ML18031A443

Responds to NRC 860418 Ltr Re Violations Noted in Insp Repts 50-259/85-45,50-260/85-45 & 50-296/85-45.Corrective Actions: Conduct of Maint Procedure Will Be Implemented by 860618 to Clarify When Review of Instructions Required

ML18031A443
Person / Time
Site:	Browns Ferry
Issue date:	05/14/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8606020240
Download: ML18031A443 (5)

Text

TENNESSEE VALLEY AUTHORlTY CHATTANOOGA. TENNESSEE S7401 5N 157B Lookout Place

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<,e ~ lr May 14, 1986 U.S. Nuclear Regulatory Commission Region II ATTN: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

Dear Dr. Grace:

BROWNS FERRY NUCLEAR PLANT UNITS 1 AND 3 NRC-OIE REGION II INSPECTION REPORT 50-259/85-45, -260/85-45, 296/85-45 RESPONSE TO STAFF ASSESSMENT OF LICENSEE RESPONSE We received J. A. Olshinski's letter to S. A. White dated April 18, 1986 wi'th enclosed staff .assessment of licensee response regarding the above subject inspection report for Browns Ferry. Our response to that staff assessment is enclosed. The information requested in Mr. Olshinski's letter regarding prior review by the Plant Operations Review Committee is also enclosed.

If you have any questions, please get in touch with R. E. Rogers at FTS 858-2723.

To the best of my knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE LEY AUTHORITY R. r idley, irector Nuclear Saf y and Licensing Enclosure cc: Mr. James Taylor, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 8606020240 860514 PDR *DOCK 05000259 8 PDR An Equal Opportunity Employer

ENCLOSURE

RESPONSE

NRC INSPECTION REPORT NOS.

50-259/85-45, 50-260/85-45, AND 50-296/85-45 JOHN A. OLSHINSKI'S LETTER TO S. A. WHITE DATED APRIL 18, 1986 Item 1 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.

Item 1.c.

Contrary to the above, the licensee failed to adhere to Standard Practice 7.6, Maintenance Request and Tracking, on April 26, 1985. Standard Practice 7.6 requires that Critical Structures SyStems and Components (CSSC) and Safety Related Maintenance Requests (MRs) shall refer to Plant Operations Review Committee (PORC) reviewed instructions unless the maintenance to be performed involves skills normally possessed by qualified maintenance personnel and does not require step-by-step details for the actual performance of the work. If a PORC reviewed instruction is required and has not been written, an MR may be written and sent to PORC for review and the plant superintendent's approval.

On April 26, 1985, Maintenance Request A-170596 was performed on the safety-related TD2C relay with detailed step-by-step work instructions on the MR which had not been PORC reviewed and approved. The work instructions involved operability verification of RHRSW pump automatic start logic circuitry which is normally verified during performance of approved surveillance instructions and is beyond the skills of qualified electrical maintenance personnel.

This is a Severity Level IV violation (Supplement I) and is applicable to all three units.

1. Basis for Deletion of the Criteria The December 23, 1985 revision to Standard Practice BF 7.6 was a general revision to implement an improved Maintenance Request form. This revision was not intended as a final resolution of the issue of the requirement for PORC review of instructions. A new procedure, the "Conduct of Maintenance" addresses this issue and is now in review. This new procedure includes a listing of the type activities which can be considered as skill of the craft.

The December 23, 1985 revision states that PORC review is required "if additional work instructions beyond the skills of the craft are required to perform maintenance." This statement summarizes the basic requirement. The words concerning "step-by-step details" were deleted because step-by-step details could specify skill of the craft activities or go beyond skill of the craft. Therefore, this is not a good criteria for determining if PORC review is required.

Ade uac of Initial Post-Maintenance Test The initial post-maintenance test demonstrated that the relay itself operated properly, but did not test the function of the contacts while in the circuit. The relay contact operation had been checked before the relay was installed. There was second party verification for the wire removals and replacements on the contacts to ensure correct installation.

This was done in accordance with Standard Pxactice BF 3.11. The shift engineer then requested the additional assurance of repair by testing the function of the relay contacts in the circuit. The surveillance instruction which normally accomplishes this requires very extensive safety equipment alignment considerations as prerequisites. The cognizant engineer (qualified maintenance personnel) determined that the shift engineer's concern could be very simply dispositioned with a simple check on this individual relay without affecting any safety equipment other than the one pump motor controlled by the relay's contacts. The test, involved energizing, the relay via a tempos'ary jumper and specifying normal

• surveillance critexia as acceptance criteria.

At the time of the violation, maintenance personnel believed that specifying the jumper to be applied and removed could have been accomplished on the Troubleshooting Plan and Log, BF 7.6, Attachment C, which does not require PORC review. The cognizant engineer decided the jumpex'ould be satisfactorily controlled on the MR without the need of an additional attachment. Operations reviewed and approved the MR similax to the review and approval that would occur for an Attachment C, Troubleshooting Plan and Log. This final test provided additional confirmation that the problem had been located and resolved befoxe xeturning the equipment to sexvice. However, it'appears this final test should have been classified as post-maintenance testing, beyond the skill of the craft.

Corrective Ste s Which Have Been Taken and Results Achieved The "Conduct of Maintenance" px'oceduxe now in review will provide clarification of when PORC review of instructions is xequired.

Corxective Ste s Which Will Be Taken to Avoid Further Violations Implementation of the procedure discussed in step 3 should prevent furthex violations. The procedure will be distributed to all maintenance and modifications personnel through the responsible section supervisor. The section supervisor has ultimate responsibility Eor determining which MRs shall be subject to PORC review. Post-maintenance testing beyond the skill of the craft will require PORC review.

Date When Full Com liance Will Be Achieved The "Conduct of Maintenance" procedure will be implemented by June 18, 1986, and full compliance will be achieved.