ML18018B946

Responds to NRC 850312 Ltr Re Violations Noted in Const Appraisal Team Insp Rept 50-400/84-41,as Noted in Insp Rept 50-400/85-04.Corrective Actions Listed

ML18018B946
Person / Time
Site:	Harris
Issue date:	04/11/1985
From:	Parsons R CAROLINA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18018B945	List: ML18018B946 ML18018B947 ML18018B948
References
CON-NRC-351 NUDOCS 8505210497
Download: ML18018B946 (10)

See also: IR 05000400/1984041

Text

Carolina Power 5 Light Company P.O.Box 101, New Hill, NC 27562 April ll, 1985 Dr.3.Nelson Grace United States Nuclear Regulatory

Commission

Region II 101 Marietta Street, Northwest (Suite 2900)Atlanta, Georgia 30323 NRC-351 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO.1 DOCKET NO.50-000 IE INSPECTION

REPORT NO.50-000/85-00

Dear Dr.Grace: Carolina Power and Light Company (CPAL)has received Mr.R.D.Walker's letter, dated March 12, 1985, which references

the results of the Construction

Appraisal Team (CAT)inspection

by the NRC in October and November 1980.You requested that CPRL respond to three specific items identified

during the CAT Inspection

Report No.50-000/80-01

Appendix A, Executive Summary, Overall Conclusions, Page A-l.We consider the CAT inspection

to have been a beneficial

experience

for the project.The thoroughness

and professionalism

demonstrated

by the team rriembers was noteworthy.

The findings and observations

noted in the conclusion

paragraphs

of the several sections of the report are being given management

attention as we continue our internal evaluations

of program improvement.

In addition to the response requested by Mr.Walker's letter, we would like to take notice of several strengths reported by the NRC appraisal.

1.There was evidence of good project management

and construction

practices at the Shearon Harris Site.These good practices include a capable project management

organization, the fact that site engineering

and inspection

activities

are primarily located and controlled

on-site, and there is extensive use of field engineers.

2.In the pipe support area, site engineering

and inspection

personnel were knowledgeable

of procedures, requirements, and responsibilities.

Procedures

and inspection

checklists

were thorough and detailed.3.The Quality Check Program appears to be a viable method of addressing

employee concerns which may help preclude future problems with employee concerns experienced

at other nuclear facilities.

In addition to the strengths noted above, we acknowledge

the three program weaknesses

that were identified.

We herewith submit (Attachment)

our responses to those items in accordance

with your request contained in Report No.50-000/85-00.

8505210497

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P*t I f ff ,I~-~r It tlt t'C J l It/I tt I~I It~lt It~III+t (tl J'~P

Dr.3.Nelson Grace~~NRC-351 We consider the management

actions being taken are satisfactory

for the resolution

of the items.Thank you for the consideration

in this matter.Yours very truly, R.M.Parsons Project General Manager Completion

Assurance.Shearon Harris Nuclear Power Plant RMP:bs A ttachment cc: Messrs.G.Maxwell/R.

Prevatte (NRC-SHNPP)

Mr.B.C.Buckley (NRC)XE X-se l 0/2-OS5

~~0 I g!1'R l h~Ik W~-

ATTACHMENT

TO CPRL LETTER OF RESPONSE TO NRC REPORT NO.50-000/85-00

The following is a summary of management

actions taken as a result of the three construction

program items reported as requiring management

attention by the"CAT" Inspection

Report 50-000/80-01

Appendix A, Executive Summary;Overall Conclusions, page A-1 issued on December 20, 1980.ITEM NO.1: Conflicts were identified

between design inputs and FSAR commitments

with regard to electrical

cable and raceway separation

which resulted in separation

deficiencies.(The response for this item is provided in two parts: (A)cable, and (B)raceway.)RESPONSE A (Cable): FCR-E-3693

was issued December 17, 1980, which provided design details for the installation

and inspection

of exposed cables to exposed cables.The Harris Plant Engineering

Section (HPES)has initiated an evaluation

of separation

requirements

for equipment to equipment, equipment to raceway, equipment to exposed cable, and exposed cable to raceway.After the design details for exposed cable to equipment are issued, Construction

Inspection-Electrical

will inspect safety-related

equipment for exposed cable separation

violations.

Exposed cable separation

violations

at tray to tray, or tray to conduit entrances and exits will be inspected as a portion of the inspection

of the safety-related

raceways.After the above items are completed, the inspection

results can be evaluated, and a projected completion

date of the rework and final inspection

can be established.

At the same time or prior to the initiation

of the separation

reinspection

of safety-related

exposed cable and safety-related

raceway, new installations

of scheduled non-nuclear

safety cable will be inspected for separation.

RESPONSE B (Raceway):

HPES has prepared an analysis of non-nuclear

safety conduit to safety-related

tray without covers which justifies the validity of the 1" separation

criteria.HPES is revising the FSAR commitments

to reflect the results of the analysis.HPES is currently clarifying

separation

requirements

for raceway to equipment.

After the design information

is issued for separation

requirements

between raceway and equipment, Construction

Inspection

will issue a procedure or revise existing procedures

to incorporate

new design information

and reinspect appropriate

inspection

points for safety-related

raceway separation

requirements.

At the same time or prior to the initiation

of the reinspection

of safety-related

raceway separation, new installations

of scheduled non-nuclear

safety raceway will be inspected for separation.

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ITEM NO.2: Hardware discrepancies

were found in non-seismic

items installed over Seismic Category I items.Failure of these discrepant

non-seismic

items could adversely affect Class 1E electrical

components.

RESPONSE: The Regulatory

Guide 1.29 Verification

Walkdown commenced on February 26, 1985, utilizing a formal CPRL Engineering

Procedure 7.6.B.Since Regulatory

Guide 1.29 is followed in the design of the Shearon Harris NPP, this wall<down serves as a confirmation

of design controlled

components

and a verification

of field run components.

As we stated during the CAT inspection, we had planned to perform this walkdown later in the construction

phase of the project.As a result of the CAT identification

of this item, we have accelerated

the walkdown schedule by initiating

a preliminary

walkdown to gain an early start on problem identification

and resolution.

The final walkdown will still occur later in the construction

sequence.Potential problems identified

during this phase will be subjected to a detailed evaluation

and/or resolution

which may consist of rework.r The following buildings have been completed under Phase 1 of the program:1.2.3.5.6.7.Waste Processing

Building (Gas Decay Tank Area)Emergency Service Water Intake Structure Emergency Service Water Screening Structure Diesel Generator Building Diesel Oil Storage Tank Building Tank Building Fuel Handling Building Phase 2 will consist of a second walkdown of the buildings in which non-seismic

components

are located in safety-related

areas.This will start as the areas approach completion.

A system will be developed by Planning and Scheduling

which will track construction

progress and identify ar eas which are approaching

completion.

It is estimated that the Phase 2 Walkdown will mainly take place during the last quarter of 1985.This will ensure an area check for components

added between the Phase 1 and Phase 2 Walkdowns.

After an area has been walked down the final time, controls will be initiated to monitor further work in the area and ensure Reg.Guide 1.29 considerations

are factored into follow-up work performed in the area.The walkdowns will be detailed enough to include checks for deficiencies

of the type noted by the CAT inspectors.

In addition to the above, as of January 10, 1985, the Construction

Inspection (CI)Unit has implemented

an inspection

program for non-Q expansion anchors in accordance

with Technical Procedure TP-39 titled"Inspection

of Drilled in Expansion Anchors".This program will ensure proper installation

of future non-Q expansion anchors for non-seismically

designed supports which are designed to survive a seismic event (SSE).XE X-sell/0-OS5

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-3-ITEM NO.3: Deficiencies

identified

in the area of interdisciplinary

and pipe to pipe clearances

indicated that the identification

and resolution

of these interferences

were not being ef f ectively addressed.

RESPONSE: The Interdisciplinary

Clearance Verification

Walkdown began on February 26, 1985, governed by a formal CPRL Engineering

Procedure 7.6.C.Because various structures, systems and components

have been designed with consideration

for minimum clearance requirements, this walkdown is a verification

of these requirements

and to evaluate any violations

of this criteria due to physical constraints

during the installation

of these components.

This program is divided into two phases.Phase 1 began February 26, 1985, and is performed concurrently

with the Regulatory

Guide 1.29 Verification

Walkdown.Phase 1 is a walkdown of the buildings in which safety-related

components

are located.The intent of Phase 1 is to identify as soon as possible any modifications

or reroutings

that may be required to ensure no detrimental

interaction

with the existing components

prior to system turnover.The following buildings have been completed under Phase 1 of the program: l.2.3.5.6.7.Waste Processing

Building (Gas Decay Tank Area)Emergency Service Water Intake Structure Emergency Service Water Screening Structure Diesel Generator Building Diesel Oil Storage Tank Building Tank Building Fuel Handling Building HPES is developing

a site unique comprehensive

clearance matrix.This matrix will be utilized by Construction

Inspection (CI)and incorporated

in the respective

inspection

Technical Procedures (TPs).Phase 2 of this program will consist of a second complete walkdown of the buildings which contain safety-related

components.

This will begin as areas approach completion.

A system will be developed by Planning and Scheduling

which will track construction

progress and identify areas which are approaching

completion.

XE X-sell/5-OS5

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