ML18019A244: Difference between revisions

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See also: [[followed by::IR 05000400/1985008]]


=Text=
=Text=
{{#Wiki_filter:Carolina Power 8 Light Company P.O.Box 101 3g MAY 7~8: 56 New Hill, North Carolina 27562 May 3, 1985 Dr.3.Nelson Grace United States Nuclear Regulatory
{{#Wiki_filter:Carolina Power 8 Light Company P.O.Box 101 3g MAY 7~8: 56 New Hill, North Carolina 27562 May 3, 1985 Dr.3.Nelson Grace United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)Atlanta, Georgia 30323 NRC-357  
Commission
 
Region II 101 Marietta Street, Northwest (Suite 2900)Atlanta, Georgia 30323 NRC-357 Dear Dr.Grace: In reference to your letter of April 0, 1985, referring to RII: TDG 50-000/85-08-01, the attached is Carolina Power R Light Company's reply to the violation identified
==Dear Dr.Grace:==
in Enclosure 1.It is considered
In reference to your letter of April 0, 1985, referring to RII: TDG 50-000/85-08-01, the attached is Carolina Power R Light Company's reply to the violation identified in Enclosure 1.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, R.M.Parsons Project General Manager Completion Assurance Shearon Harris Nuclear Power Plant RMP:sae Attachment cc: Messrs.G.Maxwell/R.
that the corrective
action taken is satisfactory
for resolution
of the item.Thank you for your consideration
in this matter.Yours very truly, R.M.Parsons Project General Manager Completion
Assurance Shearon Harris Nuclear Power Plant RMP:sae Attachment
cc: Messrs.G.Maxwell/R.
Prevatte (NRC-SHNPP)
Prevatte (NRC-SHNPP)
Mr.B.C.Buckley (NRC)85062i0068
Mr.B.C.Buckley (NRC)85062i0068 850503 PDR ADOCK 05000400, 6 PDR XEX-se7/1~S5 E E~~4 4 (~~4 7F l Eg*E~'I~\I k If d E f E ff*I I Et Ktt qt 4 tf M(E~~K!."KFC, E 4 (v~a~lf~~fr-.4~
850503 PDR ADOCK 05000400, 6 PDR XEX-se7/1~S5  
Attachment to CPM Letter of Response to NRC Report RII: TDG-50-000/85-08-01 Re rted Violation:
E E~~4 4 (~~4 7F l Eg*E~'I~\I k If d E f E ff*I I Et Ktt qt 4 tf M(E~~K!."KFC, E 4 (v~a~lf~~fr-.4~  
10 CFR 50.50(a)(l) requires Carolina Power and Light Company (CPRL)to implement the Quality Assurance Program described or referenced in its Safety Analysis Report.Section 1.8.5.3 of the CPRL Quality Assurance (QA)Program required the licensee to assure that the applicable regulatory requirements for the separation of Class IE electrical raceway and circuits are correctly translated into specifications, drawings, procedures, and instructions.
Attachment
The FSAR Section 8.3.1.2.30(b) invokes the Institute of Electrical and Electronic Engineers (IEEE)Standard 380-1970 titled, Criteria for the Separation of Class IE Equipment and Circuits.Contrary to the above, the following examples of failure to incorporate the applicable requirements were identified:
to CPM Letter of Response to NRC Report RII: TDG-50-000/85-08-01
a.The licensee's design organization approved Field Change Request E-1300 which was in direct violation of the referenced IEEE Standard.b.The licensee's drawings and notes do not require separation of cable leaving a tray and going to a conduit.There was no drawing requirement for physical separation as required by the referenced IEEE Standard.This is a Severity Level IV Violation (Supplement II).Denial or Admission and Reason for the Violation:
Re rted Violation:
10 CFR 50.50(a)(l)
requires Carolina Power and Light Company (CPRL)to implement the Quality Assurance Program described or referenced
in its Safety Analysis Report.Section 1.8.5.3 of the CPRL Quality Assurance (QA)Program required the licensee to assure that the applicable
regulatory
requirements
for the separation
of Class IE electrical
raceway and circuits are correctly translated
into specifications, drawings, procedures, and instructions.
The FSAR Section 8.3.1.2.30(b)
invokes the Institute of Electrical
and Electronic
Engineers (IEEE)Standard 380-1970 titled, Criteria for the Separation
of Class IE Equipment and Circuits.Contrary to the above, the following examples of failure to incorporate
the applicable
requirements
were identified:
a.The licensee's
design organization
approved Field Change Request E-1300 which was in direct violation of the referenced
IEEE Standard.b.The licensee's
drawings and notes do not require separation
of cable leaving a tray and going to a conduit.There was no drawing requirement
for physical separation
as required by the referenced
IEEE Standard.This is a Severity Level IV Violation (Supplement
II).Denial or Admission and Reason for the Violation:
ao The violation is correct with clarification.
ao The violation is correct with clarification.
IEEE 380-1970 allows for separation
IEEE 380-1970 allows for separation distances to be established by analysis.FCR-E-1300 was approved prior to completion of a Shearon Harris specific analysis.Similar analysis for a comparable project was available.
distances to be established
by analysis.FCR-E-1300
was approved prior to completion
of a Shearon Harris specific analysis.Similar analysis for a comparable
project was available.
b.The violation is correct with clarification.
b.The violation is correct with clarification.
Design drawing CAR 2166-B-060
Design drawing CAR 2166-B-060 provides separation details.However, the notes were intended to cover all cable, but were not clear since they referred to raceway versus raceway and exposed cable.Corrective Ste s Taken and Results Achieved: ao A Shearon Harris specific analysis has been performed which shows the acceptability of a 1" separation between the conduit and open tray.The analysis report is in the process of being submitted to the NRR.FSAR Change Notice RAF-HPES-307 has been submitted to revise the FSAR to reflect this installation.
provides separation
b.FCR-E-0563 has been issued to clarify separation requirements for exposed cable between tray and conduit.XEX-se7/3-OS5 I r{'h 1 tll\I h W't>>W h 1<<J I I W>>l~h It~11 h W h I r 11 h h Corrective Ste s Taken to Avoid Further Noncom liance: ao Subject personnel have been cautioned that required analysis must be completed prior to final approval of an FCR.b.The issuance of FCR-E-0563 is considered to be adequate corrective steps in the area of cable separation criteria.Date When Full Com liance Was Achieved: Full compliance was achieved on May 2, 1985.XEX-se7/0-OS 5
details.However, the notes were intended to cover all cable, but were not clear since they referred to raceway versus raceway and exposed cable.Corrective
c%It tl t It}}
Ste s Taken and Results Achieved: ao A Shearon Harris specific analysis has been performed which shows the acceptability
of a 1" separation
between the conduit and open tray.The analysis report is in the process of being submitted to the NRR.FSAR Change Notice RAF-HPES-307
has been submitted to revise the FSAR to reflect this installation.
b.FCR-E-0563
has been issued to clarify separation
requirements
for exposed cable between tray and conduit.XEX-se7/3-OS5  
I r{'h 1 tll\I h W't>>W h 1<<J I I W>>l~h It~11 h W h I r 11 h h  
Corrective
Ste s Taken to Avoid Further Noncom liance: ao Subject personnel have been cautioned that required analysis must be completed prior to final approval of an FCR.b.The issuance of FCR-E-0563
is considered
to be adequate corrective
steps in the area of cable separation
criteria.Date When Full Com liance Was Achieved: Full compliance
was achieved on May 2, 1985.XEX-se7/0-OS
5  
c%It tl t It
}}

Revision as of 04:58, 17 August 2019

Responds to NRC 850405 Ltr Re Violations Noted in Insp Rept 50-400/85-08.Corrective Actions:Fsar Change Notice RAF-HPES-307 Submitted to Revise FSAR to Reflect Installation of Separation Between Conduit & Open Tray
ML18019A244
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 05/03/1985
From: Parsons R
CAROLINA POWER & LIGHT CO.
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
CON-NRC-357 NUDOCS 8506210068
Download: ML18019A244 (6)
v • d • e


Text

Carolina Power 8 Light Company P.O.Box 101 3g MAY 7~8: 56 New Hill, North Carolina 27562 May 3, 1985 Dr.3.Nelson Grace United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)Atlanta, Georgia 30323 NRC-357

Dear Dr.Grace:

In reference to your letter of April 0, 1985, referring to RII: TDG 50-000/85-08-01, the attached is Carolina Power R Light Company's reply to the violation identified in Enclosure 1.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, R.M.Parsons Project General Manager Completion Assurance Shearon Harris Nuclear Power Plant RMP:sae Attachment cc: Messrs.G.Maxwell/R.

Prevatte (NRC-SHNPP)

Mr.B.C.Buckley (NRC)85062i0068 850503 PDR ADOCK 05000400, 6 PDR XEX-se7/1~S5 E E~~4 4 (~~4 7F l Eg*E~'I~\I k If d E f E ff*I I Et Ktt qt 4 tf M(E~~K!."KFC, E 4 (v~a~lf~~fr-.4~

Attachment to CPM Letter of Response to NRC Report RII: TDG-50-000/85-08-01 Re rted Violation:

10 CFR 50.50(a)(l) requires Carolina Power and Light Company (CPRL)to implement the Quality Assurance Program described or referenced in its Safety Analysis Report.Section 1.8.5.3 of the CPRL Quality Assurance (QA)Program required the licensee to assure that the applicable regulatory requirements for the separation of Class IE electrical raceway and circuits are correctly translated into specifications, drawings, procedures, and instructions.

The FSAR Section 8.3.1.2.30(b) invokes the Institute of Electrical and Electronic Engineers (IEEE)Standard 380-1970 titled, Criteria for the Separation of Class IE Equipment and Circuits.Contrary to the above, the following examples of failure to incorporate the applicable requirements were identified:

a.The licensee's design organization approved Field Change Request E-1300 which was in direct violation of the referenced IEEE Standard.b.The licensee's drawings and notes do not require separation of cable leaving a tray and going to a conduit.There was no drawing requirement for physical separation as required by the referenced IEEE Standard.This is a Severity Level IV Violation (Supplement II).Denial or Admission and Reason for the Violation:

ao The violation is correct with clarification.

IEEE 380-1970 allows for separation distances to be established by analysis.FCR-E-1300 was approved prior to completion of a Shearon Harris specific analysis.Similar analysis for a comparable project was available.

b.The violation is correct with clarification.

Design drawing CAR 2166-B-060 provides separation details.However, the notes were intended to cover all cable, but were not clear since they referred to raceway versus raceway and exposed cable.Corrective Ste s Taken and Results Achieved: ao A Shearon Harris specific analysis has been performed which shows the acceptability of a 1" separation between the conduit and open tray.The analysis report is in the process of being submitted to the NRR.FSAR Change Notice RAF-HPES-307 has been submitted to revise the FSAR to reflect this installation.

b.FCR-E-0563 has been issued to clarify separation requirements for exposed cable between tray and conduit.XEX-se7/3-OS5 I r{'h 1 tll\I h W't>>W h 1<<J I I W>>l~h It~11 h W h I r 11 h h Corrective Ste s Taken to Avoid Further Noncom liance: ao Subject personnel have been cautioned that required analysis must be completed prior to final approval of an FCR.b.The issuance of FCR-E-0563 is considered to be adequate corrective steps in the area of cable separation criteria.Date When Full Com liance Was Achieved: Full compliance was achieved on May 2, 1985.XEX-se7/0-OS 5

c%It tl t It

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