ML20035G058
| ML20035G058 | |
| Person / Time | |
|---|---|
| Issue date: | 03/29/1993 |
| From: | Cwalina G, Wilson R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20035G051 | List: |
| References | |
| REF-QA-99901262 99901262-93-01, 99901262-93-1, NUDOCS 9304260089 | |
| Download: ML20035G058 (9) | |
Text
~
ORGANIZATION:
OMEGA POINT LABORATORIES, INC.
6868 ALAMO DOWNS PARKWAY l
SAN ANTONIO, TEXAS 78238 REPORT NO.:
99901262/93-01 f
CORRESPONDENCE Deggary N. Priest, President ADDRESS:
Omega Point Laboratories, Inc.
6868 Alamo Downs Parkway San Antonio, Texas 78238 i
ORGANIZATIONAL Constance A. Humphrey, Vice President and CONTACT:
Quality Assurance Manager (210) 647-1253 NUCLEAR INDUSTRY Flame endurance and electrical ampacity ACTIVITY:
derating tests of flame retardant materials INSPECTION March 2-5, 1993 CONDUCTED:
TEAM LEADER:
/
M 2 N Richard C.
Wilson, Senior Engineer Date Reactive Inspection Section 2 (RIS2)
Vendor Inspection Branch (VIB)
OTHER INSPECTOR:
Billy H. Rogers, Reactor Engineer, RIS2, VIB APPROVED:
kBco (4
14 f7 Reactive /'p., pwalina,
Gregory Chief D6te Ipspection Section 2 Vendor Inspection Branch INSPECTION BASES:
10 CFR Part 21 and 10 CFR Part 50, Appendix B INSPECTION SCOPE:
To review portions of electrical conduit and cable tray ampacity derating tests being per-formed for Texas Utilities Electric Company for conformance to contractually imposed nuclear safety requirements PLANT SITE Numerous; especially Comanche Peak Steam APPLICABILITY:
Electric Station Unit 2, Docket No. 050-00446 l
F I
f 9304260089 930409 L
PDR GA999 ENV10 MEG 99901262 PDR
e -.
I l
4
)
1 INSPECTION
SUMMARY
)
1.1 Violation 99901262/93-01-01 (Open)
Contrary to the requirements of 10 CFR Part 21, Omega Point procedures did not address the current revision of 10 CFR Part 21 l
effective October 29, 1991, and Omega Point.had not posted a j
current copy of 10 CFR Part 21 (See Section 3.6 of this report).
j 1.2 Nonconformance 99901262/93-01-01 (Open) i i
Contrary to Criterion VIII of Appendix B to 10 CFR Part 50, and to Texas Utilities Electric Company Purchase Order No. B 0046494,-
Omega Point procured and handled cable for a test specimen as commercial grade rather than the required safety grade (see
]
Section 3.4.1 of this report).
-j 2
STATUS OF PREVIOUS INSPECTION FINDINGS There was no previous NRC inspection of this facility.
3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 Entrance and Exit Meetinos l
In the entrance meeting on March 3, 1993, the NRC inspectors l
discussed the scope of the inspection, outlined the areas to be inspected, and established interfaces with Omega Point management and staff.
The formal entrance meeting was held the day after the inspection began to accommodate the availability of.Onega i
Point personnel.
In the exit meeting on March 5, 1993, the inspectors discussed their findings and concerns with Omega Point management and staff.
l l
3.2 Insoection Scone J
Omega Point is a small, 16-employee laboratory specializing in fire testing.
The purpose of this inspection was to determine whether electrical ampacity derating testing being performed by Omega Point for Texas Utilities Electric Company (TU) was being conducted in conformance to contractually-imposed requirements-i affecting nuclear safety.
The testing was intended to qualify l
specific cable installations for the Comanche Peak Steam Electric 1
Station (CPSES).
The inspectors witnessed testing of two conduit specimens (3/4 and 2 inch) and partial testing of.ite cable-tray specimen, selectively reviewed related documentation, and inter-viewed personnel.
The inspectors observed test preparations, ongoing tests, and data acquisition, and discussed the testing with Omega Point and TU personnel.
The inspectors observed that TU directly controlled the test specimens at Omega Point.
2 l
i
f:
Tl t
Concerns related to TU will be identified to the NRC's Electrical Engineering Branch for their consideration and disposition.
3.3 Amoacity Testina Recuirements During the design of nuclear power plants, ampacity ratings (limiting cable currents) are calculated for specific conduit and cable tray configurations.
Covering the conduit or cable tray with fire barrier material such as Thermo-Lag reduces heat dissipation from the cables, so the limiting cable temperature is reached at a lower current.
The ampacity derating tests were being conducted by Omega Point under TU Blanket Purchase Order (PO) No. B 0046494 dated April 24, 1992; Blanket PO Release No. B 0046494 001 dated April 28, 1992; and Revision No. 39 dated March 3, 1993.
The TU quality assurance (QA) representative stated that no nuclear safety requirements for the ampacity testing were changed between the blanket release and Revision 39.
The PO stated that it is a
-safety-related PO; the attached " Scope of Work for Testing Services" dated April 20, 1992, invoked 10 CFR Part 21 and Appendix B to 10 CFR Part 50.
The PO covered one cable tray assembly, three conduit assemblies, and two cable bundle free air drop specimens.
The tests were performed in accordance with the TU " Test Plan, "Ampacity Derating Tests of Articles Protected with the Thermo-Lag Fire Barrier System."
The inspectors reviewed three versions of the test plan:
Revision 1, February 8, 1993; Revision 2, February 26, 1993; and Revision 3, March 3, 1993.
The Institute of Electrical and Electronic Engineers (IEEE) is drafting Stand-ard P848, " Procedure for the Determination of the Ampacity Derat-ing of Fire Protected Cables," to specify methods for measuring the derating factor; the TU test plan for the witnessed testing referenced Draft 11 dated April 6, 1992 with specified changes.
3.4 AmDacity Testina IEEE STD P848/D11 as implemented in the Omega Point testing for l
TU prescribes calculating the derating factor from two measured l
currents:
the steady-state current required to raise the cable temperature to 90*C in a 40*C ambient is measured for the Thermo-Lag covered specimen, and the corresponding current is then measured for the baseline (non-covered) specimen.
i Omega Point constructed a large walk-in enclosure to house the l
test specimens.
The test specimens were supported above the floor on wooden stands.
Electric heaters and fans were used in controlling the ambient temperature.
The power and data acqui-sition equipment was located outside the enclosure.
i 3
J The NRC inspectors reviewed records for the materials--cable, conduit, Thermo-Lag pre-cast sections and bulk material--and procedures used in fabricating the 3/4 inch conduit test specimen identified as TU Scheme AC 1 and Omega Point Project 95165, and determined that it had been procured and handled as Appendix B material obtained through CPSES.
The QA records for the materials were carefully organized in notebooks.
To enhance the validity of the test specimen, TU had it fabricated according to CPSES installation procedures by Peak Seal Company personnel assigned to the plant.
The inspector noted that the plant procedures were more specific and detailed than the Thermo-Lag material vendor's installation guide, and found no deficiencies in the procedures or workmanship.
The NRC inspectors observed an example of Omega Point's attention to detail.
The silicon controlled rectifier (SCR) controller maintained a constant current in the test specimen by removing part of the trailing edge of the sinusoidal waveform.
The current then passed through a transformer and on to the test cables.
Omega Point questioned whether the waveform applied to the test cables was sufficiently sinusoidal for accurate current measure-ments, and verified the acceptability with an oscilloscope.
3.4.1 Non-Class 1E Cable The NRC inspectors determined that the cable used in the cable tray test specimen could not be visually identified, since no markings appeared on the two short lengths protruding from the insulated cable tray.
Procurement records supplied by Omega Point covered 2600 feet of commercial grade cable shipped from a distributor, Datatech Electronic Cables Corporation of Houston, Texas, on June 30, 1988.
Although Datatech had certified certain characteristics of the' cable, there was no objective evidence to support the certification.
For example, the manufacturer's name and the reel number were not documented.
Omega Point personnel stated that the cable was installed in a cable tray test specimen for another customer in 1988.
At that time Omega Point was just establishing an Appendix B QA program; the QA manual existed, but the QA procedures were in preparation.
There are no records to further identify the cable or to trace its history since receipt at Omega Point until late 1992, when the cable tray test specimen was covered with Thermo-Lag for subsequent testing for TU.
The inspectors noted that the cable history is contrary to Section 4.1.1 of all three revisions of the TU test plan, which requires that TU will supply test item pieces including all cables, and to Section 4.1.11, which states that TU and associated contractor organizations will provide all applicable quality control documentation for the fire barrier system materials, cables, and installation.
Section 6.1 of the TU test 4
I
-m-m-
r
rr plan additionally requires that "all aspects of traceability as required by the Laboratory QA Program shall be applied," and "the cables...shall be traceable to the respective cable manufacturer and shall be supplied by TU Electric or the Laboratory with documentation of traceability."
The inspectors observed an apparent inconsistency between Section 4.1.1 of the test plan, which requires TU to supply the cables, and Section 6.1, which allows either TU or Omega Point to supply them.
Criterion VIII of Appendix B to 10 CFR Part 50 requires measures for the identification and control of components throughout manufacture and use.
The failure to adequately procure and control the cable tray test specimen cables constitutes Nonconformanet 99901262/93-01-02.
After conclusion of the NRC inspection and of the cable tray testing, the inspectors were informed that the test specimen cable had markings similar to those on the power cables that were spliced to the test specimen.
The cable still bore no manu-facturer's name, but had a code number that could be traced
'through a national organization to provide further description.
One other cable-related discrepancy with the draft IEEE standard occurred.
The TU engineering representative advised the NRC inspectors that the cable fill depth in the cable tray test specimen satisfied Draft 11, but not Draft 12, of IEEE STD P848.
Since the PO invokes Draft 11, there is no procedural concern with Omega Point in this regard, but it may affect the usefulness of the test results for specific applications.
3.4.2 Different Conduits in Ampacity Tests A discrepancy between the draft IEEE STD P848 and the test performance was noted following the completion of the Thermo-Lag portion of the ampacity test for the 3/4 and 2 inch conduit specimens.
During removal of the Thermo-Lag material from the conduit specimens, the NRC inspector observed that the test plan did not provide any removal instructions.
A TU represeniative stated that removal of the Thermo-Lag was a simple procedure and that instruction was not required.
However, approximately 60% of the conduit surface remained covered with Thermo-Lag material about 1/16 to 1/8 inch thick, even after use of a hammer and screwdriver to remove part of it.
Some of the trowelable material used to caulk seams apparently adhered to the conduit.
At that point the TU personnel decided that the surface finish of the conduit could be unacceptably altered by further efforts to remove the Thermo-Lag.
Instead, the instrumented cable assembly was inserted into a new conduit specimen for baseline testing.
Although this practice is permitted by Drafts 1, 2,
and 3 of the TU test plan, Drafts 11 and 12 of IEEE STD P848 both require that the same conduit specimen be used for both the baseline and 5
fi ~
4 i
protected test specimens.
Section 5.3.2.6 of Draft 11 specifies that the conduit is to be lifted off its support after the baseline test, and the fire protective system is to be applied to
]
that specimen.
Section 4.4.2.6 of Draft 12 specifies the same procedure, with the addition that "if the protective system can j
be removed without disturbing the cables or thermocouple placement, then the baseline tests may be performed before or after testing the protective cable system."
Paragraph 2 of all three revisions of the TU test plan states that the tests shall be performed in accordance with Draft 11 of except as otherwise outlined herein."
The NRC IEEE STD P848 "...
inspectors concluded that the conduit testing was performed in accordance with contractual requirements, but not in accordance with Draft 11 or 12 of IEEE STD P848.
l 3.4.3 TU Vendor Auditing The TU QA representative stated that TU had evaluated the report
.of a December 9-10, 1991, Tennessee Valley Authority (TVA) audit of Omega Point.
The NRC inspectors reviewed the TVA audit report and found it to cover selected criteria of American National Standards Institute standard ANSI N45.2, to support fire testing of seismic seal designs for a TVA nuclear power plant.
The findings were not significant, and the Omega Point responses 1
appeared to be prompt and complete.
TU had listed Omega Point as a qualified supplier based on comparing the TVA audit report with TU's QA manual.
TU QA performed no additional review specific to the scope of the ampacity derating testing.
The NRC inspectors did not review the TU QA program requirements to determine the acceptability of this practice.
3.4.4 TU QA Actions During the inspection, TU QA processed two Operations Notifica-tion Evaluation (ONE) forms for discrepancies identified by the NRC inspectors.
ONE 93-630 dated March 3, 1993, noted that Omega Point had performed ampacity testing without an approved PO release, which was faxed on March 3, 1993.
ONE 93-635 dated March 4, 1993, noted that, contrary to Section 4.1.1 of the test plan, the cable tray test specimen was not supplied by TU.
3.5 OA Procram Imolementation Omega Point's " Quality Assurance Manual" (QAM), Revision B, dated September 4, 1990, defined a QA program intended to meet the requirements of Appendix B to 10 CFR Part 50.
The NRC inspectors selectively reviewed the QA program and its implementation for 3
the ampacity derating tests, and verified that the tests were performed under the QA program.
QA oversight was performed by the QA Hanager, who reports directly to the Omega Point president as required by QAM Section 2,
" Organization."
6
)
l
I QAM Section 5,
" Instructions, Procedures, and Drawings," required all activities to be performed in accordance with instructions.
Revision 2 of the TU test plan required Omega Point personnel to verify and document that the TU installation proceduros were used for installing the Thermo-Lag.
During the entrance meeting the Omega Point QA manager stated that this responsibility was not appropriate, because Omega Point personnel had not been trained in the TU installation procedures.
TU promptly revised the test plan so that Revision 3 specified Omega Point's responsibility to be " witnessing" the use of TU installation procedures.
QAM Section 8,
" Identification and Control of Materials, Parts, and Components," established the requirements for identification of material or items being tested.
The inspectors observed that the test specimens were clearly identified and marked, and were adequately controlled except as noted in the nonconformance described in Section 3.4.1 of this report.
QAM Section 12, " Control of Measuring and Test Equipment and Sup-plies," and QAP-009, " Calibration and Certification of Measuring and Test Equipment," Revision B, dated December 12, 1991, defined calibration requirements for measuring and test equipment.
Temperatures were measured with thermocouples calibrated by the supplier, and the data acquisition system was calibrated by Omega Point personnel.
Currents were measured with a digital multimeter for i2% trending values, and with a clamp-on ammeter provided by TU for the i1% steady-state values.
The data acquisition system stored all data and periodically printed out hard copy summaries.
The NRC inspectors reviewed calibration records for all of the test instrumentation, with only one concern.
Test instrument calibration services had been performed for Omega Point by three vendors under commercial grade Pos.
In each case, however, the Omega Point QA manager had performed 1992 surveys of the vendor's quality assurance provisions for controlling the required calibrations.
The surveys were supplemented by surveillance activities for each individual PO.
Although Omega Point personnel were not familiar with current nuclear power industry practices for dedicating commercial grade items including services, the inspectors concluded that Omega Point had in fact developed adequate assurance that the calibration services were properly controlled.
The inspectors suggested some appropriate references to Omega Point to improve their understanding of commercial grade dedication.
With this clarification, the inspectors had no concerns regarding Omega Point's test equipment and calibration.
QAP-006, " Qualification and Certification of Quality Assurance Personnel," Revision B, dated December 5, 1991, established the training requirements for personnel working under the Omega Point QA program.
The NRC inspectors reviewed the qualification records for t - QA manager, the laboratory supervisor, and the 7
y V
h' fire technologist.
The records clearly documented the personnel qualifications and were acceptable.
QAM Section 18, " Audits," required Omega Point to perform inter-nal audits annually, and external audits as necessary to verify proper quality assurance of subcontracted activities.
QAP-004,
" Audits," Revision B, dated November 30, 1991, defined qualifi-cations for personnel performing audits and the requirements and methodology to be used for internal and external audits.
The inspectors reviewed Omega Point's most recent internal audit, No. 04-92, performed December 18, 1992.
The audit covered the QA program's implementation of 10 CFR Part 21 and Appendix B to 10 CFR Part 50.
The inspectors found the internal audit and responses acceptable, with the exception noted below in Section 3.6.
As noted above, the NRC inspectors also reviewed Omega Point's audits of three calibration service suppliers and found them acceptable.
Based on the selective observations, discussions, and reviews described above, the inspectors concluded that the Omega Point QA program and its implementation for the Thermo-Lag ampacity testing being performed for TU appeared to be adequate, with the exceptions noted.
3.6 10 CFR Part 21 Procram The NRC inspectors reviewed procedure QAP-005, " Reporting of Defects and Noncompliance," Revision B, dated November 30, 1991, which implemented the requirements of 10 CFR Part 21.
The procedure adequately covered previous requirements, but had not been revised to incorporate the substantive changes which became effective on October 29, 1991.
Discussion with the Omega Point QA manager indicated that Omega Point had been unaware of the revision to 10 CFR Part 21.
In addition, the inspectors reviewed Omega Point's posting of 10 CFR Part 21, as required by 10 CFR 21.6, and determined that the version posted was not current.
The Omega Point QA manager stated that QAP 005 would be revised and the current version of 10 CFR Part 21 would be posted by March 26, 1993.
This discrepancy constitutes Violation 99901262/93-01-01.
The NRC inspectors also noted that Omega Point commercial grade POs for calibration services improperly invoked 10 CFR Part 21.
i The Omega Point QA manager agreed to discontinue this practice.
3.7 Summary Concerns Recardina Anoacity Deratina Tests for TU The NRC inspectors identified the following technical concerns regarding the ampacity derating tests.
These concerns are described in Section 3.4 of this report, and are as follows:
i 8
h
p-I i
(a)
Non-class 1E cable in cable tray test specimen (b)
Cable tray fill depth (c)
Different conduits in anpacity tests 1
(d)
Test specimen lacked traceability documentation as required by test plan i
These concerns have been identified to the NRC s Electrical Engineering Branch for their consideration and disposition.
4 PERSONNEL CONTACTED Omeca Point:
+
D. N. Priest, President
+
C. A. Humphrey, Vice President and QA Manager
+
H.
W.
Stansberry II, Fire Technologist K. Hitchcock, Lab Technician Supervisor Texas Utilities:
+
J. L. White, Senior Engineer
+
C. Pruett, QA Representative O.
Bhatty, Issue Interface Coordinator Contractors to Texas Utilities:
+
M. K. Quick, Mechanical Engineer, Stone and Webster Corp.
R. Bridwell, QA Representative, Peak Seal Co.
R. L. Dible, Fire Protection Engineer, ABB Impell Corp.
Tennessee Vallev Authority:
K. Brown, Engineering U.S. Nuclear Reculatory Commission:
[
R. V. Jenkins, Engineer, Electrical Engineering Branch
+
i
+
Attended the entrance meeting on March 3, 1993 l
Attended the exit meeting on March 5, 1993 9
l