ML20077A479

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Responds to NRC Re Violations Noted in IE Insp Repts 50-400/83-16 & 50-401/83-16.Corrective Actions:Cable Tray & Cable Tray Support Insp Programs Revised
ML20077A479
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 06/16/1983
From: Parsons R
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20077A473 List:
References
CON-NRC-87 NUDOCS 8307220336
Download: ML20077A479 (3)


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f fflA Carolina Power & Ught Company 83 JUN 23 A 9 : 22 P. O. Box 101, New Hill, N. C. 27562 June 16, 1983 Mr.-James P. O'Reilly NRC-87 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30303

Dear Mr. O'Reilly:

In reference to your letter of May 193 1983, referring to RII: GFM 50-400/83-16, the attached is Carolina Power and Light Company's reply to the violation identified in Appendix A.

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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, g 2 :: ^N R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attachment cc: Mr. P. Kadambi (NRC)

Mr. R. Prevatte (NRC-SHNPP)

Mr. G. F. Maxwell (NRC-SENPP) 8307220336 830712 PDR ADOCK 05000400 G PDR k

Attachment to CP&L Letter of Response to NRC Report RII: GFM 50-400/83-16 Reported Violation:

10 CFR 50, Appendix B, Criterion X, as implemented by PSAR Section 1.8.5.10, CP&L Corporate QA Program Section 8.2.2 requires that inspections be performed and documented to assure maintenance of in-process inspection status.

Contrary to the above, on March 31 and April 1, 1983, several class IE electrical cable trays were found to have been installed and accepted by the electrical construction inspection personnel prior to completion of required welding inspections of the tray supports. This condition was exemplified by one of the cable tray supports associated with a class IE tray identified as C1807SB.

This is a Severity Level IV Violation (Supplement II.D).

Denial or Admission and Reason for the Violation:

Ihe violation is correct as stated. Procedures requiring the welds on supports to be inspected before cable tray is installed did not provide adequate work and inspection interface controls.

Corrective Steps Taken and Results Achieved:

The cable tray and cable tray support inspection programs have been revised.

The cable tray inspection and documentation will continue to be achieved utilizing cable tray cards. The inspector will inspect the cable tray, its connection to the support, and the support location and elevation during cable tray inspection. The cable tray support inspection and documentation were achieved by a revision to WP-203 which provides an inspection form (Exhibit 1, WP-203) to document the inspection of the support configuration and geometry by Construction Inspection and the welding inspection by QC Welding.

l During an on-site inspection, Mr. W. H. Miller added an additional concern j to violation (Report No. 50-400/83-16 and 50-401/83-16 dated May 19, 1983).

l His concern was with respect to the inspection of fire barrier steel prior to thermal lag coating.

The fire barrier is not a s ructural support for safety-related cable trays.

The inspection of the subjeer steel comes under our fire protection QA program and the steel was installed as a Regulatory Guide 1.29 item. Fire barrier steel was installed and inspected under control of Seismic Weld Data Reports. The Seismic Weld Data Reports document the material and the inspection.

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-o.,.o- -2 Corrective Steps Taken to Avoid Further Noncompliance:

Separate inspection controls have been enhanced to provide independent specific controls on both supports and raceway inspection. Work Procedures 206,' Documentation and control of the Installation and Termination of Electric Cable; 203, Installation of Seismically Supported Electrical Cable Trays, Conduits, Boxes and Bus Ducts; and Technical Procedure 42, Inspection of Safety Related or-Seismically Installed Electrical Raceways and Compo-nents, have been revised and approved to incorporate these' changes.

Date When Full Compliance Will'Be Achieved:

i Full compliance was achieved on June 10, 1983.

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