W3P89-2065, Responds to NRC Re Violations Noted in Insp Rept 50-382/89-05.Corrective Actions:Equipment Qualification Files for T95/35 Tape Splice Assemblies Updated to Incorporate Engineering Evaluation

Responds to NRC Re Violations Noted in Insp Rept 50-382/89-05.Corrective Actions:Equipment Qualification Files for T95/35 Tape Splice Assemblies Updated to Incorporate Engineering Evaluation

ML20246K366
Person / Time
Site:	Waterford
Issue date:	08/30/1989
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P89-2065, NUDOCS 8909050447
Download: ML20246K366 (5)

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Loutiana Power & Ught Company

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P. O. Box 60340 New Orleans, LA 70160 0340' f.

y' August 30, 1989 W3P89-2065-A4.05 QA L

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'U.S. Nuclear Regulatory. Commission ATTN:~ Document. Control'. Desk

. Washington,~D.C.

20555

Subject:

Waterford 3 SES.

s Docket No. 50-382 License No. NPF-38 USNRC Notice of Violation to Louisiana Power & Light Company dated July 31,1989,- (NRC Inspection Report 50-382/89-03).

' Gentlemen:

In accordance wit'h 10CFR Part 2.201, Louisiana Power & Light hereby submits in-Attachment I the response to the subject Notice of Violacion.

Please contact me or J.E. Howard should there be any questions concerning

~the. response, Very truly yours, 3

R. F.. urski

RFB/RJM/dc Attachment

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cc: Messrs. R.D.' Martin, NRC Region IV F.J. Hebdon, NRC-NRR D.L. Wigginton, NRC-hTR W3 NRC Resident Inspectors Office E.L. Blake W.M. Stevenson Q Of

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890905044~/ 890830 PDR ADOCK 05000382

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Louisiana Power & Light Response To USNRC Notice of Violation dated July 31, 1989 (NRC Inspection Report 50-382/89-05)

A.

Violation 10.CFR Part 50.49(j) requires that each licensee document the performance specifications of qualified equipment under conditions existing during and following design basis accidents (DBA').

T 10 CFR Pcrt 50.49(k) provides that licenaces are not required to requalify electric equipment important to safety in accordance with 050.49 if the Commission has previously required qualification of that equipment in accordance with NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment." Such qualification was previously required by Commission Memorandum and Order CLI-80-21 on May 23, 1980.

Paragraph 2.2(5) of NUREG-0588 states that the equipment should be located above flood level or protected agains; submerger.ce.

hen equipment could be submerged, it should be identified and demonstrated to be qualified by test for the duration required.

Contrary to the above, it was found during the period of February'13-17, 1989, that the equipment qualification assessment file LPL-EQA-6.2/16.2 for Okonite T95/35 taped splices, subject to submergence during design base accidents (DBA) and under post DBA conditions, did not establish qualification because it did not demonstrate qualification for submergence.

l This is a Severity' Level IV violation.

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. Attachment'l Louisiana Power & Light Response To USNRC. Notice of Violation dated ' July 31, 1989 (NRC Inspection Report 50-382/89-05)

-Page 2 B.

Response

1.

LP&L's Position Regarding the Violation LP&L agrees the evaluation performed for the submergence qualification

. of T95/35 splice assemblies is not entirely consistent with the cur-rent NRC policy and interpretation of 10CFR50.49 and NUREG-0588.

LP&L believes the evaluation is scientifically valid, and therefore that the analysis technically satisfies the requirements of 10CFR50.49.

Nonetheless, LP&L acknowledges the NRC basis for not-accepting the p4 evaluation.

o, 2.

Reason for the Violation LP&L performed a thorough and comprehensive evaluation of the qualifi-cation for submergence of T95/35 splice assemblies. The evaluation was summarized and submitted-to the NRC on June 21, 1969 via Letter W3F89-3066. The evaluation was based on LP&L's understanding of regulatory requirements, prior regulatory reviews and approvels, and scientific principles and anai, sis applied in engineering preblems.

l

.The evaluation provides a significant degree of confidence based on engineering principles that the subject splices would remain functional L

during and after. a Design Basis Accident, Regulatory compliance is ultimately based on engineering judgment and an understanding of regulatory requirements. The NRC however has determined the LP&L evaluation for sp} ices does not demonstrate compliance with 10CFR50.49. The reason for the violation is therefore a difference in engineering judgment and the interpretation of regulator,y requirements.

3.

LP&L Actions Taken and Results Achieved The equipment qualification files for T95/35 tape splice assemblies l

have been updated to incorporate the engineering evaluation described in section 2 and the Justification for Continued Operation (JCO) dated March 16,1989. This JC0 is an update to the February 23,1989 JC0 l

and reflects strictly editorial changes. The engineering evaluation l

provides a significant degree of confidence the T95/35 tape splice 1.

assemblies would remain operable during and following a Design Basis Accident.

l The March 16,1989 JC0 has been incorporated in the operators I

standing instructions. The JC0 identifies the equipment which has the splices subject to submergence and also identifies alternate or backup equipment or other sources which provide the equivalent information.

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. Attachment 1 Louisiana. Power & Light Response To USNRC Notice of. Violation dated July 11, 1989 (NRC Inspection Report 50-382/89-05)

Page'3 4.

Future Actions to be Taken LP&L believes this matter requires decisive corrective action which renders the T95/35 splice assemblies clearly in' compliance with 10CFR50.49, LP&L therefore will relocate the splices listed in Table-(1) above the containment building flood. level during refuel 4.

The relocation of the T95/35 splices will require the replacement of existing cables and the rerouting of conduit. The planning, engineer-ing' evaluation, procurement of material, and actual modification work cannot reasonably be accomplished during refuel 3.

Additionally, the JC0 and standing instructions will be covered in operator r**ining during refuel 3.

The training will assure operator cognizance.ad understanding on this subject.

The following actions will be'taken to avoid recurrence:

(a) The issue of the submerged splices will be reviewed with the appropriate engineering and maintenance personnel to assure an understanding of the subject of submergence qualification.

(b) LP&L conducted a thorough engineering evaluation to assure

. splices potentially subject to submergence were identified and evaluated. The results were documented in a JC0 dated February 23, 1989. The JC0 was in large part predicated on documented information. LP&L believes although the evaluation for the JC0 was thorough, this matter is sufficiently important to require additional confirmation of a different means. LP&L therefore will conduct a walk-down during refuel 3 to provide additional confirmation by visual inspection of the installed configurations.

5.

Compliance Date LP&L will be in full compliance by the end of refuel 4.

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