ML18017B347

Responds to NRC 810212 Ltr Re Violations Noted in IE Insp Repts 50-400/81-02,50-401/81-02,50-402/81-02 & 50-403/81-02. Corrective Actions:All Seismically Installed Boxes Installed W/O Instruction Details Removed

ML18017B347
Person / Time
Site:	Harris
Issue date:	03/05/1981
From:	HOWE P W CAROLINA POWER & LIGHT CO.
To:	OREILLY J P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18017B346	List: IR 05000400/1981002 ML18017B347 ML18017B348
References
NUDOCS 8103260501
Download: ML18017B347 (6)

See also: IR 05000400/1981002

Text

March 5, 1981 C;,rolina Pc.ver 8 Light Company Mr.James P.O'Reilly United States Nuclear Regulatory

Commission

Region II 101 Marietta Street, Northwest Atlanta, Georgia 30303 Dear Mr.O'Reilly: I In reference to your letter of February 12, 1981, referring to RII: GFM 50-400/401/402/403/81-2;

the attached is Carolina Power 6 Light Company's reply to the deficiency

identified

in Appendix A.It is considered

that the corrective

and preventive

actions taken will be satisfactory

for resolu-tion of this item.To the best of my knowledge, information, and belief, the corrective

action in this report is true and complete.Thank you for your consideration

in this matter.Yours very truly, P.W.Howe Vice President Technical Services NJC/gea (882/308)Attachment

cc: Mr.J.A.Jones Sworn to and Subscribed

before me this 5th day of March, 1981.,~t<<tttcrr>

Notary Public My Commission

Expires October:.4gg.~>c:~W~Qt~~~t"'lilllllllil

"

4'I I J'

Severity Level V Violation'Condition Reported: As a result of the inspection

conducted on December 29, 1980 through January 30, 1981, and in accordance

with the Interim Enforcement

Policy, 45 FR 66754 (October 7, 1980), the following violation was identified.

I 10 CFR 50, Appendix B,-Criterion V as implemented

by PSAR Section 1.8.5.5 and CPKL's Corporate QA Program Part I, Section 8.2.1 requires that construction

activities

affecting quality be prescribed

in drawings, specifications, procedures

and instructions.

Contrary to the above, Class 1E electrical

conduit box numbered B1482-SB was installed without the use of an appropriate

installa-tion drawing, specification, procedure or instruction.

On January 6, 1981 conduit box B1482-SB was found to be installed in a con-figuration

which was not prescribed

by a documented

installation

drawing, specification, procedure or instruction.

Denial or Admission and Reaso'ns of Violation:

The violation i'dentified

by NRC audit was correct as stated.The reason for installing

this box is not clear.The electrical

craft personnel had no installation

details nor were they given any instruction

to install this box.Corrective

Ste s Taken and Results Achieved: Instructions

were given to the elctrical crafts to remove all boxes that wer e not installed in accordance

with an approved installation

detail.All seismically

installed boxes (including

box B1482-SB)for which installation

details did not exist were completely

removed by February 27, 1981.Corrective

Ste s Taken to Avoid Further Noncom liance: 1.The electrical

crafts have been instructed

not to install seismic boxes without an approved installation

detail suitable for the applicable

mounting configuration.

2.A Field Change Request (FCR-E-143)

was written to address the mounting details for boxes mounted on columns.This mounting detail will satisfy the requirements

for the box in question (B1482-SB).

This FCR was evaluated and detailed by the Architect Engineer.Design details were received on February 27, 1981, and issued to the field.All required implementing

procedures

are in effect.3.CP&L Work Procedure WP-205, titled"Documentation

and Control of the Installation

of Conduit and Cable Tray", has been revised: to include boxes and has been issued for use.4.CP8L Work Procedures

WP-203, titled"Installation

of Seismic Class I Electrical

Cable Tray, Tray Suppor ts, Conduit and Conduit Supports", has been revised to include boxes and box supports.This procedure has also been issued for use.5.By including boxes in WP-205, an installation

card for each box must be signed by a Construction

Inspector as documented

evidence of a satisfactory

installation.

.Severity Level V Violation Page Two f I~e/b.C.d.Safety Related Equipment must be installed by approved drawings, specifications, procedures, and instructions.

If you do not have drawings, specifications, procedures

or instruc-tions required to install equipment, you stop and notify the elec-trical craft supervision

and Discipline

Engineer.Craft supervision

must be awar e of what equipment or'.components

are safety related.When other crafts are required to support electrical

crafts by wielding or drilling and/or installing

anchors for safety related equipment, the electrical

craft will ensure that support crafts are made aware of drawings and/or procedures

applicable

to their work operation.

The, electrical

craft supervision

will make efforts to ensure that support cr fts are knowledgeable

of requirements.

6.The Principal Electrical

Engineer and Electrical

Superintendent

have met" with Field Super intendents

and General Foremen.During these meetings, the following points were discussed:

With the above procedural

changes and the requirement

for Construction

Inspector's

sign-off on each box installation, it should not be possible for an incorrect box installation

to go undetected.

It should be noted that boxes are part of the raceway system and are routinely inspected as-.such.Date When Full Com liance Will Be Achieved: Full compliance

is considered

to have been achieved on February 27, 1981.Qi

~i