ML18004B646
| ML18004B646 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/19/1986 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NLS-86-473, NUDOCS 8612290303 | |
| Download: ML18004B646 (5) | |
Text
~L Carolina Power 8 Light Company P. O. Box 1551
~ Raielgh, N. C. 27602 (9tg) 6364464 E. E. UTLEY Senior Execvtive Vice President Power Svppiy end Engineering 5 Construction QEC 1 9 1986 SERIAL: NLS-86-073 Dr. 3. Nelson Grace, Regional Administrator United States Nuclear Regulator y Commission 101 Marietta Street, NW Atlanta, GA 30303 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICENSE NO. NPF-53 RESPONSE TO NOTICE OF VIOLATION
Dear Dr. Grace:
In reference to your letter of October 10, 1986 and Notice of Violation dated November 21,1986 referring to RII: 50-000/86-66-01, the attached is Carolina Power 2 Light Company's reply to the violation as identified.
It is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, RAW/mf (50953DK)
Attachment cc:
Mr. B. C. Buckley (NRC)
Mr. G. F. Maxwell (NRC-SHNPP) l E. E. Utley 8SXaZVoaoS Beia>9 PDR ADOCK 05000400 8
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OEC 1 9 1986 ATTACHMENTTO CPBcL LETTER OF RESPONSE TO NRC REPORT RII: 50-000/86-66-01 Re rted Violation:
10 CFR 50, Appendix B, Criter ion XVI, Corrective Actions, as implemented by the Shearon Harris Nuclear Power Plant Final Safety Analysis Report (FSAR), Section 17.1 requires that measures shall be established to assure that conditions adverse to quality, such as deficiencies and deviations are promptly identified and corrected.
Contrary to the above, as of 3uly 25, 1986, the licensee failed to establish measures to identify and correct conditions adverse to quality in that the licensee's inspection program failed to identify that electrical installation did not meet the criteria for physical separation of electrical cables for safety-related circuits. In addition, the licensee's corrective actions for electrical separation deficiencies identified during an NRC inspection conducted in 1980 were not effective in preventing recurrence of the defficiencies.
This is a Severity Level IIIviolation (Supplement II).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
Root cause analysis revealed that the primary cause of the separation deficiencies was the failure of the line organization to discharge its quality obligation in an effective manner.
This resulted in a high incidence of electrical separation interactions being constructed into the plant. A contributing factor was the added burden placed on the electrical installation process due to insufficient detailing for field run raceway.
The weakness described above placed considerable burden on the inspection process to detect separation deficiencies.
Root cause analysis also revealed secondary weaknesses of ineffective trending for separation deficiencies and non-optimal inspection performance.
Corrective Ste s Taken and Results Achieved:
Areas that contain safety related raceway, cable, and equipment have been walked down by engineering with the assistance of QA to identify remaining separation interactions.
During these walkdowns, additional separation interactions were identified. As required, these items were reworked and reinspected.
Corrective Ste s Taken to Avoid Further Noncom liance:
To reduce the complexity of installation, new electrical design in safety related areas is being pre-engineered.
Project drawing CAR-2166-B-060 has been revised to reflect the separation criteria previously identified in HPES Guideline 7.5.Q.
Craft supervision has received additional training to the new separation criteria.
Increased emphasis and accountability has been placed on craft supervision for installations involving electrical separation.
Also, other discipline work procedures have been changed to reflect their understanding of separation requirements.
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OEC19 $86 Construction inspection personnel have received additional training to the new separation
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criteria. Inspection procedures have been reviewed and revised as necessary to enhance the identification and documentation of separation violations. Installations rejected by construction inspection for electrical separation deficiencies are being trended separately to provide visibilityto management.
Although adequate corrective action has been taken, it is understood that work which may affect electrical separation willcontinue.
QA surveillance of work and inspection is an on-going program, and additional separation interactions may be identified. Any future separation problems willbe handled in accordance with existing project procedures.
Date When Full Com liance was Achieved:
Full compliance was achieved on December 17, 1986 in that the corrective action was completed.
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