ML20209A705
| ML20209A705 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/20/1986 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-471 HO-860330(O), HO-860330-(O), NUDOCS 8609080087 | |
| Download: ML20209A705 (3) | |
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- kp&L Carolina Power & Light Company SHEARON HARRIS NUCLEAR PROJECT P. O. Box 101 AUG 2 01986 New Hill, North Carolina 27562 File Number:
SHF/10-13510E Letter Number:
HO-860330 (0)
Dr. J. Nelson Grace NRC-471 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 July 21, 1986, referring to RII:
50-400/86-50-01, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1.
It is considered that the corrective actions taken/ planned are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, (f
f R. A.I Vice President Harris Nuclear Project RAW /skm Attachment cc: Messrs. G. Maxwell (NRC-SHNPP)
B. C. Buckley (NRC) kRO90SOO87 860820 ADOCK 05000400 g
PDR MEM/H0-8603300/ PACE 1/OSl h
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p Dr. N. Ceres Pags 2 Attachment to CP&L Letter of Reaponse to NRC Report RII:
50-400/86-50-01 Reported Violation 10 CFR 50.54(a)(1) requires Carolina Power & Light Ccmpany (CP&L) to implement the Quality Assurance (QA) Program described or referenced in the Safety Analysis Report.
Section 17.2.16 of the Harris FSAR requires that corrective action be initiated to preclude recurrence of significant conditions adverse to quality. Nonconformance report 85-2000 established corrective actions to prevent repeated damage to instrument tubing in the containment.
Contrary to the above, CP&L corrective action was inadequate in that on June 11, 1986 four instrument tubes were found to be damaged.
This is a Severity Level V violation (Supplement II).
Denial or Admission and Reason for the Violation:
The' violation is admitted as stated. Safety related instrument sensing lines routed between the primary and secondary shield wall were found to be in a bent configuration which violated engineered slope requirements. The reason for the damage to the instrument tubing can be attributed to general lack of attention by workers in the area. The subject instrument tubing referenced by NCR 85-2000 and again in the violation is located in a congested area where insulating and other work activities are ongoing. Due to the routing configuration and thermal constraints of the subject tubing, physical protection (ie. tube track) is not practical.
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Corrective Steps Taken and Results Achieved:
The bent tubing noted by the inspector was evaluated and corrected under the control of. Construction Work Request and Authorization (CWR&A) No. 2005-00499 and Work Procedure WP-304, Installation of Safety Related and Seismic Process Tubing and Instrumentation.
Due to its vulnerability, a walkdown to detect any further damage to the subjec.t tubing is planned prior to Construction's final Room and Area Turnover to Operations. Any damage noted at that time will be evaluated and corrected as required.
Corrective Steps Taken to Avoid Further Noncompliance:
Craft personnel have been informed of the violation during scheduled tool box meetings. Craft have been informed on prevention of damage and of assured disciplinary action when t:ecurrences of damage to instrumentation tubing attributable to negligence is noted.
MEM/HO-8603300/ PACE 2/0S1
Dr. N. Grace Page 3 NRC-471 As a further precaution, high visibility signs have been affixed and/or high visibility barricade tape spirally wrapped around instrumentation tubing considered highly vulnerable to damage.
Having these signs and/or barricade tape in place during the remaining construction phase should act as constant reminders to workers in the vicinity of instrumentation tubing of its vulnerability.
Date When Full Compliance Will Be Achieved:
Full compliance of this item is pending the above mentioned walkdown to detect and correct damage prior to Room and Area Turnover.
It is currently projected that full compliance will be achieved by September 30, 1986.
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