ML20078M507
| ML20078M507 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/23/1983 |
| From: | Parsons R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20078M503 | List: |
| References | |
| CON-NRC-117 NUDOCS 8310250211 | |
| Download: ML20078M507 (3) | |
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Carolina Power & Light Company
--83 SEP 27 A 9 : 2 0 P. O. Box 101, New Hill, N. C. 27562 September 23, 1983 Mr. James P. O'Reilly NRC-Il7 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 19,1983, and a September 2,1983 meeting between CP&L and the NRC referring to Ril: GFM S0-400/83-16, attached is Carolina Power and Light Company's supplementary response, relative to additional NRC concerns identified at the September 2,1983 meeting.
It is considered that the actions taken are satisfactory for the resolution of the item.
Thank you for your coasideration ht this matter.
Yours very truly, g
& :;f' R. M. Parsons Project General Manager Shearon Harris Nuclear Power Plant RMP/sh Attachment ec:
Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)
Mr. B. C. Buckley (NRC) 8310250211 831013 PDR ADOCK 05000400 G
3 Attachment to CP&L Letter of Supplementary Response to the NRC Report RII:
GFM 50-400/83-16 Subsequent to our June 16,1983 response to the NRC Report No. GFM 50-400/83-16, dated May 19,1983, concerning cable tray support welding inspection, the following clarifies our intentions relating to the NRC concerns:
a.
Our program as related to supports already in place.
A method is being developed to assure that all supports and their inspection points will not be overlooked. This method will be incorporated into site procedures when it is fully developed. A work package concept will be developed uniquely identifying all supprts with pertinent information and inspection reports enclosed. Any questions that arise during the development of the work packages will be reverified in the field.
b.
How assessment of inspection access would be accomplished (NRC felt that the inspection groups must have input).
f Surveillance teams, coasisting of a Q.C. welding inspector and a Discipline Engineer, will survey the cable tray supports and identify areas where access could possibly be a problem.
Marked-up drawings will be used indicating
.possible inaccessible areas. The identified areas will be dispositioned by either verifying that inspection records exist or action will be taken to perform the necessary inspection.
In addition, while inspecting cable tray, the C.I. inspection group will be alert for potential access problems for the inspection of the cable tray supports. If the installation of the cable tray could prevent the support from being inspected, the cable tray installation card will not be signed and the proper individual will be notified of the existing condition. This condition will be resolved prior to acceptance of the raceway.
c.
How shop and field welds are distinguished.
Fabrication drawings and erection drawings, as modified by applicable FCR's and DCN's, will be used to identify field welds. These field welds will be identified and documented in the support package.
d.
How removal, reinstallation and reinspection of supports and tray will be handled and controlled (AFRR's and RRN's are of concern to the NRC).
Should it become necessary to remove items to allow access for inspection, the removal, reinstallation and reinspection will be accomplished and controlled in accordance with procedures. WP-206 addresses the removal and rework of cable.
WP-205 addresses the removal of raceways.
These procedures, as well as procedure AP-X-05 for removal and reinstallation of previously inspected items, are being reviewed to ensure adequate controls exist.
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Protection of cable already pulled.
General guidance for the protection of cable during installation and/or rework is covered in WP-206 and WP-210 which address acceptable means of protecting cable with regard to support, protection from surrounding work, etc.
The above actions will be accomplished by December 2,1983.
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