ML20133E131
| ML20133E131 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/31/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8507220407 | |
| Download: ML20133E131 (4) | |
Text
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b TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1
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400 Chestnut Street Tower II E
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May 31, 1985 2
N U.S. Nuclear Regulatory Comission Region II c3 ATTN:
~Dr.' J. Nelson Grace. Regional Administrator W
101 Marietta Street,'NW, Suite 2900 Atlanta, Georgia ~30323
Dear Dr. Grace:
SEQUOYAH NUCLEAR PLANT UNITS 1 JNL 2 - NRC-0IE REGION II INSPECTION REPORT 50-327/84-38 AND 50-328/84 SUPPLEMENTAL RESPONSE TO VIOLATION j
Our response to the subject inspection report was submitted to NRC by the March 15, 1985 letter from me to you. As stated in our response to item of violation 327/84-38-01 and 328/84-38-01, enclosed is a supplemental response which provides the report of the task force established to evaluate postmodification testing and functional testing of equipment after modifications.
1 If you have any questions, please get in touch with R. E. Alsup at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
j Very truly yours.
TENNESSEE VALLEY AUTHORITY
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. A. Domer, Chief Nuclear Engineering Branch Enclosure cc(Enclosure):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Records Center Institute of Nuclear Power Operations 1100 circle 75 Parkway, Suite 1500 Atlanta,~ Georgia '30339 72{
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An Equal Opportunity Employer g6C/
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FOLLOW-UP RESPONSE - NRC-01E INSPECTION REPORT NOS.
50-327/84-38 AND 50-328/84-38 R. D. WALKER'S LEITER TO H. G. PARRIS DATED MARCH 29,1985 Items 327/84-38-01 and 328/84-38-01 This response provides the report of the special task force setup by plant management on postmodification testing (PMT)/ functional testing of equipment after modifications. As stated in our original response, this task force was to address root causes and corrective actions. The following outline defines the scope of activities reviewed by the task force.
I.
Survey selected engineering change notices / design change requests completed since 1979 and determine if PMTs or functional tests should have been performed.
A.
If functional tests and/or PMTs are determined not to be required, the task force will so indicate.
B.
If functional tests and/or PMTs are determined to be required, the task force will verify, as apolicable, that:
1.
PMTs/ functional tests were performed.
2.
PMTs/ functional tests were adequate to:
a.
Demonstrate that new or modified components perform their intended function.
b.
Ascertain the effect of the modification on the overall system.
Avoid inadvertently affecting an operating system or component.
c.
3.
Any surveillance instructions employed in functional tests adequately test the modification.
4.
Office of Engineering (OE) correctly applied the engineering program procedure criteria for detcrmining when to issue a PMT scoping document.
5.
OE prepared a scoping document and that it was adequate for scoping the PMT.
6.
PMTs are consistent with the OE scoping document.
7.
PMT/ functional test instructions include the following:
a.
Test scope and objective b.
Prerequisites c.
Precautions
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4 d.
Limitations and action e.
Acceptance criteria f.
Reference to the application, technical specification, drawings, specifications, codes or other requirements g.
Provision for recording details of the conduct of the test, including observed deficiencies, resolution, and retest h.
Requirements that valve lineups, temporary connections, dis-connections, or jumpers be restored to normal or it refers to another instruction for restoration to normal 8.
PMTs/ functional tests were performed according to instructions.
9.
PMT/ functional test acceptance criteria were defined and satisfied.
10.
Test deviations were resolved and retesting accomplished as cppro-priate.
II.
Evaluate PMT/ functional test problems ioentified prior to this surveillance and verify thst:
A.
Corrective action has been defined and adequately addresses the problem.
B.
Corrective action is being tracked or is complete.
III. Evaluate plant instructions controlling PMTs/ functional tests to ensure they properly implement higher level documents.
Subsequent to establishing the above outline, NRC published IE Information Notice No. 85-23, " Inadequate Surveillance and Postmaintenance and Postmod-ification System Testing" on recent events at the McGuire Nuclear Power Facility. The task lorce reviewed this industry operating experience item to determine if the criteria was in line with NRC recommendations to verify the adequacy of Sequoyah's PMT/ functional test programs.
It was concluded that the Sequoyah Nuclear Plant outline was more than adequate in its scope.
The task force expended approximately 150 man-days to perform this surveil-lance.
The Sequoyah work item status report was used to select modifications for review. The reviewed modifications were performed through the period of years from 1979 to 1985, and all were considered by the work item status report to be field complete. A total of 124 modifications were surveyed, including 63 requiring functional tests, 4 requiring PMTs, and 26 engineering change notices issued to clear temporary changes (TACFs) to the plant. Of the 93 modifications reviewed which involved testing activities, 8 had areas of concern on the specific modifications, but none of these affected oper-ability of safety-related equipment. The 8 items of concern were subsequently dispositioned as follows:
A.
Three (3) concerns were resolved when additional facts were related to the survey team.
B.
Four (4) concerns were resolved by the performance of additional func-tional tests. All were satisfactory.
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2 C.
One (1) concern is being tracked to resolve discrepancy between func-tional test data and subsequent sis. All data was within technical specification limits.
f The following recommendations were made to strengthen programmatic areas of Sequoyah's testing program. Each recommendation is being or has been imple-mented by plant management.
i
- A.
A change to plant instruction will be proposed to address testing of temporary alterations (significant changes), especially those that
'later become permanent modifications.
i B.
There are no specific requirements for content of functional test in-structions in AI-19. 'As a minimum, the test scope, precautions, and acceptance criteria should be required in functional test instructions.
Revision requests to AI-19, Part IV, are being prepared to address this Conce rn.
C.
A memorandum has been prepared to request OE to include any USQD special j
rsquirements concerning testing in PMT scoping documents. Also, a re-t
.v.sion request to AI-19, Part IV, is being proposed to alert test 1..truction preparers to review USQDs to ensure that any special require-
- a. ats are included in the test instructions.
I D.
A revision requ2st to Al-19 is being prepared to add requirements for identifying and correcting test deficiencies during PMT/ functional test performance.
a All items will be completed by September 6, 1985.
In summary, the task force noted a substantial improvement over the years of 1979 to 1985 of workplans in requiring and including details for post-modification testing. The later workplans were'found to be improved over the earlier ones in terms of completeness, attention to detail, and tech-i nical adequacy. Overall, Sequoyah's program to' test modifications were
,found to be adequate;' however, the recommendations stated above will be implemented to strengthen and clarify the-program.
f e
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