ML20154N046
| ML20154N046 | |
| Person / Time | |
|---|---|
| Issue date: | 03/11/1986 |
| From: | Merschoff E, Petrosino J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20154N017 | List: |
| References | |
| REF-QA-99901038 99901038-85-01, 99901038-85-1, NUDOCS 8603170181 | |
| Download: ML20154N046 (5) | |
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1 ORGANIZATION: MINNES0TA MINING AND MANUFACTURING COMPANY SAINT PAUL, MINNESOTA REPOPT INSPECTION INSPECTION NO.: 99901038/85-01 DATE(S): 11/20-22/85 ON-SITE HOURS: 44 CORRESPONDENCE ADDRESS: 3M Company Ceramic Materials Department ATTN: Mr. Joseph T. Bailey Department Manager 225-4N-07 3M Center Saint Paul, Minnesota 55144-1000 ORGANIZATIONAL CONTACT: Mr. W. P. Nitardy TELEPHONE NUMBER: (612) 733-6262 NUCLEAR INDUSTRY ACTIVITY: 3M currently offers the nuclear industry a one hour UL rated fire barrier wrapping system for protecting electrical cables.
I ASSIGNED INSPECTOR: !w ~
'J.' J. feprosino,' Reactive Inspection Section (RIS
[6' Date
/
OTHER INSPECTOR: E. Yachimiak, RIS APPROVED BY: ,
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E. W. Merschof#f Chief, RIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE: A. BASES: 10 CFR Part 21 B. SCOPE: The purpose of this inspection was to review the circumstances surrounding an NRC concern which was identified during a recent Ft. Calhoun outage inspection. PLANT SITE APPLICABILITY: Enrico Fermi 2 (50-341); Ft. Calhoun 1 (50-285); Haddam Neck (50-213); Hope Creek 1 (50-354); Nine Mile Point 1 (50-220); (continued on next paqe) 8603170181 860313 PDR GA999 ENV3MCO 99901038 PDR
e a t ORGANIZATION: MINNESOTA MINING AND MANUFACTURING COMPANY SAINT PAUL, MINNES0TA REPORT INSPECTION NO.- 99901038/85-01 RESilLTS: PAGE 2 of 4 PLANT SITE APPLICABILITY: (continued) Palisades (50-255), Perry 1 (50-440); Ouad Cities 1 & 2 (50-254/265); Rancho Seco 1 (50-312); Salem 1 & 2 (50-272/311); and Watts Bar 1 & 2 (50-390/391). A. Violations None. B. Nonconformances
- 1. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 1 of the 3M quality assurance manual (85-01-01):
- a. The 3M Company did not perform or control ampacity derating computer code activities, in accordance with documented instructions. These activities included engineering, research, data processing and document control.
- b. Documented procedures or instructions to control activities affecting quality were not initiated by the 3M Company for its cable ampacity derating computer code development, in-process program activities, or modifications thereof.
- 2. Contrary to Criterion II of Appendix B to 10 CFR Part 50 and Section 2 of the 3M QA manual, three employees out of a sample of ten had not received the required QA program indoctrinatinn (85-01-02).
- 3. Contrary to Criterion I, of Appendix B to 10 CFR Part 50 and Section I of the 3M QA manual, the QA Manager does not report to a management level which would enable him to achieve the recuired authority and organizational freedom, including suf ficient independence from cost and schedule. Examples of this as of November 22, 1985, are (85-01-03):
- a. The QA Manager reported to the manager of production instead of the 3M Ceramic Department Manager, as indicated on the organizational chart within the QAM.
- b. The annual 3M personnel performance evaluation for the OA Manager is initiated and completed by the 3M Production Manager.
C. Unresolved Items None. t
B 4
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ORGANIZATION: MINNESOTA MINING AND MANUFACTURING COMPANY SAINT PAUL, M!NNES0TA REPORT INSPECTION NO.- 99901038/85-01 RESULTS: PAGE 3 of 4 D. Background Information During a recent NRC inspection at the Omaha Public Power District (OPPD) Fort Calhoun Station, concerns were identified relative to cable ampacity derating values that the 3M Company provided to OPPD. The derating values were requested by 0 PPD for use with the 3M "Interam" fire wrap system. The specific NRC concerns are: OPPD did not verify the validity of the ampacity derating values supplied to them by the 3M Company. Failure of OPPD to assure the validity of the derating values is identified as a deficiency, item #D.5.2-1, in NRC report #50-285/85-22. A misinterpretation by OPPD or other NRC licensees could occur, because of the manner in which the derating valaes were stated and supplemented with percentages for quick reference. Additionally, a lack of standards for the acceptance or rejection criteria of " fire wrapped" cables and raceways, was revealed.
- The lack of this criteria has prompted fire wrapping manufacturers to calculate and provide their own derating values.
E. Other Findings or Comments Ampacity Derating Methods _ The 3M Company is taking additional measures to assure the accuracy of its derating values. The methods which 3M are utilizing to obtain the cable ampacity derating values are discussed below:
- a. Two methods of determining ampacity derating factors are currently utilized by 3M. One involves a mathematical computer model, and the other involves 3M's experimental test data results,
- b. The 3M Company documented and correlated separate computer code run results with specific National Electrical Code (NEC) copper conductor ampacity tables. In addition, they expressed their derating value in a percentage. This derating percentage was based on the computer generated ampacity data, which when compared to the NEC ampacity value, resulted in a less conservative derating factor.
Currently, there are no industry wide standards that manufactures or licensees could utilize for guidance when using the "Interam" fire wrap system or other similar products. c- ,- ---
O i ORGANIZATION: MINNES0TA MINING AND MANUFACTURING COMPANY SAINT PAUL, MINNES0TA REPORT INSPECTION NO.- 99901038/85-01 RESilLTS: PAGE 4 of 4 Part 21 The 3M Company is currently evaluating the computer code and derating percentage values as potentially reportable 10 CFR Part 21 items. All affected licensees are identified on page 1 of this inspection report. An evaluation of a previous problem was reviewed by the NRC inspectors and subsequently discussed with 3M QA personnel. This item concerned fire barrier ceramic cord which had been utilized to secure the "Interam" system once it was wrapped around the cable or raceway. Degradation of the cord could occur at certain humidities. The 3M Company is reevaluating this situation following discussions with the NRC inspector. 10 CFR 50 Appendix R Implications on Caole Ampacity Derating During the recent Outage Inspection at Fort Calhoun Nuclear Station by the NRC a deficiency was identified concerning Appendix R compliance modifications. These modifications consisted of the wrapping of electrical conduit and cable trays with 3M's Interam fire prctection wrapping system. The "engineerir q" analysis performed by 0 PPD staff members to determine if cable ampacicy derating was required consisted of comparing the FSAR cable rating design value (125% of design load) with a 3M supplied ampacity derating factor. No documented records could be produced to assure that the informatien supplied by 3M was acceptable and within the original design parameters for their proposed modifications. Since there are no standard tables available to determine cable ampacity derating factors for insulated conduit or cable trays, an analysis should have been performed to verify the validity of 3M's derating factors. Therefore, deficiency item #D.5.2-1, on NRC inspection report 850-285/85-22 for the Fort Calhoun station was identified. E. Persons Contacted tlilliam Nitardy QA Manager ** Randall Koza Sr. Product Development Engineer ** Richard Licht Production Development Supervisor ** Joseph T. Bailey Ceramic Department Manager ** Thomas Sheehm Marketing Manager ** Pobert Topness Production Manager ** Diane Trumble Document Control Coordinator
** Exit meeting attendees.
F LT t PAGE / OF / REPORT NO. 9990 /c# N'-r-?/ DOCUMENTS REVIEWED NO. TYPE D0C. NO. DATE COMMENTS
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TYPE CODE: DWG - DRAWING SPEC - SPECIFICATION PRO - PROCEDURE QAM - 0A MANUAL P.O. - PURCHASE ORDER I.M. - INTERNAL MEMO ,}}