ML18019A291
| ML18019A291 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/03/1985 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-377 NUDOCS 8508020370 | |
| Download: ML18019A291 (6) | |
Text
Carolina Power & Light Company p~
P. O. Box 101 New Hill, North Carolina 27562 3uly 3, 1985 Dr. 3. Nelson Grace United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323 NRC-377
Dear Dr. Grace:
In reference to your letter of 3une 5, 1985, referring to RII: GFM/RLP 50-000/85-16, the attached is Carolina Power ttt: Light Company's reply to the violation identified in Enclosure l.
It is considered that the corrective action taken is satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, t +~R. A. Watson Vice President Shearon Harris Nuclear Power Plant RAVY:sae Attachment cc:
Messrs. G. Maxwell/R. Prevatte (NRC-SHNPP)
Mr. B. C. Buckley (NRC) 8508020370 850703 PDR ADOCK 05000400 8
- PDR, XEX-se7/1-OS5
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Re orted Violation:
10 CFR 50.55(f)(1) requires CPRL to implement the quality assurance program described or referenced in the Preliminary Safety Analysis Report.
Section 1.8.5.5 of the CPRL Quality Assurance Program requires that measures be established to insure that inspections are conducted in accordance with documented instructions, procedures, and approved drawings.
Contrary to the above, on May 10, 1985, the inspector identified at least two instances where electrical field modifications were being performed that did not meet the procedural requirements of construction work procedure "Installation of Seismically Supported Electrical Cable
- Trays, Conduit,
- Boxes, and Bus Ducts" (WP-203).
In addition, the Electrical Field Modifications were not documented as a Field Change Request/Permanent Waiver (FCR/PW) within 5 days, as required by this procedure.
This is a Severity Level V Violation (Supplement II).
Denial or Admission and Reason for the Violation:
The violation is admitted with the following clarifications:
l.
Electrical Discipline Engineers (Harris Plant Construction Section) through oversight failed to originate required documentation for design change approvals within the specified time span (5 working days).
2.
WP-203 was interpreted by the implementing personnel to allow the processing of field modifications up to, but not including, final inspection and acceptance.
The "authorization to proceed" was considered to be applicable to the inspection effort, as well as the work.
Inspection control was still in effect since the procedure prohibited final inspection acceptance prior to approval of the FCR/PW associated with the modification.
Corrective Ste s Taken and Results Achieved:
The Electrical Field Modification Log has been reviewed for additional discrepancies associated with the requirement to initiate an FCR/PW within five days of the issuance of a modification.
Approximately forty-five '(05) cases were identified where the five-day requirement was not met, though about forty (00) of these had been followed by the issuance of FCR/PW's, prior to the review.
The'emaining ones were resolved with the initiation of FCR/PW's following the review effort. NCR's 85-1293, 85-1530, and 85-1618, and QA Surveillance Report QASC-85-1223 identify the discrepancies found during the review.
XEX-se7/3-OS5
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Corrective Ste s Taken to Avoid Further Noncom liance:
Electrical Discipline Engineers and Technicians responsible for electrical component installations covered by WP-203 have been reinstructed in the applicable procedural requirements.
Also, WP-203 has been revised to place the initiation and the approval of electrical field modifications under control of the Harris Plant Engineering section.
The revision also requires that Construction Inspection be provided a copy of the modifications, and invokes the approved FCR/PW as a prerequisite to final inspection acceptance.
Date When Full Com liance Was Achieved:
Full compliance was achieved on 3une 28, 1985.
XEX-se7/0-OS5
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