ML20058D633
| ML20058D633 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/25/1990 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS905903, NUDOCS 9011060186 | |
| Download: ML20058D633 (3) | |
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COOPER NucLEA9 5T A16oN Nebraska Public Power District
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CNSS905903 October 25, 1990 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555
Subject:
NPPD Response to Inspection Report 50 298/90 29 Centlemen:
turing an NRC inspection conducted July 16, 1990, through September 3, 1990, a violation was issued for failure to follow procedure.
Following is the statement of violation and our response thereto in accordance with 10 CFR 2,201.
Statement of Violation Failure to Follow Procedure 10 CFR 50, Appendix B, Critorion V requires that activities affecting quality shall be accomplished in accordance with instructions, procedures, or drawings, Maintenance Proceduro (MP) 7.,0.1, " Work Item Tracking Corrective Maintenance," Revision 13, dated November 11, 1989, specifies in Step 4.9.2 that maintenance affecting safety related equipment will be performed in accordance with documented instructions.
MP 7.2.49, "ASCO Solenoid Valve Maintenance " Revision-3, dated January 25, 1990, requires in Step 7.5 that a special instruction sheet with signature points for assigned Quality Control (QC) be provided.
Contrary to the above, two instances were identified, Maintenance Work Requests 89 4566 and 90 0295, where personnel were not provided special instruction sheets with appropriate assigned QC requirements.
This is a Severity Level IV violation, (Supplement.1) (298/9029 01),
Renson for Violation Although the two referenced Maintenance Work Requests (MVR's) did not
-containspecir.1in)s,tzuctionsheetsasrequiredbyStep7,5ofMP7.2.49, "ASCO Solenoid Val o.Waintenance", the scope of the work performed did not warrant the use'of special. instructions as detailed below.
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U S..Nuclocr R gulotary C:mmissicn Octcber 25, 1990 page 2 During the QC review of the work package as required by the prerequisites section of Mp 7.2.49 for MWR 89 4566, the solenoid valve was identified as necding replacement.
This fact is documented by an N/A (not applicable) in Step 7.4 of the procedure. This indicated that a rebuild kit was not to be used. The intent of Step 7.5 is to perform a QC review of the ASCO repair kit's bulletin and assign QC hold and witness steps in the form of special instructions.
Since the valve was to be replaced, a repair kit was not to
.be used and Step 7.5 also became not applicable.
Therefore, the requirement. to provido a special instruction sheet to the craft did not exist. However, the QC Inspector who reviewed Step 7.5 exercised poor judgereent and signed this step instead of marking it N/A. As such, from an overview of documentation associated with MWR 89 4566, it would appear that a special instruction sheet was required.
The second MVR (90 0295) used in the basis for the alleged violation did use an.ASCO repair kit to rebuild the solenoid valve. This MWR was reviewed per the requirements of Steps 3.1.2, 3.1.6, and 7.5 of Mp 7.2.49.
During the QC review of the ASCO repair kit's bulletin, it was determined that the bulletin did not contain any specific criteria, e.g. torque values, for which QC or special instructions should be applied. As such, special instructions were not generated for this MWR.
The failure of the QC Inspector.to document that no QC or =pecial instructions were required was a poor judgement.
i Corrective'Steos and the Results Achieved
. Interim actions that have been taken include a review of.the potential violation with the applicable Maintenance Department persont el and the issuance of an Inter District letter from the Division Manager of Nuclear
. Operations.
The letter was to all CNS craft personnel and re emphasized
-the necessity for strict cotopliance with approved station procedures, t
Corrective Steos Which W111 be Taken to Avoid Further Violations
.A thorough review of Mp 7.2.49 has resulted in a procedure change being i
E initiated which will provide better guidance for the craft and'should t
preclude' violations of this nature in the future.
The revised procedure will-include-a separate attachment for-recording special. instructions and will also require the craftsman to record the'ASCO bulletin number in the procedore.
Changes have also been made to clarify the Q.C. review requirements for l
this procedure.
It is expected that this procedure revision will be approved and implemented by January 1, 1991.
l Date'When Full Como11ance Will Be Achieved Full compliance will be achieved with the approval of Revision.4 to Mp.7.2.49."ASCG Solenoid Valve Maintenance". This revision is expected' to be approved by January 1,1991'.-
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U.S. Nuc10:r R gGlct:ry C mmicsicn Oct:bar 25, 1990 Page 3 Should you have any questions concerning this matter. please contact my office.
Sincerely.
o 'C od revors Senior Staff Advisor CAT:sg:Ju cc:
U. S. Nuc1 car Regulatory Commission Region Office Region IV NRC Resident Inspector Cooper Nuclear Station
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