ML20203H948
| ML20203H948 | |
| Person / Time | |
|---|---|
| Issue date: | 03/26/1986 |
| From: | Merschoff E, Petrosino J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20203H930 | List: |
| References | |
| REF-QA-99900225 NUDOCS 8604300058 | |
| Download: ML20203H948 (11) | |
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ORGANIZATION: THE FOXB0R0 COMPANY FOXBOR0, MASSACHUSETTS i REPORT INSPECTION INSPECTION NO.- 99900225/85-01 DATE(S): 12/9-13/85 ON-SITE H0llPS- 94 CORRESPONDENCE ADDRESS: The Foxboro Company ATTN: Mr. J. W. Graham Vice President 38 Neponset Avenue . Foxboro, Massachusetts 02035 ORGANIZATIONAL CONTACT: Mr. M. J. Berberian, Corporate QA Manager TFlFPHnNF NilMRCR* (A171 Cat 97Cn PRINCIPAL PRODUCT: Industrial Control Systems & Instruments NUCLEAR INDUSTRY ACTIVITY: Current nuclear in house orders are for the following utilities: Arizona Public Service, Florida Power & Light, Duke 1 Power, Power Authority of the State of New York, Northern States Power, GPU l Nuclear Corporation (Three Mile Island), and Gulf States Utilities. M
/\i ASSIGNED INSPECTOR: _+w / ,
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/J'.~ JfPe tosino, Reactive Inspection Section (RIS) Date 3-26 oc OTHER INSPECTOR (S)- E. Yachimiak, RIS T. Keck, Brookha N tional Laboratories APPROVED BY: .
Mer[sc E. W. Merschoff// Chief, RIS, Vendor Program Branch Date l INSPECTION BASES AND SCOPE: A. BASES: 10 CF,R Part 21 and Appendix B to 10 CFR Part 50 B. SCOPE: This inspection was made as a result of a Haddam Neck Licensee Event Report concerning the degradation of electrical conductor , insulation on The Foxboro Company's "E-line" electronic controllers. PLANT SITE APPLICABILITY: See next page. 8604300058 860428 PDR GA999 EMVFOXB 99900225 PDR
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ORGANIZATION: THE FOXB0R0 COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.- 99900225/85-01 RESULTS: PAGE 2 of 9 Plant Site Applicability: Arkansas 1 & 2 (50-313/368); Beaver Valley 1 & 2 (50-334/417); Bellefonte 1 & 2 (50-438/439);Braidwood 1 & 2 (50-456/457); 1, 2 & 3 (50-259/260/296); Brunswick 1 & 2 (50-324/325); Browns Ferry Byron 1 & 2 (50-454/455); Callaway (50-483); Calvert Cliffs 1 & 2 (50-317/318); Catawba 1 & 2 (50-413/414); Clinton 1 (50-461); Cook 1 & 2 (50-315/316); Cooper Station (50-298); Crystal River (50-302); Davis-Besse-(50-346); Dresden 2.& 3 (50-237/249); Duane Arnold (50-331); Enrico Fermi s50-341); Farley -1 & 2 (50-348/364); Fitzpatrick (50-333); Fort Calhoun (50-285); Fort Saint Vrain (50-267); Ginna (50-244); Grand Gulf (50-416); Haddam Neck (50-213); Hatch 1 & 2 (50-321/366); Indian Point 2 & 3 (50-247/286); Kewaunee (50-305); Lacrosse (50-409); LaSalle 1 & 2 (50-373/374); Limerick 1 & 2 (50-352/353); Maine Yankee (50-309); Millstone 1, 2 & 3 (50-245/336/423); Monticello (50-263); ) Nine Mile Point 1 & 2 (50-220/410); North Anna 1 & 2 (50-338/339); Oyster Creek (50-219); Palisades (50-255); Palo Verde 1, 2 & 3 (50-528/529/530); . Peach Bottom 2 & 3 (50-277/278); Perry (50-440); Pilgrim (50-293); Point Beach 1 & 2 (50-266/301); Prairie Island 1 & 2 (50-282/306); Quad Cities 1 & 2 (50-254/265); Rancho Seco (50-312); Hiver Bend (50-458); Robinson (50-261); San Onofre 1, 2 & 3 (50-206/361/362); Seabrook(50-443);Sequoyah 1 & 2 (50-327/328); South Texas 1 & 2 (50-498/499); Saint Lucie 1 & 2 (50-335/389); Surry 1 & 2 (50-280/281); Three Mile Island 1 & 2 (50-289/320); Trojan (50-344); Turkey Point 3 & 4 (50-250/251); Vermont Yankee (50-271); Vogtle 1 & 2 (50-424/425); Washington Nuclear 2 & 3 (50-397/508); Waterford (50-382); Watts Bar 1 & 2 (50-391/390); Wolf Creek (50-482); Yankee Rowe (a0-029); and Zion 1 & 2 (50-295/304). A. Inspection ~ Issues 1
- 1. The purpose of this inspection was to:
- a. Review the conductor insulation degradation problem which was identified on LER #84-017, dated October 4,1984 from the Haddam Neck Nuclear Station. Additionally, to evaluate The Foxboro Company's (TFC) determination that 10 CFR Part 21 does not apply to the insulation degradation,
- b. Determine the adequacy of the implementation of TFC's quality assurance program at the Highland facility and the corporate office.
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1 ORGANIZATION: THE FOXBORO COMPANY ! FOXBOR0, MASSACHUSETTS I REPORT INSPECTION Mn . QQQ An??R /RR _01 DFRf fl TR - DMr 1 nf o l l B. Inspection Findings
- Violations
- 1. Contrary to Section 21.21, " Notification of failure to comply or existence of a defect," of 10 CFR Part 21:
- a. TFC failed to notify the Commission of a defect in the conductor insulation of an interconnection coil cord cable set'(cable set),
part number N0101NW or N0101PW. This was identified to TFC by the San Onofre Nuclear Station in the fall of 1978. TFC's Component Failure Analysis Report # 1979-CFA-28, dated June 11, 1979, indicates that a defect was found and identified at an NRC licensee, which involves "... crumbling and disintegration of insulation...." However, no evaluation for reportability was performed or notification made to the Commission or the applicable licensees concernin the insulation degradation defect until October 18, 1985 85-01-01). This is a Severity Level III violation (Supplement VII).
- b. TFC procedures which were adopted as required by 10 CFR Part 21 failed to adequately provide for evaluating deviations for reportability or infonning the licensee of deviations in order that the licensee could cause the deviation to be evaluated.
The following examples are deviations which TFC was cognizant of but were not evaluated for reportability or transmitted to the licensees for their evaluations, specifically (85-01-02):
- 1. TFC Report # 1984-CFA-08, " Leaking / Corrosion on
' ~ Electrolytic Capacitors" - (Sangamo-generic)
- 2. TFC Report # 1985-CFA-019(SI),." Transistor / Diode / Relay Failures" - (UCM Power Supply).
- 3. Highland # 11364/11365, " Failure of Pen Drive (PWA)
Cards-N227S Recorders" - (Peach Bottom).
- 4. ~ Highland # 1102-1104 "2A0VAI intermittent output supply"
-(NortheastUtilities).
I I I
-1 l
1
t - l l ORGANIZATION: THE FOXB0RO COMPANY FOXBOR0, MASSACHUSETTS l REPORT INSPECTION NO_- 4Q900775/85-01 RESULTS: PAGE 4 of 9
- 5. Highland # 4112, " Power Supply Fuse Problem" - (Pilgrim).
- 6. Highland #5169, "62H Electronic Controllers - Erratic Outputs" - (End of Life).
This is a Severity Level IV violation (Supplement VII) Nonconformances
- 1. Contrary to Criterion II, " Quality Assurance Program," of Appendix B to 10 CFR Part 50 and Section 2.7 of TFC Highland Quality Program
, Manual, no indoctrination program was established or implemented for any personnel performing activities that affect nuclear quality with the exception of the Q.C. inspectors and assembly line personnel (85-01-03).
- 2. Contrary to Criterion V, " Instructions, Procedures, and Drawings,"
of Appendix B to 10 CFR Part 50 and Section 4.1, of TFC's Corporate Quality Assurance Procedure 3.18.3 (85-01-04):
- a. Procedures were not adequately established to provide instructions for personnel to notify the Foxboro Nuclear Safety Sub-Committee (NSS) of "... conditions adverse to quality ...."
- b. Inadequate procedure implementation was evidenced by the lack of NSS records to indicate the following deviations were evaluated for 10 CFR Part 21 reportability:
- 1. Peach Bottom letter to TFC, dated July 22, 1985 " Failed printed circuit cards," utilized on safety related model '
- No. N 2275 recorders.
- 2. Report No.1984-CFA-08 "Sangamo Electrolytic Capacitors, Series 139R, Leaking and Corrosion found in Three Lots."
- 3. Report No. 1985-CFA-019(SI) " Transistor diode and relay failures in the UCM Power su plies," (this was identified as.a "Long-standing problem" .
- 4. Highland No. 1102-1104 "2A0VAI, intermittent output supply" - (Northeast. Utilities).
- 5. Highland No. 4112 " Power supply fuse problem" - (Pilgrim).
i. s . ORGANIZATION: THE FOXB0R0 COMPANY ' FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.- 99900225/85-01 RESULTS: PAGE 5 of 9
- 6. Highland No. 5169 "62H Electronic Controllers - Erratic Outputs" - (End of life susceptibility).
- 3. Contrary to Criterion VII, " Control of Purchased Material, Equipment, and Services," of Appendix B to 10 CFR Part 50, an outside calibration laboratory was on TFC approved vendors list, without any documented audit results in TFC files (85-01-05).
- 4. Contrary to Criterion XII, " Control of Measuring and. Test Equipment," of Appendix B to 10 CFR Part 50 and TFC Highland Plant Quality Procedure 56.01, instrument numbers 204700-1 (cal. due date 08/18/85), and 20425-1 (cal. due date 11/16/85) were found to have calibration due dates which were past due.
These instruments were found in the Highland manufacturing - areas where they could be utilized (85-01-06). l
- 5. Contrary to Criterion XVIII, " Audits," of Appendix B to 10 CFR Part 50 and Section 18 of TFC Highland Plant Quality Program Implementation Plan, in-process internal audits were not performed quarterly as required for "all stages of operations" by the Highland Plant quality control audit schedule as indicated below (85-01-07):
. One out of the 37 scheduled audits was not performed in the first calendar quarter of 1985.
. 30 out of the 37 scheduled audits were not performed in the second calt.1dar quarter of 1985.
~
. 37 out of the 37 scheduled audits were not performed in the third calendar quarter of 1985.
. 37 out of the 37 scheduled audits were not performed in the last caleridar quarter of 1985, as of December 13, 1985. j C. Background Information TFC manufactures industrial electrical and pneumatic control systems, I devices, and instruments. Several of TFC manufacturing locations in the U.S., Canada, and England, supply components to the U.S. nuclear industry.
The insulation degradation problem was identified with TFC E-Line controllers, and is found on the " cable set," TFC Part Number N0101NW or N0101PW. The " cable set" is a 15 conductor coiled cord cable with a
~' ' ORGANIZATION: THE FOXBOR0 COMPANY FOXBOR0, MASSACHUSETTS ',i ii REPORT INSPECTION NO.- 99900225/85-01 RESULTS: PAGE 6 of 9 l, molded plug at one end and a terminal block at the other end. The coiled cord cable was a procured item and was supplied by two manufacturers. The manufacturers were Whitney-Blake Company and Gavitt Wire and Cable. The E-line controllers and associated cable sets were manufactured and assembled by TFC during the approximate period of 1960 - 1974. Until 1984, cable set replacement units were offered by TFC. TFC was first informed of the degradation problem by the San Onofre Unit 1 nuclear station in the fall of 1978. The conductor insulation ; disintegrated on all conductors while the cable jacket remained intact. TFC was again informed of the same problem by the Haddam Neck Plant. in November of 1984. LER #50-213/84-017 was generated by Connecticut Yankee (CY). The University of Connecticut performed an analysis of two of the degraded cable sets for CY and concluded in a letter to CY and Northeast. Utilities, dated August 2, 1985, that:
- a. "... an inadequate amount of stabilizers or poorly chosen stabilizers, would contribute to the severe ... breakdown, in this case ... lack of effective stabilizers may explain the degradation ,
under apparently mild service conditions ...." ' 9
- b. "
... the type of insulation is not known exactly, but may be synthetic rubber ... possibly of the butad1ene-stycene (Bona-S) or butadiene-acrylonitrile (Buna-N) type ....,,
- c. "... insulation ... is badly embrittled, both inside and outside the jacket ... touching the insulation caused it to crack and fall off...."
- d. "... the conclusion seems clear that the insulation used in these '
units has poor stability, whether for reasons mainly of stabilizer choice and amount or of the rubber type being inappropriate for this application ...." l In response to this problem, Foxboro stated in an October 18, 1985 letter ) to CY'that the cable has a design life of ten years and insulation should ' be examined for deterioration at least annually and that TFC "does not believe that 10 CFR Part 21 applies because the instruments pre-date the regulation." ) However, the notification requirements of 10 CFR Part 21 still apply : if a deviation amounting to a defect, as defined by Part 21 is discovered l i
i. I ORGANIZATION: THE FOXBOR0 COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.- 99900225/85-01 RESULTS: PAGE 7 of 9 after the effective date of 10 CFR Part 21. If it was not possible for TFC to determine whether the deviation could create a significant safety hazard for the installed equipment application, then all pertinent information should have been provided to the end-user for evaluation and determination of whether a reportable defect exists. TFC was notified of the insulation degradation by the San Onofre Nuclear , In the fall of 1978, San Onofre informed TFC Plant, Unit 1, in 1978. that they were having failures with the cable sets in which the conductor insulation disintegrated on all conductors while the cable jacket remained intact. San Onofre stated that the insulation "... exhibited ozone type attack and failure (crumbling and disintegration of insulation)." During the time period when TFC was first notified in 1978 and the November 1984 notification by CY, no actions were taken by TFC to:
- 1. Notify the Commission of a defect.
- 2. Notify the licensee for them to cause an evaluation to be performed.
- 3. Perform a 10 CFR Part 21 reportability evaluation (reference violations 85-01-01/02).
D. Other Comments
- 1. _1sulation Degradation TFC has stated that the cable set which was utilized in their E-Line controllers has a design life of ten year, after which, "end of life susceptibility" is reached. Further, the, have stated the insulation should be inspected "at least annually." However, no information could be produced which indicated that a specific ten year design life was-factored into the performance of the cable set, or that the 10 year product life span has been transmitted to the end users.
An analysis was performed by the University of Connecticut (UC) on two " cable sets" from the Hac'"M Neck Plant. Their conclusion states: "... the conclusion seems clear that the insulation used in these units has poor stability, whether for reasons mainly of stabilizer choice and amount or of the rubber type being inappropriate for this application." They go on to say that the key factor in the degradation appears to be "... material selection ...." Consequently, it appears that the maximum life of,the cable sets is 10 years and the cable sets should be inspected at least annually as suggested by Foxboro. Discussions with the cable manufacturers have determined that the coil cord sets typically have a life expec-tancy of 31-10 years under mild service conditions and environment.
t- , e ORGANIZATION: THE FOXBORO COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.* 49400999/RE 01 RF9fil T9
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- 2. 10 CFR Part 21 During discussions with TFC personnel from many different departments, -
it was observed that a lack of cognizance of 10 CFR Part 21 was apparent. Two departments which independently evaluate failures and deviations appear to do an adequate job of analyses and reaching the root cause of failures or deviations. However, it was apparent that the personnel were not aware of any 10 CFR Part 21 considerations. I Because of the lack of awareness of the 10 CFR Part 21 procedure the completed analyses appear to stop at a department section supervisor level. Discussions with the department section supervisor personnel indicate that they too are unfamiliar with the Part 21 requirements, (reference nonconformance 85-01-04).
- 3. Product "End-of-Life" Foxboro control equipment is used widely throughout the nuclear industry in commercial nuclear applications. The Haddam Neck LER #50-312/84-017 described the degradation of cable insulation.
The cause of this deterioration was stated as, "... obviously a function of age ...", in the LER. On October 18, 1985, Foxboro issued letters to all applicable customers identifying "End-of-Life" rusceptibility on model-E cable sets. These coil cord cable sets were stated as having a
" design" life of ten years, after which the insulation of the individual wires would deteriorate. Additionally, possible "End-of-Life" 'ailures of electrolytic capacitors and silver plated switch contacts were mentioned.
However, this correspondence has been the only one that Foxboro has made concerning "End-of-Life" failures. During discussions with Foxboro management, concerns were expressed as to the " design" life of other Foxboro components. Since it could not be demonstrated that " design" life was information known by the customer, Foxboro components may not be receiving appropriate maintenance checks to ensure their continued operability by the applicable licensees. Further discussion over this item revealed that Foxboro will be evaluating the need to inform nuclear customers of "End-of-Life" susceptibility in other Foxboro components. i i J
ORGANIZATION: THE FOXBORO COMPANY FOXBOR0, MASSACHUSETTS REPORT INSPECTION NO.- 99900225/85-01 RESULTS: PAGE 9 of 9
- 4. Highland Facility Tour: \ ,
A tour was conducted of the Highland Plant operations which included the calibration laboratory, wave soldering, shipping / , receiving, PC card assembly and general product repair areas. A sample of 18 instruments were reviewed during the tour to verify , that required recalibrations of instruments were being performed. Two out of 18 had not been calibrated as required. They were ; identified as instrument # 204700-1 (calibration due date 8/18/85), , and instrument # 20425-1 (calibration due date 11/16/85)(reference nonconformance #85-01-06). E. Persons Contacted J. W. Grahm Vice President ** ; M. J. Berberian QA Manager-Corporate ** '
, R. M. Grahn CQA**
1 W. F. Griffin QC Engineering (QCE) D. R. Scamman QCE C. O. Wilson QCE . Marion Tiehle Inspection Support , Surinder Kumar QCE M. Faria QCE-Customer Support G. Hill QCE ! H. Rizvi Component and Reliability R. La Rose Lomponent and Reliability D. W. Moon Reliability L. Hewey CQA Labs C. Lundstedt Lab R. Vaillancourt Senior Buyer . C. Stevens QCE \ W. Tripp Test Equipment. :
** Attended. exit meeting. ,
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