ML20141N177
| ML20141N177 | |
| 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-860227-03, NUDOCS 8603040447 | |
| Download: ML20141N177 (5) | |
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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.c
Title:
Prerequisite Testing Revision No.
4 Reflects Comments Description On Plan Prepared and Recou. mended bv,:.
Review Team L_
Leader 2~
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Date Approved by:
Senior Review Team be d.h- /
VAft 1/94, Date 8603040447 860228 PDR ADOCK 05000445 l
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ISAP III.c V
Prerequisite Testing
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described the issue in the CPSES Safety Evaluation Ieport, Supplement Nc. 7, as follows:
"....the TRT review found that craft personnel verified and signed for initial conditions on some prerequisite test data sheets, contrary to Section 4.10.9 of CF-SAP-21, ' Conduct of Testing,' which require.1 that this be done by the STE (System Test Engiacar]. Further investigatien revealed a memorandum i
issued by the Lead,Startu? Engineer on March 31, 1983, count erman:!ing this requirement of CP-SAP-21.
The subject of the memorandum (STM-83084) was 'ETG Petsonnel Schedule Change,' but it also indicated that craft personnel (ETG) l (Electrical Test Group] may verify prarequisite conditions for Prerequisite Test Instructions XCP-EE-1 and XCP-EE-14.
Issuing such a memorandum in lieu of executing a properly approved change to CP-SAP-21 is in violation of CP-SAP-1,
'Startup Admini-rrative Procedures Manual,' Section 4.4.3.1, which requires a pern,anent or interim change to be approved and issued to all asnual holders in accordance with CP-SAP-1.
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It appears that as a result of the memorandum, 24 of the 35 tests reviewed by the TRT had prerequisite conditions icproperly verified by craft support personnel.
Fifteen were XCP-EE-14, but nine were XCP-EE-24, ' Fixed Battery Pack Operated Ecergency Lighting Units,' which were not authorized by the memorandem." Page J-87, Item 4., " Assessment of Safety Significance."
and summariced the issue:
"...the TRT fouad that TUEC startup management authorized, by memorandum, test support craftsmen to verify initial conditions for certain prerequisite test procedures in violation of Startup Administrative Procedure CP-SAP-21,
' Conduct of Testing '" Page J-13. Item 3.Z.3, " Findings for Test Program Issues."
2.0 ACTION IDENTIFIED BY hRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-17, Item 4.2.3,
" Prerequisite Testing," as being necessary to rescEve this issue, are as follows:
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" Rescind the startup memorandum (STM-83084), which waa issued d
in conflict with CP-SAP-21, and ensure that na ether memoranda were issued which are in conflict with approved procedures.
Also. conduct a review of all ether prerequisite test records to determine those that had preregt;! sites sip;ned by craf t personnel, and assess the ftpact of those improperly verified on s.ubsequent testieg activities."
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ISAP III.c
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(Cont'd)
3.0 BACKGROUND
Startup Administrative Procedure CP-SAP-1, "Startup Administrative Procedure Manual," authorizes the Startup Manager to issue interim procedure changes or other necessary instructions on a temporary basis. These changes are required to be issued with specific instructions concerning their applicability and use.
Instructions issued in this manner are required by CP-SAP-1 to be followed with a permanent procedure revision.
Startup Interoffice Memorandum (SIM-83084) authorized electrical test-group personnel to validate prerequisites / initial conditions for Prerequisite Test Procedures, XCP-EE-1, "Megger Testing," and XCP-EE-14. " Molded Case Circuit Breaker and Thermal Overload Relay / Heater Testing." Startup Administrative Procedure CP-SAP-21 requires System Test Engineers verify prerequisites prior to conducting the test.
The NRC-TRT identified other prerequisite tests which had prerequisites / initial conditions signed by unauthorized craft personnel, p
4.0 CPRT ACTION PLAN
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4.1 Scope and Methodology The objective of this action plan is to identify Startup Interoffice Memoranda which may be in conflict with approved Startup Administrative Procedures, identify prerequisite test records which may have prerequisite / initial conditions signed as complete by craft personnel, and to evaluate the impact of these actions upon subsequent testing.
4.1.1 SIM-83084 was rescinded by issuance of SIM-84220 dated September 25, 1984.
4.1.2 System Tes: Engineers were instructed that SIM-83084 was rescinded and that it is their responsibility to verify test prerequisite / initial conditions for the affected test.
4.1,3 All craft test support personnel were instructed that they shall not verify test prerequisite / initial conditions nor shall they conduct any tests without supervicion of a System Test Engineer.
4.1.4 Startup Interoffice Memoranda were reviewed to determine if any other directives have been issued
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which conflict with requirerents of the Startup x_)
Administrative Procedures.
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4 Peg 2 3 of 4 ISAP III.c (Cont'd) s 4.0 CPRT ACTION PLAN (Cont'd) 4.1.5 All prerequisite test records were reviewed to identify other cases where craft personnel signed initial conditions for prerequisite tests.
4.1.6 All prerequisite test / instructions were analyzed to determine the consequences of improper prerequisite / initial conditions verifications.
4.1.7 The results of the SIM and prerequisite test records and instructions review will be evaluated to assess the impact on subsequent testing activities.
4.1.8 Identified discrepancies, if any, will 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 Developeent, Approval and Confirmation of Implementation of Corrective Action."
4.2 Participants Roles and Responsibilities 4.2.1 The Startup Manager was responsible for rescinding SIM-83084 and reinstruction of all STEs and craf t support personnel with regard.to their responsibilities relating to verification of initial conditions for prerequisite testing.
4.2.2 Startup Interoffice Memoranda were reviewed by the Startup Manager and the Startup Special Projects Group Supervisor.
4.2.3 The Startup QA Specialist was responsible for reviewing prerecuisite test / instructions and records.
4.2.4 The Startup Special Projects Group Supervisor and the CPRT Test Programs Review Team Leader will perform the SIM and prerequisite test record review evaluations.
4.2.5 The CPRT Test Programs Review Team Leader will overview the tasks performed by startup personnel.
4.2.6 The CPRT Testing Programs Review Team Leader will be responsible for evaluating the overall results of this action plan.
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ISAP III.c
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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Qualifications of Personnel 4.3.1 The Startup personnel participants will be qualified in accordance with CP-SAP-19. " Training / Qualification Requirements for Startup Personnel."
4.3.2 The CPRT Testing Programs Review Team Leader meets the qualifications as prescribed by the CPRT Program Plan.
4.3.3 The Review Team Leader assures that other personnel providing assistance are appropriately qualified.
4.4 Acceptance Criteria r
4.4.1 FSAR Sections 14.2.3, " Test Procedures," and 14.2.4,
" Conduct of Test Program," will be used to determine if the Startup Administrative Procedures and Prerequisite Test Instructions are adequate to properly implement the commitment to control the performance of prerequisite testing.
4.4.2 The Startup Administrative Procedures and Prerequisite Test Instructions will provide the acceptance criteria for the evaluation of the impact, if any, of improper verifications of prerequisite / initial conditions on subsequent testing.
4.5 Decision criteria The action plan will be considered complete when it has been determined to the satisfaction of the CPRT that there has been no adverse impact on the accomplishment of the prerequisite and preoperational testing programs as prescribed in the FSAR, or, if necessary, when corrective actions have been properly implemented.
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