IR 05000400/1986039
| ML18019B030 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/05/1986 |
| From: | Conlon T, Merriweather N, Prevatte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18019B029 | List: |
| References | |
| 50-400-86-39, NUDOCS 8606190598 | |
| Download: ML18019B030 (16) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report No.:
50-400/86-39 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
May 5-9, 1986 I
Inspector:
N.
erriweather R. Prevatte Approved T.
E.
Con on, C ie Engineering Program Branch Division of Reactor Safety SUMMARY License No.:
CPPR-158 Date Signed g -s-- gd.
Date Signed Date Signed Scope:
This routine, unannounced inspection involved areas of instrumentation components and system record review and followup on previously identified enforcement items.
Results:
No violations or deviations were identified.
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REPORT DETAILS Persons Contacted Licensee Employees
- R. A. Watson, Vice President, Harris Project
- G. A. Meyer, General Manager, Completion
- N. J. Chiangi, Manager QA/QC
- G., L. Forehand, Director QA/QC Construction
- E. J. Wagner, Engineering General Manager
- S. R. Zimmerman, Manager - Nuclear Licensing
- R. A. Somers, Superintendent Construction Inspe
- O.K. Powell, Unit Supervisor Construction Inspe
- A. H. Rager, Electrical Manager
- K. V. Hate, Principal QA Engineer
- L. I. Loflin, Engineering Manager
- M. F. Thompson, Jr.,
Engineering Manager
- H. L. Williams, Project Civil Engineer
- E. Kwalick, Electrical Engineer
- E. E. Willett, Project Mechanical Engineer
- P. Brady, Senior Engineer
- H. F. Wagner, Specialist QA/QC
- M. Wallace, Specialist - Regulatory Compliance
- D. Tibbitts - Specialist Regulatory Compliance Other Organizations
- J. P. Kirk, Daniels Construction Company (DCC)
D. Walker, QA Surveillance, DCC
- G. Attarian, Electrical Engineer, EBASCO
- M. Petrizzo, Electrical Engineer, EBASCO
- J.
Somma, Electrical Engineer, EBASCO NRC Resident Inspectors G. Maxwell, Senior Resident Inspector
- G. Humphrey, Resident Inspector
- Attended exit interview ction ction Exit Inter view The inspection scope and findings were summarized on May 9, 1986, with those persons indicated in paragraph I above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio J
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3.
Licensee Action on Previous Enforcement Matters a ~
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(Closed)
Violation 50-400/85-08-01,
"Inadequate Design Control for Raceway Separation."
The inspector reviewed the licensee's response to NRC, dated May 3, 1985, and determined it to be acceptable.
The inspector held discussions with licensee representatives and examined the corrective actions as stated in the letter of response.
The violation occurred because the licensee's design organization approved Field Change Request (FCR)
E-1304, which was in direct violation of Electrical and Electronic Engineers (IEEE) Standard 384-1974 for cable separation between open raceway and conduit and design drawings and notes did not require separation of cable leaving a tray and going to a conduit.
A review of the applicable records indicates that FCR-E-4563 was issued on April 25, 1985, by Harris Plant Engineering Section (HPES) to specify separation requirements for exposed cable and raceway and exposed cable and electrical equipment.
An analysis has been performed by EBASCO which demonstrates the acceptability of a 1 inch separation between non-nuclear safety (NNS)
conduit and open safety-related tray considering the damage potential is contained within the conduit.
Testing was also performed by Wyle Laboratories under test report number 47879-02 (Revision A) to resolve existing separation issues and to allow reduced separation requirements for other configu-rations.
This analysis and testing is allowed by IEEE 384-1974 for establishing reduced cable separation requirements.
The FSAR was revised to incorporate a table of reduced separation requirements based on the analysis and Wyle tests report.
The reduced separation require-ments were evaluated and accepted by NRR in Safety Evaluation Report, Supplement No.
(NUREG 1038).
NCR No.
85-1665 was issued to document and track cable installations that did not meet the requirements of FCR-E-4563.
A total of 1482 exposed cable items were identified and are being evaluated and dispositioned by engineering using Procedure No. 7.5.g,
"Engineering Evaluation of Electrical Separation Inspection Reports."
The corrective action wi 11 be accept as is, rework or install barriers.
To prevent recurrence of the above violation, the licensee issued a
memo to HPES personnel to remind them that required analysis must be completed prior to final approval of a FCR.
Based on the above, it appears that the licensee is now in full compliance.
(Closed)
Unresolved Item 50-400/85-08-02,
"Evaluation of Reduced Separation Between Non-Class IE Conduit and Open Class lE Raceway."
This item was the result of an inspector concern regarding the acceptability of an analysis performed by EBASCO for allowing a one inch separation between an enclosed Non-Class lE raceway (i.e., conduit)
and an open top Class 1E cabletray.
The analysis was. provided to NRR in a letter, dated June 19, 1985, and subsequently testing was performed by Wyle Laboratories (test report number 4789-02, Revision A) to resolve
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existing separation issues and to approve configurations for future design.
The FSAR was revised incorporating the reduced separation criteria in Table 8.3.1.10 in which it states that where separation could not be maintained, th'e lesser separation distances were established by test, analysis, or installation of suitable barriers in accordance with IEEE 384-1974.
NRR reviewed the test report and analysis and issued a safety evaluation report (NUREG-1038 Supplement No. 3) which concluded that the test program and test results were acceptable.
Based on the above this item is considered closed.
(Closed)
Violation 50-400/85-04-01,
"Inadequate Inspection for Electrical Separation."
The inspector reviewed the licensee response to Region II, dated April 10, 1985, and found it to be acceptable.
The inspector verified that the corrective action stated in the response are correct.
A review of the applicable records show that the electrical separation deficiency had been documented and evaluated by engineering.
As a result of this evaluation, the licensee has identified the need to install an electrical tray cover to eliminate the separation problem.
CPL-2166-S-4012 (Rev. 3)
and CPL-2166-S-4012 SOl, Rev. (I) drawings issued on May 7, 1986 detail the requirement for this tray cover installation.
The licensee will install this and other required trays after completion of cable pulling activities and prior to area turnover from contstruction to operations.
This item is closed.
(Closed)
Unresolved Item 50-400/84-49-02,
"Cable Tray Overfill."
This item was the result of an inspector concern of the capability of the licensee's program to identify, track and resolve problems associated with potential cable tray overfill.
At the time of the above concern cable pulling was less than 50 percent complete.
At present, cable pulling is approximately 95 percent complete.
A review of the licensee's program in this area shows that steps have been incorporated into work and inspection procedures to insure that these deficiencies are identified by inspection personnel.
In addition, the licensee has performed a walkdown of tray installations that had been previously inspected to insure that existing deficiencies have been identified.
Cable capacity tests have been performed by Hyle Labora-tories u'nder test Report Number 47879-4 to justify cable derating in cases where cable tray, covers or fire wrapping must be used to meet the applicable separation requirements.
To verify the licensees implementation of this program, the inspector, accompanied by Harris Plant Engineering Staff personnel, toured the plant and identified five cases of potential cable tray overfill.
The licensee was able to satisfactorily demonstrate that these items had been previously identified or that programmatic control existed to insure that these and other possible existing deficiencies would be identified and corrected.
Although cable pulling and rework of all identified problems has not been completed; the licensees program, with effective management and supervisory attention, should successfully address and resolve this item.
This item is close s
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(Closed)
Unresolved Item 50-400/85-39-02, Review the Causes of NCR-85-1665 for Reportability.
The item was identified when an NRC inspector was reviewing NCR 85-1665, (dated July 9, 1985)
for separation difficulties.
The licensee had chosen to develop a list of all cables (approximately 1482 identified) that did not meet the separation criteria and document them on NCR 85-1665.
The inspector questioned whether the licensee had reviewed the NCR for reportabi lity under
CFR 50.55 (e).
The inspector discussed the above unresolved item to determine if this NCR had been evaluated for NRC reportability.
The licensee provided a background for why the NCR was generated and a
copy of the reportability evaluation traveler, dated July 30, 1985.
It appear s that during a
NRC Construction Appraisal inspection in September 1984, concerns were identified in the electrical area dealing with lack of design requirements for minimum separation or barrier requirements for exposed cables.
Inspection criteria for exposed cables were issued by design in FCR-E-4563 R/0 dated April 25, 1985, as part of the corrective action for NRC Violation 85-08-01.
Inspection procedures were revised to incorporate these requirements and were issued Nay 1985.
A reinspection program was then undertaken to reinspect safety-related equipment and raceways accepted prior to Nay 1985.
All installations that had not been inspected were inspected to the revised procedures issued in May 1985.
Those installations inspected for the first time that did not meet the acceptance requirements for exposed cables were documented on NCR-85-1665 to facilitate turnover of the system for testing.
This item was therefore, deemed not reportable by the licensee because the final checkpoint for inspection of these problems had not been passed considering the new inspection program.
The inspector agreed with the licensee's evaluation.
4.
Unresolved Items Unresolved Items were not identified during the inspection.
5.
Instrument Components and Systems Record Review (52055)
The objectives of this inspection were to determine if the licensee's system for preparing, reviewing, and maintaining records are functioning properly, whether records reflect work accomplishment in accordance with procedures, SAR commitments and NRC requirements, and to determine whether there are any potentially generic problems, management control inadequacies, or other weaknesses of safety significance.
The inspector reviewed the licensee's log book for tracking nonconformance reports (NCRs)
and randomly selected
NCRs in the instrumentation area for examination.
The NCR log was reviewed specifically from calendar years 1984 through 1986.
The NCRs selected are identified as follows:
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NCR-Nos.
- 84-0093
- 85-0409
- 85-0685
- 86-0225 85-1792
- 85-0638
- 85-0684
- 86-0078
- 85-0473
- 86-0191
- 86-0309
- 86-0043
- 86-0065
- Indicates NCR Reportability Evaluation Traveler was reviewed.
The NCRs identified above were reviewed to determine whether:
Records are legible, complete and promptly reviewed by qualified personnel.
Reporting requirements of 10 CFR Part 21 and Part 50 were recognized during evaluation and appropriate action was taken where necessary.
Records have been routinely processed, timely evaluated, and controlled through established channels for resolution of the root cause as well as the immediate problem.
Records are properly identified, stored, indicate current status, and can be retrieved in a reasonable time.
Nonconformance reports include the status of corrective action or resolution, and adequate justification if provided for use-as-is di spos ition.
The results of the record reviews indicate that NCRs were being documented, tracked, evaluated, dispositioned and closed out in accordance with procedures and NRC requirements and the corrective action prescribed appeared to be adequate to resolve the nonconformances and to prevent recurrence.
The inspector questioned the 'licensee about the status of completion of instrumentation installations.
The licensee indicated that there were approximately 32 instrument installations that are remaining to be worked and out of this total there are approximately 14 safety-related instruments requiring rework or new installations.
Based on the above, the inspector considered it to be inappropriate at this time to review corporate audit schedules for instrumentation audits since almost all the work has been completed.
The inspector did review a copy of the last corporate audit of instrumentation installations which was performed during the period October 7-11, 1985.
The audit identified two concerns.
One concern involved improper storage of two safety-related valves and various fittings.
This item was corrected and closed during the audit.
The second concern involved work packages that were not properly reviewed and approved and referenced to a
superseded calculation sheet.
This item was reviewed and closed out in Audit No. PAA/0081-85-0 T,
In addition to the annual QA audit above, the licensee has a
QA surveillance unit that periodically monitors construction, quality control and engineering.
The activities being reviewed are described in Procedure No.
CQA-28,
"QA Surveillance."
The inspector reviewed the procedure and verified that it requires surveillances of instrument installations and housekeeping and storage.
This procedure requires that a surveillance plan be developed.
The inspector reviewed the surveillance plan for the two areas identified and selected QA surveillance reports of instrument installations and housekeeping and storage which were conducted during calendar years 1985 and 1986.
Discussions with the licensee revealed that the instrumentation program was shut down in the fall of 1984 and w'as restarted in early 1985.
Therefore, all the work was conducted during the 1985 and 1986 time frames which was considered in making the record selections.
Seventeen QA surveillance reports of housekeeping and storage reviews were selected from the schedule planner for review.
The surveillance reports were reviewed to confirm that routine surveillances were performed during 1985 and 1986, that required storage conditions of warehouse storage areas, power block and other areas were being maintained, and that nonconforming conditions were identified and corrected.
All records reviewed were found to be acceptable.
The inspector also selected five QA surveillance reports of instrument installations from the QA surveillance planner.
The planner showed that surveillances were scheduled on a weekly basis for 1985 and 1986.
The surveillance reports were reviewed to confirm that routine surveillances were conducted during 1985 and 1986, that the scope of the surveillance was achieved, and that all concerns and nonconformances were documented and corrected in accordance with licensee procedures.
All records in this area were found to be acceptable.
A list of the surveillance reports reviewed are as follows:
Kousekee in Surveillance Re orts Period of Surveillance 85-031 85-0252 85-460 85-500 85-698 85-1010 85-1089 85-1325 85-1526 85-2267 85-2388 85-0159 86-0286 86-0043 86-0517 86-0571 86-0630 1/7-11/85 2/11-15/85 3/18-22/85 4/1-5/85 4/29-5/3/85 6/5-17/85 6/8-7/3/85 7/17-7/31/85 7/13-8/14/85 11/20-12/4/85 12/4-18/85 1/8-22/86 1/22-2/5/86 2/19-3/5/86 3/5-20/86 3/20-4/3/86 4/3-16/86
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Instrument Surveillance Re orts 86-0382 86-0163 85-1727 85-941 85-1656 Period of Surveillance 2/20-22/86 1/20-24/86 9/10-13/85 5/19-24/85 8/26-30/85 llithin the areas examined, no violations or deviations were identifie I