ML20069B488
| ML20069B488 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/26/1994 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-94-0073, W3F1-94-73, NUDOCS 9405270256 | |
| Download: ML20069B488 (6) | |
Text
e Entergy Opsrations,Inc.
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.ENTERGY
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R. F. Durski an w
%Aar 3My vc a et. :ro j W3F1-94-0073 A4.05 PR May 26, 1994 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES j
Docket No. 50-382 License No NPF-38 NRC Inspection Report 94-07 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in, the response to the violation identified in Appendix A of the subject Inspection Report.
Additionally, your inspection report identified a weakness regarding the failure to incorporate, or at least flag the existence of, service bulletins into applicable sections of the Cooper Industries Diesel Generator Technical Manual 457001225.
It should be noted that Entergy Operations, Inc. acknowledges this weakness and has taken steps to assure that it is thoroughly evaluated. Specifically, the Operational Experience Engineering (0EE) Department will consider the weakness when they assess the Vendor Equipment Technical Information Program later this year. Any reccmmendations identified by Ott will oe evaluatea and impiemented as appropriate.
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I NRC Inspection Report 94-07 Reply to Notice of Violation W3FI-94-0073 Page 2 May'26, 1994 If you~have any questions concerning this response,.please contact
- C.J. Thomas at (504) 739-6531, 1
Very truly yours.
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dV h
ski irector
- Nuclear Safety RFB/CJT/tjs Attachme3+
cc:
L.J. Callan, NRC Region IV D.L. Wigginton, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office (WADM526) l
ATTACHMENT TO W3F1-94-0073 PAGE 1 0F 4 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 94-07 VIOLATION N0. 9407-01 Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, states, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures appropriate to the circumstances.
Contrary to the above, on March 25, 1994, Mechanical Maintenance Procedure MM-003-041, "Five Year Emergency Diesel Generator Inspection," Revision 0, Section 8.9, was not appropriate to the circumstances, in that'it did not provide instructions to clean and lubricate the fuel injector pump mounting fasteners in accordance with specifications provided in Cooper Industries Diesel Generator Technical Manual 457001225.
RESPONSE
(1)
Reason for the Violation Entergy Operations, Inc. admits this violation and believes that the root cause was inappropriate action in that personnel responsible for the initiation and review of MM-003-041 failed to comply with Administrative Procedure MD-001-028, " Writer's Guide for Maintenance Department Procedures." MD-001-028 requires individuals who initiate and review new plant procedures to make every effort to ensure that the procedures are technically accurate and complete.
Relevant information must be thoroughly reviewed to produce and maintain consistently high quality, dependable procedures.
Entergy Operations, Inc. believes that this event may have been prevented had a thorough review of Cooper Industries Diesel Generator Technical Manual 457001225 been performed.
It should be noted that Technical Manual 457001225 and Standard S0-123 are listed in the reference section of MM-003-041.
l ATTACHMENT TO l
W3F1-94-0073 PAGE'2 0F 4 Cooper Industries Diesel Generator Technical Manual _
j 457001225 includes a copy of Cooper Service Bulletin 710. This service t-bulletin directs the reader to Standard SD-123 which is also included in the technical manual.
Collectively, these specifications require that fuel injection pump mounting fasteners be cleaned and lubricated with petroleum type lubricants (Lubrip1 M e 630 series is recommended).
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and that the running torque of fasteners with nylon or deformed l
thread locking features be added to the specified torque.
Cooper Service Bulletin 710 and others were receiv'e.d by the diesel.
l generator system engineer on April 2, 1991. The engine.er reviewed l
and processed the service bulletins in accordance sith' Administrative Procedure UNT-004-035,' Revision 2, " Control of Vendor Information."
As part'of that review, the engineer noted that Mechanical Maintenance Procedure MM-003-015, "18 Month Emergency Diesel Engine i
Inspection," was impacted by the service bulletins and that Mechanical Maintenance (MM). should review the procedure for updates.
Additionally, the enginaer requested that the service bulletins be.
i placed in Section 19A cf Technical Manual 457001225. Section 19A had l
been designated as the section to store Cooper serv!ce bulletins for future reference.
1 At the time Cooper Service Bulletin 710 was received, MM-003-015 was the only MM procedure to provide instructions for inspecting the diesel engine. - Additionally, the procedure did not include instructions for removing and installing fuel injection pnos.
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Consequently, when MM reviewed the procedure against C' Service Bulletin 710 they did not update the_ procedure to ine the l
revised torquing instructions for the fuel injection nting fasteners.
j On February 6, 1992, and August 29, 1992, MM implemented two new diesel engine inspection procedures -- MM-003-042, " Ten Year Emergency Diesel Engine Inspection," and MM-003-041, "Five Year Emergency Diesel Engine Inspection." Both procedures incorporated instructions for removing, calibrating and installing fuel injection pumps that were consistent with the applicable section of Technical Manual 457001225. However, both procedures failed to provide instructions to clean and lubricate the fuel injection pump mounting fasteners in accordance with specifications provided by Cooper Service Bulletin 710 and Standard SD-123.
Entergy Operations, Inc.
believes that had MM personnel thoroughly reviewed Technical Manual 457001225 against MM-003-042 and HM-003-041 this event may have been prevented.
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ATTACHMENT TO 4
W3F1-94-0073 PAGE 3 0F 4 (2)
Corrective Steos That Have Been Taken and the Results Achieved The diesel system engineer issued Condition Report CR-94-265 on the same day the NRC communicated their concerns over whether the diesel generators cou?d be considered operable with questionable prestress on the fuel inaection pump mounting fasteners. Additionally, the engineer contactea Cooper Industries for an evaluation. Cooper i
Industries stated that the installation was acceptable, as long as i
the fasteners were not cleaned (which they were not), because the residual lubricant and fuel oil would have ensured acceptable i
prestress. Also, the. torque specified by the applicable drawing in Technical Manual 457001225 took into account the additional torque needed to compensate for the locking feature running torque. This position is supported by the fact that there have been no failures of fuel injection pump mounting fasteners on the diesel generators.
The fuel...jection pump mounting fasteners on Emergency Diesel Generator 'A' disassembled during the Refuel 6 Outage were reassembled using Lubriplate 630-AA.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations Four corrective steps will be taken to avoid further violations:
1.
The MM personnel involved with the initiation and technical review of MM-003-041 and MM-003-042 will be counseled per the Improving Human Performance Program.
2.
MM-003-041 and MM-003-042 will be revised to provide instructions to clean and lubricate the fuel injection pump mounting fasteners in accordance with the specifications provided in Technical Manual 457001225.
3.
Cooper Industries Drawing KSV-18-4, " Fuel Injection Pump," will be annotated to require that fuel injection pump mounting fasteners be lubricated with Lubriplate 630-AA or equivalent.
4.
This event will be discussed with Maintenance and Engineering Support Personnel as part of the Continuing Training Program.
-ATTACHMENT T0.
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~PAGE!4 0F14
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.(4).
Date When Full Como1iance Will Be Achieved-Corrective. steps 1 through 3 will::be~: completed by July' 29, 1994.
Corrective step 4 will.be completed by December 30,-1994.
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