ML24302A277
| ML24302A277 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Wolf Creek, Susquehanna, Limerick, Waterford, LaSalle  |
| Issue date: | 10/28/2024 |
| From: | Sargenski P Marmon Industrial Energy & Infrastructure, RSCC Wire & Cable |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML24302A277 (1) | |
Text
Marmon Industrial Energy & Infrastructure October 28, 2024 Attn: Document Control Desk U.S. Nuclear Regulatory Commission (NRC)
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Subject:
RSCC Wire & Cable LLC-interim update to Part 21 Retraction of Final Notification
Dear Sir or Madam,
This letter to the Nuclear Regulatory Commission (NRC) is an update to a prior written notification to the NRC of shipments of a non-compliant material in accordance with 10 CFR 21.21(d)(4).
On July 23, 2024, RSCC Wire and Cable LLC (RSCC) discovered a reel of insulated conductor which had been segregated due to an off standard report (OSR) had shipped to customers noted in Attachment 1 to this memorandum. The reel was determined to be non-compliant due to failure of insulation tensile and elongation at break (EAB) test following air oven aging. The extent of condition is limited to a single production work order and a single part number. All non-compliant insulated conductor has been accounted for. On July 25, 2024, RSCC submitted a written notification to the NRC of a shipment of non-compliant material in accordance with 10 CFR 21.21(d)(4), and on August 23, 2023, RSCC submitted a letter to the NRC of what it believed would be its Final Notification to the NRC about this matter in accordance with 10 CFR 21.21(d)(4).
However, during the subsequent course of RSCC's review and implementation of corrective actions, RSCC learned that an additional non-compliant shipment was identified with the same condition, and on September 6, 2024, RSCC notified the NRC of this development and requested the redaction of the August 23, 2024 submission based on this new information.
On September 6, 2024, a retraction of Final Notification was requested for additional containment actions. While implementing corrective actions, an additional non-compliant shipment was identified (with same condition) and RSCC notified this customer. Root cause was traced to the application of laboratory sampling and testing frequencies, and the scope of containment actions was expanded. Attachment 1 to the September 6 update identified the impacted customers and product limited to the work orders listed.
On September 17, 2024, RSCC submitted an interim update letter to the NRC on this matter, identifying an additional customer that received non-conforming product.
On September 26, 2024, RSCC provided an update to the NRC on the status of its evaluation of the extent of condition and resulting corrective actions where RSCC estimated that its evaluation and any additional necessary corrective actions would be identified by October 4, 2024. Among other reasons for the time delay is that the testing process for potentially impacted material includes a 14-day aging test. At the time, RSCC believe it would have a final updated report ready for the NRC by October 7, 2024, which would include the results of the extent of condition, including all impacted customers, and corrective actions, along with the results of a third party audit verification of RSCC's implemented corrective actions.
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1-D Bradle,y P,~ ltoiJd, r.in Er;Jn~, CTQ602ii PltOM; 860*653-8300 F.ax:860-6!>3-8~1 Given that RSCC's evaluation has shown that the shipment of non-conforming product is more widespread than originally anticipated, RSCC has decided to expand the scope and breath of our review to ensure that RSCC has identified and corrected for the full extent of this matter. As a result, RSCC is looking back over all shipments over the past 18 months to ensure all non-conforming product has been accounted for. We are performing this review as expeditiously as possible, but due to the extent of the potentially impacted sites, the need to coordinate with multiple customers, and the time to undertake the necessary testing requirements of the product, the letter will serve as an interim update as we complete the more comprehensive review. Attachment 1 provides the list of impacted customers to date, and we have indicated therein at which point each set of customers have been identified. Attachment 2 provides the information required under 10 CFR 21.21(d)(4) as known at this time, and updates the previous submission of this information to the NRC in RSCC's September 6 letter. Notably, it updatesSection V (for the expanded scope of shipped non-compliant product),Section VII (to reflect additional corrective action and the completion date for certain actions).
At this point, RSCC has notified all customers that we have identified received non-compliant material, and RSCC requested return of the non-compliant material. With respect to the known issues, root cause(s} and corrective action(s} have been identified, taken, and implemented to address the non-compliant escapes. Furthermore, as previously noted, RSCC has engaged a third party auditor to evaluate the implementation of the corrective actions. This review has been completed, and demonstrates all identified corrective actions for known shipments have been implementedC.
If you have any questions related to this issue, the evaluation, and/or corrective action(s), please contact me at the number listed below my name. We will also reach out to your office to brief you on these developments.
Sincerely, Phillip s*~rgenski
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Quality Assurance Manager Direct: 860-653-8376 Phillip.sargenski@marmoniei.com Cc:
Aaron Folkening - President RSCC Wire and Cable LLC (d.b.a MarmonlEI}
Marmon Industrial Energy & Infrastructure : Customer Exhibit As identified in July 25. 2024 report to the NRC:
RSCC (Manufacture) Part Number FS01014-002 (A820146}
==
Description:==
1C 14 AWG 7 /.0242" TC XLPE Firewall SIS Grey 600V Work Order: 727472 RSCC Customer Plant Customer PO Number Sales Order Number 139572 Wolf Creek Wolf Creek WCNOC-8000002251 139531 Constellation Dresden 1451762 139530 Constellation LaSalle 1451264 136622 Constellation Limerick 1405573 136475 Constellation Peach Bottom 1404513 138627 Entergy Arkansas Nuclear One 61231961 136393 Entergy Waterford 3 61094275 136346 Talen Susquehanna 708635 135564 Entergy Harbor Davis Besse 45686968 As identified in September 6. 2024 update to the NRC:
RSCC (Manufacture) Part Number FN12014-000 (C530120)
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- .1ic860-65-3-830, Part Number Shipment Date WSR81301304 3/19/2024 00000013741 3/18/2024 00000013741 3/18/2024 0012509502 1 9/28/2023 0012509502 1 9/25/2023 991790024 1/31/2024 143-8846163 9/28/2023 91210017 9/29/2023 0000112273006 9/28/2023
==
Description:==
12C 14 AWG 7/.0242 TC XLPE Firewall Ill, Nuclear M1K1 8/k CSPE 600V Work Order 917765 Quantity (FT) 1178 2200 2750 2000 1100 550 700 6000 3000 RSCC customer Plant customer PO Number Part Number Ship Date Quantity-FT Sales Order 138425 Constellation Galvert Qiffs 1418988 00014702511 As identified in September 17. 2024 update to the NRC:
RSCC (Manufacture) Part Number FN07014-000 (C530070
==
Description:==
7C 14 AWG 7/.0242 TC XLPE Firewall Ill M1K1 8/k CSPE 600V Work Order 994687 RSCC customer Plant customer PO Number Part Number Sales Order CUrtiss - Wright 139430 Nuclear Middleburg Heights, OH 3220543 c.530070 Division IR Marmon Electrical A &erlcthfre H*tf'I*~*~ ComPtittY 3/26/2024 3178 Ship Date Quantity-FT 3/29/2024 100
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ON Marmon Industrial 11 Energy & Infrastructure : Transfer of information per 10 CFR 21.21{d){4)
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i) Name and address of the individual or individuals informing the Commission.
Phillip Sargenski, Quality Assurance Manager RSCC Wire & Cable LLC, 20 Bradley Park Rd, East Granby, CT 06026 ii) Identification of the facility, the activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or contains a defect.
RSCC Wire & Cable LLC shipped safety-related product to customers listed in Attachment 1.
{iii) Identification of the firm constructing the facility or supplying the basic component which fails to comply or contains a defect.
RSCC Wire & Cable LLC manufactured the insulated conductor.
{iv) Nature of the defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply.
Insulated conductor is non-compliant due to failure of insulation tensile and elongation at break (EAB) test following air oven aging.
{v) The date on which the information of such defect or failure to comply was obtained.
Initial discovery occurred on July 23, 2024, with additional identification of non-compliant product subsequently, as listed in Attachment 1 to NRC letters dated September 6, 2024 and September 17.
{vi) In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for, being supplied for, or may be supplied for, manufactured, or being manufactured for one or more facilities or activities subject to the regulations in this part.
Customers that received non-compliant safety-related products from RSCC Wire and Cable are identified in.
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(vii) The corrective action which has been, is being, or will be taken; the name of the individual or organization responsible for the action; and the length of time that has been or will be taken to complete the action.
1-Implement electronic HOLD process in ERP system for work orders with applied nonconformance(s) until completion of disposition, released by Quality Engineer. Quality Engineer, Completed 8/22/2024 2-Add confirmation process at final QC Inspection/ Test that all applicable nonconformance(s) have been resolved with verification of conforming data associated with inspection and testing. QC Manager, Completed 9/13/2024 3-Add independent verification at final document review that all applicable nonconformance(s) have been resolved. QA Manager, Completed 8/27/2024 4-Updated criteria for laboratory sampling and testing frequencies to include every work order.
Completed 9/13/2024 5-Audit completed by 3rd Party NQA-1 Lead Auditor for verification of effective implementation.
Completed 10/1/2024 (viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.
The non-compliant insulated conductor may not be relied upon to perform its safety-function.
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