ML19341C521

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Responds to NRC 791018 Ltr Re Violations Noted in IE Insp Repts 50-416/79-15 & 50-417/79-15.Corrective Actions:Ge Completed Tests in Jul 1980 to Demonstrate Qualification of Power Generation Control Complex Cable Connectors
ML19341C521
Person / Time
Site: Grand Gulf  Entergy icon.png
Issue date: 02/20/1981
From: Mcgaughy J
MISSISSIPPI POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
AECM-81-59, NUDOCS 8103030687
Download: ML19341C521 (15)


Text

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., l i y-% -c.O t.3 J, aarg MISSISSIPPI POWER & LIGHT COMPANY A A Helping Build Mississippi P. O. B O X 16 4 0, J A C K S O N MI S SIS S I P PI 39205

  1. $,*$rTTN,%f February 20, 1981 Office of Inspection & Enforcement U. S. Nuclea- Regulatory Cecmission Region II 101 Marietta Street, N.W.

Suite. 3100 Atlanta, Georgia 30303 Attention: Mr. J. P. O'Reilly, Director Dear Mr. O'

$ . Q. .

SUBJECT:

Grand Gulf Nuclear Station

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,\y/ Nc) g Units 1 and 2 Docket Nos. 50-416/417

_! u File 0260/15525/15526

-j ': 2 0 :21981 - b RII:DKW 50-416/79-15 and

50-417/79-15 cf u.s. '=".scuuren58

  • IE Inspection Report of D

/Q.1 7/24-8/24/79

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AECM-81/59 if; A l j n u

References:

1) MAEC-79/158, 10/18/80 (IE Inspection Report)
2) AECM-79/127, 11/12/79
3) AECM-80/20, 1/15/80
4) AECM-80/241, 9/30/80 Mississippi Power p.,,T,ight Company received a Notice of Viola-tion as Appendix A to your letter dated October 18, 1979 which transmitted IE Inspection Report 79-15. One item of noncompli-ance, nine unresolved items, and one inspector follow-up item were identified in the report.

Mississippi Power & Light has responded to the Notice of Vio-lation in Refere: ces 2, 3, & 4 listed above. Our final response is contained in Attachment A to this letter.

Although we have not previously submitted written responses to " unresolved items" or " inspector follow-up items", Attachment "B" provides responses to those items outlined in the subject inspec-tion report. We elect to provide this information due to its rele-vence to the Attachment A response to the Notice of Violation.

A draft response was discussed with your Mr. Tom Conlon on 30/7 February 5 and 10, 1981. At that time it was agreed to delay this .5 response until February 20, 1981.

//

8103030l87 .

M ember Middle South Utilities System .

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[ MISSISSIPPI POWER & LIGHT COMPANY Mr. J. P. O'Reilly AECM-81/59 NRC Page 2 4

Additional information may be found in our Final Report on our Potentially Reportable Deficiency (PRD)-79/04, letter number AECI-81/80, dated February 20, 1981.

Yours truly, i

p g J. P. McGaughy, Jr.

EWC:mt Attachment ,

cc: Mr. N. L. Stampley

-l Mr. R. B. McGehee Mr. T. B. Conner 1

Mr. Victor Stello, Director Division of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. G. B. Taylor

, South Miss. Electric Power Association P. O. Box 1589 Hattiesburg, MS 39401 re e k *

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Attachment A to AECM-81/59 Page 1 of 2 RESPONSE TO VIOLATION NUMBER 416/79-15-09 AND 417/79-15-09 " FAILURE TO MEET MIL-SPEC REQUIREMENTS" I. Corrective Steps Taken And Results Achieved Mississippi Power & Light acknowledges that at the time of the inspection, July 24 through August 24, 1979, there were inade-quate tests available to confirm the adequacy of pull test values in use. The deficiency, of inadequate pin crimping in certain Power Generation Control Complex (PGCC) interconnecting cables, was originally discovered and reported as a Potentially Reportable Deficiency to your office February 23, 1979 A com-prehensiva inspection to determine extent and correct deficien-cies discovered was underway at the time of the NRC inspection.

As discussed in item 2.d., pages 9 and 10 of the inspection report, the acceptance values of 15 pounds for 16 AWG wire and 8 pounds for 20 AWG wire were utilized for the inspection in progress. Preliminary tests performed by the General Electric Co. had indicated, with a high cor.fidence level, the adequacy of the pull values utilized.

Meetings were conducted on November 16, 1979, with the Regula-tory Staff and on Fe$r~u'ary 14, 1980, with'the Region II staff.

As identified in those meetings, an addendum to the General Electric Co. NEDO 10466A was prepared to remove any ambiguities regarding connector requirements. In a letter dated January 10, 1980 from E. P. Stroupe of GE to 0. D. Parr of the NRC, Errata and Addenda sheets applicable to NEDO 10466A were submitted for NRC approval. If this " Errata and Addenda" is approved, MP&L will review our FSAR requirements to determine if incorporation is necessary.

In July, 1980, CE completed extensive tests to demonstrate the qualification of PGCC caole/ connectors and panel connectors to the full requirements of IEEE 323-1974 and 344-1975. The results of this qualification testing also clearly demonstrated the

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Attachmsnt A to AECM-81/59 .

- Page 2 of 2 adequacy of the eight (8) and fifteen (15) pound pull force / '

-crimp strength values applied at the Grand Gulf jobsite for l pull testing of 20 AWG and 16 AWG wire size crimps respectively. .

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The combination of actions:

(1) the confirmation of eight and 15 pound pull force values by tests conducted by GE per 10CFR50, Appendix B

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.j(2) the demonstration of qualification of PGCC cables / connectors

! to the full requirements of IEEE 323-1974 and IEEE 344-1975 should serve to close out the infraction. The Qualification Test records are available for examination at General Electric at San Jose, with a copy of the test report available at the I CGNS jobsite.

. II. ~ Corrective Steps Taken To Avoid Further Noncompliance Since GE has qualified their pull. test values, no additional 4

actions are required.

j III. Date When Full Compliance Will Be Achieved Full compliance has been achieved.

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Attachment B to AECM-81/59

- Page 1 of 11 ATTACHMENT 'T' UNRESOLVED ITEMS i

INTRODUCTION r j The NRC IE Inspection Report officially notified Mississippi Power &

J Light Company of eight (8) Unresolved Items and (3) one NRC Inspec-

! tor follow-up item as follows: I

1. Unresolved items 416/79-15-01 and 417/79-15-01, Aging effects on electrical properties of low force pin crimps. '
2. Unresolved items 416/79-15-02 and 417/79-15-02, Aging effects i

on conductor insulation.

3. Unresolved items 416/79-15-03 and 417/79-15-03, Aging effects on connector clamp strength.
4. Unresolved items 416/79-15-04 and 417/79-15-04, Shield wires not pull tested.
5. Unresolved items 416/79-15-05 and 417/79-15-05, Environmental effects on hipot test results.
6. Unresolved items 416/79-15-06 and 417/79-15-06, Broken wire strands inside pin barrel.
7. Unresolved items 416/79-15-07 and 417/79-15-07, Evaluation of cable outer jacket damage.
8. Unresolved items 416/79-15-08 and 417/79-15-08, Rework of cable failing continuity check.
9. Infractions 416/79-15-09 and 417/79-15-09, Failure to meet 4

Mil-spec requirements. (Covered in -Attachment A)

10. Inspection follow-up items 416/79-15-10 and 417/79-15-10, Failure to meet ANSI N45.2 requirements.

UNRESOLVED ITEMS 01 THROUGH 08 General Electric completed tests in July 1980, to demonstrate qualifi-cation or PGCC cables / connectors and panel connectors to full require-

! ments of IEEE 323-1974 and 344-1975.

The purpose of the qualification tests was to obtain data that pro-l vides reasonable assurance that the installed PGCC cable assemblies l will perform their safety related functions. The testing included PCCC cable assembly test samples which were fabricated to simulate observed and postulated pin crimping anomalies as well as normal manufactured product. The environmental parameters for testing (temperature, humidity and seismic) enveloped the environmental i

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Attachm:nt B to AECM-81/59 Page 2 of 11 parameters specified for the BWR 4, 5, and 6 control room normal and abnormal environmental limits. The tests were conducted in the following sequence:

Assembly and Inspection Baseline Functional Testit.g-Accelerated Thermal Aging Post-Aging Functional Testing Seismic Vibration Aging and DBE ' Exposure Post-Seismic Functional Testing Environmental Functional Testing Destructive Testing Test Data Reduction and Analysis The Qualification Test records are available for examinatior. st General Electric.

The test results, as applicable to the Unresolved Items of the NRC IE Inspection Report, are included below.

1. UNRESOLVED ITEM 01, EFFECT OF AGING ON LOW MECHANICAL FORCE CRLaPS A low force crimp is defined by General Electric to be less than 15 pounds pull strength for 16 AWG wire and lest than 8 pounds for 20 AWG wire.

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To create low force crimps for testing, General Electric measured the relationship of crimp depth to crimp strength - a shallow or light crimp would yield a low strength crimp, a deep or heavy crimp would yield a high strength crimp. In the preparation of test samples, proper operation of calibrated crimping tooling yielded crimps normally above the 20 pound range for 20 AWG wire and above the 40 pound range for 16 AWG wire. By upsetting the

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crimping process and tooling, it was possible to create crimps down to the 1-2 pound range, but not reproducibly with high yield.

In the Qualification Test Program, two of the objectives were:  ;

a. Dete ___._ _..._ .....w or accelerated thermal aging on low l

! force crimps.

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Attachment B to AECM-81/59 '

Page 3 of 11 l b. Confirm the adequacy of 8 and 15 pound pull force values.

For these two objectives, twenty-four (24) connector assembly i test samples were produced - 16 with 16 AWG wire crimped to 16 AWG contact pins (300 pins total) and 8 with 20 AWG wire crimped to 16 AWG contact pins (300 pins total). The 24 test samples, designated N,-3, 12, 13, Nb -1 through 6, Nd+ c 1 through 6, -

N -1, N +N -1 & 2, N -1 & 2, N -1&2 and N -1&2 were subjected e f c n. o p to accelerated thermal aging and then tested (each pin) for i

insulation resistance and hipot. Eleven (11) of the samples were then sequenced through seismic and environmental conditions of test, again with insulation resistance and hipot measurement I i

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! on each pin after each set of qualification test conditions.

Finally, the 24 test samples were destructively tested. The de-structive crimp pull testing showed that 7% of the crimps were low force (600 pins total - 500 pull tested - 35 low force -

35/500 = 7%).

Test results show that, specifically, the low force crimped i

pins were not affected by any of the conditions of accelerated thermal aging, seismic and environmental testing. Analysis of 4 destructive crimp pull testing data also confirms the adequacy of the 8 and 15 pound.xalues for field testing.

4 2. UNRESOLVED ITEM 02, THE EFFECT OF AGING ON THE INSULATION PRO-PERTIES OF NICKED AND/OR CUT INSUIATION PGCC cable assembly test samples were altered to contain damaged insulation and cut wire strands within the crimped pin barrel.

The insulation of 182 conductors was damaged by cutcing through 50% of the insulation thickness of 50% (91 conductors) of the samples and 25% of the insulation thickness on the remaining 50%. The conductors were positioned so that the cuts faced ,

each other. . These test samples, designated Nd + N , were as-sembled in this manner for testing to determine the effect of

aging on nicked, gouged or cut insulation.

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I ' Attachment B to AECM-81/59 F

Page 4 of 11 i Insulation Conductors ,

Sample Connector Mfr. Contacts Material No. AWG (

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d c -1&2 Cannon Cannon Raychem 37 16

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i N+ -566 Amphenol Amphenol Tefzel 44 20 [

d c N +N -768 Amphenol Amphenol Vulkene 8 16 d c  ;

$ Additional test samples were configured with damaged i sulation ,

only. These test samples, designated N -1 and 2, were altered x ,

i to contain damaged insulation similar to that described for [

samples N +N ' i d c Insulation Conductors Sample Connector Mfr. Contacts Material No. AWG N -1 Amphenol Amphenol Tefzel 8 16 x

Ng -2 Amphenol Amphenol Vulkene 8 16 f Each test sample was hipot tested to 2200 Vac prior to quali-i fication testing. Each sample was hipot tested at 1760 Vac before and after each test sequence following thermal aging.

1 All test samples were subjected to accelerated thermal aging, 1.

j seismic and abnormal environmental conditions. No failures

l. occurred. Test sample Nd+N c 2,4,6 and 7 were subjected to thermal aging, seismic, and abnormal environmental conditions. No '

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failures occurred. ~

Test sample N -1 was subjected to a hipot test of 2200 Vac and thermally aged without failure of the insulation and no visual

] evidence of damage propagation. Test sample N -2 was subjected to the same tests as N -1 and additionally to seismic and ab-normal environmental conditions, without failure of the conductor

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insulation and no visual evidence of damage propagation. .

I i Two test samples, N -1 and 2, of PGCC cable assemblies were p .

l altered with insulation damage to expose bare wire and assembled i with the defects face to face. One pin of 10 per sample failed 1

hipot testing. This result could be expected with uninsulated conductors in close proximity.

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Attachmsnt B to AECM-81/59 Page 5 of 11 >

The revised General Electric PCCC inspection procedure accepts cable 2

insulation that is nicked, gouged or cut unless bare wire is exposed.

The PGCC cable qualification test results demonstrate, with reasonable assurance, that there is no effect of aging on nicked and/or cut in-sulation.

3. _UNPESOLVED ITEM 03, AGING EFFECTS ON CONNECTOR CLAMP STRENGTH The test data for low mechanical strength crimps indicate that a crimp atrength as low as approximately 2 pounds with the connector clamp tightened

? onto the cable will maintain electrical integrity over th'e qualified life of the cable. No crimp separation caused by either cable clamp loosening or crimp failure was observed. Normally, Power General Control Complex

cabies are secured to support structures (wire grills or brackets) in the' panels and cabinets which provide further cable support and reduced strain on the cable that is in contact with the clamp. Therefore, the
clamp does not normally support the entire cable weight. Seismic testing on aged cables, showed that the cable clamps performed their intended function, f 4. UNRESOLVED ITEM 04, SHIELD WIRES NOT PULL TESTED

! Shielding on cables is not critical except for sensitive neutron monitoring

instruments where separate routing and conduits are required. In general, shielding is preventive rather than demonstrative 1y required.

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Over the years, General Electric has found that plants have very different noise characteristics depending on the location and layout of equipment, f wiring and ground systems. Since there are " noisy" plants and " quiet"

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e plants (and all gradationA in between) Gene'ral Electric has taken the 1

action to call for shielding and for the use of twisted pairs whenever low-level signals are involved. Should a shield not be connected, the twisting of the twisted pair will suffice in most cases. The twisting of the twisted, shielded pairs provide the majority of the protection from in-ductive pickup of noise, with the shields providing excess margin. Since I many PGCC cables are multiple, twisted shield pairs which are then twisted into a cable, loss of a shield connection on one or more f 3 he pairs would not cause function failures. In addition to the natural impedance, j the shielding effect of the adjacent pairs with their shields. grounded would aid in excluding noise. In the " noisy" plant, a disconnected shield f

! may result in unsatisfactory system performance. The condition will be i

readily apparent during pre-op and startup testing and can be easily l found and corrected, I

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Attachm:nt B to AECM-81/59 Page 6 of 11 ,

There are two systems supplied by General Ilectric which must have shield integrity - the Neutron Monitoring System (NMS) and the Process Radiation Monitoring System (the Main Steamline Radiation Monitor). For both systems the connectors involved are not the multipin (MIL-C-5015 type) connectors which were of concern in the NRC Inspection (Infraction and Unresolved Items). For the Neutron Monitoring System a three-pin, connector is used and the shield carries the signal return so that an open shield results in a downscale reading and alarm. For the Process Radiation Monitoring System, the connector is coaxial type with completely different assembly methods from the crimp poke-home type.

The great majority of the shielding used by General Electric in PGCC (and non-PCCC) is preventive and called for as sound engineering practice rather than as a requirement for safety.

The pull testing of shield wires is not necessary to assure safe operation.

Since multi-conductor connectors have numerous shields, the loss of an individual shield is not apt to be detrimental to the performance of the circuitry. The cable which was of concern contained three shields that were off in a 48 pin con-

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nector. The three shfeld wires which'd'e're off will not affect the function of the circuitry.

5. UNRESOLVED ITEM 05, ENVIRONMENTAL EFFECTS OF HIPOT TESTING Hipot tests for all assemblies at the factory and at site are performed in ambient temperature and humidity. These tests i are a quality search for workmanship problems (which could l

I cause electrical faults) which are not readily identifiable by inspection or other means. Stray strands, wires scraped over sharp edges within assemblies, etc. can be (and are) un-covered by impressing a high voltage on otherwise floating-from-ground conductors. The voltage chosen is sufficiently higher i than the operating voltages to assure proper function of the

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Attachmtnt B'to AECM-81/59

- Page 7 of.11 .

circuits, but low and brief enough so no damage is caused.

These tests are not tests of the materials or components but are for.Q.C. purposes only. The individual materials and com-ponents have all previously been tested and qualified for their application.

To date, there is no evidence that any hipot failure hAs been caused'by high or low humidity. In the operational condition, no. failures are expected from high or low humidity since the operating and accident environments are well within the limits of the wire, cable and connectors.

The concern for the effect of dense smoke environment on hipot test results can be satisfied for the following reasons:

1. The ability of the crimps to meet or not meet a destructive pull test will not be affected by smoke in the atmosphere.

Nor will there be any effect on hipot testing for nicks /

cuts in insulation. Smoke is not a significant conductor and the location of the nicks / cuts of concern are within the connector housing, away from the air currents that would transport the smoke.

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2. The function of the crimp, to provide electrical continuity, will not be adversely affected by smoke in the atmosphere.

The conductivity is determined by the contact area.

3. Any connector, with or without crimp problems or nicked / cut insulation, may have leakage paths generated by smoke depost-tion but the PGCC connectors will be least affected due to the protection afforded by the insert and connector shell.
4. Neither IEEE 323-1974 nor NUREG 0588 require consideration of smoke as an environmental agent. This is undoubtedly due to the major effort in the past few years on fire protection and separation. If there was such a requirement, other devices would be far more susceptible than covered connectors. The PCCC is in compliance with NRC fire prevention .

! and protection requirements.

4 Attachment B to AECM-81/59 Page 8 of 11

6. UNRESOLVED ITEM 06, WIll STRANDS BROKEN IN CONNECTOR BARREL ON ONE CONDUCTOR OF CABLE 5551/SZ51-006 Except for the thermocouple extension cables, all functional conductors are stranded with 7 or 19 strands. This is for flexibility and to assure that if some damage causes broken strands, other strands can continue to function. None of the 16 AWG or 20 AWG conductors carry anywhere near rated' current as evidenced by the lack of significant temperature rise in the cables. Loss of several strands at any point along the conductor causes an insignificant increase in resi tance (loss is proportional to resistance). Also, since the thermal con-ductivity of the copper on both sides of the broken strands is good, increased resistance from higher temperature is minimal (resistance, hence loss, is proportional to temperature).

Cable inspection experience for this defect indicates that wire strands are normally not cut through, as noted on the referenced cable. What sometimes happened was that the wire stripper nicks one or more outer wire strands during cable fabrication.

When the electrician examined the wire for this characteristic he would bend the pin back and forth. Nicked strands often break when this is done. There is no flexing at this point when the hemostat issused for the pull-test.

A spot check of 50 16-AWG and 50 20-AWG GGI cable data sheets (2752 conductors total) indicated six " nicked wires." There was no indication of any broken or missing strands.

In the General Electric PGCC Cable / Connector Qualification Test program, test samples N +

I d c were altered to simulate broken wire strands within a crimp connection. The test samples' vere altered by cutting away 10% of the conductor strands of 50% of the samples and 25% of the conductor strands in the remaining 50%. The cut strands were removed so that the crimp contained l approximately 90% of the normal volume of conductor strands of one sample and approximately 75% of the volume of the other sample. This condition automatically creates low mechanical

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Attachment B to AECM-81/59 Page 9 of 11 i

strength crimps because a normal manufactured crimp was applied assuming a normal volume of conductor strands. All 182 conduc-tors, 91 with 10% cut-strands and 91 with 25% cut strands, were ,

- subjected to accelerated thermal aging, seismic and the abnormal .

environmental conditions, without alteration of the electrical properties and integrity of the low mechanical strength crimps.

M In summary, broken strands, even as many as 25%, cause no func-tional impairment in any control or insttumentation wire. At the worst, broken strands are a worksmanship fault.

7. UNRESOLVED ITEM 07, EVALUATION OF CABLE OUTER JACKET DAMAGE ON 4 CABLE 8347/SP-64/006 The purpose of the jacket is to provide protection to the pri-mary conductors and their insulation during the life and use of the cable and scrapes, cuts and tears in the jacket demon-I strate the jacket is functioning as designed. The decision to repair or not repair the damage or replace the cable can be made based on the seriousness of the damage, the environment and location of the damaged area on the installed cable, and the continued need for this additional protection for the primary conductor.

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With regard to cable 8347/SP64-006,

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the, actual damage was a one-fourth inch circumferential jacket cut 2.5 feet from the .

cable end. This is within the scope of the cable reinspection plan. The cable was repaired with Insultape as required.

The five foot limitation in the cable inspection plan for a damaged outer jacket was established because that is a length I

that would normally be accessible during this inspection. Cables

, are 100% inspected full length for this characteristic after factory PGCC system test, immediately prior to shipment to the

site. The check at the site of accessible portions of cables 4 was added to obtain an indication of installation damage. The I amount of such observed damage has been minimal.

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Attachment E to AECM-81/59 Page 10 of 11

8. UNRESOLVED ITEM 08, REWORK OF CABLE FAILING CONTINUITY CHECK Wire pairs 4 and 5 of cable 8248-SV41-001 were reported to have failed a continuity check and the cable was returned for rework. The pairs had been cut and taped back, and the pre-vious inspection sheets were not in the data folder. The cable was reported to have been QC inspected and accepted prior to its failure of the continuity check. This could not be con-firmed as the original inspection sheet was not found.

The cutting and taping of the conductors was an error by an electrician. Cutting and taping would have been an acceptable disposition to a nonconformance where unused conductors exist within a cable. In this case, there were no unused conductors.

The continuity check detected the error, as it should have, and a repair was indicated.

The first set of data sheets for this cable was misplaced or, for some reason, never turned in. Thus, it was necessary to initiate a new set of paper to cover rework and reinspection of the cable.

DiSPECTOR FOLLOWUP ITEM: FAILURE TO MEET ANSI N45.2 REOUIREMENTS Two deficiencies to ANSI 45.2 were not documented as of July 26, 1979: ... .

1. Flat head pins (identified on July 9, 1979)
2. Missing " spring" or " clip" on Amphenol connectors (identified July 18, 1979)

Flat head pins were identified cn a cable in July 1979. General Electric initiated FDDR JB1-768 on July 26, 1979 to establish cri-teria for flat head pins and institute 100% inspection and repair for the condition. Inspection of 21,340 pins resulted in finding 35 flat head pins. The low frequency of occurrence was judged to be sufficient positive evidence to halt further inspection for a condition which was not significant to the function of the component in the circuitry.

i Attachmene B to AECM-81/59 Page 11 of 11 Concerning missing "J" springs in Amphenol connectors, General

Electric initiated FDDR JB1-768 on July 26, 1979, calling for 1007.

inspection and repair for the condition.

In response to the MP&L Corrective Action Report (CAR) No. 231, which identified and tracked this concern, appropriate cha;nges were made to the GE I&SE QA Manual to assure deficiencies are pro-perly identified and corrected.

SUMMARY

General Electric has successfully completed qualification testing of PGCC cables / connectors and panel connectors, similar to the installed PGCC equipment at GGNS, to the full requirements of IEEE 323-1974 and 344-1975. In its testing, General Electric simulated the workmanship. anomalies of concern in the NRC IE Inspection Report Nos. 50-416/79-15 and 50-417/79-15. It has been demonstrated that
j. test samples which included such anomalies do withstand conditions of 'ccelerated a aging, seismic and environmental testing without degradation of functional integrity.

l General Electric has implemented prudent and timely inspection and repair actions on delivered PGCC equipment at GGNS to assure the functional integrity and high quality of that product.

And, General Electric has taken appropriate action to clarify the intent of NED0-10466A regarding PGCC connectors by submitting Addenda

  1. 1 to the NRC.

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