ML18019A244

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
Issue date:	05/03/1985
From:	PARSONS R M CAROLINA POWER & LIGHT CO.
To:	GRACE J N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
CON-NRC-357 NUDOCS 8506210068
Download: ML18019A244 (6)

See also: IR 05000400/1985008

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

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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

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