W3P89-3042, Suppls 890403 Response to Violations Noted in Insp Rept 50-382/89-02 Re Failure to Impose 10CFR21.Process for Dedicating Okonite Splice Matls Consists of Inclusion of Requirements on Purchase Orders & Performing QA

Suppls 890403 Response to Violations Noted in Insp Rept 50-382/89-02 Re Failure to Impose 10CFR21.Process for Dedicating Okonite Splice Matls Consists of Inclusion of Requirements on Purchase Orders & Performing QA

ML20247F251
Person / Time
Site:	Waterford
Issue date:	05/18/1989
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-89 W3P89-3042, NUDOCS 8905300033
Download: ML20247F251 (3)

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LOUISIANA / 317 BARONNESTREET P. O. BOX 60340 POWER & LIGHT NEW ORLEANS, LOUISlANA 70160 (504) 595-3100 NONdrNU May 18, 1989 W3P89-3042 A4.05 QA U.S. Nuclear Regulatory Commission 4

ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Violation 8902-02, Failure to Impose 10 CFR Part 21

References:

1.

LP&L Lette. No. W3F89-0070 dated 04/03/89 from B.F. Burski to U.S. Nuclear Regulatory Commission I.

2.

NRC Letter dated 04/18/89 from L.J. Callan to J.G. Dewease Gentlemen:

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Louisiana Power & Light hereby submits the following information on the subject violation as a suppleme. 1., ?.he response that was provided in Reference 1.

This information, which is contained in Attachment 1, addresses your request expressed in Reference 2 for a description of the process and technical bases used to support dedication of Okonite splice materials at Waterford 3.

If you have any questions concerning this response, please contact i

T.J. Gaudet at (504) 464-3325.

Very truly yours, R.F. Burski l

Manager Nuclear Safety 6 Regulatory Affairs l

RFB:TJG:ssf l

Attachments cc:

R.D. Martin (NRC Region IV), J.A Calvo (NRC-NRR), D.L. Wigginton (NRC-NRR), NRC Resident Inspectors Office, E.L. Blake, W.M. Stevenson 8905300033 890518 PDR ADOCK 05000382 O

PDC "AN EQUAL OPPORTUNITY EMPLOYER" 8.,

L k

1*,.

Attachment to W3P89-3042 L

Page 1 of 2 0,

ATTACHMENT 1 Dedication of Okonite Splice Materials for Use in Class 1E Applications at Waterford 3 History and Technical Bases The splice materials purchased.from The Okonite Company for use at Waterford 3 are Okonite T-95. Insulating Tape, Okonite No. 35 Jacketing Tape and Okonite Nuclear. Cement. These materials were first procured for Waterford 3 during construction in 1979 by EBASCO, the Architect Engineer, The EBASCO purchase order (P.O. No. WP3-2005, Specification LOU-1564.249G, Revision 2) invoked nuclear. qualifications and 10 CFR Part 21, both of which were accepted by Okonite. The order was subsequently filled on March 12, 1980 as documented on the Certificate of Conformance provided by Okonite (Okonite Order No. 01-81251).

During this time, reviews were performed to ensure suitability of the materials. Test Report No. NQRN 3 was developed by Okonite in June, 1980 to support qualification of the materials. Although the Report has been revised four times through October 1988, it still provides the necessary justification to envelope the Waterford 3 environment. Additional evidence that.the materials are suitable is provided in other qualification test reports contained in the Waterford 3 EQ files for Okonite tape splices.

On 04/07/89, LP&L performed a Quality Assurance Surveillance at Okonite (Report No. Q-3-A35.39.A13.89.1).

As evidenced by a review of Okonite's records during the Surveillance, the tapes and cement have not changed since 1979.

Dedication Process The process for dedicating Okonite splice materials consists of including various requirements on the purchase ordet's and performing a commercial grade Quality Assurance (QA) Surveillance of Okonite.

The purchase orders require Okonite to certify that there has been no changes in design, material manufacturing or interchangeability of the item (s) between 3/12/80 and the date of manufacture of the item (s) furnished on the present purchase order. The orders also invoke Okonite's QA Program and state that LP&L shall be notified of any defect or noncompliance found in the item (s) furnished. Lastly, the orders contain a list of standard requirements that are to be followed for the iter (s) furnished by Okonite.

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,o Attachment to W3P89-3042 Page 2 of 2 As stated above, LP&L recently performed a commercial grade QA Surveillance of Okonite. The purpose of this surveillance was to verify that proper controls are in effect for ensuring that Okonite's Certificate of Conformance is valid.

Items ordered from Okonite will continue to be purchased as commercial grade and dedicated in the above manner.

LP&L is confident that the above i

approach ensures the acceptability of such material, j

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