ML18019A244: Difference between revisions

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| issue date = 05/03/1985
| issue date = 05/03/1985
| title = 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
| title = 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
| author name = PARSONS R M
| author name = Parsons R
| author affiliation = CAROLINA POWER & LIGHT CO.
| author affiliation = CAROLINA POWER & LIGHT CO.
| addressee name = GRACE J N
| addressee name = Grace J
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| docket = 05000400
| docket = 05000400
Line 15: Line 15:
| page count = 6
| page count = 6
}}
}}
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                                                                 NRC-357 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Commission
Atlanta, Georgia 30323
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
==Dear Dr. Grace:==
that the corrective
 
action taken is satisfactory
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 .
for resolution
It is considered that the corrective action taken is satisfactory for resolution of the item.
of the item.Thank you for your consideration
Thank you for your consideration in this matter.
in this matter.Yours very truly, R.M.Parsons Project General Manager Completion
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)
Assurance Shearon Harris Nuclear Power Plant RMP:sae Attachment
Mr. B. C. Buckley (NRC) 85062i0068 850503 PDR   ADOCK   05000400, 6                   PDR XEX-se7/1~S5
cc: Messrs.G.Maxwell/R.
 
Prevatte (NRC-SHNPP)
E
Mr.B.C.Buckley (NRC)85062i0068
                                            ~       ~
850503 PDR ADOCK 05000400, 6 PDR XEX-se7/1~S5  
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Attachment
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to CPM Letter of Response to NRC Report RII: TDG-50-000/85-08-01
                                                                                                  ~   4   7 F
Re rted Violation:
l   Eg*       E ~     'I             ~ \   I                                 E f     E ff k                  If                d Et
10 CFR 50.50(a)(l)
                                                                                          *I Ktt I
requires Carolina Power and Light Company (CPRL)to implement the Quality Assurance Program described or referenced
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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
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regulatory
                                  !. "KFC, E
requirements
4
for the separation
(
of Class IE electrical
v
raceway and circuits are correctly translated
                                            ~   a   ~       ~ ~
into specifications, drawings, procedures, and instructions.
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The FSAR Section 8.3.1.2.30(b)
 
invokes the Institute of Electrical
Attachment to CPM Letter of Response to NRC Report RII: TDG-50-000/85-08-01 Re   rted Violation:
and Electronic
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.
Engineers (IEEE)Standard 380-1970 titled, Criteria for the Separation
Contrary to the above, the following examples of failure to incorporate the applicable requirements were identified:
of Class IE Equipment and Circuits.Contrary to the above, the following examples of failure to incorporate
: a.     The licensee's design organization approved Field Change Request E-1300 which was in direct violation of the referenced IEEE Standard.
the applicable
: 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.
requirements
This is a Severity Level IV Violation (Supplement II).
were identified:
Denial or Admission and Reason for the Violation:
a.The licensee's
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.
design organization
: 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.
approved Field Change Request E-1300 which was in direct violation of the referenced
Corrective Ste   s Taken and Results Achieved:
IEEE Standard.b.The licensee's
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.
drawings and notes do not require separation
: b. FCR-E-0563 has been issued to clarify separation requirements for exposed cable between tray and conduit.
of cable leaving a tray and going to a conduit.There was no drawing requirement
XEX-se7/3-OS5
for physical separation
 
as required by the referenced
I r{ 'h tll 1
IEEE Standard.This is a Severity Level IV Violation (Supplement
          \   I   h     W' t>>W h
II).Denial or Admission and Reason for the Violation:
1 J I I
ao The violation is correct with clarification.
W>>l ~
IEEE 380-1970 allows for separation
h It   ~     11                                   h h
distances to be established
W h   I r
by analysis.FCR-E-1300
11     h
was approved prior to completion
 
of a Shearon Harris specific analysis.Similar analysis for a comparable
Corrective Ste s Taken to Avoid Further Noncom liance:
project was available.
ao   Subject personnel have been cautioned that required analysis must be completed prior to final approval of an FCR.
b.The violation is correct with clarification.
: b. The issuance of FCR-E-0563 is considered to be adequate corrective steps in the area of cable separation criteria.
Design drawing CAR 2166-B-060
Date When Full Com liance Was Achieved:
provides separation
Full compliance was achieved on May 2, 1985.
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
XEX-se7/0-OS 5
Ste s Taken and Results Achieved: ao A Shearon Harris specific analysis has been performed which shows the acceptability
 
of a 1" separation
c%
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
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has been submitted to revise the FSAR to reflect this installation.
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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
}}

Latest revision as of 19:23, 3 February 2020

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 NRC-357 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 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 .

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

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E 4

4

( ~

~ 4 7 F

l Eg* E ~ 'I ~ \ I E f E ff k If d Et

  • I Ktt I

4 qt K

tf M(E ~ ~

!. "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 tll 1

\ I h W' t>>W h

1 J I I

W>>l ~

h It ~ 11 h h

W h I r

11 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

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