ML20238A190

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Identifies Unresolved Item in NRC 841011 Rept 84-22 Re Bisco Fire Seals Certification & Burned QA Records.Recommends That Vendor Program Branch Perform in-depth Insp of Bisco to Determine If QA Program Adequate
ML20238A190
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 12/02/1985
From: Phillips H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Zech G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20237F760 List: ... further results
References
NUDOCS 8708200395
Download: ML20238A190 (3)
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i December 2,1985 E X Hi s i r Alo. 19 i

Docket Nos: 50-445/446 i MEMORANDUM FOR: Gary G. Zech, Chief _ _

Vendor Program Branch THRU: Thomas F. Westeman, Chief l Comanche Peak Group FROM: H. S. Phillips, Senior Resident Inspector Comanche Peak

SUBJECT:

BISCO FIRE SEALS CERTIFICATION AND QA RECORDS WHICH BURMED l

I filentified an unresolved item in NRC Report 84-22 dated October 11, 1984 which dealt with questionable certification with respect to testing of BISCO seals. Recently I asked Mr. Thomas . Young to followup on this item. During the last two weeks he has identified-two statements that may be false with respect to meeting the test require-ments of ASTM E-119 and IEEE 634 as required by FSAR (Enclosure 5)-

l and Gibbs & Hill Specification No. 2323-MS-38F and to retaining

! QA records. This work is being done under TUGC0 Contract No. CP-0707 j l (between TUGC0 and BISCO). This work involves the design and testing 1 l of numerous configurations of electrical penetration seals.

I Gibbs & Hill specification No. 2323-MS-38F requires that the electrical penetration configuration be tested in accordance with ASTN E-119 and IEEE 634 testing requirements. While reviewing documentation, it was noted that BISCO Letter No. 3346-271 (Enclosure 1 certifies-that these test requirements were met; however, a summary) of test results (Enclosure 2) states that the IEEE test requirements for i Test No. PCA-76 were not considered. BISCO Seal Design Matrix l

(Enclosure 3) identifies Texas Utilities Services and BISCO drawings, '

material, and tests. It also shows approval by the American Nuclear Insurers (ANI). The NRC inspector found no objective that this  !

design configuration was tested to IEEE 634 requirements.

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i' During this review, the NRC inspector learned that in October 1976 portions of the tests perfomed on Test No. PCA-76 failed and subsequent i tests demonstrated that this design configuration passed. In a conversation with Mr. Gary Fedor, a BISCO Development Engineer at Park Ridge, Illinois, the NRC inspector found that the ANI had rescinded their acceptance of Test No. PCA-76 because test data / documentation had been lost in a fire in the summer of 1976. In BISCO letter dated September 1986 (Enclosure 4) there is a statement that it was either burned in a fire or lost after the fire. Since the testing was done in October 1976, these statements appear to be conflicting or false.

The fire of 1976 was preceded by a 1975 fire.  ;

1 The circumstances of these fires are interesting because (1) records were not adequately protected, (2) corrective action was not taken {

after the 1975 fire, (3) records of test failures were lost, (4) there <

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is a question of how many quality records were lost, and (5) was any aspect of this reportable per 10CFR Part 21 requirements?

The ANI required B1500 to retest. Enclosure 2 shows that Test No.

748-183 (very similar to PCA-76) failed in 1985 and Test No. 748-134 (not similar; i.e. size and tray configuration) passed in 1984 The 1934 test preceded Texas Utilities request to load fuel in September 1984 and the ANI request for retest and subsequent failure was after the requested fuel load date. Two questions arise: (1) was the 1984  !

test appropriate for the specific configuration, and (2) does BISCO )

documentation indicate that Texas Utilities Equipment Qualification 1 (EO) Program is adequate; i.e. are the technical reviews BISCO design and testing adequate and does their audit of BISCO verify test data to be dependable and backup test reports and certifications. If the Vendor Program Branch performs an inspection, please furnish any information concerning these questions to assist in inspecting Texas Utilities EQ activities concerning BISCO.

It is recommended that the Vendor Program Branch perform an in-depth  !

inspection of BISCO to determine if their QA program assures that safety related activities are controlled and penetration seals are  ;

designed and tested in accordance with requirements. It is also recommended that a determination be made as to whether certifications and statements are false and should be investigated.

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-3' If you have further questions regarding.this matter,' please contact me at (817) 897-2201. .j H. S. Phillips, Senior Resident inspector.  !

Comanche Peak

Enclosures:

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1. BISCO Letter No. 3346-271 1
2. Summary of Testing j
3. BISCO Design. Configuration '
4. BISCO Letter Dated 9-16-85
5. FSAR i

i cc: T. Westerman 1

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