ML20141N178
| ML20141N178 | |
| 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-860227-04, NUDOCS 8603040449 | |
| Download: ML20141N178 (12) | |
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COMANCHE PEAK RESPONSE TEAM
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\\J ACTION PLAN ISAP III.d
Title:
Preoperational Testing Revision No.
4 Reflects Comments Description On Plan
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Prepared and v
3 Recommended by-p Review Team Leader
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8'2 I' Date Approved by:
Senior Q, b Review Team f2 /z7 lTL Date ptR3oiB88 8t88)!g5
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Preoperational Testing
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described the issues in the CPSES Safety Evaluation i
Report, Supplement No. 7, as follows:
"In TP Category 5, the TRT found that System Test Engineers (STEs) were not on controlled distribution for design changes applicable to systems to which they were assigned; rather, they were required to obtain this information on their own initiative from the document control center prior to starting a test and were then required to incorporate that information, as applicable, into the test procedure. While the TRT did not identify any specific problems as a result of this practice, it considers this practice to be weak since it relies too heavily on the motivations and initiatives of test personnel to ensure that they have current design information when they are developing test procedures and before conducting. tests.
Typically, these are periods when they could be under more than normal pressure. Additionally, because of the number and nature of the problems found in the document control system by s
the TRT QA/QC Group, the TRT could not reasonably conclude that the document control system problems identified did not affect testing activities." Page J-13, Item 3.2.3, " Findings for Test Program Issues."
"The TUEC Startup Group relies heavily on the accuracy and completeness of the design documents, which are included in the document control system, in its preparation of test i'
procedures and during the conduct of testing. A number of problems were identified in the document control system by the TRT QA/QC Group during its review. While the TRT Test Program Group did not find that these problems adversely affected those portions of the testing program that it included in its review, the TRT cannot conclude with reasonable assurance that the document control system problems had no adverse effect on testing activities." Page J-14. Item 3.2.4, "Overall Assessment and Conclusions."
2.0 ACTION IDENTIFIED BY NRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-18, Item 4.2.4,
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"Preoperational Testing," as being necessary to resolve this issue are as follows:
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" Establish measures to provide greater assurance that STEs and (m-other responsible test personnel are provided with current controlled design documents and change notices.
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ISAP III.d (Cont'd) s 2.0 ACTION IDENTIFIED BY NRC (Cont'd)
Provide'NRC with reasonable assurance that the document control system problems identified by the TRT QA/QC Group did
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not affect the testing activities."
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3.0 BACKGROUND
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m The: Startup Administrative Procedure CP-SAP-21, " Conduct of Testing," as reviewed; by the NRC-TRT, stated that thd STE was required to:
" Review the system; drawings and applicable design changes to determine 'that the as-built component / system will be adequately tested by the current procedure revision to
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demonstrate proper component / system operation."
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'lhe TRT reviewers' concerns were twofold: t(1) that this requirement may rely too heavily on an STE's motivati.on and initiative at the' time when he is under more than normal jcb pressure and is expected to start testing'; activities and that he may not have the latest design information in his possession, and (2) that the problems identified by the NRC-TRT QA/QC Group with the Document Control Center (DCC) for construction activities may have adversely affected the testin'g program.
.l The NRC-TRT QA/QC Group's findings were specifically addressed in CPSES Safety Evaluation Report, Supplement No. 11 at Page 0-10, Item 3.2.2, " Document Control Issues," as follows:
"The QA/QC Group found that prior to 1984, there were numerous recurring administrative and erecedural deviations in the document control function. Many of these recurring deficiencies were identified by internal and external audits.
But there was little follow up or verification by TUEC
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l management that effective corrective actions were taken, until l#
early in 1984 when the document control' center (DCC) 4 monitoring / team began reporting to senior management. The currentidccument control program, with an estimated' error rate of:one' percent or less, was found to be adequately staffed and effective. }The problem of incorrect and incomplete drawing packages appears to have been corrected.
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In-sudary,theQA/QCGroupfoundthecurrentdocumentation control program to be acceptable. However, prior to 1984,1as Os identified by CAT [ Construction Assessment Team] and TUEC, there wasta document control breakdown. Although many of the i
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'N ISAP III.d (Cont'd)
3.0 BACKGROUND
(Cont'd) document control deficiencies have been corrected, the implication of past inadequacies on construction and inspection have potential generic significance which has not yet been fully analyzed by TUEC."
Subsequent to TUEC submitting Revision 2 of the CPRT Program Plan and ISAP to the NRC, sampling from the population described below in Section 4.1.2.4, " Prerequisite Test Population Definition," has proceeded. The original intent was to prepare one population to be sampled, screened, and evaluated for impact on both the prerequisite and preoperational test programs. The original population identified proved adequate for prerequisite testing but not for preoperational testing.
The CPRT, with SRT concurrence, proceeded to prepare a separate population for the preoperational test pregram evaluation. The additional population prepared for the preoperational test program evaluation is described below in Section 4.1.2.5, "Preoperational Test Population Definition."
The action plan presented in Section 4.0 was developed to include a review of past and current administrative requirements for use of design documents during testing; a review of che technical test
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procedures utilizing the design documents; and a random sampling and evaluation program to determine the effectiveness of the administrative requirements.
4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to resolve the two design document related issues identified by the NRC-TRT. The first issue will be investigated to determine any additional measures required to insure that STEs and other responsible test personnel are efficiently and effectively provided with current design documents for use in their testing activities.
The second issue will be investigated to determine if the problems with DCC identified by the NRC-TRT QA/QC Group had an adverse affect on the testing program activities.
The individual objectives and tasks for each issue are discussed separately below.
4.1.1 STE's Access to Current Design Documents
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This task will determine if administrative procedures
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and work practices by the Startup and DCC organizations are adequate to provide for the use'of current design documents in the performance of testing activities, and
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ISAP III.d
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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) to identify' additional requirements, if any, which need to be established to ensure compliance with this requirement.
The steps required to complete this task are: reviewing the Startup Administrative Procedures as they relate to use of current design documents; reviewing the organizational interface and work practices between the Startup and DCC organizations; and interviewing individual STEs.
4.1.1.1 Startup Administrative Procedure Review Review Startup administrative procedures to determine if practices are likely to lead to a programmatic discrepancy. The procedures will be reviewed to determine when administrative requirements need to be applied to the use of design documents, that s
the requirements are clearly stated, and
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indicate the timsliness for use of current design documents. The CPRT will perform this i
review.
4.1.1.2 Startup and DCC Interface Review the organizational interfaces and work practices between the Startup and DCC organizations which are applicable to the acquisition and use of current design documents. Determine the adequacy of past and present practices in meeting the 4
requirements of the testing program.
Identify and implement improvements if' required. The CPRT will perform these j
reviews.
4.1.1.3 System Test Engineer Interviews Interview Systen Test Engineers to determine their methods of complying with the current design document requirement and to further assess the need to upgrade existing procedures and methods. The CPRT will conduct these interviews.
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ISAP III.d
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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Potential for DCC Problems to Adversely Affect the Testing Program This task will evaluate the effect of DCC problems identified by NRC-TRT QA/QC Group on the testing program by determining the Startup organization's response to properly aut5orized design changes initiated by Engineering, processed through the DCC organization, and requiring a testing response by Startup.
The Startup organization utilizes drawings as a primary resource in the preparation of technical test procedures and the execution of testing. Other resources are used, however they are not controlled by the DCC. Startup responds to three methods of changing the design by Engineering. The three Engineering design change procedures are:
direct issuance of a revision to a design drawing which does not incorporate f-w the other two methods; issuance of a Design Change
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Authorization (DCA) which is a design drawing change described in approved documents issued temporarily until the actual design drawings may be updated and issued; and issuance of a Component Modification Card (CMC) which is similar to the DCA.
An evaluation program will be developed and performed which will focus on opportunities for a DCC error to begin a chain of events which results in a testing error. Error opportunities involve design changes, communicated by way of changes to design documents distributed and controlled by DCC, where the design change created a need to change a test procedure, perform retesting, or perform additional testing.
This type of evaluation was designed to preclude the nature of DCC errors from affecting the results.
The Startup organization utilizes only a fraction of the design documents prepared for the project. This subset of design documents and the changes to them are easily identified and the boundaries of a valid population of design changes readily established.
The CPRT decided that a sampling program to resolve this issue would be appropriate because there are no
(T programmatic deficiencies identified to date, the
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criteria by which they will be evaluated in this study
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ISAP III.d (Cont'd) x s-4.0 CPRT ACTION PLAN (Cont'd) will be the same, the population of items to be sampled is homogeneous (i.e., the process by which these items are handled by the DCC is the same), and thus a sampling program in accordance with Appendix D will aid in determining whether or not systematic discrepancies exist.
The potential adverse effect of the DCC problems identified by the NRC-TRT QA/QC Group on the testing programs will be evaluated by: determining a calendar interval when DCC problems could have adversely affected startup; identifying and reviewing procedures and instructions which utilized DCC controlled design documents; defining the population of changes to the design documents; random sampling the population of changea; and evaluating the sampled design changes for adverse effects on the prerequisite and preoperational test programs.
The steps which are required to accomplish this task are described below:
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4.1.2.1 Period of Interest Determine the period of interest during which Startup could have been adversely affected by DCC problems. This period will begin at the start of prerequisir.e testing by Startup and the end date will be based on the results of CPRT review and assessment of CPSES Monitors Team monitcring reports of DCC performance.
These same reports were utilized by the NRC-TRT in their evaluations.
4.1.2.2 Prerequisite Test Instruction Review All prerequisite test instructions will be reviewed to determine the types of design documents controlled by DCC which were used during the execution of prerequisite testing.
-All design documents of this type will be included in the prerequisite test population.
The CPRT will perform this review.
4.1.2.3 Preoperational Test Procedure Review All preoperational test procedures performed during the period of interest and not
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ISAP III.d
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(Cont'd) 4 4.0 CPRT ACTION PLAN (Cont'd) completely reperformed thereafter will_be 4
reviewed to identify the design documents referenced by the test procedures and controlled by DCC.- The design documents identified will be included in the 4
prerequisite test population. A preoperational test sub-population will be identified from this list of referenced desigt, documents. This review will be performed by the CPRT.
4.1.2.4 Prerequisite Test Population Definition l
The population of all design drawing revisions, all DCAs, and all CMCs issued during the period of interest and used by the Startup organization in the preparation of 3
test procedures or during the execution of testing will be identified. The CPRT will identify the prerequisite population with
! t assistance from TUGC0 Nuclear Engineering.
Preliminary estimates indicate that the population will include approximately 75,000 items.
4.1.2.5 Preoperational Test Population Definition The preoperational test population will be identified'from the design document reference list created by Section 4.1.2.3 which includes only the flow diagrams and control i
circuit. schematic diagrams.- In the hierarchy i
of engineering design documents, these two classes of drawings will:have the most significant influence.on preoperational j
testing. This population will be' identified by the CPRT. Preliminary estimates indicate that the population will include approximately 1,100 iters.
4.1.2.6 Population Screening Criteria Each document change'in the prerequisite and preoperational test populations will be screened until it meets the following criteria:
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ISAP III.d
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4.0 CPRT ACTION PLAN (Cont'd)
The change is to a design document.
The change is issued through DCC.
The document is referenced by a-test procedure or is used during the performance of a specific test.
The test precedures which reference or utilize the affected documents were performed during the period of interest and were not completely reperformed following the period of
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j The document change occurred prior to performance of the test.
The change would require a test or retest.
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The CPRT will perform the evaluations with assistance from TUGC0 Startup.
4.1.2.7 Sample Evaluation After random selection and screening, testing records will be examined for each sample item to determine the following:
I Whether a test was conducted by Startup per the change, or Whether Startup documentation demonstrated they were aware of the change.
i A negative finding in both cases will constitute a discrepancy. The CPRT will 2
perform the evaluations with assistance from TUCCO Startup.
4.1.3 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."
O Corrective action, if required, will be implemented T
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ISAP III.d
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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) according to Appendix H "CPRT Procedure for the Development, Approval, and Confirmation of Implementation of Corrective Action."
4.2 Participants Roles and Responsibilities 4.2.1 Organizations involved 4.2.1.1 CPSES Startup Group 4.2.1.2 TUCCO Nuclear Engineering Group 4.2.1.3 CPRT Testing Programs Review Team 4.2.2 Scop: for each Organization 4.2.2.1 CPSES Startup Group Revise Startup Administrative O
Procedures and instruct STEs on new procedure requirements.
Implement corrective actions resulting from the CPRT investigation into the effect on testing due to.DCC problems, and Provide qualified personnel to assist in the screening and sample evaluation.
4.2.1.2 TUGCO Nuclear Engineering Group Provide engineering drawing history data for sample preparation.
I 4.2.2.3 CPRT Testing Programs Review Team Evaluate the CPSES document control program and applicable Startup Administrative Procedures and control methods, Review and concur with applicable
,Q Startup Administrative Procedures
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ISAP III.d
\\m-(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Determine whether the testing program has been adversely affected by DCC problems and specify corrective actions, if necessary, and Overview the work performed by other organizations assisting CPRT.
4.2.3 Lead Individuals 4.2.3.1 Mr. S. M. Franks CPSES Startup Group 4.2.3.2 Mr. J. E. Rushwick CPRT Testing Programs Review Team Leader 4.3 Personnel Qualifications 4.3.1 The CPRT Testing Programs Review Team Leader meets the f-w qualifications as described by the CPRT Program Plan.
k, 4.3.2 The Startup personnel participants will be qualified in m
accordance with CP-SAP-19, " Training / Qualification Requirements for Startup Personnel."
4.3.3 The Review Team Leader assures that other personnel providing assistance are qualified.
4.4 Procedures The following procedures will govern revision of Startup Administrative Procedures:
CP-SAP-1, Startup Administrative Procedures Manual CP-SAP-21, Conduct of Testing 4.5 Acceptance Criteria The acceptance criteria for the two investigated issues are discussed below:
4.5.1 STEs Access to Current Design Docurents The procedures and methods are adequate to the
(T satisfaction of the Testing Programs Review Team Leader
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to assure that STEs and other responsible test personnel are cognizant of and are provided with
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(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) current design documents. This finding must be supported by the results of random sampling and evaluation of the use of design change documents.
4.5.2 Potential for DCC Problems to Adversely Affect the Testing Program In order for DCC problems identified by the NRC-TRT QA/QC Group to be judged to have had no adverse effect on preoperational or prerequisite testing, a properly selected, screened, and evaluated design change document sample must meet the following criteria:
4.5.2.1 Prerequisite Test Program The design change was tested an evidenced by approved test data or was documented as being monitored by Startup as an open item.
4.5.2.2 Preoperational Test Program L
A preoperational test procedure incorporated the design change or was documented as being monitored by Startup as an open item.
4.6 Decisien Criteria 4.6.1 STE's Access to Current Design Documents The administrative procedure (s) are satisfactory or, if necessary, are revised to the satisfaction of the Testing Programs Review Team Leader and concurred with by the Senior Review Team.
4.6.2 Potential for DCC Problems to Adversely Affect the Testing Program The objective of the random sampling and evaluation program is to provide reasonable assurance that the problems identified by the NRC-TRT did not, in fact, adversely affect the test program.
If one or more discrepancies are found to have adversely affected the test program an expanded investigation will be undertaken in accordance with Appendices D and E.