scope of the inspection included the following:

A.

Review of procedures and inspection records.

B.

Review of statistical sampling and analysis results 4 04 1 1Od

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C.

Review of GE test results of low strength mechanical crimps and nicked, cut conductor insulation.

D.

Observation of onsite work and work activities associated with inspection and repair of PGCC cable assemblies.

III. CONCLUSIONS The concerns were substantiated. The inspection resulted in one infraction and eight unresolved items and one inspector follow-up item.

All are discussed in paragraph IV.C.2.

IV.

DETAILS OF INSPECTION A.

PERSONS CONTACTED Licensee Employees s

  • T. E. Reaves, Manager of QA
  • P. W. Sly, QA Field Supervsior
  • W. E. Edge, QA Program and Audits Coordinator
  • B. C. Lee, Electrical QA Representative
  • J. C. Fuller, QA Representative Other Organizations
  • J. R. Valdez, QA Engineer (Bechtel)
  • R. L. Scott, Manager of QA (Lechtel)
  • J. K. Conway, Assistant Project Field QC Supervisor (Bechtel)
  • W. M. Barrentine, Manager, Control Room Engineering (GE)
  • B. E. Woodward, Manager, PGCC Field Programs (GE)
  • P. M. Briggs, Principle QC Engineer (GE)
  • P. F. Mcdonald, Manager, Electrical Services (GE)
  • W. A. Shanks, Resident Site Manager (GE)
  • D. L. Thompson, QC Supervisor (GE)

Other personnel contacted included three QC inspectors and six electricians.

  • Attended one or both exit interviews conducted on July 27, 1978 and August 24, 1978.

B.

EXIT INTERVIEW The preliminary findings of the inspection were summarized on July 27, 1979 and August 24, 1979 with those persons indicated in paragraph IV.A above. The eight unresolved items listed below were discussed in detail. The nonconformance and inspector followup item listed below were not discussed because they were identified subsequent to August 24, 1979, during additional review of licensee commitments. The licensee was informed by telephone on September 18, 1979, of these two items.

1.

Unresolved item 416/79-15-01 and 417/79-15-01, Aging effects on electrical properties of low force pin crimps, 12.b snai

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2.

Unresolved item 416/79-15-02 and 417/79-15-02, Aging effects on conductor insulation.

3.

Unresolved item 416/79-15-03 and 417/79-15-03, Aging effects on connector clamp strength.

4.

Unresolved item 416/79-15-04 and 417/79-15-04, Shield wires not pull tested.

5.

Unresolved item 416/79-15-05 and 417/79-15-05, Environmental affects on hipot test results.

6.

Unresolved item 416/79-15-06 and 417/79-15-06, Broken wire strands inside pin barrel.

7.

Unresolved item 416/79-15-07 and 417/79-15-07, Evaluation of cable outer jacket damage.

8.

Unresolved item 416/79-15-08 and 417/79-15-08, Rework of cable failing continuity check.

9.

Infraction 416/79-15-09 and 417/79-15-09, Failure to meet Mil-spec requirements.

10.

Inspector follow-up item 416/79-15-10 and 417/79-15-10, Failure to meet ANSI N45.2 requirements.

C.

CONCERNS, DISCUSSION AND FINDINGS 1.

CONCERNS:

General Electric, the nuclear steam supply system supplier, employed Tompkins and Beckwith of Jacksonville, Florida, to make a visual inspection and to start making corrections on problems found with PGCC cables. When many of the connectors were broken down, the pins would fall out in your hand, having not been properly crimped to the wire. As many as 36 out of a 48 pin connector often failed a pull test.

Many pins were bent and would not make an electrically secure connection when mated with another connector. The only way to find and determine if a pin is bent, in most cases, is to visually inspect said pin. The procedure set in motion by Thompkins and Beckwith, at first, was an inspection which consisted of breaking down each connector and re-assembling 100 percent.

To examine and correct all of these cables and connectors is time consuming and costly. Each week, General Electric has come up with new proced:% s - lowering the number of pins to be tested and passing over some cables completely.

The method now being used to pull test the pins without breaking down the connectors

is doubtful, at the very best and does not follow sound electrical i,OfI

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The method of percentage testing might suffice in other fields, but we are talking about the systems that operate, control and shut down the whole plant.

2.

DISCUSSION:

GE Field Disposition Instruction (FDI) number WAGN provides a.

the general requirements for inspection and repair of PGCC cables. FDI number WAGN invokes procedure II CA-010, " Field Cable Inspection" which provides specific requirements for inspection and repair.

Iritially procedure II CA-010 did require 100 percent breakdown and reassembly of the connectors for inspection and repair.

The procedure consists of an exterior visual inspection, an interior visual inspection, a pull test, an electrical test and a reassembly inspection.

Specific requirements of the initial procedures consisted of the following:

(1) Visual Inspection (Exterior):

(a) Inspect the shell of the connector to ensure that the connector, receptacle, shell and clamp (strain relief) were tight with each other.

(b)

Inspect the connector for concentricity and and capability of fitting to mating panel connector.

(c)

Inspect the cable jacket for defects of a depth no greater than 1/3 of the jacket thickness.

(d) Inspect the strain relief clamp for tightne.ss and to ensure that at least 1/3 of the clamp width engaged the ca51e jacket.

(e)

Inspect the rubber boot to ensure tightness to the cable to prevent connector rotation on the cable.

(2) Visual Inspection (Interior):

After disassembly of connector backshell, inspect the following:

(a) Inspect each conductor to ensure that there were no gouges, nicks or cuts visible on conductor insulation.

(b)

Inspect shrink tubing on conductors to ensure that shrink tubing was free of splits and tight on conductors.

(c)

Inspect solder on shields or pins to ensure that the joint was unbroken with firm adherance between the shield / pin and wire.

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(3) Pull Test. Af ter extracting each pin from one end of the cable, the following visual inspections were per-formed.

(a)

Inspect each pin to ensure the pin was not damaged (e.g., bent or deformed).

(b) Inspect each contact to ensure that the contact was not split by or near the crimp connection.

(c) Perform pull test of each crimped connection o

using an adapter affixed to the pin and a pull test gage.

Initial pull test acceptance values were 45 pounds for 16 AWG wire and 20 pounds for 20 AWG wire.

(4) Electrical Test (a) Test each conductor and shield for continuity from end to end.

(b) Perform high potential (Hipot) testing of ecch cable.

(5) Reassembly Inspection.

After reassembling connectors per GE's Cable Assembly Instruction Manual, the following inspections were performed.

(a) Verified that the condition of the shell was concentric and capable of fitting to the mating panel connector.

(b) Verified that the rubber boot and strain relief clamp were tight on the cable and that the cable could not rotate in the clamp.

(c) Verified that all pins were seated firmly and equal distant in the insulator.

Any deficiencies discovered during the inspection were repaired in accordance with procedures specified by procedure II CA-010.

b.

GE's Principal QC Engineer stated that Grand Gulf was the only site at which a 100 percent inspection program was initiated. The intial objective was to perform a 100 percent inspection of Grand Gulf, determine the extent of the PGCC cable deficiencies, and incorporate the resultant data into inspection programs for other sites. After initiating the Grand Gulf program, GE decided that the inspection procedures were too strict and resulted in a high number of unnecessary rejects. For example, GE feels that damaged pins resulted 3 nii i{3

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from on-site handling since a " roll-up" inspection is per-formed which checks for bent pins during preparation of cable assemblies prior to shipping.

Another example given was the use of vulkene insulation which is sof ter and more pliable tha-tefzel insulation and is therefore more susceptible to damage. Grand Gulf is the only site at which vulkene insulation is used in PGCC cable assemblies. GE has periodically revised the procedure based on the following:

the result of unavoidable and unnecessary damage to connector assemblies during inspection for " workmanship" defects which had little or no impact on functional operation; the results of tests conducted at GE's manufacturing facility, and the results of statistical analysis.

A comparison of the revised procedure requirements with the initial requirements is provided below:

(1) Visual Inspection (Exterior)

(a) Added a Cannon 12-gage socket pin concentricity inspection and straightening procedure.

(b) Replaced individual shell and connector insnection with one inspection for broken parts of deformation which interferes with assembly.

(c) The cable jacket inspection remained unchanged.

(d) Deleted inspections of the strain relief clamp and rubber boot.

(2) Visual Inspection (Interior)

(a) Changed inspection requirements for ccnductor insulation to accept gouges, nicks and cuts so long as bare wire is not exposed.

(b) Shrink tubing inspection requirements remain unchanged.

(c) Solder joint inspection requirements remain unchanged.

(3) Pull Test.

(a) Pin extractions are no longer required unless repair is required.

(b) Deleted the inspection of each pin for damage.

(c) Deleted the inspection of each contact to ensure that the contact was not split by or near the crimp connection.

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(d) Changed the pull test method and the pull test acceptance values. The pull test is now performed without extracting the pin by clamping locking pliers (hemostats) with an attached pull test gage to each conductor.

Although the locking pliers result in compressed and damaged insulation, insulation is repaired if bare wire is exposed.

Pull force acceptance values have been decreased to 15 pounds for 16 AWG wire and 8 pounds for 20 AWG wire.

(4) Electrical Test Changed such that testing is only required when pins have been extracted.

(5) Final Reassembly Inspection.

(a) Deleted verification that the condition of the shell was concentric.

Verification that the condition of the shell is capable of fitting to the panel connector is unchanged.

(b) Added torque requirements for strain relief clamp.

Tightness verification of rubber boot and strain relief clamp remain unchanged.

(c) Added tolerance requirements to pin equal distance verification.

(d) Added verification that cable ID marker is legible.

As before, any deficiencies discovered during the inspection require repair.

GE has grouped the connectors into the following four categories c.

for which statistical sampling and/or analysis has been performed.

Category No.

Description

20 AWG conductor in 16 gage pin

16 AWG conductor in 12 gage Bendix pin

16 AWG conductor in 16 gage pin

16 AWG conductor in 12 gage pin GE's Control and Instrumentation Division has classified the low strength mechanical crimps and nicked, cut conductor insulation as major quality characteristics. A major quality characteristic is defined as a characteristic which, if n'1 100

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nonconforming, is unlikely to result in personal injury but may result in a major operational or functional degradation (significant reduction in service life) of the system of which it is a part. GE's Principle QC Engineer stated that although low scrength mechanical crimps and nicked, cut conductor insulation appeared to be a minor quality charac-teristic, it was decided to classify them as major because of the importance of PGCC cables to plant operation and safety.

A minor quality characteristic is defined as a characteristic, if nonconforming, may result in a minor operational or functional degradation (reduced service life)

of the system of which it is a part.

For a major quality characteristic, GE requires that statistical sampling and analysis be conducted to a.65 Acceptable Quality Level (AQL) in accordance with MIL-STD-105D, " Sampling Procedures and Tables for Inspection by Attributes".

Based on the results of statistical analysis of samples obtained from each connector category, revised inspection requirements have been established for each category and are discussed below.

(1) Category 1: Although a sample per MIL-STD-105D was not obtained, analysis of available data by GE indicated that connectors of this category would not meet a.65 AQL.

As a result, all category 1 connectors except those containing 48 pins are 100 percent inspected to the revised procedural requirements. 48 pin category 1 connector inspection requirements are as follows.

(a) Visual interior and exterior inspections, electrical testing and reassembly inspections are performed per the revised procedural requirements.

(b) Pull testing is performed on the outer two rows of 34 pins of the connector.

If a pin in the outer of a connector does not meet the pull two rows test requirements, pins are extracted such that the remaining connector pins can be pull tested.

If the pins in the outer two rows meet pull test requirements, the remaining pins are not pull tested.

(c) Statistical analysis of available data by GE indicates that of the entire Category 1 PGCC cable population, the current 48-pin connector inspection procedure will miss approximately four crimps with strengths less than the acceptance values specified by the procedure.

Of the PGCC cable assemblies containing 48 pin category I connectors, there are 98 class 1E (i.e., the safety classification of the electric equipment and systems that are essen-tial to emergency reactor shutdown, containment isolation, reactor core cooling, and containment

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and reactor heat removal, or are otherwise essential in preventing significant release of radioactive material to the environment) divisional cables containing 162 connectors.

Of these assemblies, there are 52 class 1E cable assemblies containing 86 connectors to which the revised pull test requirements are applicable and have not received 100 percent pull testing.

(2) Category 2: 391 cable assemblies containing 580 connectors with 4060 pins have been exempted from further inspection based on a sample and analysis per MIL-STD-105D. Of the 580 exempted connectors, there are approximately 307 class IE divisional connectors.

Of the 232 pin sample from 32 cable assemblies, there were two pull test rejects and no insulation damage rejects. The two pull test rejects were in one cable with values of 12 and 14 pounds (versus a 15 pound acceptance value).

(3) Category 3: 77 cable assemblies containing 137 connectors with 890 pins were exempted from further inspection based on a sample and analysis per MIL-STD-105D. Of the 137 exempted connectors, there are approximately 57 class IE divisional connectors. Of the 313 pin sample from 50 cable assemblies, there were three pull test rejects and two insulation damage rej ects. The three pull test rejects were in one cable with values of 10, 12 and 14 pour.ds (versus a 15 pound acceptance value).

(4) Category 4: Analysis of available data by GE indicated that these connectors would not meet a.65 AQL, and all connectors are being inspected to 100 percent of the revised procedural requirements.

d.

Paragraph 7.1.2.2.5.3.f of the Final Safety Analysis Report for Grand Gulf Nuclear Station states that " detailed design basis, description, and safety evaluation aspects for the PGCC system are documented and presented in GE Topical Report:

"I' owe r Generation Control Complex"; NED0-10466, Rev. 1 (9/77)." Paragraph 3.3.4.1.3 of GE NED0-10466 states that " based on the design requirements, the optimum connector is one that meets (as a minimum) MIL-C-5015G", Military Specification for Military Connectors, dated 10 June 1977.

GE's field cable inspection procedure II CA-010 and statistical sampling procedures do not verify compliance with MIL-C-5015G requirements. For example, paragraph 3.4.1 of MIL-C-5015G states that " contacts shall conform to MIL-23216", " Contacts, Electric Connector, General Specification for..." MIL-23216C dated 7 November 1969 specifies that the minimum axial load required to separate the wire from the contacts which have not been subjected to thermal conditioning (Composition A),

either by pulling the wire out of the wire barrel or breaking the wire within the barrel, shall not be less than the i09 1 102

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applicable limit specified in Table IX."

Table IX of MIL-C-23216C specifies a minimum axial load of 50 pounds for 16 AWG wire and 20 pounds for 20 AWG wire.

GE procedure II CA-010, Revision 4, specifies pull test acceptance values of 15 pounds for 16 AWG wire and 8 pounds for 20 AWG wire.

Additionally, pull test acceptance valves for statistical sampling and/or analysis of Grand Gulf category 1, 2, 3 and 4 PGCC cable assemblies were based on pull test acceptance values of 15 pounds for 16 AWG wire and 8 pounds for 20 AWG wire. GE has stated that the pull test acceptance values employed are based on 25 percent of wire yield strength to avoid damage to the installed cable assemblies. Although GE has conducted seismic, mechanical and electrical testing whose results tend to support a contention that low mechanical strength crimps do not necessarily impair electrical perfor-mance, current sampling and inspection procedures do not ensure that the PGCC cable assembly installations meet the requirements of MIL-C-5015G.

This failure to comply with MIL-C-5015G requirements appears to be a noncompliance and is identified as Infraction 416/79-15-0 and 417/789-15-09; Failure to meet MIL-spec requirements.

e.

As previously discussed, inspection procedures have been revised such that pull test acceptance values have been significantly reduced and conductor insulation nicks, cuts and gouges are now acceptable unless bare wire is exposed.

GE has provided seismic, mechanical and electrical test results which tend to indicete that low strength mechanical crimps do not impair electrical performance.

GE has also provided hipot test results which indicate that conductor insulation nicks, cuts and gouges which do not expose bare wire are unlikely to impair electrical performance.

No tests were conducted which attempted to determine if the reduced requirements would result in reducing electrical performance due to aging effects on the cable assemblies.

The following questions concerning aging effects were asked.

(1) What effect does aging have on electrical properties of low mechanical strength crimps? Although it was reported that a recent test was conducted with a mated pair of connectors with low and high force crimps in an oven at 200 degrees Celsius which caused failure of the insula-tion on the wire and in the connector insert with no significant change in the resistance through the con-nector, test results and analysis were not provided.

This item was identified as unresolved item 416/79-15-01 and 417/79-15-01, Aging effects on conductor insulation.

(2) What effect does aging have on the insulating properties of conductor insulation? Would aging affect the results for nicked, cut insulation? Has an insulation test been performed with nicked, cut wires in direct contact?

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Current procedures allow acceptance of thin stretched insulation resulting from pull testing - have insulation tests been conducted to determine at what insulation thickness the hipot test may fail? Will a nick or cut propogate with age? There was no data available at this time concerning these questions. This was identified to the licensee as unresolved item 416/79-15-02 and 417/79-15 -02.

(3) Since it becomes more imperative that adequate strain relief be provided by the cable clamp if low strength mechanical crimps are accepted, what effect does aging have on the clamp seizure of the cable outer jacket?

Does the strength of the clamp to cable connection weaken with age? This condition could result in the application of excessive forces to low strength mechan-ical crimps as a result of seismic forces or cable bending at or near the clamp? Although a cable bending test had been performed by GE which indicated that the cable clamp would provide adequate strain relief, no information was available concerning aging effects.

This item was identified as unresolved item 416/79-15-03 and 417/79-15-03, Aging effects on connector clamp strength.

(4) Under what environmental conditions was hipot testing for conductor insulation nicks, cuts performed? Would humidity or dense smoke produce unacceptable results?

This item was identified to the licensee as unresolved item 416/79-15-05 and 417/79-15-05, Environmental ef fects on hipot test results.

f.

The inspector observed work and work activities associated with PGCC cable inspection and repair in the areas of inspection, pull testing, continuity testing, hipot testing, and repair. The following conditions were observed.

(1) Pin "D" of cable number 5551/SZ51-006 was observed to have approximately six wire strands broken inside the barrel. The cable had passed the pull test and this condition would not have been detected under current procedures (which do not require pin inspections after successful pull test) if the insulation had not been a

damaged. The licensee was asked if this condition been observed previously, and would this condition impair functional operation of the circuit? This item was identified to the licensee as unresolved item 416/79-15-06 and 417/79-15-06, Wire strands broken inside barrel.

(2) Cable number 8347/SP64-006 was observed to have a damaged outer jacket.

Current exterior inspection procedures provide for inspection and repair of cables 3 oa1 1Od i,

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to 5 feet from the end.

The location of the damage from the end of the cable was not determined.

The licensee was asked if the damage was within the scope of current procedures. This item was identified to the licensee as unresolved item 416/79-15-07 and 417/79-15-07, Evaluation of cable outer jacket damage.

(3) Wire pairs 4 and 5 of cable 8248/SV41-001 was reported to 1. ave failed a continuity check and was returned for rework. After rework, the pairs had been cut and taped back, and the previous inspection sheets were not in the data folder.

The cable was reported to have been QC inspected and accepted prior to its failure of the cor.tinuity check. The licensee was asked why the pairs had been cut and taped back, and if this repair method was authorized by current inspection and repair pro-cedures? The licensee was also questioned as to what had happened to the data sheets which documented failure of the continuity check and why the cable, which had been QC inspected and accepted, had been reworked.

These questions could not be answered at this time.

This item was identified to the licensee as unresolved item 416/79-15-08 and 417/79-15-08.

g.

In addition to the items observed by the inspector, the licensee had issued Corrective Action Request (CAR) number 31 which identifies areas in the on-site PGCC Quality Assurance Program which do not comply with ANSI N45.2-1971 requirements for identification and control of nonconforming items and corrective actions. ANSI N45.2 requires prompt identification of nonconforming items and correction as soon as practicable.

The two deficiencies identified below had not been documented as of July 26, 1979:

(1) Flat head pins (identified on July 9,1979)

(2) Missing " spring" or " clip" on Amphenol connectors (identified July 18,1979)

Evaluation and resolution of the CAR had not been completed.

This item is identified as inspector follow-up item 416/

79-15-10 and 417/79-15-10, Failure to meet ANSI N45.2 require-ments h.

Completed cable inspection data sheets were reviewed to determine the effectiveness of the current sample inspection procedure for 48 pin category I connectors. Current procedures do not require pull testing of twisted pair shield wires. The cable inspection data sheet for cable number 8248/IP53-001 indicated three shields that were "0FF".

When questioned three site electricians and one QC inspector performing PGCC cable inspection and repair work stated that they knew of no conductor that was pulled out of the connector pin prior to removal of the connector back shell.

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Since shields are no longer pull tested by current procedures, the licensee was asked if the impact on circuit functional opera-tion resulting from defective shield wires had been evaluated, and if the number of apparently defective shield wires contained in this cable would ef fect the analysis? No information was available concerning these questions at this time. This item was identified to the licensee as unresolved item 416/79-15-04 and 417/79-15-04, Shield wires not pull tested.

3.

FINDINGS:

The concerns were substantiated in that the current PGCC inspection program does not meet the licensee FSAR commitment to MIL-C-5015G.

Infraction 416/79-15-09 and 417/79-15-09 (as discussed in paragraph IV.C.2.d) documents this item.

Additionally, in light of the classification of low strength mechanical crimps and nicked, cut conductor insulation as a major quality characteristic which can result in a significant reduction in PGCC service life, the functional acceptability of these defects under the current PGCC cable inspection program (which has been established under statistical sampling and analysis per MIL-STD-105) could not be determined.

The impact of low strength mechanical crimps and nicked, cut conductor ina"1ation on service life has been addressed by unresolved items 416/79-15-01 and 417/79-15-01, 416/79-15-02 ar.d 417/79-15-02, 416/79-15-03 and 417/79-15-03, and 416/79-15-05 and 417/79-15-05 as discussed in paragraph IV.C.2.e).

Finally, the current GE QA program on site does not meet the requirements of ANSI N45.2-1971 for identification and correction of nonconformances outside the scope of current procedures.

Unresolved items 416/79-15-04 and 417/79-15-04, 416/79-15-06 and 417/79-15-06, 416/79-15-07 and 417/79-15-07, and 416/79-15-09 and 417/79-15-09 and inspector follow-up item 416/79-15-10 and 417/79-15-10 (discussed in paragraphs IV.C.2.f, g and h) address items concerning identification and correction of nonconformances outside the scope of current procedures.

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