ML20244B704
| ML20244B704 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/07/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8906130227 | |
| Download: ML20244B704 (2) | |
See also: IR 05000382/1989002
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JUN f(989,
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In Reply Refer To:
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Docket: 50-382/89-02
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Louisiana Power'& Light Company
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'. ATTN:
J.'G. Dewease,' Senior Vice President-._
Nuclear; Operations
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317 Baronne Street.
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New Orleans' Louisiana- 70160-
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Gentlemen:t
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Thank you for your ; letters, dated April 3'and May 18,'1989? in resporse to-
- our letters,; dated March 2 and April 18,;1989. . We understand based ori
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discussions-with your Mr. D. V. Gallodorol(during_a telephoneLeon'versation).
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on June 1,1989..that the vendor, 0konite..will be placed in your qualified
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supplier list and subjected to on" site requalification audits at least every
3 years. We"will review the implementation of your corrective action during'
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a future inspection'to determine that full compliance has been achieved and.
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will be maintained.
Sincerely,
D&a
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James L. Milhoan, Director.
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Division of Reactor Projects
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Louisiana Power & Light Company
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ATTN: 'R. P. Barkhurst, Vice President
' Nuclear Operations l
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P.O. Box B
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Killona, Louisiana' 70066
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Louisiana Power & Light Company
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ATTN:
J. R. McGaha, Jr., Plant Manager'
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P.O. Box B.
Killona,-Louisiana '70066
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Louisiana Power & Light Company
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Louisiana Power.,& Light-Company.
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ATTN:
R. F. Burski, Manager, Nuclear
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Safety & Regulatory Affairs.
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317 Baronne Street-
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P.O. Box 60340
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New Orleans, Louisiana. 70160
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' Louisiana Power & Light: Company.
ATTN: >L; W.- Laughlin, Site '
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Licensing Support Supervisor
P.O. Box B:
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Killona, Louisiana, 7.0066
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Louisiana Power & Light' Company
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ATTN:
G.-M. Davis, Manageri Events
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Analysis Reporting &~ Response
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-P.O. Box B~
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Killona, Louisiana J70066-
Middle South Services
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ATTN: Mr. R.?T. Lally
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P.O. Box 61000
. New Orleansi Louisiana 70161
Louisiana Radiation Control Program Director'
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bec to'DMB.'(IE01)
bec distrib. by RIV:
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R,. D. Martin, RA
SectfonChief-(DRP/A)
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ProjectEngineer(DRP/A)
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.Lisa Shea, RM/ALF
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D.;Wigginton, NRR Project Manager (MS:
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1. Barnes
B. McNeill
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MAY I 91989
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LOUISIANA / 3i7sAnoNNeSrater e
(504)595 3100
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NEW ORLEANS, LOUISlANA 70160
POWER & LIGHT
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May 18, 1989
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U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
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Washington, D.C. 20555
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Subject: Waterford 3 SES
Docket No. 50-382
License No. NPF-38
Violation 8902-02, Failure to Impose 10 CFR Part 21
References:
1.
LP6L Letter No. W3P89-0070 dated 04/03/89 from R.F. Burski
to U.S. Nuclear Regulatory Commission
2.
NRC Letter dated 04/18/89 from L.J. Callan to J.G. Dewease
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Gentlemen:
Louisiana Power & Light hereby submits the following information on the
subject violation as a supplement to the response that was provided in
Reference 1.
This information, which is contained in Attachment 1,
addresses your request expressed in Reference 2 for a description of the
process and technical bases used to support dedication of Okonite splice
materials at Waterford 3.
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If you have any questions concerning this response, please contact
T.J. Gaudet at (504) 464-3325.
Very truly yours,
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R.F. Burski
Manager
Nuclear Safety & Regulatory Affails
RFB:TJG:ssf
Attachments
cc:
R.D. Martin (NRC Region IV), J. A Calvo (NRC-NRR), D.L. Wigginton
(NRC-NRR), NRC Resident Inspectors Office, E.L. Blake, W.H. Stevenson
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Attachmtnt to
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Page 1 of 2.
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ATTACHMENT 1
Dedication of Okonite Splice Materials for Use
in Class 1E Applications at Waterford 3
Historv_ and Technical Bases
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The ' splice materials purchased 'from- The Okonite Company for use' at
- Waterford 3 are Okonite T-95 Insulating Tape,:0konite No. 35 Jacketing Tape
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and Okonite Nuclear Cement. These materials were first procured-for
Waterford' 3 during construction in' 1979 by EBASCO, the Architect: Engineer.
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The EBASCO purchase order (P.O. No. WP3-2005, Specification LOU-1564.249G,
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Revision 2). invoked' nuclear qualifications and 10 CFR Partl21, both of
which were accepted by Okonite.. The order was subsequently filled on. March,
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12, 1980'as documented on the certificate of Conformance provided by
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Okonite (Okonite Order No. 01-81251).
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materials. Test Report No. NQRN 3 was developed by Okonite in June, 1980 _
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During this time, reviews were performed to ensure suitability of the
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to support qualification of the materials. Although.the Report has been.
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revised four times through October.1988, it still. provides the necessary
justification to envelope the Waterford 3 environment. Additional evidence
that the materials are suitable is provided in other qualification test
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reports contained in the Waterford-3 EQ files for Okonite tape splices,
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On 04/07/89, LP&L performed a Quality Assurance ' Surveillance at Okonite '
(Report No. Q-3-A35.39.A13.89.1).
As evidenced by a review of Okonite's
records during the Surveillance, the tapes and cement have not changed
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since 1979.
Dedication Process
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The process for dedicating Okonite splice materials consists of including
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various requirements on-the purchase orders and performing a commercial-
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grade Quality Assurance (QA) Surveillance of Okonite.
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The purchase orders require Okonite to certify that the..a has been no
changes in design, material manufacturing or'interchangeability of_the
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item (s) between'3/12/80 and the date of manufacture of the item (s)
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furnished on the present purchase order. -The orders also invoke Okonite's
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QA Program and state that .LP&L shall be notified of any defect or
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noncompliance found in the item (s) furnished. Lastly, the orders contain a
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list of standard requirements that are to be followed for the item (s)
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. furnished by Okonite.
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Attachment to
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As stated above,'LP&L recently performed a commercial grade QA Surveillance
of Okonite. The purpose.of this surveillance was to verify that. proper
controls are in effect for~ ensuring that Okonite's Certificate of
Conformance is valid.
-Items ordered from Okonite will continue to-be, purchased as commercial
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Lgrade and dedicated in the above manner. LP&L is confident'that the above
approach ensures the acceptability.'of such material.
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LO UISI AN A / 317 BARONNE STREET
P. O. BOX 60340
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POWE A & LIGHT
NEW ORLEANS. LOUISlANA 70160 *
(504)595 3100
N3fsEsC
April 3,1989
A4.05
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U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
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Washington, D.C. 20555
Ltbject: Waterford 3 SES
Docket No. 50-382
License No. NPF-38
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NRC Inspection Report 89-02
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Gentlemen:
In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby
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submits in Attachment 1 the responses to the Violations identified in
Appendix A of the subject Inspection Report.
If you have any questions concerning these responses, please contact
T.J. Gaudet at (504) 464-3325.
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Very truly yours,
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R.F. Burski
Manager
Nuclear Safety & Regulatory Affairs
RFB:TJG ssf
Attachment
cc:
R.D. Martin, NRC Region IV
J.A. Calvo, NRC-NRR
D.L. Wigginton, NRC-NRR
NRC Resident Inspectors Office
E.L. Blake
W.H. Stevenson
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N541567C
"AN EQUAL OPPORTUNITY EMPLOYER"
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Attcchment.tol
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Paga 1 of 9
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ATTACIDfENT- 1
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LP&L Responses to the Violations Identified in Appendix A
of Inspection Report 89-02
VIOLATION NO. 8902-01
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Failure to Adhere to Documented Drawings-
Criterion V of. Appendix B to,10 CFR Part 50 and the licensee's approved
quality assurance program description require that' activities affecting
quality.shall be' prescribed by and accomplished in accordance with
documented instructions, procedures, or drawings, of a type appropriate to-
the circumstances.
Design Drawing 1564-1539, R26 for pressurizer surge line Sample Isolation
Valve.2SL-V25D51 specifies that the material for Item 11;(valve gland' studs)'
shall be ASME SA-193 Grade'B6 or~B7.?
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Contrary. to the above, a valve gland stud for Valve 2SL-V2505 had been
incorrectly replaced with ASMS SA-193 Grade'B8 material.
'This is'a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation
The root cause of this violation is personnel error.' In accordance
with UNT-5-015, " Work Authorization Preparation and Implementation,"
a work authorization'(WA 01018888) was prepared to install * packing
gland fastener material on the pressurizer surge line sample isolation
valve. The existing material ~was badly corroded and needed-
replacement. Section 5.7.5 of UNT-5-015 states that all replacement'
parts and materials installed in plant systems shall be
"like-for-like" replacements or' engineering approved equivalents.. lit
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also states that the parts,shall be obtained from the' warehouse'and'be
traceable-to a Requisition on Strcas(R08) number. ' In an tttempt to
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comply, with Section 5.7.5 of UNT 5-015,- Design Drawing 1564-1539, the
field control drawing for this valve, was obtained. . When viewing this
drawing, which was a poor quality reproduced copy made from an
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aperture . card;(micro-film), the responsible individual misinterpreted
the material designation to be SA 193 B8 as opposed to the specified
SA 193 B6. ' Consequently, the incorrect material (SA 193 B8 material)
was entered on WA 01018888 and the ROS ticket as a "like-for-like"
replacement. On 4/13/88, the incorrect material was then installed.
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.W3P89-0070:
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(2)- Corrective Steps That Have Been Taken'And The Results Achieved.
On 2/9/89, Maintenance generated a quality. notice-(QN QA-89-037)to'-
formally address'and resolve the concern. .On 1/12/89,;a non-
conformance Condition # Identification'(CI 260888) was issued to
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disposition:the incorrectly installed material.'~ Calculations.
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performed under CI 260888'and the application.of the SA 193 B8=
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material as a gland fastener supported the operability of,the pressure.
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boundary.- 'Accordingly, the:: shift supervisor accepted 'the-use~of the
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material,
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Since Engineering has: recommended;that the replacement materiali.
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conform to4the design' drawing, the material will be replaced during'
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the next refueling' outage with.the correct.SA'193 B6 material under;~
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CI 260888'and the associated work authorization'(WA 01033177). ' Note:
this action is separate:from the violation response _and;-therefore,
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'does-not need to be completed to be in. full compliance.
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The individuals, responsible for the violation were counselled'on'the
importance of obtaining clear and legible drawings prior to' continuing
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work when the; field control' drawing is of poor quality.
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.(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
To prevent recurrence, Maintenance Procedure MD-1-014 " Conduct'of-
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Maintenance," will be revised to address'the use of unclear drawings.,
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(4) Date When Full Compliance Will Be Achieved
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Procedure MD-01-014 will be revised by June 1, 1989,Lat which time
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LP&L will be in full compliance.
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VIOLATION NO. 8902-02-
Failure to Impose 10 CFR Part 21
Section 21.31.of 10 CFR Part 21 requires the licensee to specify on each
procurement document for a basic component that the provisions of.-10;CFR
-Part 21 apply..
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Contrary to the above, since~1985, the licensee hasinot specified on,
procurement documents for basic components placed with the'.Okonite
Company, thattthe provisions of 10 CFR Part 21 were applicable.-
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This'is a Severity Level IV violation..
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RESPONSE-
(1) Reason For The Violation
The root'cause of this violation is' programmatic.in that the. planti
procedure that was used for processing procurement documents . lacked
adequate instructions for ensuring nuclear requirements were not' invoked
when 10CFR part 21 requirements were not imposed.
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Plant' Administrative Procedure UNT-8-001, '.' Processing of Procurement
Documents," described the methods used by plant personnel-fromL1979-1987
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to initiate procurement documents for plant station modifications', spare
and replacement components,-subcomponents, parts, material, tools and
services required to support plant operations. Through the use.of this
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procedure, plant personnel, from 1982-1987, requested purchase orders to
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be placed with The Okonite Company for tape and cement which were to be
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used as basic components at Waterford 3.
'(NOTE: A basic component, as
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defined in 10CTR21.3 means a plant' structure, system,. component or part
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thereof necessary to assure (i) the integrity of the reactor coolant
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pressure boundary, (ii) the capability to-shut down the reactor and
maintain it in a safe shutdown condition, or (iii) the capability to
prevent or mitigate the consequences ~of accidents'which could result in
. potential offsite. exposures comparable to those referred to in 10CFR part
100). Since the procedure lacked adequate instructions for ensuring
nuclear requirements were not invoked when 10CFR part-21 requirements
were not imposed, sis'Okonite orders (Purchase Order Numbers 10450,
12403, 14107, 65603, 85303 and 97037) were placed imposing certification
to Qualification Test-Reports without imposing J R part 21.-
(2) Steps That Have Been Taken And The Results Achieved
In November 1987, this procedural problem was, corrected.- On' November 9,
1987, UNT-8-001 was replaced with Nuclear Operations Engineering
Procedure NOEP-004', "The Engineering Procurement Process". Step 5.1.3.2
.of NOEP-004 requires the, procurement engineer.to draft procurement-
documents in accordance with Nuclear Operations Engineering Instruction
NOEI-152, " Safety-Related Procurement Methods &' Standard Technical &
QA Statements." N0EI-152 (Revision 1 dated 9/8/87) provides-guidelines
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and methods for Nuclear operations Engineering personnel to use when;
specifying technical and quality requirements on' safety-related
procurement cscuments.
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' Section 5.2 of NOEI-152 describes the method used to obtain :
safety-related structures, systems, components,. parts.or services that
are' subject to unique design or specification requirements or:that'
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cannot be procured to the manufacturer's, catalog or industry, standards
-alone. This method applies to components ordered from The Okonite. ..
Company., Step. S'.2.3: specifically states .that procurement specifications
shall invoke 10CFR part 21 on the supplier. .To date, however, The'-
Okonit'e Company still refuses. co accept :10CFR part 21.. . Consequently,-
when such action from a supplier' occurs, the basic component (s) being
purchased will; be identified in the ~ order as- commercial grade lin
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accordance with Step 5'5.11.of NOEI-152. -Items ordered from the Okonitet
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Company have been since November, 1987 and.will continue to be' purchased-
- as commercial: grade..
.(3) Corrective Steps Which Will Be Taken To Avoid Further Violations.-'
NOEI-152, as described above provides adequate instruction.to prevent
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recurrence of a similar type of violation in the future.-
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(4) Dkte When Full Compliance Will Be Achieved
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I.P&I, is currently in full compliance,
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VIOLATION NO.~8902-03
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yailure to [ollow procedures
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Criterion V of Appendix B to.10 CFR Part 50 and the-licensee's approved
quality assurance program des ~cription require that activities affecting;
quality.'shall be prescribed by and accomplished'in accordance with documented.
instructions, procedures, or drawings,' of a type appropriate L to. the
circumstances,
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Contrary to the above, the licensee failed to implement procedures as shown'in-
the following examples:-
contrary to Section 5.7.7 in Procedure NOEI-152, Revihion 1, the licensee
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failed to identify shelf life' requirements in Purchase Order WP016013 for-
Buna-N parts.
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Contrary to Section 5.4.3.2 in Procedure UNT-7.-021, Revision :1, the-
licensee failed to. update at least.five ~rendor technical manuals =to
incorporate data to support replacement AGASTAT relays installed during
Modification SM 1701.
contrary to Section 5.2.1.4'in Procedure UNT-8-001, the-licensee' failed
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to properly dedicate commercial grade replacement electrical resistors
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which had been procured on Purchase Order W117408.
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This is a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation
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The root cause for examples one and three Mited in the violation is
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personnel error.
(Note: LP&L denies that example two is a violation of
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failing to follow procedures.
A' discussion'of the basis for denial is
provided on pages 8 and 9.)
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Example 1-
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Nuclear Operations Engineering Instruction NOEI-152, " Safety-Related
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Procurement Methods & Standard Technical & QA Statements," provides
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guidelines and methods for specific technical and quality requirements
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on safety-related procurement documents and for dedicating commercial
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grade items for safety-related use during the procurement process. Step
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5.7.7 of N0EI-152 states that "Other requirements may be.noted as part of
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the Procurement Documents to identify the neer for... shelf, life..."
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Using this guidance provided in NCEI-152, a p;ocurement engineer
generated a purchase order (P.O. WP016013):to order seal kits for ASCO
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solenoid valves on the diesel generator. The Kits contained Buna-N'
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(Butadine/ Acrylonitrile) items which have n-limited shelf life.
(Note: Limited shelf life items are those that have a shelf life of less
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than 40 years). Based on this information and in accordance with Step'
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5.7.7 of NOEI-152, shelf life data for the Buna-N items should have been
but was not included,on the purchase order.
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Example 3~
. Plant Administrative Procedure UNT-7-021'(Revision 4),," Spare PartsL .
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Equivalency Evaluation Report (SPEER)/ Parts Quality Level Determination
(PQD),"".provided the methods'used to process either.a SPEER or a
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PQD. .A SPEER would be used to determine whether afspare or. replacement _'
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.part, not;of. original design or having a technical difference, is2
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acceptable for use in the original' application.,LA PQD_would be used to'
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determine.the quality requirements;of a part 9 hen the quality level.is
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unknown.and to provide for_the'. dedication ofLsuch' commercial; grade.: items
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!in-'a safety-related application'after the quality, level has been~
determined.' Plant Administrative Procedure UNT-8-001, " Processing of
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Procurement Documents," described the methods:used by plant personnel'
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from 1979-1987 to initiate procurement- documents for plant' station
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modifications,? spare and replacement components,'subcomponents, parts,
material,' tools and services required to . support plant operations.
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~Using the. guidance provided in UNT-7-021 andLUNT-8-001, a purchase order ~
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(P.O. W-11794-K) was generated to. order ~ thirty. replacement electrical-
resistors. -Step 5.1.10-of UNT-7-021' stated that a PQD shall not be:
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required for the use of like for like commodity type items for,non-code-
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application or where the code or standard does not specify code material.
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Since the replacement resistors wert like:for'like: commodity type it' ens,
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the parts were ordered as Commercitl Grade-(QC-3),-and in accordance with
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step 5.1.10 of UNT-7-021, no PQD ras performed. Although this action.
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appeared to be appropriate, it was in direct conflict with step 5.2.1.4
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of UNT-8-001 which stated:
"a SPEER/PER (project evaluation request).shallibe. initiated forfall
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parts or components for use in a safety-related system determined
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to be ' Commercial Grade' (QC-3) except.those items previously'
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approved and included in Reference 2.16 (UNT-7-003,." Control of-
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Expendable Material"), 2.26 (UNT-5-007,L" Plant Lubrication-
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Programs"), 2.27 (RAN 457001798,:" Plant Expendable Materials-
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Manual") _ or other approved engineering design or design change
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documents."
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Consequently,-the ordered parts were designated as. Commercial' Grade without'
the proper dedication. Two _ of the thirty resistors (under Work Authorization
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01017698.and Condition Identification 255518)'were. installed.in a position
indicator as a_like for like replacement.(NOTE:-Post installation tests-had-
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been performed to ensure that the indicator operated properly.)
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(2). Corrective Steps That Have'Been Taken'And The Results Achieved
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Example 1
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A Quality Notice (QN.QA-89-009) was issued on 1/13/89 to formally
address and track the corrective actions for the procedural violation.
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Page 7 of 9
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Procurement Engineers, including the individual responsible for the
procedural violation, were required to review the quality notice and
were instructed to impose shelf life requirements on all orders for
items that have a limited shelf life.
The Waterford 3 Materials Management Information System was updated to
reflect a five year shelf life for the Buna-N items.
Example 3
A Quality Notice (QN QA-89-004) was. issued on 1/13/89 to formally address
and track the corrective actions for the procedural violation.
On November 9, 1987,.UNT-8-001 was replaced with Nuclear Operations
Engineering Procedure NOEP-004, "The Engineering Procurement Process."
NOEP-004 addresses commercial grade procurement in greater detail than
did UNT-8-001.- To ensure consistency with NOEP-004, UNT-7-021 has been
revised. In particular, the exemptica regarding commodity type items,
Step 5.1.10 of UNT-7-021, has been'delefed.
The twenty-eight resistors remaining in the warehouse were downgraded to~
non-safety (QC-2). This action will require that a PQD be performed
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before the resistors are used in a safety-related application. The 'two
resistors that were installed in the plant were evaluated in accordance
with NOEP-004, Section 4.4.3, and NOEI-152, Section 5.5 and found to be
acceptable for their intended use.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
Example 1
NOEI-152 will be revised to insure that shelf life requirements are
imposed on orders for items having a limited shelf life.
An overall program will be established to ensure that shelf life controls
are consistently applied in the appropriate plant procedures. A review
of items in stores will be done to identify and correct other shelf life
data deficiencies.
(This effort will be tracked under quality notice QN
QA-89-071 dated 3/17/89).
Example 3
Based on the corrective actions that have been taken for this example,
further violations of this type'should be prevented.
(4) Date When Full Compliance Will Be Achieved
Example 1
Revision to Procedure NOEI-152 will be completed by July 1, 1989. The
stores review is expected to be completed by December 31, 1989, at which
time LP&L will be in full compliance.
Example 3
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LP&L is currently in full compliance.
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Basis for Denying Example Two of Violation 89'02-03
LPE denies that Section 5.4.3.2 of- UNT-7-021 was violated since the
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applicable. technical manuals were updated. Subsequent to'the' citing'of this
apparent violation.during an NRC Exit Meeting',- LPE inunediately generated a
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quality notice (QN QA 89-005) to document-the finding and address its, root.
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cause. Baced on a review of Station Modification (SM) No.1701: and its -
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associated documentation,. LPE determined. that the manuals had been. adequately
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updated and no further; action was necessary. Consequently,.the QN was-
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dispositioned as' invalid. 'The'following information substantiates this
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position.-
'Using the guidance provided'in Plant Administrative. Procedure UNT-7-021,
Revision 1, '.' Spare Parts Equivalency Evaluation,". Spare Parts Equivalency
Evaluation Report (SPEER) No.85-231 was generated to' support the replacement
of' Commercial Grade Agastat' Relays'with Class 1E Agastat Relays. Step 5.4.3.2
of UNT-7-021'(Revision:1) required that' changes to documents affected by the:
SPEER are to be initiated in accordance with Trocedure PE-2-006, " Plant
Engineering Station Modification." Accordingly, SM'1701 was initiated to
update the design documents associated with SPEER 85-231. During the-
processing of SH 1701, evaluations.were requested and performed to document
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the known differences between and' applications.of the Agastat 7000 Series
Relays (commercial gradd and the E7000 Series Relays (1E grade).
In general
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these evaluations (Reference Project Evaluation Requests 60312, 60536 and
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70520) concluded that although the.7000 Series Relays were no different from
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the E7000 Series Relays, the E7000 Series should be used for future
replacements of Agastat Timing Relays.
The evaluations became part of the SM 1701 package. Also included in the SM
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Package was LPE's documented actions that were takes to use the E7000 Serier
Relays to replace E7000 or 7000 Relays in safety-related applications. The
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following actions were taken:
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1.
ME-7-005, " Time-Delay Relay Setting Check, Adjustment and Functional.
Test," was revised to require that emergency diesel generator (EDG)..
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agastat relays in safety-related (SR) applications be replaced by SR'(E
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Series) relays. This procedure also requires that E Series relays be
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replaced every 10 years from date of manufacture. The Waterford 3 Plant
Preventive Maintenance Program was revised to include this replacement
frequency.
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2.
Maintenance history was reviewed on both EDGs to verify that no
unqualified relays were installed as replacements. This review revealed
that only two agastat relays were replaced and both were replaced by
safety-related relays.
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Based on the above information, the following notice (Referew:e LPE Letter
No. W3E86-0260 dated 11/3/86) was placed in each of the applicable manuals:
This notice serves to accommodate the recent policy of Amerace Corp. to
provide Agastat relays for safety-related applications with the "E"
prefix designation.
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Agastat 7000 series relays qualified by Amersee Corporation'for Nuclear
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application have model numbers with an "E" prefix.
Part number design discrepancies may exist where agastat relays are shown
in a particular design drawing that do not have the "E" prefix where in
fact the corresponding field installed relay may now have the "E"
designation.
Conversely, a field installed relay may be found to be an
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Agastat relay qualified by a subvendor..(instead of Amerace) and found to
not be from a subgrade batch of commercially produced relays, that do not
have the "E" prefix, in certain applications.
Further.information may be obtained from checking the responses to PElR
70520, PEIR 60312, and PEIR 60536.
The applicable manuals that were updated with this information were:
Technical Manuals 457000005, Volume 1 (R [ Revision] 0); 457000212 (R2)-
457000225, Volume 4 (RI); 457000238 (RO); 457000281 (RS); 457000854-(RI) and'
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457001225, Volume 3.(R8).
(Note: Technical lianual 457000106 was originally
listed in SM 1701 as requiring an update, but a revision to this manual was
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not actually required as indicated on an Engineering Review Comment Resolution
Form.)
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On January 13, 1989, QN QA-89-005 was issued to address the apparent
procedural violation of not updating the noted manuals. After a review of the
information contained in SPEER 85-231, SM 1701 and the applicable Technical
Manuals,, the QN was dispositioned as invalid.
(Note: In addition to the
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manuals stated above, Technical Manuals 457000291 (RO) and 4570002146 (RI) had
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been included in the QN as needing an update. Both manuals were determined to
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be not applicable to the issue.)
Consequently, LPE bel.'r as that the appropriate Technical Manuals were
adequately updated in i . ardance with IINT-7-021. Therefore, in light of the
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information provided above, LPE requests that this example be reevaluated.
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