ML18017B347

Responds to NRC 810212 Ltr Re Violations Noted in IE Insp Repts 50-400/81-02,50-401/81-02,50-402/81-02 & 50-403/81-02. Corrective Actions:All Seismically Installed Boxes Installed W/O Instruction Details Removed

ML18017B347
Person / Time
Site:	Harris
Issue date:	03/05/1981
From:	Howe P CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18017B346	List: IR 05000400/1981002 ML18017B347 ML18017B348
References
NUDOCS 8103260501
Download: ML18017B347 (6)

Text

C;,rolina Pc.ver 8 Light Company March 5, 1981 Mr. James P. O'Reilly United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303

Dear Mr. O'Reilly:

I In reference to your letter of February 12, 1981, referring to RII: GFM 50-400/401/402/403/81-2; the attached is Carolina Power 6 Light Company's reply to the deficiency identified in Appendix A. It is considered that the corrective and preventive actions taken will be satisfactory for resolu-tion of this item.

To the best of my knowledge, information, and belief, the corrective action in this report is true and complete.

Thank you for your consideration in this matter.

Yours very truly, P. W. Howe Vice President Technical Services NJC/gea (882/308)

Attachment cc: Mr. J. A. Jones Sworn to and Subscribed before me this 5th day of March, 1981.,~t<<tttcrr>

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Severity Level V Violation Condition Reported:

' As a result of the inspection conducted on December 29, 1980 through January 30, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violation was identified.

I 10 CFR 50, Appendix B,- Criterion V as implemented by PSAR Section 1.8.5.5 and CPKL's Corporate QA Program Part I, Section 8.2.1 requires that construction activities affecting quality be prescribed in drawings, specifications, procedures and instructions.

Contrary to the above, Class 1E electrical conduit box numbered B1482-SB was installed without the use of an appropriate installa-tion drawing, specification, procedure or instruction. On January 6, 1981 conduit box B1482-SB was found to be installed in a con-figuration which was not prescribed by a documented installation drawing, specification, procedure or instruction.

Denial or Admission and Reaso'ns of Violation:

The violation i'dentified by NRC audit was correct as stated. The reason for installing this box is not clear. The electrical craft personnel had no installation details nor were they given any instruction to install this box.

Corrective Ste s Taken and Results Achieved:

Instructions were given to the elctrical crafts to remove all boxes that wer e not installed in accordance with an approved installation detail. All seismically installed boxes (including box B1482-SB) for which installation details did not exist were completely removed by February 27, 1981.

Corrective Ste s Taken to Avoid Further Noncom liance:

1. The electrical crafts have been instructed not to install seismic boxes without an approved installation detail suitable for the applicable mounting configuration.

2. A Field Change Request (FCR-E-143) was written to address the mounting details for boxes mounted on columns. This mounting detail will satisfy the requirements for the box in question (B1482-SB). This FCR was evaluated and detailed by the Architect Engineer. Design details were received on February 27, 1981, and issued to the field. All required implementing procedures are in effect.

3. CP&L Work Procedure WP-205, titled "Documentation and Control of the Installation of Conduit and Cable Tray", has been revised: to include boxes and has been issued for use.

4. CP8L Work Procedures WP-203, titled "Installation of Seismic Class I Electrical Cable Tray, Tray Suppor ts, Conduit and Conduit Supports",

has been revised to include boxes and box supports. This procedure has also been issued for use.

5. By including boxes in WP-205, an installation card for each box must be signed by a Construction Inspector as documented evidence of a satisfactory installation.

.Severity Level V Violation

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6. The Principal Electrical Engineer and Electrical Superintendent have met "

with Field Super intendents and General Foremen. During these meetings, the following points were discussed:

Safety Related Equipment must be installed by approved drawings, specifications, procedures, and instructions.

b. If you do not have drawings, specifications, procedures or instruc-tions required to install equipment, you stop and notify the elec-trical craft supervision and Discipline Engineer.

C. Craft supervision must be awar e of what equipment or '.components are safety related.

d. When other crafts are required to support electrical crafts by wielding or drilling and/or installing anchors for safety related equipment, the electrical craft will ensure that support crafts are made aware of drawings and/or procedures applicable to their work operation. The, electrical craft supervision will make efforts to ensure that support cr fts are knowledgeable of requirements.

With the above procedural changes and the requirement for Construction Inspector's sign-off on each box installation, it should not be possible for an incorrect box installation to go undetected. It should be noted that boxes are part of the raceway system and are routinely inspected as -.

such.

Date When Full Com liance Will Be Achieved:

Full compliance is considered to have been achieved on February 27, 1981.

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