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 CAROLINA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
CON-NRC-357 NUDOCS 8506210068
Download: ML18019A244 (6)

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

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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.

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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.

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