ML20064C493
| ML20064C493 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/03/1982 |
| From: | Parsons R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20064C444 | List: |
| References | |
| CON-NRC-20 NUDOCS 8301040414 | |
| Download: ML20064C493 (3) | |
Text
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PM 07 Ngy O. Box 101, New Hill, N. C.
27562 November 3, 1982 Mr. James P. O'Reilly NRC-20 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 3100)
Atlanta, Georgia 30303
Dear Mr. O'Reilly:
In reference to your letter of October 4, 1982, referring to RII: JRH 50-400/82-32, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.
It is considered that the corrective and preventive actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, W
R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attachment cc:
Mr. P. Kadambi (NRC)
Mr. G. F. Maxwell (NRC-SHNPP)
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l 8301040414 821214 PDR ADOCK 05000400 G
Attachment to CP&L Letter of Response to NRC Report RII: JRH 50-400/82-32 Reported Violation:
10 CFR 50, Appendix B, Criterion III, as implemented by Carolina Power and Light Corporate QA Manual Section 3, requires that design changes including field changes shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design.
Contrary to the above, process control cabinets SA-09, SA-13, SB-10 and SB-14 were installed per FCR-M-462 without verifying that the mounting design specified in the FCR met the original seismic qualification test requirements that were performed on the equipment by the vendor.
This is a Severity Level V Violation (Supplement II).
Denial or Admission and Reason for the Violation:
The violation is correct as stated. Vendor qualification of the Process Control Cabinets was with bolted attachment; however, no record was kept to indicate the degree or extent of actual surface contact of the cabinet perimeter structural members between the bolt attachment points. The FCR-M-462 that was initiated to allow the use of shims was approved by the original design organization, but did not address the need for full contact. The design organization communication with the vendor responsible for seismic qualification was verbal and indicated that shimming would not impact qualification or bolt loading. When backup documentation from the vendor for verification of seismic qualification acceptability was requested, the vendor stated the qualification was based on physical testing and the impact of contact other than 100% could not be analytically evaluated.
Corrective Steps Taken and Result Achieved:
The design organization attempted to structurally analyze the impact of increased downward deflection without full bearing on embed steel, but could not finitely satisfy the vendor qualification due to the complex framing of the cabinet.
The CP&L design organization approved FCR-M-485, Rev. 1* requiring the use of shims in combination with epoxy grout to simulate the vendor qualification assuming 100%
contact.
- FCR-M-485, R2 was approved 9-1-82 which clarified shimming material to be used.
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I Attachment (Cont'd.)
i Corrective Action Taken to Avoid Further Noncompliance:
The design organization is reviewing mounting details for all seismically qualified equipment to verify concurrence between vendor requirements and design documents.
As part of the NRC Seismic Qualification Review Team program, the design organi-zation will address and resolve differences between as-built conditions and mounting details specified.
pate when Full Compliance Will Be Achieved:
Prior to fuel loading of Unit 1.
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