A09661, Submits Response to Review of RI-91-A-0145 Issues Concerning Plant Activities
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August 16, 1.191 Docket No. 50-336 A09661 RE: Employee Concerns Mr. Charles V. Behl, Director Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PennsylvLnia 19406 Dear Mr. Behlt Hillstone Nuclear Power Station, Unit No. 2 RI-91-A-0145 Ve have completed our review of identified issues concerning activities at Hillstone Station. As requested in your transmittal letter, our response does not contain any personal privacy, proprietary, or safeguards information.
The material contained in this response may be released to the public and placed in the NLC Public Document Roem at your discretion.
The NRC letter and our response have received controlled and limited distribution on a "need to know" basis during the preparation of this response.
ISSUE:
On June 12, 1991, preventive maintenance action was authorized on an environmentally qualified component without the proper quality controls.
A Non-0A work order (two page AVO) was used to perform vork on the motor operator for the "B" Shutdown Cooling Heat Exchanger to "C" HPSI Pump Suction Valve (2-SI-662) in violation of Administrative Control Procedure ACP-0A-2.16.
Specifically, the inspection governed by 2701J-7, 2701J-10 and 270lJ-ll may require the addition of grease or other consumables. The addition of grease or other consumables, if not properly controlled as vould be done using OA work orders, disqualifies the equipment qualification.
Please discuss the validity ci the above assertion.
Vere the EE0 boundaries affected by thi-preventive maintenance activity?
If deficiencies are found in work control and/or procedures, please notify us of the corrective actions you have taken to prevent recurrence.
Please provide us with an assessment of the significance with regard to safety of any identified deficiencies.
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I 9110310049 911011 PDR ADOCK 05000336 P
1 Mr. Chnrlos V. B:hl, Directer U. S. Nuclear Regulatory-Consission A09661/Page-2 August 16, 1991 kgyponse The Automated Vork Order-(AVO) in question was H2-90-06370.
The AVO vas-issued as a non-0A AVO in accordance with the clarification to the Environmental Qualification Program provided via a memo from the Generation
-Engineering Department relating to preventive maintenance on EE0 components.
Based on the concerns of the Job Supervisor-and the Quality Services Department (OSD) regarding vork on EE0 components without a OA work order, the work was not performed.
Since no work vas performed, no EE0 boundarles were affected and the-assertion stated in the above issue is not valid.
Subsequent to this job, NNECO has re-evalue "1 its guidance on the conduct of EE0 Maintenance and has elected to withdrav the guidance memo referenced above.
Therefore, all maintenance performed on EE0 equipment vill be performed on OA cc three-page vork orders.
The OA Lubrications Program is currently being incorporated into applicable administrative procedures for Hillstone Station. Vben the revisions to these procedurcs have been completed ar.d approved, NNEGO vill reviev the Maintenance Forms associated vith the Praventive Maintenance Program and revise these forms as necessary.
'After-our reviev and evaluation, ve find that this issue did not present any-indication of a compromise of nuclear safety, Ve vere-avare of this concern as a result of the Job Supervisor bringing the issue to management's attentior..
Actions vere taken to address. the issue and maintain appropriate control over EE0 boundaries. Ve recognize the need to I
strive for a higher level of performance while performing EEQ Maintenance i
and we are aggressively vorking tover.ds this objective. Ve appreciate the opportunity to respond and explain the basis of our actions. Please contact my staff if there are any 'further questions on any of these matters.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR:
E. J. Hroczka Senior Vice President t
BY:
V. D. Romberg i
Vice President cc:
V.
J. Raymond, Senior Resident Inspector, Millstone Unit Nos.
1, 2, and 3 E.
C. Venzinger, Chief, Projects Branch No.
4, Division of Reactor I
Projects E. H. Kelly, Chief, Reactor Projects Section 4A
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