ML20206J640
| ML20206J640 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/12/1986 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-457 NUDOCS 8606270228 | |
| Download: ML20206J640 (3) | |
Text
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n Cp&L Carolina Power & Light Company clr SHEARON HARRIS NUCLEAR PROJECT P. O. Box 101 M
New Hill, North Carolina 27562 2
JUN 1x ss65 to c3 File Number:
SHF/10-13510E Letter Number:
HO-860309 (0) l Dr. J. Nelson Grace NRC-457 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323
Dear Dr. Grace:
In reference to your letter of May 14, 1986, referring to RII:
50-400/86-25-01, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1.
{
l It is considered that the attached response is satisfactory for l
resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, b4 R. A. Watson Vice President i
Harris Nuclear Project RAW /ime Attachment cc: Messrs. C. Maxwell (NRC-SHNPP)
B. C. Buckley (NRC) 8606270228 860612 PDR ADOCK 05000400 G
PDR MEM/HO-8603090/PAGE 1/OSI.
I' l
TE of
S Dr. J. Nelson Grace Page 2 NRC-457 Attachment to CP&L Letter of Response to NRC Report RII:
50-400/86-25-01 10 CFR 50, Appendix B, Criterion V, and the accepted Quality Assurance Program (PSAR, Section 1.8.5.5) collectively, require that instructions, procedures, or drawings include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, Work Procedure WP-148, R4, as implemented by the licensee does not require engineering to provide inspection personnel with complete acceptance criteria prior to initiating their inspections. NRC observations on April 10, 1986, of licensee inspection activities concerning penetration seals P2175 and P2177 and discussions with responsible licensee personnel identified that applicable acceptance criteria (i.e., generic FCRs relative to inspection activities) were not documented on the inspection record until after the inspector had initiated his inspection and determined that the installed penetration closure did not agree with the engineering acceptance criteria provided.
This is a Severity Level V violation (Supplement II).
Denial or Admission and Reason for the Violation:
The violation is denied for the following reason. The violation is incorrect as stated in that CP&L is not committed to the requirements of 10CFR50, Appendix B and Section 1.8.5.5 of the PSAR for the penetration seals noted above since they are neither safety-related nor fire protection items. Installation activities for fire protection penetration seals are required to satisfy the QA program requirements described in PSAR Section 1.8.6.
Activities governing penetration seals are controlled by Work Procedure WP-148.
This procedure requires the penetration closure engineer to " Enter applicable FCR's/PW's and/or NCR's affecting the installation of the penetration closure" in the work package.
Frequently, it is not known whether or not a generic FCR will be needed at the time the installation package is issued; therefore, these FCR's are entered on the inspection record by the engineer in the field when it is determined that a FCR is applicable to the installation. These entries are sometimes made after inspection has started, but are normally made prior to CI acceptance of the seal. A final review by the penetration closure engineer prior to sending the work package to the QA records vault provides additional assurance that the current design requirements, including FCR's, have been implemented.
MEM/HO-8603090/PAGE 3/0S1
1 1
A Dr. J. Nelson Grace Page 3 NRC-457 The penetration seals in question had not passed the established inspection points affected by the FCR. The inspector found that the penetration closures did not comply with the acceptance criteria provided and did not accept them. The fact that the FCR employed in the preparation for installation of sealing material was not listed in the installation package prior to start of inspection had no effect on the quality of the installation. The only detrimental effect resulting from not listing an FCR prior to inspection is the possible need for reinspection to verify compliance with the provisions of the FCR. Adequate controls are in place to assure that penetration seals are installed and inspected to the design requirements.
Corrective Steps Taken:
No corrective action is required as current procedural controls are effective in assuring penetration seals are installed in accordance with applicable design criteria.
MEM/HO-8603090/PAGE 4/0S1.