ML20141N173
| ML20141N173 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/1986 |
| From: | NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | |
| Shared Package | |
| ML20141N167 | List: |
| References | |
| PROC-860227-02, NUDOCS 8603040442 | |
| Download: ML20141N173 (5) | |
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l COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.a.4
Title:
Traceability of Test Equipment Revision No.
4 Reflects Commentai Description On Plan Prepared and Recommendedb[y*.[ eI Review Team Leader I'O Date 1
Approved by:
Senior Review Team (6
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VA/27[fL Date pg3040442860228 A
ADOCK 05000445 O
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4 Prgs 1 of 4 ISAP'III.a.4
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Traceability of Test Equipment
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-72 and 73, Item 4. " Assessment of Safety Significance," as follows:
"...although temperatures.were taken and logged during the i
test (ICP-PT-55-11. " Thermal Expansion,"), the specific
[ temperature] measuring device used at each monitored location was not logged. As a resuic the calibration of the measuring i
device could not be. traced to the monitored location with the information contained in the test data packages. The TRT found that the completed test data packages did contain the calibration data for the measuring devices used, but as alleged, the devices could not be traced directly to specific monitored locations. While pursuing this metter, the TRT interviewed TUEC pere >nnel who participated in the testing and found that a test coordinator maintained a log which tied the devices to the specific monitored locations; however, the log was not made a part of the test data package. The TRT pointed out to TUEC that while the direct connection was not required j
by the test procedure as written, the data must be included as t
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part of the test data package."
1 2.0 ACTION IDENTIFIED BY NRC l
The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-17, Item 4.2.1, " Hot Functional Testing," as being necessary to resolve this issue-are as follows:
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" Incorporate the information necessary to provide traceability j
between thermal expansion test monitoring locations and measuring instruments. Also establish administrative controls to assure appropriate test and measuring equipment traceability during future testing and plant operations."
3.0 BACKGROUND
The traceability between the calibration of temperature measuring instruments and the monitored locations was not documented in the
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1CP-PT-55-11, " Thermal Expansion," test data package. -The approved i
1 test procedure used for conduct of the test did contain requirements for recording pertinent data relating to the calibration of temperature measuring instruments.
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Pag 2 2 of 4
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ISAP III.a.4 (Cont'd) s_,
3.0 BACKGROUND
(Cont'd)
The requirements of the approved test procedure were not complied with during conduct of the test as required by CP-SAP-21 " Conduct of Testing." The data was readily available but not in the format required by the approved test procedure. The personnel responsible for conduct of the test elected to create a separate log which related the temperature measuring instruments to the monitoring teams that used the instruments. The monitoring teams were assigned specific test packages which identified the locations that were monitored. Therefore, the instrumentation used could be correlated to the location by the known assignments of monitoring teams and specific test packages. The data obtained by the temporary temperature measuring instruments was used for information only and was not used to judge acceptability of the test or to substantiate any engineering calculations.
The cause of this error is attributed to the engineering personnel temporarily assigned to Startup for thermal expansion testing not being thoroughly indoctrinated in Startup administrative requirements for conduct of testing.
The individuals were not adequately familiar with processing Test Procedure Deviations as O.
required by CP-SAP-12 when they desire to deviate from approved procedural requirements. Possible generic implications are that other test personnel may have deviated from approved test procedures without complying with Startup administrative procedure requirements to document approved deviations from those procedures.
The test data package in question was incomplete and had not i
received final approval by the Joint Test Group. One of the l
objectives of the review process is to assure the test data package is complete in accordance with administrative procedure 1
requirements.
4.1 Scope and Methodology The objective of this action plan is to ensure that ICP-PT-55-11 has traceability of measuring and teet equipment and that administrative controls are in place to assure such a
traceability during future testing and plant operation.
The following tasks were or will be implemented to achieve the above objective:
4.1.1 Test Procedure Deviation (TPD) No. 36 was issued to include information that related specific test instrument identification numbers to the locations
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where the test instrumeias were used in the test data
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package. Test Deficiency Report No.-3418 and TPD No.
1 37 were issued to provide traceability to calibration
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4 Pega 3 of 4 ISAP III.a.4
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(Cont'd) 4.0 CPRT ACTION PLAN of the instruments and to include the required calibration data relating to the instrument identification numbers in the test data package for ICP-PT-55-11.
4.1.2 All Startup personnel responsible for conduct of l
testing were reinstructed on the existing Startup administrative requirements applicable to the traceability of measuring and test equipment.
4.1.3 Startup personnel responsible for conduct of testing I
were reinstructed on the existing Startup administrative requirements applicable to the use of Test Procedure Deviations.
4.1.4 Administrative controls applicable to documentation requirements for measuring and test equipment which have been established for the Initial Startup Test program will be reviewed for adequacy and improved if
/N necessery.
V) 4.1.5 Adminictrative controls applicable to documentation requirements for measuring and test equipment which have been established for station vperation and maintenance activities will be reviewed for adequacy and improved if necessary.
4.1.6 Geartup Administrative Procedure requirements for indoctrination and training of Startup personnel will be reviewed to ensure that lessons learned from this activity, if any, are incorporated.
If procedure changes are made, applicable Startup personnel will be reinstructed on the changes.
4.1.7 Identified discrepancies, if any, vill be processed according to Appendix E "CPRT Procedure for the Classification and Evaluation of Specific Design or Construction Discrepancies Identified by CPRT."
Corrective Action, if required, will be implemented according to Appendix H, "CPRT Procedure for the Development, Approval and Confirmation of Implementation of Corrective Action."
4.2 Participant's Roles and Responsibilities
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4.2.1 The Startup Special Projects Group Supervisor was
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responsible to ensure that the information on measuring
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Pags 4 of-4' a
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ISAP III.a.4 (Cont'd) 1 4.0 CPRT ACTION PLAN (Cont'd) i and test equipment used for thermal expansion testing
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is included in the completed test data package for l
i ICP-PT-55-11.
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l 4.2.2 The S artup Manager was responsible for ensuring that 3
all Startup personnel had been adequately reinstructed on the requirements for measuring and test equipment
-traceability and proper utilization of test procedure t
deviations.
4.2.3 The CPRT Testing Programs Review Team Leader is responsible for reviewing existing administrative i
controls for documenting.the traceability of measuring and test equipment used for Preoperational Testing, g
t Initial Startup Testing, Operation ap.d Maintenance activities and assuring necessary :orrective actions are taken.
4.3 Qualifications of Personnel 4.3.1 The CPSES Startup Manager and Startup Special Projects i
Group Supervisor ara qualified to the highest level
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provided in CP-SAP-19, " Training / Qualification j
Requirements for Startup Personnel."
4.3.2 The CPRT Testing Programs Review Team Leader meets the i
j qualifications as described by the CPRT Program Plan.
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4.3.3 The Review Team Leader assures that other personnel providing assistance are appropriately qualified.
4.4 Acceptance Criteria i -
Administrative control for measuring and test equipment traceability will be acceptable if applicable administrative procedures require identification and calibration information for measuring and test equipment used to obtain acceptance i
data be entered on the permanent test results record.
4.5 Decision Criteria The action plan will be considered c.omple':e when the CPRT determines that applicable administrative procedures are adequate to control measuring and test equipment traceability i
documentation and there is reasonable assurance that measuring and test equipment inforeistion is being properly handled.
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