ML20042D280

Responds to Violations Noted in Insp Rept 50-382/89-29. Corrective Actions:Importance of Complete Documentation of Evaluations for Temporary Alterations Stressed to Plant Engineering Staff

ML20042D280
Person / Time
Site:	Waterford
Issue date:	01/02/1990
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P89-2171, NUDOCS 9001080210
Download: ML20042D280 (4)

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Loulenena Power & Light Contpany

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5 P. O. Box 60340 l Nw Orleant, LA 70160 0340 Tot, 604 695 2805 L

R. F. Burski Nuclear Safety & Regulatory Attats .

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W3P89-2171 A4.05' QA January'2, 1990 v

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U.S.; Nuclear Regulatory Commission

-ATTN Document Control Desk

- Washington, D.C._ 20555

Subject:

Waterford 3 SES

< Dochet No. 50-382 License No.:NPF-38 NRC Inspection Report 89-29

.'Gentlement

-In accordance with 10 CFR-2,201, Louisiana Power & Light hereby submits in

. Attachment l'the response to the Violation identified in Appendix A of the subject inspection Report.

If you.have any questions concerning this response, please contact L.W. Laughlin.at (504) 464-3499.

Very truly yours, yLJ RFB/DDG/ssf.

Attachment cc Messrs. R.D. Martin, NRC Region IV F.J. Hebdon, NRC-NRR D.L. Wigginton, NRC-NRR E.L. Blake W.H. Stevenson NRC Resident Inspectors Office

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An Enteruy Company

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ATTACHMENT 1 i h .

I LP&L RESPONSE TO THE VICLATION IDENTIFIED IN APPEND 1X A ,

0F INSPECTION REPORT 89-29 l g

[ = VIOLATION NO. 8929-02 i

, , y, Failure to Provide Adequate Test Control L

Criterion'XI of 10 CFR Part $0,' Appendix B, requires, in part, that all

[ testing required to demonstrate that structures, systems, and components will, perform satisfactorily in service is identified and performed in (21 .

'.accordance with written test procedures, which incorporate the requirements  :

and acceptance limits contained in applicable design documents.

f I Contrary to the above. Temporary Alteration (TA) 89-22 was made during

' refueling. outage three to provide temporary services through a containment f

'j building penetration. The licensee failed to identify and perform a post-installation test to prove operability of the temporary penetration i k closure for the potential conditions in the containment building during the  !

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' period of installation.

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This is a Severity Level IV violation.

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' RESPONSE 6

.(1)- Reason for the Violation L The root cause of this violation is incomplete documenting of the engineering evaluation for Temporary Alteration (TA) 89-22. TA 89-22 ,

was ; initiated to provide a method of passing electrical cables and/or  ;

mechanical hoses through the containment building during Refuel 3 and provide containment isolation via the HVAC vacuum breaker line (Penetration'13).  ;

As described in the TA package, the temporary enclosure ~of the l' penetration consisted of a 1" thick by 24" diameter blind flange which contained various size holes. Pipe nipples were welded to these holes -

to permit passage of' electrical cables and air hoses for temporary ,

containment services during refueling. The flange assembly was secured to the existing penetration with twenty 1 1/4 - 8 stud bolts and nuts. Two 0-rings were used to provide a seal between the containment and the piping interior. This is the same configuration e that is used to perform the Local Leak Rate Test (LLRT) of valve CVR 202. As discussed in the TA package, the space between the pipe nipples and the temporary electrical cables and/or mechanical hoses ,

-were sealed with RTV silicone sealant to prevent air leakage from containment.

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', .. W3P89-2171 C Page 2.of 3  !

The text of the Inspection Report states in part "The TA/WA package  !

was silent on either a containment building penetration tightness test i or.an engineering evaluation." .It should be noted that an evaluation I was performed by Plant Engineering and included in the TA package. *

LP&L consciously chose not to perform a post-installation test since-the. evaluation prior to the installation concluded that the ,

installation would provide adequate containment integrity for Mode 5 -

k and 6 conditions.

P From LP&L's communication with the inspector during the inspection, it  ;

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'is LP&L's understanding that the violation was initiated because the  ;

l. evaluation failed to explicitly state that the flange (secured by 20 ,

p' bolts'and sealed with double 0-rings) was adequate to prevent air' leaka6;e from containment. LP&L agrees that such an explicit statement

• was not contained in the evaluation documentation. However, LP&L g . disagrees with the contention identified by the title of the violation l: that. omission of the explicit statement regarding the evaluation of .

!" the flange represents a " Failure to Provide Adequate Test Control".

LP&L considers the TA package to be technically adequate for the following reasonst

~1) The evaluating engineer was aware that the flange assembly was '

previously used for Local Leak Rate Testing (LLRT) and therefore was sufficient for its intended purpose.

2). The evaluating engineer specified using the Mechanical

[E Maintenance Torquing procedure (MM-6-011) in the TA package to '

ensure the flange assembly was properly attached to the t

' penetration. -l 3). The TA package from the previous refueling outage (TA 88-011) was f consulted and referenced in the TA. That package specified that the flange assembly was sufficient for this specific application.

By referencing the previous package the evaluating engineer 3 acknowledged the acceptability of the flange assembly.

, Based on the above LP&L ngrees that, for completeness of the documentation, the evaluation should have contained an explicit statement regarding~the suitability of the flange seal and therefore admits the violation.

(2) ' Corrective Steps That Have Been Taken and the Results Achieved The details surrounding this violation have been discussed with the Plant Engineering staff to stress the importance of complete documentation of evaluations for TAs.

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Page 3 of 3'

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l f" , _(3) l Corrective Steps Which Wil1~ be Taken to Avoid Further Violations O' - LP6L believes this v'iolation is'an isolated case. This was determined -

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' :,since:the subject inspection reviewed 26 TA packages and found.only  !

Lthis~one._ case of inadequate documentation of an engineering  ;

T. i " evaluation. Therefore..the corrective. action' discussed in section'(2) .;

is adequate to avoid further violations. l t

3 (4) Date When Full Compliance Will'Be Achieved:

' LP&L is currently-in full ~ compliance.

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