ML20091D147
| ML20091D147 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/30/1992 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | Martin R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20091D133 | List: |
| References | |
| W3F1-92-0134, W3F1-92-134, NUDOCS 9204080108 | |
| Download: ML20091D147 (3) | |
Text
p a ' 9 "4 f/p
_sg"ENTERGY t r. uurm W3 F1 0131 M. 05 QA March 30, 1992 U.S. Nuclear llegulatory Commission ATTN Documelit Control Desh
-.,,,..;._.;)q' Washington, D.C. 20555 s7' p.
Subject :
Waterford 3 SES l
i Dochet No. 50-382 b
"."- l License No. NPF-38 NRC luspection Heport 91-31 gggioNIV Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, l'ic, hereby submits in Attaclunent I the response to the violation identitled fu Appendix A of the subject inspection Report, f
if you have any questions concerning this responso, pleaso contact T.W. Gates at (501) 739-6097.
Very truly yours, h.
1' n4 H FB /TWG /ssf Attachment _
m.
[R.D. Martin, NRC Region IV,
ec:
D.L. Wigginton,'NRC-NRR R.H. McGohee N.S. Reynolds NRC Resident inspectors Office l
h -O 7b' 9,704080108 920402 PDR ADOCK.05000382 Q
Attachinout to W31*l-92-0131 Page 1 of 2 4
ATTACllMENT 1, ENT,l'IlGY OPEllATIONS, INC. IIESPONSE TO Tile VIOI.ATION IDENTIFIED IN APPICNDIX A OF INSPECTIONllEl'OltT 91-31 VIOLATION No. 91-031-01
-Technical Specification 0.8.1.a requires, in part, that written procedures shall be maintained covering the activities recommended in Appendix A of flegulatory Guido 1.33, Hovision 2, February 1978.
Contrary to the above, on January 2,1992, during stroho testing of tho actuator for essential chilled water flow control valve CilW-129AB, Section 8.10 of Maintenanco Proceduro MM-007-027 Revision 0, Change 2. "flydramotors -
Models Nil 92 and A1192 Removal, Maintenance, Testing, and Installation," was found to bo technically incorrect. Section 8,10 had been changed onco before on December 20, 1990, because it could not be performed properly as written, due to inadequato technical reviews.
RESPONSE
(1) lleason for tho Violation Entergy Operations, Inc. admits this violation and believes that the root cause la personnel error in that the technical reviewer for Maintenanco Procedure MM-007-027, Revision 0, Change 2, demonstrated inadequato attention to detail when perfortr'ng the review. The technical review of Change 2 was performed by an experienced technician trained in hydramotora who should have been able to identify the problem in Section 8.10. in this particular caso, the technician's experience with the subject material, combined with inattention to detail, may have contributed to the inadequato review; because of his familiarity with the process in question, he may have understood the steps even though there was information missing and the sequence was not clear.
i (2)
Correctivo Steps That flavo Heen Taken and the Hesults Achieved Quality Notico (QN)92-002 was issued to document the problem with MM-007-027 and track correctivo action.
MM-007-027,1 Revision 0, Change 3 was approved on February 6,1992..
L Change 3 is intended to be an interim solution until a completo revision of the procedure can be issued. To that end,. the General Manager - Plant i.
Operations has imposed limits on the use of the procedure untilit nan be revised, approving it "for 'immediato need' use only; first line supervisor to be present."
The Mechanical Maintenanco Superintendent discussed this event with
- mechanical maintenanco personnel as part of. the department's duty week training program. In addition to covering the technical error in MM-007-027, the discussion emphasized the importance of providing feedback by docamenting problems found in procedures or instructions.
1
~
Attaciunent to W3F1-92-0131 page 2 of 2 e,
In addition, as speelfled in the QN 92-002, the Maintenaneo Superintendent
-discussed this event with Mechanical Maintenanco personnel at a general shop inoeting.- The importance of attention to detail was emphaufred, partleularly in the context of the technical review process.
Fliudly, although the technical review process is, for the inout part, -
considered to be dependable and tvilablo, review ludicates that improvement la possible. Generally speaking, proceduro revisions and changes are written to correct speelfic deficiencies noted during use of the procedurel in such cases, it would be reasonable to include the individual that noted the discropuncy in the procedure review process. 11y capitalizing on the knowledge of personnel that are intimately faunillar with the discrepancy being addressed, the review process la strengthened, especial _ly when the process in question is highly complex un it was in this examplo.
tendent has directed that personnel To that oud, the Maintenaneo i n:
identifying a deficiency that resula in a revision or a chango to a procedure bo included-to the extent posulblo-in the review process for the updated proceduro. Again, this should strengthen the proceduro review process by taking advantage of speelfic knowledge or insight that may be available.
_ (3)
Correctivo Steps Whleh Will Ito Taken to Avoid Further Violations First, a revision to Maintenance proceduro MM-007-027, "llydramotors -
Models N1192 and A1102 Itemoval, Maintenaneo, Testing, and installation,"
will be issued to incorperate the various changes and make the procedure onBler to uso.
Secondly, although a number of sessions have ht on held _with Malutenanco Department personnel to disetius this event, the ludividual who perforcied the technical review of Change 2 tc MD-007-027 will be formally cotuneeled to further highlight the importance of attention to dotall in general and to
'the technical review process in particular.
(4)
Date When Full Compliance Will llo Achioved The proceduro revisions will be complete by June 10, 1992.
, _......