ML20206K645

Notice of Violation from Insp on 881017-27 & 881101-04. Violation Noted:Itt Barton,Model 763 & 764 Pressure Transmitters File Did Not Adequately Establish Qualification for Submergence During DBA & post-DBA Conditions

ML20206K645
Person / Time
Site:	Waterford
Issue date:	11/23/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206K640	List: IR 05000382/1988027 ML20206K636 ML20206K645
References
50-382-88-27, NUDOCS 8811290476
Download: ML20206K645 (2)

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APPENDIX A NOTICE OF VIOLATION Louisiana Power & Light Company (LP&L) Docket: 50-382 Waterford Steam Electric Station, Unit 3 Operating License: NPF-38 ,

l During an NRC inspection of the environmental qualification (EQ) of equipment conducted on December 8-12, 1986, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2. Appendix C (1988), the violations are listed below:

A. 10 CFR 50.49(j) requires the licensee to document the performance specifications of qualified equipment under conditions existing during and following design basis accidents (DBA). l t

10 CFR 50.49(k) provides that licensees are not required to requalify  ;

electric equipment important to safety in accordance with $50.49 if the Comission has previously required qualification of that equipment in i acccrdance with NUREG-0588, "Interim Staff Position on Enviromental

Qualifict. tion of Safety-Related Electrical Equipment." Su d qualification was previously required by Comissior 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 lesel or protected against submergence. Where equipment could i be submerged it should be identified and demonstrated to be qualified by )

test for the duration required.  ;

l Contrary to the above, during the period of December 8-12, 1986, the ec,uipment qualification assessment file LPL-EQA-8.2A for ITT Barton,  ;

Model 763 and 764 pressure transmitters, did not adequately establish [

qualification because of failure to demonstrate qualification for submergence during DBA and post DBA conditions. l I

This is a Severity Level IV violation. (SupplementI)(382/8827-01) f B. Paragraph (j) of 10 CFR 50 49 requires that a record of qualification must i be maintained in an auditable form for the entire period during which the covered item is installed or is stored for future use. This permits verification that each item of electric equipment important to safety I covered by 650.49 is qualified for its applicatier and meets the specified perfomance requirements when subjeated to the conditions pred!cted to be present when it must perfom its safety function up to the end cf its ,

qualified life. F Paragraph (k) of 10 CFR 50.49 permits equipment to be qualified according to NUREG-0588. Such qualification was previously required by Comission [

Memorandum and Order CLI-80-21 on May 23, 1980.  ;

j G811290476 881123 PDR ADOCK O'5000382 O PDC

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! Section 5(1) of NUREG-0588 requires qualification documentation to verify that each type of electrical equipment is qualified for its application.

The basis for this qualification shall include an explanation that demonstrates all elements riecessary to establish the qualification of the complete

equipment.

Contrary to the above, as of December 12, 1986, information in EO j file EE00 8.1/8.1A for Rosemount 1153 Series A transmitters, qualified to i

NUREG-0588, did not adequately establish qualification because the equipment documentation failed to eddress the use of General Electric RTV silicone rubber sealant in lies of an electrical cable seal assembly configuration that was used during testing.

I Thi is a Severity Level *.V violation. (SupplementI)(382/8827-02) l Pursuant to the provisions of 10 CFR 2.201, Louisiona Power & Light Company is a hereby required to submit to this office, within 30 days of the date of the i letter transmitting this Notice, a written state 07nt or explanation in reply, including for each violation: (1) the reason for the violation if admitted, (2)thecorrectivestepswhichhavebeentakenandtheresultsachieved, i

(3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, i consideration will be given to extending the response time.

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1 j Dated at Arlington, Texas, this 2,3pj day of h vend % 1988 l

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