IR 05000382/1989005

Discusses Insp Rept 50-382/89-05 on 890213-17 & Forwards Notice of Violation.No Addl Info Was Provided to Change NRC Position & Therefore Util in Violation of Requirements.Basis for NRC Determination of Violation Provided

ML20248B866
Person / Time
Site:	Waterford
Issue date:	07/31/1989
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
Shared Package
ML20248B869	List: IR 05000382/1989005 ML20248C252
References
EA-89-111, NUDOCS 8908090352
Download: ML20248B866 (4)

Text

.

. _ _ _ _ - _ _ _---_

,

kg

~'

g

%, <. >

JUL 3'l 195 Y .

.. .

O In Reply Refer To:

Docket: -50-382/89-05-EA 89-111

, 4

' Louisiana Power..& Light Company.

/ ATTN: J. Senior Vice President Nuclear. Operations-317 Baronne Street.

,

LNew Orleans, Louisiana ~10160 ,

150BJECT: ~ NOTICE.0F VIOLATION'(NRC INSPECTION REPORT 50-382/89-05)

Dear Mr. Dewease:

.This refers to the NRC inspection. conducted on Februar

'Waterford Steam Electric Station, Unit 3 (Waterford-3)y, 13-17, 1989, at of activities

, ,

authorized by NRC. License No,'NPF-38. The-inspection was conducted to examine LP&L's.. actions in response.to previous NRC inspection findings regarding

. environmental qualification. (EQ) of. equipment. These. previous findings were

,. ' documented in NRC Inspection Reports 50-382/86-32,50-382/88-27,and .

'

V 50-382/88-31 fomarded to you by letters dated April 6,1987, November,23, i1988, and February 9, 1989, respectively. A copy of the report for the

' current ~ inspection was sent to you by letter dated March 17, 1989. 4 ,

,

NRC's concerns' regarding:the environmental qualification of equipment at

,

Waterford-3 were discussed on June 1-, 1989, during an Enforcement Conference held in' the Region IV' office between you and other members'of your' staff and

Messrs.FJ. L. Milhoan,'L'. J. Callan, and other members of the NRC Region IV'

-staff. The issues discussed during the Enforcement Conference included the' ,

environmental qualification of taped splices, an issue discussed in Inspection ~

l Report'50-382/89-05, and the environmental qualification of.certain

. safety-related cables,~an issue that was not discussed in the inspection; i

'

report but:was raised during a March 23,'1989, telephone call between LP&L's

" R. P. Barkhurst and. Messrs. Milhoan and-A. B. Beach of my staff. In both cases, NRC's: concerns centered on the performance of these electrical components in a submerged environment.

We have completed our review of the information provided during the Enforcement 2 -i Conference and subsequent to the Enforcement Conference in your letter to the i x ;NRC dated June 21,.1989. This letter provided a' summary of the Enforcement Conference ^information provided by your staff. The NRC review included both information submitted to the NRC prior tu the Enforcement Conference by LP&L and the new information provided during the June 1 Conference.

Asithe. result of this review, we have determined that Waterford-3 is in j

- l compliance with.10 CFR Part 50.49 with respect to the EQ of potentially l

, submerged cables. With respect to the 20 of potentially su merged j RIV:C:PSS* .AD:DRS*' D:DRP* E RA c .TStetka/cjg JJaudon JLMilhonn G rn RDM in l

/ /89 ./ /89 s

/ /89 ~1/M/89 9/p/89 j

• previously concurred i b\

"

8908090352 890731 PDR ADOCK t5000382 e\

Q PDC l l

c-- -_- . - _ _ _ - _ - - - - _ .A

,

w -

-

-

,3,

.- .g.; +

,

-

..

,.; 7

Louisiana Power & Light Company ~ -2-p Okonite'T95/35 taped splices, we have determined that LP&L has not provided

'any additional information that would change-our position and is therefore in

, violation of.' requirements. The basis for our determination of a violation is

. discussed in.the following paragraphs.

'

s As presented in the June.1 Enforcement Conference LP&L's position was  !

that the Okonite splices were qualified for submergence. L'P&L supports this

.

position on the following bases:

<

LOCA type steam testing followed by a 5 minute submergence test;

A long-term submergence test of T95 insulation (without the jacket)

P, in tap water;

• -

y 'NRC acceptance of this LOCA type steam testing in Supplemental Safety Evaluation Report (SSER)-5, dated June 1583 and SSER-8 dated

'

December 1984; .  ;

"'

NRC acceptance of this type testing during hearings on the licensing.

~of'the Seabrook plant, and

Co.coatibility of cable and splice materiil based upon a review of 'l proov t literature and qualification reports for XLPE-and.EPR insula nd cables.

NRC's basis for not sccepting the qualification of the splices for submergence is consistent with NUkEG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," dated Ju~iy 1981. 1

' Paragraph 2.2 of NUREG&O588 requires equipment subject to submergence to be i

'

qualified by. test. These test conditions must represent the environment,a1 conditions to which the equipment will.be subjected. The LOCA type steam test l and the long-term submergence in tap water test do not meet the requirements i of NUREG-0588~1n that they do not reflect the actual environmental conditions j to which the splices would be subjected. Additionally, a test conducted on one 1 type of. splice (e.g.. an Inline splice) cannot be extrapolated for a different l

"

type of splice. Your staff was informed of this position in numerous discussions with NRC inspection and staff personnel'.

I At the time of the EQ Audit in January 1983, the submergence qualification of J Okonite splices was discussed. The LP&L response to the audit finding was that i no splices would be located below the fhod level and that a construction

~

l procedure would be revised to prohibit splices below the flood level. l

'

SSER-5, which addressed this EQ Audit, specified that equipment subject to submergence.would be qualified for submergence in accordance with NUREG-0588. ,

'

SSER-8 closed out the EQ issues identified in the EQ Audit based upon the NRC understanding that equipment qualification at Waterford-3 was in accordance with 10 CFR Part 50.49 and NUREG-0588 and that no equipment would be subjected )

to submergence. These SSERs did not change the NRC position on submergence qualification.

'

, ,

.

_ _ _ _ _ _ _ _ _ _ _ _ . _ _ __ J

-_-__

.

. n 1

* .

-

!

l Louisiana Power & Light Company -3-l l l

We acknowledge that the equipment submergence issue addressed during the Seabrook nuclear plant licensing hearing may have been a point of confusion with your staff. However, the numerous discussions between the NRC and your staff, which included the NRC staff members involved in the hearings, should have clarified this decision.

We note further discussion of this decision in Appendix B of your June 21 ,

letter. The NRC position remains that the issue was decided only because the licensee (for Seabrook) informed the hearing board that no equipment would be

-

located below the postulated flood level.

We note that LP&L had tested Okonite splices for submergence on EPR type cable. As we discussed earlier in this letter, the NRC position is that this testing does not provide qualification because it does not reflect the actual environmental conditions to which this splice configun. tion would be subjected. Additionally, as was discussed in the June 1 Conference, the testing of one manufacturer's.EPR type cable does not provide qualification for other manufacturers' EPR type cables. Furthermore, since your Okonite splices are used on other. types of cables (e.g., neoprene and Tefzel), the NRC position remains that to qualify these splice configurations for submergence requires a submergence test that duplicates the actual environmental conditions. This position is consistent with the provisions of NUREG-0588.

We conclude that a violation of 10 CFR Part 50.49 with respect to the submergence qualification of Okonite T95/35 taped splices did occur. Based upon our '

understanding that the equipment affected by the submerged splices have redundant qualified substitutes that are not subjected to submergence, the condition does not meet the criteria for escalated enforcement action. Our understanding is based upon your submittal of a Justification for Continued Operation on February 23, 1989.

You are required to respond to this violation, in writing, in accordance with the provision of Section 2.201 of the NRC's " Pules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based upon the specifics contained in the Notice of Violation enclosed with this letter.

Sincerely, ORIGINAL SIGNED BY ROBERT D. MARTIN Robert D. Martin Regional Administrator cc w/ enclosure:

Louisiana Power & Light Company ATTN: R. P. Barkhurst, Vice President Nuclear Operations P.O. Box B Killona, Louisiana 70066

_

--

, as ,

- n -

.- .

,

wm.gy [~h??

.

y .. $ +

' ' [', ' #

.j g

.

- *

r, ;g, , .y

.O

"'

I 23'. >

%'

'

,.

[7y[v'

.

,g- hPyu. . ~

-

.

.,,

- < . ,

\j f ^ u' ,

i.ib ,

, _

, .

,

' '

,,

Y - % . , . ,

, t

' '

]}Lo'uisianaPower& Light, Company,. L-4-- .

- m

'

'If n .. ,)

diz:- < 4 '.' .. . r, .. ..

'

%" '. , Slouisiana' Power & Light. Company. ,

' '

' ATTN:s tJ. - R. 'McGaha , Jr. , Plant Manager, '

'

tLP;0. Box B. , .

-

-

' K111ona 3 Louisiana .70066 :

B, lLouisianaLPower & Light Company

'e ,

ATTN:: R. F.. Burski, Manager, Nuclear

, ,

cSafety & Regulatory Affairs 317;Baronne Street.

LP.O. Box'60340L

.fNew Orleans,. Louisiana .701601 x

."

Louisiana' Power &: Light Company 9

ATTN

"

s l. W. Laughlin,- Site

• '

j Licensing' Support Supervisors

P.O. Box.B-

1. ,

lK111ona. Louisiana'c70066 .

, . - .

,i b '

. Louisiana" Power & Light Company ~,

ATTN: '!.G..M.'. Davis, Manager Events

._ ' Analysis. Reporting & Response

'P;0.. Box B'- '

'

lK111oni,7 Louisiana'70066

"

Middle' South Services-

' '

,

'

ATTN:;4Mr. R. T. Lally.

-P.O.-Box 61000 .

.

'I New' Orleans ,l. Louisiana 70161 1 Louisiana Radiation Control Program Director bdctItDMB(IE01) , ,

.!

\

R" ,-3 bec distrib; by RIV: f RR1 ,

R. D. Martin, RA 1 iSectionChief.(DRP/A),

'

-

DRP l MIS System

'

'RPB-DRSSi .

% ;ProjectEngineer(DRP/A) RSTS Operator -

eRIV. Filet DRS j

>/ D.-Wigginton~,NRRProjectManager(MS: 13-D-18)

O Lisa.Shea; RM/ALF-T. Stetka' ,

,

e G. Sanborni

? .-J; Lieberman. 0E '

) p. x '

l

,

--'

t 1

a +

,

,

t .\

< r

!( ,

.

i 2. . 1

'

.

..

'I '

k j :

s,

)

7, <

'

w _Q :_ w -_ _ 9 _