ML20004E448
| ML20004E448 | |
| Person / Time | |
|---|---|
| Issue date: | 10/16/1980 |
| From: | Barnes I, Foster W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20004E430 | List: |
| References | |
| REF-QA-99900116 NUDOCS 8106120196 | |
| Download: ML20004E448 (10) | |
Text
. e w+ege ebet-J U.S. NUCI. EAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEENT REGION IV Report No. 99900116/80-02 Program No. 51300 Company:
Bunker Ramo Corporation Amphenol North America 9201 Independence Avenue Chatsworth, California 91311 Inspection Conducted: September 22-25, 1980 Inspector i
sh Jt/hth VW. E. Foster, Contractor Inspector
/ Date ComponentsSection II Vendor Inspection Branch Approved b
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/
4 I. Barnes, Chief
/ Dste ComponentsSection II Vendor Inspection Branch Summary Inspection on September 22-25, 1980 (99900116/80-02)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria, and appli-cable codes and standards; including follow-up on regional requests; follow-up on deviations; and manufacturing process control.
Implementation of 10 CFR Part 21 was also inspected.
The inspection involved twenty-seven inspector hours on site.
Results:
In the four (4) areas inspected, no unresolved items were identified, i
the following two deficiencies, and six deviations were identified:
Deficier. ies : Follow-up on Regf m.1 Requests - practices were not consistent with paragrrph 21.21 of 10 CFR 21 and paragraph 4.6 of QAP No. 10 CFR 21, dated March 12, 1978 (See Notice of Violation, Item A).
l Implementation of 10 CFR Part 21 - practice was not consistent with paragraph l
21.6 of 10 CMI 21 (3ee Notice of Violation, Item B).
Deviations: Follow-up on Deviations - practices were not consistent with:
(1) Bunker Ramo Corporation's corrective action response letter dated March 31, 1980 (See Notice of Deviation, Item A); and (2) Criterion V of Appendix B to l
l 10 CFR 50, and paragraph 6.1 of Quality Assurance Procedure No. 1-10, Revision l
G, dated May 25,1978 (See Notice of Deviation, Item B).
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2 Manufacturing Process Control practices were not consistent with Criterion V of Appendix B to 10 CFR 50; paragraphs 6.2.1 and 7.1 of Quality Assurance Pro-cedure No. 3-2, Revision K, dated April 24,1978 (See Notice of Deviation, Item C);Section IV, paragraphs 1.8 and 1.9,Section VIII, paragraph 1.2 and Table D of Manufacturing Layout Supplement No. 1147, Revision C, dated July 8, 1974, (See Notice of Deviation, Item D); paragraphs 4.5.4 and 7.3.2 of the Nuclear Quality Assurance Manual, Revision 6, dated January 5,1979 (See Notice of Deviation, Ites E).
Implementation of 10 CFR Part 21 practices were not consistent with Criterion IV of Appendix B to 10 CFR 50 (See Notice of Deviation, Item F).
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3 DETAILS SECTION A.
Persons Contacted
- C.
Baldwin, Director - Industrial Relations
- E. Beaupre, Director - Program Management V. Bermudez, Operator - Machine
- D. Bosch, Plant Superintendent
- G. Deegan, Controller - OPS E. J. Haddad, Planner - Senior Production (Nuclear)
R. Raghavan, Inspector - Tool and Gauge
- R. Stackhouse, Supervisor - Quality Control
- L.
Stupay, Vice President - Engineering J. Wisdom, Supervisor - Production
- H. D. Wright, Manager - Quality Assurance
- Attended Exit Interview.
B.
Follow-up on Regional Requests
===1.
Background===
Electrical wires of 14 and 16 AWG had separated from their associated crimped terminal lugs in electrical penetration assemblies shipped to the Callaway Plant, Unit No. 1.
Hardware manufactured by the Bunker Ramo Corporation had also been shipped to Wolf Creek Generating Station, Unit No. 1; therefore, the problems could be generic to SKUPPS.
2.
Objectives The objectives of this area of the inspection were to verify that the manufacturer had:
(1) taken adequate corrective actions and pre-i ventive measures regarding the crimping problems, and (2) notified the Commission.
3.
Methods of Accomplishment The preceding objectives were accomplished by:
i a.
Reviewing the following documents to verify that:
(1) A program existed for corrective action and preventive measures, (2) notifi-cation of the Commission had been included, and (3) the program had been implemented:
i (1) Quality Assurance Procedure No. 10 CFR 21, dated March 12, 1978 - Nuclear Products Failure Investigation and Analysis Reporting, i
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4 (2) Fiald Change /hawork Plan - SNUPPS Project, No. E-001, Revision 1, for Callaway No. 1 and Wolf Creek, and associ-ated data sheets, dated May 1980, for activity at Wolf
- Creek, (3) Field Change / Rework Plan, No. E-001, Revision 2, dated August 20, 1980, and (4) Failure Investigation and Analysis Report No. 0001, dated March 17, 1980.
b.
Rcviewing the following customer Purchase Orders (P.O.) to verify that 10 CFR Part 21 had been invoked:
(1) Bechtel Power Corporation P.O. 's No.10466-E-035-1, through
-5, all Revisions 2 and all dated November 7, 1978, (2) Commonwealth Edison Company P.O.'s Nos. 190268, Change Order, dated August 7, 1979; and 190269, Change Order, dated August 7, 1979, and (3) Bechtel Power Corporation P.O. No. 7220-E-20-AC, Revisions 7 and 12, dated April 7, 1978 and March 4, 1980, respectively.
4.
Findings a.
Comments (1) The manufacturer maintains that. faulty crimps resulted due to using improper crimpers on heavy duty lugs and the problem was isolated to heavy duty lugs. The NRC inspector pointed out that past crimping problems on the Midland Project were not on heavy duty lugs, this statement was acknowledged by the QA Manager.
(2) Faulty crimps had been identified in the Junction Boxes j
rather than throughout the wiring of the Electrical Pene-tration Assemblies. During the course of this inspection, l
crimping of 14-16 AWG terminal lugs was not observed:
l apparently, none was in progress.
I (3) The NRC inspector was informed that Continuity, Insulation Resistance, and Dielectric Tests were relied upon to reveal j
defective crimps (4) Some terminal lugs (12, 14 and 16 AWG) had been replaced on the junction boxes at Wolf Creek out Bunker Ramo p 3rsonnel will retc.rn there and travel to Callaway to make additional Corrections.
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5 (5) Bunkar Ramo had not instituted any new programs, subsequent to problem identification, to preclude recurrence.
The hardware had been shipped and current orders do not use heavy duty terminal lugs of 14-16 AWG.
(6) The aforementioned customer purchase order revisions and change orders invoked 10 CFR Part 21.
b.
Deficiency See Notice of Violation, Item A.
Paragraph 4.1 in Quality Assurance Procedure No. 10 CFR 21 states in part, "When a defect or deviation is surfaced at Bunker Ramo SAMS which might constitute a substantial safety hazard, a Failure Investi-gation and Analysis Report (FIAR) shall be initiated..
." Para-graph 4.6 states in part, "When the FIAR analysis of the defect and/
or deviation indicates that a substantial safety hazard condition exists, the responsible officer... must notify the NRC Regional Office... Bunker Ramo SAMS responsible officer must also followup with a written Failure Investigation and Analysis Report to the NRC Regional Office within five (5) days of learning of the defect A cover letter must accompany the Failure Investigation and Analysis Report with:
the name and address of the individual or individuals informing the commission; the number and location of all such com-ponents in use at, supplied to, or being supplied for one or more facilities or activities subject to 10 CFR Part 21; the corrective action which has been, is being, or will be taken; the name of the individual or organization responsible for the action; and the length of time that has been, or will be taken to complete the action.
Contrary to the above:
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(1) Failure Investigation and Analysis Report No. 0001, dated March 17, 1980, was forwarded to Region V of the Office of Inspection and Enforcement, without an accompanying cover letter to provide the required 10 CFR Part 21 reporting information.
(2) The Failure Investigation and Analysis Report addressed only electrical penetratioa assemblies furnished to the Union Electric Callaway site, that had been identified to contain loose terminal lugs, although a similar condition existed in electrical penetration assemblies furnished to the Kansas Gas and Electric Wolf Creek site.
This is a deficiency.
The QA Manager maintained that a copy of the Failure Iuvestigation and Analysis Report No. 0001, dated March 17, 1980, and a cover letter were sent to the Office of Inspection and Enforcement, Region V.
He was unable to locate a copy of the cover letter at Bunker Ramo, during the course of this inspection.
6 In an effort to confirm the foregoing, NRC personnel at the Office of Inspection and Enforcement, Region IV determined that:
(1) the NRC file of Part 21 reports contained no information from Bunker Ramo, and (2) Bunker Ramo had submitted Failure Investigation and Analysis Report form and its attachment to Region IV, without a cover letter.
C.
Implementation of 10 CFR 21 1.
Objectives The objectives of this area of the inspection were to verify that suppliers of safety related equipment had established and implemented procedures in accordance with 10 CFR 21.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Reviewing the aforementioned (paragraph B.3.b.) custemer orders to verify the equipment was safety related and 10 CFR 21 had been invoked.
b.
Reviewing the aforementioned (paragraph B.3.a(1) procedure to verify that procedure (s) had been established and implemented.
3.
Findings a.
Deficiency See Notice of Violation, Item B.
b.
Deviation From Commitment During this area of the inspection, it was determined that no l
provisions had been made to invoke 10 CFR 50, Appendix B on l
suppliers.
See Notice of Deviation, Item F.
D.
Follow-up on Deviations 1.
Objectives The objectives of this area of the inspection were to verify that the vendor had taken the corrective actions and preventive measures stated in their correspondence to IE regarding deviations.
2.
Methods of Accomplishment The preceding objectives werc accomplished by:
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7 Observing test and measurement equipment stored in cabinets a.
in the electrical calibration laboratory to verify that cor-rective actions had been taken.
b.
Reviewing the Master (vellum) of Qaality Assurance Procedure No. 3-1, Revision L, dated February 1,1980, to verify that preventive measures had been taken.
3.
Findings (Open) Deviation (Inspection Report No. 80-01):
The inspector a.
determined that the Active Instrument Cabinet contained test equipment which displayed calibration labels that indicated calibration was past due (See Notice of Deviation, Item A).
The inspector determined that the Master of QAP No. 3-1 had been revised by the committed date specified in Bunker Ramo Cotporation's corrective action letter cf March 31, 1980, but it had not been copied and distributed (See Notice of Deviation, Item B).
E.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that measures had been established and documented to control manufacturing, inspection and test activities. Also, to verify these activities had been accomplished in accordance with the established and docu-mented measures. Additionally, verification of indication of mandatory hold points in appropriate documents.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Reviewing the following documents to verify measures had been established and documented to control manufacturing, inspection and test activities:
(1) The Nuclear Quality Assurance Manual, Revision G, dated January 5,1979, Sections 4.0, 6.0, 7.0, 8.0, 9.0, and 12.
(2) Quality Assurance Procedures, Nos.
(s) 2-4, Revision D, dated April 20, 1978 - Work Instructions,
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8 (b) 7-1, Revision F, dated April 27, 1978 - Materials Traceability, (c) 8-1, Revision E, dated September 23, 1978 - Final Inspection and Acceptance, (d) 8-6, Revision D, dated April 27, 1978 - In Process Product Verification Iuspection, (e) 9-1, Revision J, dated April 27, 1978 - Indication of Inspection Status and Control of Stamps, (f) Manufacturing Layout / Traveler, Revision 3, dated June 20, 1980, for Part No. 50027630-05, Precrimp Module Pigtail Assembly, Serial No. 800818-1-04, (g) Manufacturing Layout Supplement No. 1147, Revision C (some pages are identified as: 1 2 3 ), dated July 8,
- 1974, (h) Manufacturing Layout /Tra';c. ate, Issue 4, dated July 11, 1979, for Part No. 50027267-XX, Post Crimp Module, (i) Manufacturing and Inspection Travelers (2), Issue 3, dated November 28, 1978, for Part No. 50027259-02, Pre Crisp Modula (j) Manufacturing and Station Layout / Traveler', Issues 2 and 13, dated August 8, 1978, and January 23, 1980, respectively, (k) Manufacturing and Inspection Traveler, Issue 1, dated July 15,1980, for Assembly No. 50023688, EPA-9A, Serial No. AS183-6, and its associated Process Sheet, Issue 1, dated July 11, 1980, and (1) Acceptance Test Procedure No. 255, Revision F, dated April 21, 1980, Electrical Penetration Assemblies for Byron and Braidwood Unit Two.
b.
Observing activities in the Mold, and Fabrication and Test Areas to verify that accomplishment had been in accordance with estab-lished and documented measures.
c.
Reviewing the aforementioned (paragraph B.3.b) customer orders to verify that 10 CFR 50, Appendix B had been invoked, and to what extent.
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3.
Findings a.
Comment The customer orders had invoked 10 CFR 50, Appendix B in its entirety.
b.
Deviations From Commitment (1) See Notice of Deviation, Item C.
(2) See Notice of Deviation, Item D.
(3) See Notice of Deviation, Item E.
Notice of Deviation -
Item C - The NRC inspector observed that Crimp Tool No. TW850 0248-1 was being used to crimp splices in 1/0 AWG conductors for the Precrimp Modules.
Investigation revealed that the Crimp Tool was not under the tool calibration program.
The NRC inspector observed five Precrimp Module Pigtail Assemblies, Part No. 50027630-05, and their associated manufacturing documents, on a workbench to which a Crimp Tool was mounted. After questioning, the NRC inspector was informed that crimping had been accomplished two to four weeks ago on Crimp Tool No. TW-850-0288 (Thomas and Betts) which was the Crimp Tool mounted on the work bench.
Investigation revealed that the Crimp Tool had been due for calibration on November 15, 1979.
The NRC inspector did observe the tensile test of one sample allegedly made with the tool and reviewed the tensile test record of another sample, both were satis-factory.
Item D - The crimper used was identified as TW850-0282. The inspector was informed that Table D of Manufacturing Layout Supplement 1147, Revision C, 3 dated July 8, 1974 had been changed regarding the specified crimper. A review of the engineering copy of the document indicated that extensive revision is being made; however, the area of concern had not yet been identified for revision.
Item E - The inspector observed that Manufacturing and Station Layout / Traveler, Issue 2, dated August 8, 1978 was in use in the Mold Area while the latest document was Issue 13, dated January 23, 1980.
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10 F.
Exit Interview 1.
The inspector met with management representatives denoted in para-graph A. at the conclusion of the inspection on September 25, 1980.
2.
The following subjects were discussed:
a.
Areas inspected.
b.
Violation identified.
c.
Deficiency identified.
d.
Deviations identified, e.
Contractor response to the report.
The contractor was requested to structure his response under headings of corrective action, preventive measures, and dates for each deviation.
Additionally, management representatives were requested to notify the Commission in writing if dates require adjustment, commitments require modification, etc.
3.
Management representatives acknowledged the comments made by the inspector.
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