ML20031D133

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QA Program Insp Rept 99900325/81-01 on 810119-23. Noncompliance Noted:Implementation of 10CFR21 Was Not Consistent W/Paragraphs 21.6 & 21.21(a) & Followup on Solder Pot Test Inadequate
ML20031D133
Person / Time
Issue date: 02/25/1981
From: Barnes I, Foster W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20031D114 List:
References
REF-QA-99900325 NUDOCS 8110090343
Download: ML20031D133 (10)


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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV u

Report No.

99900325/81-01 Program No. 51400 Company:

Brand-Rex Company t-Electronic and Industrial Cable Division Main Street Willimantic, Connecticut 06226 Inspection conducted:

January 19-23, 1981 Inspector:

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/ v-W. E. Foster, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch Approved by: I8 2 -w-r i I. Barnes, Chief Date ComponentsSection II Vendor Inspection Branch Summary j

Inspection conducted on January 19-23, 1981 (99900325/81-01).

Areas Inspected:

Implementation of 10 CFR Part 50, Appendix B criteria, and applicable codes and standards; including follow up on a regional request; implementation of 10 CFR Part 21; follow up on deviations; and follow up on an unresolved item.

The inspection involved twenty-seven (27) inspector-hours on site.

Results:

In the four areas inspected, the following two violations, three nonconformances and one unresolved item were identified:

Violations:

Implementation of 10 CFR Part 21 practice was not consistent i

with paragraphs 21.6 of 10 CFR Part 21 (See Notice of Violation, Item A); and 121.21 (a) of 10 CFR Part 21 (See Notice of Violation, Item B).

Noncon formances:

Follow up on regional request practice was not consistent with Criterion V of Appendix B to 10 CFR Part 50; paragraph 4.0.1 of In-Process Inspection Procedure No. QC-146, Revision 12, dated September 1980 and para-graphs 1.f and 2. of Testing Procedure, undated (See Notice of Nanconformance, Item A).

i 8110090343 810623' PDR GA999 EMVDREX 99900325 PDR

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Follow up on deviations practice was not consistent with Criterion V of Appendix B to 10 CFR Part 50, and an unnumbered, unsigned, and undated procedure entitled,

" Procedure For Repair Request" (See Notice of Nonconformance, Item B); practice was not sansistent with Criterion VI of Appendix 8 to 10 CFR Part 50, and Manufacturing Procedure No. 030, Revision 0, dated April 1978 (See Notice of 2

Nonconformance, Item C).

Unresolved Items:

Follow up on regional request-two procedures which address solder pot test, in the Irradiation Area, differ regarding the number of reels to be sampled (See Details Section, paragraph B.4.d.(1)); unable to ascertain the validity of criteria used to conclude nor.-notification of purchasers (See Details Section, paragraph B.4.d.(2)).

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DETAILS SECTION A.

Persons Contacted

  • A. Airola, Engineer-Quality Assurance
  • J. Arbogast, Supervisor-Quality Control
  • R. H. Bamford, Manager-Sales and Marketing

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  • C. J. Crawford, Manager-Purchasing
  • I.

N. Dwyer, Manager-Product Development

  • G. Glynn, Director-Manufacturing
  • G. Graeber, Vice President and General Manager
  • A. E. Landry, Manager-Marketing and Production Services G. J. Obsharsky, Foreman-Jacketing D. Poulin, Foreman-Irradiation J. F. Osbor.1, Area Manager L. B. Roberts, Manager-Quality Assurance
  • S. Sandberg, Engineer-Senior Product
  • H. R. Tucker, Plant Manager
  • E. M. Walton, Manager-Industrial Market J. F. Wood, Area Manager
  • Attended Exit Interview B.

Follow up on Regional Requests

===1.

Background===

Duke Power Company personnel notified personnel at the Office of Inspection and Enforcement, Region II, on July 3, 1980, of a deficiency at the Catawba Nuclear Station.

The deficient condition was an uncured conductor (No. 31) in a 61 conductor cable manufac-tured by Brand-Rex Company.

The conductor should have been cured by the irradiation process.

2.

Objectives The objectives of this area of the inspection were to vcrify that the manufacturer had:

(1) taken adequate CJrrective actions and pre-ventive measures, and (2) assessed generic implications.

3.

Methods of Accomplishment The preceding objectives were accomplished by:

a.

Reviewing the following accuments to verify that adequate corrective actions had been taken:

4 (1) Brand-Rex C'ampany, Electronic and Industrial Cable Division's letters, dated -

(a) July 21, 1980; To:

Duke Power Company, Attn:

Mr. P. M.

McBride;

Subject:

Brand-Rex Corrective Action Report, (b) September 29, 1980; To:

Duke Power Company, Attn:

Mr. R. Patterson;

Subject:

Field Problem Evaluation, (c) October 31, 1980; To:

Mill Power Supply, Attn:

Mr. Morehead;

Reference:

Scrapping of Non-Irradiated Conductor Cable, (d) September 15, 1980; To:

Duke Power Company; authorizes release of matt. rial evaluated at Catawba Station, during September 15-19, 1980, (e) September 5, 1980; To:

Duke Power Company; authorizes release of material evaluated at McGuire Station, during September 8-11, 1980, and (f) October 31,1980; To:

Duke Power Company; Attn:

Mr. Wylie;

Subject:

Brand-Rex Test Program-Suitability of Thermoplastic (Non-Irraciated) Polyethylene....

(2) Brand-Rex Company, Electronic and Industrial Cable Division's memorandun dated September 3, 1980; To:

Mr. P. McBride; From:

Mr. L. B. Roberts;

Subject:

Unirradiated Product-Brand-Rex Cable.

(3) An undated, unsigned document entitled-Ouke Power Meeting.

(4) hat Solder Iron and Hot Solder Pot Test Procedures.

(5) Hot Solder Pot test records at the (a) QC Laboratory, (b) Cabling (Industrial and Electronic), (c) In-Process Inspection Station, and (d) Irradiation Area.

b.

Observing the hot solder pots-immediate preceding entry-and a demonstration of the hot solder pot test in the QC Laboratory.

Reviewing the Brand-Rex Company Wire and Cable Division's 10 c.

CFR Part 21 report, dated October 8, 1980, to verify that corrective action had been addressed.

4.

Findings a.

Comments i

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5 (1) During the activity at' Catawba, McGuire, and Oconee to determine the extent of uncured conductors in the 61 conductor cable, a different uncured conductor (No. 51) was identified in two reels.

However, a Brand-Rex letter, dated July 21, 1980, states the problem was isolated to conductor No. 31.

The letter also states that the material applicable to conductor No. 31 was processed (irradiated) during the period of May 25 - July 18, 1979, with total footage used in the 61 conductor cable.

Also, uncured conductors, which should have undergone the irradiation process, were found in cables of four other configurations.

The dates of irradiation of the latter cables spanned the period of July 20, 1978 through February 29, 1980.

(2) Other purchasers of Class IE irradiated products during the period of July 20, 1978 through February 29, 1980, were identified to the NRC inspector as:

Arizona Public Service Company, Philadelphia Electric Company, The Cleve-land Electric Illuminating Company, and Tennessee Valley Authority.

These purchasers were not identified as being the total number of purchasers of Class IE irradiated products during July 20, 1978 through February 29, 1980.

(3) All defective cables at Catawba have been replaced with acceptable cable.

(4) Brand-Rex is conducting a test program for Duke Power regarding the suitability of thermoplastic (non-irradiated) polyethylene insulation located outside containment.

Environmental conditions cover the auxiliary building and a high energy line break.

(5) One-hundred percent hot solder pot tests have been instituted at cabling, irradiation, and final inspection for all orders.

At final inspection, samples are taken from both ends of the reeled cable.

The hot solder pot test is in addition to the tensile strength and elongation tests of the conductor insulation.

b.

Violations None.

c.

Ncnconformances See Notice of Nonconformance, Item A.

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d.

Unresolved Items (1) The Solder Pot Test and Tasting Procedures located in the Irradiation Area differ regarding the samples to be sub-jected to the solder pot test.

The latter document requires checking the first reel off the take-up at the start of a shift and the start of an order, while the former document requires a sample from every reel.

As a result of this apparent conflict, the NRC inspector was unable to determine the validity of the requirements.

(2) The records indicated that the uncured (non-irradiated) conductor was not restricted to:

(1) number 31 in the 61 conductor cable or (2) the period of May 25 - July 18, 1979.

According to the records, uncured conductors, which should have undergone the irradiation process, were found in four other cable configurations with dtes of irradiation spanning July 20, 1978 through Fev uary 29, 1980.

Brand-Rex personnel acknowledged that there were other purchasers of Class IE irradiated products, during the period of July 20, 1978 through February 29, 1980, but considers the problem to be isolated to the Duke Power Company because of:

larger size, shorter lengths, con-ductor size and color, and use of interlock armor.

Consequently, other purchasers had not been notified.

The NRC inspector was unable to ascertain that larger size, shorter lengths, conductor size and color, and the use of interlock armor were valid criteria for concluding that other purchasers were not affected and required no notifi-cation, because individual conductors are irradiated prior to cabling and installation of the armor.

C.

Implementation of 10 CFR Part 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 Part 21.

2.

Methods of Accomplishment The preceding objectives were accomplished by:

a.

Reviewing the following customer orders to verify that the equipment was safety related and 10 CFR Part 21 had been invoked:

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7 (1) Mill-Power Supply Company's Purchase Order No. E-93417-31 dated October 24, 1979, (2) Philadelphia Electric Company's Purchase Order No. MS367072, and

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(3) Public Service Electric and Gas Company's Purchase Order No. 10855-E-170 (Q) - AC, dated August 29, 1979.

b.

Reviewing In-Process Inspection Procedure No. 121, Revision 11, dated May 1980, entitled-Control of Nonconforming Material Pro-cedure, to verify that internal procedures had been established.

c.

Interviews with cognizant personnel to determine locations of posting.

3.

Findings The aforementioned customer orders identified the equipment as safety related and invoked 10 CFR Part 21.

a.

Violations (1) See Notice of Violation, Item A.

(2) See Notice of Violation, Item B.

b.

Nonconformances None.

c.

Unresolved Items None.

D.

Follow up on Deviations i

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 were accomplished by:

Deviewing the following documents to verify that stated correc-a.

tive actions had been taken:

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(1) Production and Inventory Control Procedures Handbook, dated October 1, 1980, (2) Extrusion Guideline Books at Machine Nos. 34, 38, 49, and 75, (3) Operating Memo No. 317-00-1, Issue 1, dated September 9, 1975, entitled - Splicing Procedure... Shorting Pro-cedure...,

(4) Engineering Procedure No. XII-0-2, Revision 0, dated November 21, 1980, entitled - Procedure For Design and Document Control...,

(5) Engineering Revisions for -

(a) Arizona Public Service Company, Part Nos. T7-7216 75 Pr/22 and T7-7216 50 Pr/22, both dated August 18, 1980, (b) Duke Power Company, Part No. T-7368, dated June 13, 1980, and (c) Public Service Company of New Hampshire, Part Nos.

T-7858 1 Pr/16 and T-7858 1 Pr/16, dated June 23, 1980 and July 21, 1980, respectively.

(6) An unnumbered, unsigned, and undated document entitled -

Procedure For Repair Request.

(7) Repair Request Forms, Nos. -

(a) 02057, dated January 20, 1981, Part No. T-7732 4/16, Reel No. 4197, Order No. AE-85118-3, and (b) 08560, dated January 19, 1981, Part No. T-7420 61/16, Reel No. 1017, Order No. E-88341-1.

(8) Respool Request Form No. 04759, dated January 17, 1981, Part No. T-7730 12/14, Reel No. 026643, Order No. B-85143-6.

b.

Observing an interlock armor repair on Part No. T-7732 4/16, Reel No. 4197.

3.

Findings a.

(Closed) Deviation (Inspection Report No. 80-01):

The inspector verified that:

(1) documented instructions had been generated to initiate Shop Orders and (2) primary extrusion guidelines were located at the machine where the task was being performed.

During this activity, the follcwing condition was identified:

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Primary Extrusion Operating Guidelines contain a space for an Approval signature; however, numerous guidelines did not contain a signature in the appropriate space.

The procedure that requires guidelines does not address approval (See Notice of Nonconform-ance, Item C).

b.

(Closed) Deviation (Inspection Report No. 80-01):

The inspector verified that photographs of actual joints had been added to Operating Memo No. 317-00-1, Issue 1, dated September 9, 1975.

c.

(Closed) Deviation (Inspection Report No. 80-01):

The inspector verified that:

(1) a new procedure (see D.2.A.(4) above) addressed engineering changes singly and with an engineering change memo and (2) engineering changes (see D.2.a.(5) above) had been approved by Quality Assurance.

d.

(Closed) Deviation (Inspection Report No. 80-01):

The inspector determined that the previously identified procedure had been eliminated from the system; however, identical tags were still in use.

(See Notice of Nonconformance, Item B).

E.

Follow up on Inspector Identified Unresolved Item 1.

Objectives The objectives of this area of the inspection were to verify that inspector identified unresolved items, durira previous inspections, had been corrected and resolved satisfactorliy.

2.

Methods of Accomplishment The preceding objectives were accomplished by:

a.

Reviewing the following documents to verify that resolution had been effected:

(1)

Interoffice Memorandum, To:

J. Boucher, W. Dailey, et al; Frcm:

H. Tucker; Dated:

June 20, 1980;

Subject:

Manu-facturing Guidelines....,

(2) General Manufacturing High Voltage Tes' Procedure No.

Mfg 129, Revision 1, dated July 1980 ei titled - Wet High Voltage Test, and (3)

Reel tags on reels of material for recording of time when reels are immersed and removed from water and identi-fication of the operator.

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Findings Resolved-Unresolved Item (Inspection Report No. 80-01):

The inspector verified that:

(1) a require-ent had been established to record the times when reels of wire, cable were immersed in and removed from water and (2) the requirement was being followed.

F.

Exit Interview 1.

The inspector met with management representatives denoted in para-graph A. at the conclusion of the inspection on January 23, 1981.

2.

The following subjects were discussed:

a.

Areas inspected.

b.

Violations identified.

c.

Deviations (Nonconformances) identified.

d.

Unresolved Items 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 violation and each nonconformance.

3.

Most of the remarks by management related to the violations; they requestea notification if NRC issued a bulletin or some other document.

Also, the inspector was informed that extruding machines were being dedicated for specific items, the inspector stated the need to document this dedication.

4.

On February 13, 1981, Mr. Airola was informed by telephone, that the unresolved item regarding approval signatures on the Primary Extrusion Guidelines had been re-evaluated and would appear in the report as a nonconformance.

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