ML20207K838
| ML20207K838 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/18/1986 |
| From: | Debbage A, Gass K, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K578 | List: |
| References | |
| SWEC-SQN-21, SWEC-SQN-21-R01, SWEC-SQN-21-R1, NUDOCS 8701090537 | |
| Download: ML20207K838 (7) | |
Text
r y l
TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-21 l SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 TITLE: Post Modification Testing i
j REASON FOR REVISION: To incorporate TAS and SRP comments SWEC
SUMMARY
STATEMENT: The items in this report were identified by the Nuclear f Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed. Concerns A02850219013-001, and -002 were closed by the NRC. Corrective action is in progress for concerns A02850219013-003 and -004.
- i. PREPARATION PREPARED BY:
i N > tif % h l SIGNATURE DATE
.i REVIEWS
- PEER:
W$ hai SIGNATURE
//-Ad.- VL DATE
- <d4'E$$N _ r lZ $
SIGNATURE DATE CONCURRENCES CEG-H: _ r.I/re.nu #/2(,/FL g SRP: :.hwf LLJH J2.9 7-Kf SIGNATURE DATE / SIGNATURE *[ / DATE APPROVED BY:
r (!b '
$~l$*bb N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
E l 2242T k 8701090537 861222 v PDR P ADOCK 05000327 PDR I
r- .
, , =
l I
)
l l
1 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element
Title:
Post Nodification Testing SWEC Concerns: A02850219013-001
-002
-003
-004 Source Document: NRC Inspection Report 327, 328'/84-38 Report Number: SWEC-SQN-21 Evaluator: IlfM J. J. Knightly Date Reviewed by: Y[ Of a L //-K- I? (,
Date K. R. Gass Approved by* l L 'e s If 46!fs '
A. G. Debbad 6 ate' 1856T
r I
Report SWEC-SQN-21 Post Modification Testing I. Introduction-
-During a Nuclear Regulatory Commission (NRC) inspector follow-up (reference 1) of an inadvertent unit 2 Safety Injection (SI) which occurred in December 1984, the inspector performed a detailed review of the SI switch operation and its design. This review, which identified a related series of testing and design review deficiencies, resulted in several NRC violations and follow-up items which were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis as follows:
- 1. A02850219013-001, Inadequate Post Modification Testing (Violation 327, 328/84-38-01)
- 2. A02850219013-002, Inadequate Post Modification Testing (Also Violation 327, 328/84-38-01)
- 3. A02850219013-003, SI Actuation Problem (Violation 327, 328/84-38-03)
- 4. A02850219013-004, Lack of Test for Switch Replacement (Inspector Follow-up Item (IFI) 327, 328/84-38-06)
Information on the background, corrective actions taken, verification methodology, verification analysis, completion status, and pertinent references for these four issues is included in this report.
II. Verification of SWEC Issues A. Background
- 1. Startup testing for unit 1 in 1979 identified problems with the safety injection block hand switches which tended to spring back past the neutral position to the reset position, thus initiating spurious sis.
- 2. SQN placed cautionary placards above the switches, placed administrative controls in appropriate procedures and initiated
, a design change request (SQ-DCR-775) June 26, 1980, to replace the switches.
- 3. The Un-reviewed Safety Question Determination (USQD) for the DCR, approved November 5, 1982, indicated that new hand switches would stop in the normal position; no switch design problem was investigated nor identified.
- 4. New switches were installed in February 1983. These switches had the original design problem.
- 5. In January 1985, a design change was initiated to replace the switches with a different type to prevent a recurrence of the spurious sis.
Page 1 of 5
e .
j This series of events resulted in: (1) NRC violation 84-38-03, Failure to determine and correct hand switch problem (2) NRC violation 84-38-01, Failure to perform testing and (3) NRC follow-up item 84-38-06 concerning the 1985 design change. '
B. Corrective Actions Following the identification of two instances of inadequate system l modification testing in violation 327, 328/84-38-01, SQN established I a task force to review their modification testing activities. This l included Post Modification Tests (PNTs). Functional Tests (FTs), and l applicable Preoperational (PREOP) Tests. SQN stated (reference 4) l that this post-modifications task force (PMT) would address root l causes and corrective actions related to post-modification problems. l The task force report (reference 3) stated that the task force l reviewed 93 modifications that were performed through the period of i 1979 to 1985 and identified eight as having areas of concern. l 1
Additional functional testing was performed in order to resolve l four of the eight concerns identified. Out of the remaining l concerns, three were resolved when additional information was l obtained. The last concern deals with modifying the unit 1 B l Train Feedwater Regulation Yalves in order to increase their i associated stroke times. This item was scheduled for completion l by April 18, 1986, and was being tracked by SQN Corrective Action l Tracking System (CATS) item 85201. l l
The Task Force identified other discrepancies and concerns in the l form of recommendations. SQN's May 31, 1985 response to violation l 327, 328/84-38-01 identified four of these recommendations that were lR1 to be acted on in order to strengthen the Sequoyah Testing Program. l These four recommendations and their final disposition are addressed l below: l l
- 1. TACFs - Revise the Nuclear Quality Assurance Manual (NQAM) and l Plant Instructions to address testing of temporary alterations, I including those which later become permanent modifications. I l
The NQAM was revised accordingly to read, " Temporary l alterations which are considered significant changes as I determined by Plant Operations Review Committee (PORC) and/or i become permanent modifications by the submission of a Design l Change Request (DCR) shall be tested: (a) to assure system l Integrity; and (b) to provide for evaluating the performance of l the alteration before system operation." Administrative l t
Instruction AI-9, " Plant Modifications Before Licensing" was l l revised in the same manner. l i
'i
~
i l
i l Page 2 of 5 i
m__ . - . . -, m
f -
^
l
- 2. FT Instructions - Specify in AI-19 that FT instructions contain I as.a minimum, the test scope, precautions, and acceptance i criteria. g AI-19 was revised to require FT instructions to contain: test I
scope; prerequisites; precautions; acceptance criteria; test equipment data; provisions for recording details of the te,st; I and verification sign off. .
I f
- 3. '1D 0 Special Requirements - Include any USQD special ,
r .irements concerning testing in PNT secping documents, and ,
review USQDs to ensure that any special requirements are ,
included in the test instructions. ,
8 AI-19, Part IV was revised to include a precaution for the work plan preparer to review USQDs for any special test requirements. I I
- 4. Test Deficiencies - Revise AI-19 to include requirements for identifying and correcting test deficiencies during PRT/FT ,
performance. p AI-19, Part IV was revised to include complete and specific I guidelines as to the documentation and disposition of test l deficiencies. ,
1 Following verification of the SQN corrective actions, NRC closed I
(reference 5) the violation 327, 328/84-38-01, Failure to Conduct Post Nodification Tests. I In addition to the specific corrective actions described above, the I
SQN overall controls for plant modifications are described in the 1986 Sequoyah Nuclear Performance Plan,Section II.3. These I controls are aimed at improving the accountability and quality of I modification work, and include provisions related to the SWEC l concerns:
Prepare a Plant Nodifications Package (PNP) document for each I proposed modification, with a designated'section covering ,
testing procedures.
I Perform engineering evaluations of proposed modifications ,
including USQD review.
l Define acceptance criteria in the PMP for each installation. I i
Perform quality control inspections to verify satisfactory i installation and testing. 8 s
l l
Page 3 of 5 t
( ,e
+
C. Verification Methodology - The SWEC concerns identified for Employee Concerns Tast Group (ECTG) verification were stated as follows:
RIMS NUM3ERS Issues RIMS ITEM A02 850219 013 Inadequate Post Modification Test RIMS-001 did not identify equipment design deficiency requiring NCR which was late. See RIMS 003 and 004 for snowball effect.
A02 850219 013 Failure to conduct adequate Post RIMS-002 Modification Test resulted in design NCR and management control of NCR was not effective.
A02 850219 013 TVA and Westinghouse review of NCR RIMS-003 -
and USQD did not identify design deficiency and resulted in DCR which did not solve SI actuation problem.
A02 850219 013 Another DCR replaced deficient RIMS-004 switches with different type to prevent SI actuation but did not perform test to detect the original reset after release problem.
ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this issue and the NRC status and tracking system for the issue. This review of the pertinent documentation formed the basis for this verification activity.
D. Verification Analysis ECTG verified that corrective actions described in II-B had been accomplished and that the NRC violation concerning post modification testing was closed. SQN's commitment to and controls for improving the accountability and quality of modifications, including effective performance of engineering reviews / evaluations, are described in the Sequoyah Nuclear Performance Plant Section II.3.
E. Completion Status The completion status summary is as follows:
- A02850219013-001 The corrective actions concerning f post modification testing are I complete, and the NRC has closed the I R-l related violation 327, 328/84-38-01. This SWEC concern is closed. I Page 4 of 5
r .
.e 4 a'
- A02850219013-002 The corrective actions concerning ,
post modification testing are complete, and the NRC has closed the related violation 327, 328/84-38-01. This SWEC concern is '
closed. I
- A02850219013-003 SQN's controls for and commitments ,
to effective engineering evaluations are documented in the Nuclear i g_l Performance Plan. Following implementation of these corrective actions and closure by the NRC of violation 327, 328/84-38-03, this i SWRC concern can be closed, i
- A02850219013-004 SQN's replacement and testing of hand switches is in progress. I Following completion of these I corrective actions and closure of I the NRC inspector follow-up ites ;
327, 328/84-38-06, this SWRC concern can be closed. .
III. References
- 1. NRC Inspection Reports 50-327/84-38 and 50-328/84-38, dated February 13, 1985, from R. D. Walker to H. G. Parris
- 2. NRC Letter, " Reports 50-327/84-38 and 50-328/84-38," dated March 29, 1985, from R. D. Walker to H. G. Parris
- 3. TVA Letter, "Sequoyah Nuclear Plant units 1 and 2 - NRC-0IE Region II Inspection Report 50-327/84-38 and 50-328/84 Supplemental Response to Violation," dated May 31, 1985, from J. A. Domer to J. N. Grace
- 4. TVA Letter, " Response - NRC-0IE Inspection Report Nos. 50-327/84-38
, and 50-328/84-38," dated March 15, 1985, J. A. Domer to J. N. Grace
- 5. NRC Inspection Reports 50-327/86-20 and 50-328/86-20, dated April 23, 1986, from J. A. Olshinski to S. A. White Page 5 of 5