ML20197K066
| ML20197K066 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/13/1986 |
| From: | Wooldridge R WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#286-185 OL, NUDOCS 8605200248 | |
| Download: ML20197K066 (37) | |
Text
SELATED CORRESNNW t
WORSH AM, FORSYTHE, SAM PELS & WOOL,IDGE g -,
g~
TMiRTV-Two MUNDRED.2OOt BevaN TOWER M.o.SamptLS Jot A.
MAM DAU.AS. Texas 75201 sesy es noStar A. wookonsoor Nest D. ah0ERSON p"
SPENCge C.mtkyta Le RONALD M.MANSON TELEPMONE (214) 979 30C0 or Cous.$
J. DAN SOMahNAM p J,O S. i m eO N 6@ imam TRaves E. vahDEmPOOL
(
JuDa?M n.JCMNSON
,CAEg A.FC % T'ME se CMano L. ADAM S s,
..,},4 y
=
caviD C. Lontaoam
~
./,
A Tris'CoreEn fat eo. con JoM= w.MearvNotDS
.'Q fg TMOMAS r. LiLLanD
, t. ]
ROStnf m. wsSE f f,
TIMOTMT A. MACR Nl g,,{,
wM.STEPMEN SOv0 P
Mann R, waSEM CMRISTOPMgm m. MeLTgmSEmotn AOBE AT p. OLivtm Mann SCM* ART 2 Fhy 13, 1986 a.CMa= D O. moo. c NaNCYC L. SETMuRCM CCCELia J.Sau=cm JOC A, Davis EmeC M.PEftnSON Peter B. Bloch, Esq.
Dr. Kenneth A. McCollom Chairman Dean Atcmic Safety and Division of Engineering, Licensing Board Architecture and Technology U. S. Nuclear Regulatory Oklahoma State University Coninission Stillwater, Oklahoma 74074 Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnson 881 West Outer Drive Oak Ridge National Laboratory Oak Ridge Tennessee 34830 P. O. Box X, Building 3500 Oak Ridge, Tennessee 34830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50-445 and 50-446 O
Dear Administrative Judges:
Applicants have this date delivered to Mr. Vincent S. Noonan the Caranche Peak Response Team Issue-Specific Action Plans (ISAPs)
III.a.1 " Hot Functional Testing (HPT) Data Packages", VII.a.9 " Receipt and Storage of Purchased Fhterial and Equipnent", and Revision 2 of ISAP VII.b.1 "Onsite Fabrication", developed by the Cananche Peak Response Team.
As a part of our continuing effort to keep the Board apprised of matters which relate to the licensing of Cananche Peak, we are enclosing four copies of each ISAP. This material is not being offered into evidence at this time, and is provided for information only.
Respectful y, b605135000445 8605200
,/,,
/
/m f,
.)
O o
Robert A. Wooldridg RAW:tj Enclosures cc: Service List
<JSc3
4 SERVICE LIST Mr. Peter B. Bloch, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20535 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Elizabeth B. Johnson Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 Mrs. Juanita Ellis President, CASE 1426 South Polk Street Dallas, Texas 75224 Renea Hicks, Esq.
Assistant Attorney General Environmental Protection Division P. O. Box 12548, Capitol Station Austin, Texas 78711 Nicholas S. Reynolds, Esq.
William A. Horin, Esq.
Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W.
Suite 700 Washington, D.C. 20036 Mr. W. G. Counsil Executive Vice President Texas Utilities Generating Company Skyway Tower,25th Floor 400 N. Olive Street Dallas, Texas 75201 Mr. Thomas G. Dignan, Jr.
Mr. R. K. Gad, III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Mr. Roy P. Lessy, Jr.
Morgan, Lewis & Bockius 1300 M Street, N.W.
Washington, D.C. 20036
t Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive *, Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin Christic Institute 1324 North Capitol Street Washington, D.C. 20002 Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. William L. Clements Docketing & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stuart A. Treby, Esq.
Office of the Executive Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 thairman Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Ellen Ginsberg, Esq.
U.S. Nuclear Regulatory Commission 4350 East / West Highway,4th Floor Bethesda, Maryland 20814 Billie Pirner Garde Citizens Clinic Director Government Accountability Project 1555 Connecticut Avenue, N.W.
Suite 202 Washington, D.C. 20036 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111 David R. Pigot Orrick, Herrington & Sutclif fe 3
600 Montgomery Street San Francisco, California 94i11
o t:
Mr. Shannon Phillips 4
Resident Inspector 4
Comanche Peak SES 1
c/o U.S. Nuclear Regulatory Commission P. O. Box 38 Glen Rose, Texas 76043 Anthony Roisman, Esq.
Executive Director Trial Lawyers for Public Justice 2000 P. Street, N.W., Suite 611 Washington, D.C. 20036 9 %"
Robert A. Wooldridge p
~
Dated: May 13,1986 e
i 4
I _
CPRT-417 Log No. TXX-4797 FILE NO. 10068 TEXAS UTILITIES GENERATING COMPAhT SKYWAY TOWER. 400 NORTH OLIVE STREET. L.B. El
- DALLAS, TEXAS 75201 May 13, 1986 witum a coussic EBECufwt viCE Passionsev Mr. Vincent S.
Noonan Director, Comanche Peak Project Division of Licensing U.
S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION SUBMITTAL OF ISSUE-SPECIFIC ACTION PLANS OF THE COMANCHE PEAK RESPONSE TEAM (CPRT) PROGRAM PLAN
Dear Mr. Noonan:
Transmitted herewith are Comanche Peak Response Team Issue-Specific Action Plans (ISAPs) III.a.1 " Hot Functional Testing (HFT) Data Packages" (Revision 4), VII.a.9 " Receipt and Storage of Purchased Material and Equipment", and VII.b.1 "Onsite Fabrication" (Revision 2).
ISAPs III.a.1 and VII.a.9 are new additions to the Revision 3 Program Plan.
ISAP III.a.1 should be placed behind the " Appendix C, Testing" tab and, ISAP VII.a.9 should be placed behind ISAP VII.a.8 in the Revision 3 Program Plan.
Also enclosed is a replacement page for the list of QA/QC ISAPs. This page should be placed immediately behind the " Appendix C,
QA/QC" tab in the Revision 3 Program Plan.
The enclosed Revision 2 of ISAP VII.b.1 replaces Revision 1 currently in Revision 3 of the Program Plan.
This submittal completes Revision 3 of the CPRT Program Plan.
Should you have any questions please do not hesitate to call either John Beck or myself.
Very truly yours, W.
G. Counsil
]&. l J
^
By:
yJohnW. Beck Vice President WGC:tj Enclosures A snvssuos or rexas ursurses stecranc courAxv J
QA/QC ISAPs I.d.1 QC Inspector Qualifications I.d.2 Guidelines for Administration of QC Inspector Test I.d.3 Craft Personnel Training VII.a.1 Material Traceability VII.a.2 Non-Conformance and Corrective Action System VII.a.3 Document Control VII.a.4 Audit Program and Auditor Qualification VII.a.5 Periodic Review of QA Program VII.a.6 Exit Interviews VII.a.7 Housekeeping and System Cleanliness VII.a.8 Fuel Pool Liner Documentation VII.a.9 Receipt and Storage of Purchase Material and Equipment Receiving Inspection VII.b.1 On-Site Fabrication VII.b.2 Valve Disassembly VII.b.3 Pipe Support Inspections VII.b.4 Hilti Anchor Bolt Installation VII.b.5 DELETED VII.c Construction Reinspection / Documentation Review Plan
COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.a.1
Title:
Hot Functional Testing (HFT) Data Packages Revision No.
4
"* " E
Descrfption On Plan
/
Prepared and Recommended b (,
Review Team N
Leader M
7,19g(
Date Approved by:
Review Team u
Date W*s2 1/4rs i
Rsvision:
4 Pags 1 of 14 ISAP III.a.1 Hot Functional Testing (HFT) Data Packages i
1.0 DESCRIPTION
OF ISSUES The title of this Action Plan does not accurately reflect the scope of work which is addressed, but is utilized in order to correspond to the specific heading in the NRC letter dated September 18, 1984.
The actuai scope of work includes all preoperational test data packages and FSAR commitment compliance.
1.1 Hot Functional Testing 1
The NRC-TRT described the issue'in the CPSES Safety Evaluation Report, Supplement No. 7 at Pages J-73 through J-75, Item 4.(6), " Assessment of Safety Significance." The full text of the NRC-TRT description of the issue is presented in
. and is summarized as follows:
(a) Hot functional test procedure 1CP-PT-02-12. " Bus Voltage and Load Survey," had been completed.
Subsequently, changes were made to the transformer tap settings. The JTG (Joint Test Group) decided a retest was not required.
(b) Hot functional test procedure (CP-PT-34-05, " Steam Generator Narrow Range Level Verificaticn." was performed with three temporary level transmitters.
When the permanent transmitters were installed, the JTG
-specified only a cold calibration retest.
(c) Hot functional test procedure 1CP-PT-55-05,
" Press'urizer Level Control," was performed with a defective level transmitter. When the transmitter was replaced, the JTG specified'only a cold calibratien retest.
l (d) Hot functional test procedure 1CP-PT-55-05,
" Pressurizer Level Control:" the speed of a chart recording device was changed without being documented on a test deficiency report (TDR).
The NRC-TRT summarized the issue at Page J-13, Item 3.2.3,
" Findings for Test Program Issues," as follows:
...the TRT found that three HFT data packages were approved by the TUEC Joint Test Group (JTG) that failed to meet all of the'objec_tives stated in the test procedures.
f a
Rsvision:
4 Paoa 2 of 14 ISAP III.a.1 (Cont'd)
1.0 DESCRIPTION
OF ISSUES (Cont'd)
The NRC-TRT conclusions with regard to the issue are at Page J-76, " Conclusion and Staff Positions," as follows:
...It appeared that the overall objectives of the CPSES Unit 1 preoperational test program were being satisfactorily met, thus providing reasonable assurance that the plant is properly designed and constructed and that its operation will not pose a threat to public health and safety. While some of the allegations had valid basis, none was considered to have safety significance or generic implications.
1.2 FSAR Chapter 14.2, " Initial Test Program," Review As described in ICAP III.b, " Containment Integrated Leak Rate Test," Revision 4, the NRC-TRT expressed concern that there may be undocumented deviations from testing commitments made in the FSAR.
While ISAP III.b focuses exclusively on the test which gave rise to the issue, the CPRT determined that it would be appropriate to address the NRC-TRT's concern relating to other FSAR commitments during the evaluation of approved test data packages to be undertaken in this Action Plan.
2.0 ACTIONS IDENTIFIED BY NRC 2.1 Hot Functional Testing 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:
Review all completed preoperational test data packages to ensure there are no instances where test objectives were not met, or prerequisite conditions were not satisfied. Address the four items identified by the TRT, along with appropriate resolution.
2.2 FSAR Chapter 14.2, " Initial Test Program," Review j
The action identified by the NRC-TRT in the CPSES Safety I
Evaluation Report, Supplement No. 7 at Page J-17, Item 4.2.2,
" Containment Integrated Leak Rate' Testing," as-being necessary to resolve this issue is as follows:
l Rsvision:
4 Page 3 of 14 ISAP III.a.1 (Cont'd) 2.0 ACTIONS IDENTIFIED BY NRC (Cont'd)
TUEC has identified deviations from FSAR commitments related to the CILRT. TUEC shall identify all other deviations from FSAR commitments which were not previously identified to NRC.
I
3.0 BACKGROUND
Startup Administrative Procedure, CP-SAP-16, " Test Deficiency and Nonconformance Reporting," establishes requirements for the use of Test Deficiency Reports (TDRs). TDRs are issued when unacceptable or indeterminate conditions exist in system or equipment operating characteristics, test documentation, or for any testing procedure noncompliance. TDRs contain a description of the specific problem, the corrective action required, and/or the retesting necessary to resolve the problem.
For example, when the initial conditions described in a procedure cannot be met because permanent plant equipment is not installed, a TDR may be initiated to document the condition and to establish corrective action and/or retest requirements for the equipment. The consequence of proceeding with a test with outstanding TDRs is evaluated by CPSES management. The retests are specified by considering the objective of the preoperational test, function of the specific equipment, and the station test schedule which determines whether other opportunities will be available for the retest.
Startup Administrative Procedure, CP-SAP-12 " Deviations to Test Instructions / Procedures," allows deviations from approved test procedures when certain approval and documentation requirements are met.
The form used to document such deviations is known as a Test Procedure Deviation (TPD). The level of management approval required depends upon whether or not the TPD involves a change in procedure intent.
Both TDRs and TPDs become part of the completed test record reviewed by the JTG prior to acceptance of the test results.
The JTG consists of representatives from the major onsite organizations. TUGC0 has organized the JTG to assure effective coordination of the engineering, construction, and operations activities related to the startup program.
Revision:
4 Page 4 of 14 ISAP III.a.1 (Cont'd)
3.0 BACKGROUND
(Cont'd)
The JTG consists of the following members :
Manager, Nuclear Operations - Chairman Manager, Plant Operations - Vice-Chairman Manager - CPSES Startup Assistant Manager - Nuclear Engineering Westinghouse Representative The JTG membership is knowledgeable of the plant design, FSAR requirements, and the test program administrative requirements and procedures. The group has sufficient organizational freedom and diversity to assure that objectivity will be maintained.
The NRC-TRT reviewed all but seven of the JTG-approved preoperational test data packages associated with hot functional testing. The NRC-TRT also reviewed two of the five acceptance test data packages. These acceptance tests were non-safety-related and no concern was expressed with respect to this category of tests.
In Revision 3 and previous revisions to ISAP III.b. " Containment Integrated Leak Rate Test," the approach to the FSAR commitment compliance review was to examine additional FSAR sections if discrepancies were noted in the test program commitments. This Action Plan examines the test program related commitments.
FSAR compliance considerations related to the design and construction of CPSES are being conducted unde; the Design Adequacy and Quality of Construction Programs described in Appendix A and B, respectively, to the CPRT Program Plan.
4.0 CPRT ACTION PLAN The objective of this Action Plan is two fold:
a) to provide reasonable assurance that the CPSES preoperational testing program was and is being accomplished according to applicable Regulatory Guides, FSAR commitments, Startup Administrative Procedures, and individual test procedures; and b) to satisfactorily resolve the four specific concerns identified by the NRC-TRT.
1 An FSAR Amendment is currently being prepared for submittal to the NRC which changes some of these position titles. However, the same organizations were and continue to be represented.
Ravision:
4 Pcge 5 of 14 ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1 Scope and Methodology The scope of work includes all of the preoperational test data packages approved by the JTG as of April 1, 1986. The approach to the work is as follows: develop criteria for the evaluation of completed test data packages; evaluate the three test data packages and resolve the NRC-TRT concerns related thereto; and evaluate the remaining test data packages not reviewed by the NRC-TRT.
4.1.1 Criteria Development The evaluation of completed test data packages will be conducted using written acceptance criteria.
(These criteria have been developed and are presented in, " Criteria for Evaluation of Completec Test Data Packages.")
4.1.2 NRC-TRT Identified Concerns The three test data packages cited in Section 1.0 will be evaluated. The four specific concerns identified by the NRC-TRT will be resolved.
4.1.3 Evaluation of Twenty-seven Test Data Packages Shortly after receipt of the NRC letter dated September 18, 1984, the CPRT initiated a programmatic evaluation of approved test data packages. The approach used at that time consisted of evaluating the seven HFT related packages not reviewed by the TRT and a sample of twenty other packages considered most safety-significant.
4.1.4 Evaluation of the Remaining Test Data Packages Excluding the sixteen that were reviewed by the NRC-TRT, there have been 190 preoperational tests performed to date.
Each of the data packages associated with these tests has been reviewed and approved by the JTG at least once and, as a consequence of steps 4.1.2 and 4.1.3 above, thirty of them have undergone a second evaluation. While there is no evidence thus far to indicate that a programmatic deficiency exists with respect to the Unit 1 preoperational test program, this population of 190 tests will be further examined through the application of a sampling program. Details of the program are provided in Section 4.5.
]
Ravision:
4 Page 6 of 14 e
ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.5 Startup Administrative Procedures 4.1.5.1 The evaluation criteria shown in Attachment 2 will be incorporated into the Startup Administrative Procedures.
4.1.5.2 The process by which the Startup organization identifies and reports FSAR commitment deviations to TUGC0 Nuclear Licensing will be reviewed. Procedure changes or new procedures will be prepared, as necessary.
4.1.6 Corrective Action 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 Development, Approval, and Confirmation of Implementation of Corrective Action."
4.2 Procedures The procedures to be used are the existing CPSES procedures, augmented by checklists where necessary.
As a means for documenting and tracking the evaluation of each test data package, a Test Deficiency Report will be issued prior to starting the work and dispositioned according to CP-SAP-16, " Test Deficiency and Non-conformance Reporting."
4.3 Participants Roles and Responsibilities l
4.3.1 CPSES Joint Test Group (JTG)
The JTG members, or their designees, who are qualified to review preoperational test results and who did not perform the original review, will be responsible for evaluation of completed test data packages.
The JTG will be responsible for specifying corrective actions and retest requirements for the TDRs issued as a result of this evaluation effort.
Rsvision:
4 Page 7 of 14 ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2 CPSES Startup Group The Startup group will provide the information necessary for the JTG to perform the work according to existing procedures.
4.3.3 Testing Program Review Team The Testing Program Review Team Leader, or his designee, will monitor the evaluation process to assure the objectives of this Action Plan are being met.
He will review and concur in the evaluation criteria and the fir.al evaluation results for each test data package. The Review Team Leader will also perform the Startup Administrative Procedure review.
4.4 Qualifications of Personnel 4.4.1 The JTG consists of the following members who are qualified for review and approval of preoperational test procedures and results as specified in the FSAR Section 14.2.2.7:
Manager, Nuclear Operations - Chairman Manager, Plant Operations - Vice-Chairman Manager - CPSES Startup Assistant Manager - Nuclear Engineering Westinghouse Representative Those individuals designated by the JTG members to assist them in performance of the evaluations are also qualified for review of preoperational test results.
Prior to initiating the reviews of test data packages, the JTG and its representatives were indoctrinated in the NRC-TRT's interpretation of the regulatory position stated in Regulatory Guide 1.68, " Initial Test Programs for Water-Cooled Nuclear Power Plants," paragraph C.3 and the specific criteria in Attachment 2, " Criteria for Evaluation of Completed Test Data Packages."
4.4.2 The CPRT Testing Program Review Team Leader meets the qualifications described in the CPRT Program Plan. He will assure that other team members are appropriately qualified.
2 See Note
, Page 4
l R2 Vision:
4 Page 8 of 14 ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Sampling Program Each test data package is the end result of the sum of the preoperational testing activities. The CPRT has deemed that a random sample of test data packages would be an appropriate method of investigation for potential programmatic l
deficiencies in the preoperational test program. The following describes the three specific populations to be sampled according to the guidelines contained in Appendix D of the CPRT Program Plan, "CPRT Sampling Policy, Application and Guidelines." In each case, the minimum sample size will be sixty.
4.5.1. Population of TDRs This population is comprised of all the TDRs written in connection with the 190 test data packages.
4.5.2 Population of TPDs This population is comprised of all the TPDs written in connection with the 190 test data packages.
4.5.3 Population of FSAR Commitments This population is comprised of all the preoperational test specific commitments presented in FSAR Chapter 14.2, " Initial Test Program."
4.6 Acceptance Criteria Each testing related FSAR commitment was met, or if not, the reason was documented and reported to the NRC.
Each test objective was not invalidated by the use of the Test Procedure Deviation, or, if it was, appropriate retesting had been required.
Each test objective was not invalidated by the use of the Test Deficiency Report, or, if it was, appropriate retesting had been required.-
The Startup Administrative Procedures will be acceptable to the Review Team Leader if measures have been established to preclude having undocumented FSAR deviations.
Ravision:
4 Pagt 9 of 14 ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.7 Decision Criteria If any acceptance criterion is not met, the sample evaluated will be expanded in the appropriate population according to Appendix D, "CPRT Sampling Policy, Applications and Guidelines."
e
r Ravision:
4 Pags 10 of 14 ISAP III.a.1 (Cont'd)
Description of Issue Identified by NRC The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Pages J-73 through J-75, Item 4.(6), " Assessment of Safety Significance," as follows:
Final acceptance by TUEC of HFT results does not occur until the Joint Test Group (JTG) has conducted its review of the data and approves the completed test data package. In a sample of 17 out of 25 completed HFT data packages, the TRT found four instances in which not all of the test objectives had been met, yet the JTG had completed their review and had approved the test data package.
These instances were:
(a) Preoperational test procedure 1CP-PT-02-12, " Bus Voltage and Load Survey," intended to demonstrate that during all modes of plant operation, optimum current and voltage will be present at all the buses and associated equipment. After the test was completed, the STE noted in review of test data that the voltages recorded in paragraphs 7.8.2.1 and 7.8.3.1 did not meet the acceptance criteria specified in the test procedure.
A test deficiency report (TDR) was initiated.
Subsequent TUEC engineering evaluation of the out-of-tolerance voltages documented in the TDR required that changes to some of the transformer output settings used during the conduct of the test were necessary to bring the voltages within the originally specified acceptance criteria.
In accordance with the test procedure, these changes necessitated that some portions of the test be performed again. However, the JTG approved the data package without requiring these portions of the test to be performed again. Therefore, the test data package contained invalid data for that test; thus, the test objective had not been met.
(b) Procedure 1CP-PT-34-05, " Steam Generator Narrow Range Level Verification," intended to demonstrate at hot, no-load conditions, that the specified narrow range level channels for each steam generator indicate properly at the upper and lower instrument taps and compare properly with each other for actual changes in steam generator water level. The transmitters for level detectors 1-LT-517, 518, and 529 were found defective prior to initiation of testing and, thus, temporary equipment was substituted. The test was performed with the temporary equipment and declared successful. After the test, the specified transmitters were installed. The Joint Test Group (JTG) approved the completed test package m,.,
.-.-.,_.,.,,m.
Rsvision:
4 Page 11 of 14 ISAP III.a.1 (Cont'd)
(Cont'd) l containing data taken with temporary transmitters. The only retest requireo after installation of the detectors was cold calibration (not calibration at hot, no-load conditions);
thus, this test objective was not met and no other requirements were imposed by the JTG to monitor performance when the transmitters are placed in service.
(c) Procedure ICP-PT-55-05, " Pressurizer Level Control," intended to demonstrate the control aspects of the system in conjunction with the chemical and volume control system. In addition, there was a note on page 12 of the procedure that stated, 'This test is provided to verify the capability of the pressurizer level control system to monitor pressurizer level over the range of installed instrumentation and to observe that all alarm and control functions are operational.' A prerequisite condition (paragraph 6.13) required the plant to be in hot standby condition. During conduct of pressurizer level indication testing in accordance with the procedure (paragraph 7.1), the System Test Engineer (STE) noted that a level detector (1-LT-461) was registering marginal readings.
He documented this and recommended a calibration check of the detector. After the test was completed, this was done, and it was determined that the detector was out of calibration, and attempts to calibrate it were unsuccessful. The corrective action was to replace the detector and perform a cold calibration (not calibration in hot standby condition); thus, this test objective was not met.
The JTG-approved test data package contained level cata taken with a detector that subsequently proved to be out of calibration, thereby invalidating the test data and no other requirements were imposed by the JTG to monitor the performance of the new detector when it was placed in service.
(d) Additionally, during the conduct of Proced' ire 1CP-PT-55-05 discussed in (c) above, the speed of the recording chart for the pressurizer level was changed from 2.5 cm/ minute, as required by paragraph 7.2.6c, to 15 cm/ hour. The TRT l
l determined that this was done to avoid running out of chart paper during the test. This deviation from the approved test procedure should have been documented on a TDR even though, in this case, the chart speed was inconsequential since the recorded trace data were not being relied upon to prove any of the system's performance features.
Rsvision:
4 Pags 12 of 14 ISAP III.a.1 (Cont'd)
(Cont'd)
The TRT discussed these findings with startup management, including l
the Startup Manager, who is a JTG member. The Startup Manager informed the TRT that with respect to ICP-PT-34-05 and ICP-PT-55-05, the JTG had made a conscious decision not to require hot calibrations on the instruments in question since the accuracy of their calibrations could be determined during a subsequent plant heatup. While the TRT understood this, it pointed out that the JTG had not specified in the retest requirements that these hot calibration determinations must be made; it only specified a cold calibration. Therefore, there was no mechanism to draw attention to the fact that these instruments had not been operationally tested previously under hot plant conditions. The TRT, therefore, did not consider the test objectives to have been fully met.
With respect to ICP PT-02-12, when the TRT identified the need to perform some portions of the test again as a result of the actions taken to implement TUEC's engineering evaluation of the out-of-tolerance voltages, a TDR was immediately initiated by the startup group. The need for performing portions of the test again was apparently overlooked by the JTG during its review. The TRT, therefore, considered that the test objectives had not been fully satisfied and that the JTG review of this data package had been less than adequate.
i 1
e
}
n ;
Rs'1sion:
4 Paga 13 of 14 ISAP III.a.1 (Cont'd) l
)
Criteria for Evaluation of Completed Test Data Packages The following guidelines shall be used for reevaluation of completed I
preoperational test data packages as required by Action Plans III.a.1 and III.b to ensure:
1.0 That the test satisfied applicable FSAR commitments; 2.0 That the test objectives were not invalidated as a result of Test Procedure Deviations (TPDs) that were issued during conduct of the test; and 3.0 That the test objectives were not invalidated as a result of inappropriate corrective actions or ratests associated with Test Deficiency Reports (TDRs) issued during the test or as a result of test data package review.
NOTES:
(1) Particular attention must be given to TPDs that were issued to modify test prerequisite (initial) conditions, or test methodology such that the stated test objectives could not have been attained under the "as tested" conditions or system configuration.
l (2) Particular attention must be given to TPDs that were issued to l
delete the requirement to have permanent plant equipment l
installed for test conduct or that substituted temporary equipment for permanent plant equipment before or during the test.
(3) Particular attention must be given to the specified retest requirements for TDRs which documented permanent system component (s) that were not installed for conduct of the test or unacceptable test results with respect to the stated test acceptance criteria.
(4) Regulatory Position C.3 of Regulatory Guide 1.68, Revision 2, states in part; "To the extent practical, the duration of the test should be sufficient to permit equipment to reach its normal equilibrium condition, e.g., temperatures and pressures, and thus decrease the probability of failures,
Rsvision:
4 Pcgs 14 of 14 4
ISAP III.a.1 (Cont'd)
(Cont'd) including "run in" type failures, from occurring during plant operation." For each case where permanent plant equipment was not installed for the test, the JTG aust judge on a case basis
(
the acceptability of the test or retest requirements after the permanent equipment was installed with regard to the above regulatory position.
l l
a
~k COMANCHE PEAK RESPONSE TEAM ACTION PLAN Item Number:
VII.a.9
{
\\
Title:
Receipt & Storage of Purchased Material and Equipment I
Revision No.
O Description Original Issue Prepared and F~~
Recommended by:
Review Team Leader Date
/3 h
s e
l Approved by:
Senior Review Team m _ d, / - /
$/o/u Doce
Rsvision 0
Pegs 1 of 6 ISAP VII.a.9 Receipt and Storage of Purchased Material and Equipment
1.0 DESCRIPTION
OF ISSUE IDENTIFIED BY NRC This action plan was initiated to address a concern identified by the NRC:
that the CPRT was not providing verification of material and equipment compliance with procurement / design requirements.
This concern is documented on page 91, line 15 in the minutes of a public meeting held between the NRC and TUGCO on December 19, 1985 at Arlington, Texas.
2.0 ACTION IDENTIFIED BY NRC Action was not specified by the NRC in correspondence.
3.0 BACKGROUND
The Design Adequacy Program and a portion of ISAP VII.a.4, " Audit Program and' Auditor Qualification," cover key aspects of safety-related design and manufacturing activities including the specification of design requirements in the procurement documents.
The Quality of Construction and QA/QC Adequacy Program essentially cover construction activities beginning with the removal of materials / equipment from the warehouse or storage area. This ISAP will provide coverage on the receipt and storage activities which occur after manufacturing and before issue of materials / equipment from storage for installation. The results of the implementation f
of this action plan will provide useful input to the Quality of Construction and QA/QC Adequacy Program collective evaluation process and will ensure that receipt and storage program problems that may have occurred are appropriately considered in the final evaluation.
Safety-related procurements range from simple consumable materials
(
such as re-inforcing steel and weld rod to complex engineered equipment such heat exchangers and motor control centers.
Consequently, receipt inspection activities and storage / maintenance requirements vary significantly. The specific types of safety-related material / equipment to be reviewed will be selected to provide a reasonable cross-section of design complexity and a reasonable chronological spread of receipt activities at CPSES.
f:
Rsvisien:
O Pcg1 2 of 6 ISAP VII.a.9 (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 The objective of this action plan is to assess the adequacy of the CPSES Receipt Inspection and Storage Program and evaluate the effectiveness of its implementation. The evaluation will provide reasonable assurance that any unidentified programmatic problems have been identified and evaluated, that potential hardware problems have been identified and evaluated, and that the current Unit 2 and common area Receipt Inspection and Storage Program is satisfactory.
The following tasks will be implemented to achieve these objectives:
Select procured material / equipment to be audited.
Identify specific Receiving Inspection Reports to be reviewed.
Develop checklists for review of program documents.
Review program documents to verify adequacy.
Develop checklists for receipt inspection and storage / maintenance records audit.
Perform audit of receipt inspection and storage / maintenance records.
Ider.tify deviations.
4.1.0 A minimum of thirty-five (35) procurement specifications will be selected to provide a reasonable cross-section of material and equipment complexity. A minimum of two (2) Receipt Inspection Reports (RIR),
for each type of material / equipment identified, will be selected for a detailed review. The selection process will assure that the RIR's chosen represent a reasonable historic cross-section of the receipt
, inspection and storage / maintenance process.
l
.fE.
l.
o Rsvision:
O Pagn 3 of 6 ISAP VII.a.9 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.3 A program review checklist will be developed containing general criteria to evaluate programmatic compliance with 10CFR50, Appendix B, criteria IV, VII, X, XIII and SAR sections 17.1.4, 17.1.7, 17.1.10, and 17.1.13.
The historic and current program documents which address the receipt inspection and storage / maintenance of the material / equipment covered by the selected RIRs will be reviewed for adequacy.
4.1.4 The applicable procurement specification, purchase order, project procedure, checklist and/or manufacturer's documentation (for storage and maintenance requirements) will be reviewed to identify the following:
Method of acceptance Acceptance by source verification.
Acceptance by receipt inspection.
In this case identify attributes to be verified at receipt inspection.
Acceptance by supplier certificate of conformance. The basis for the use of this method of acceptance will be evaluated to determine that the necessary assurance of an acceptable item was provided.
Acceptance by post-installation test at job site.
Documentation requirements to accompany shipment.
Applicable storage requirements and maintentance requirements.
This information will be documented on the records review checklists as specific criteria to be used in receipt inspection and storage / maintenance record review. As necessary, individual checklists will be
. developed for review of each RIR chosen.
It is anticipated that each Records Review Checklist will contain some criteria generic to all Receipt Inspections and Storage / Maintenance and some criteria unique to the particular RIR chosen for review.
o Ravicion:
0 Psg2 4 of 6 ISAP VII.a.9 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 1 4.1.5 Using the Records Review Checklist (s) developed above, perform reviews of selected RIRs and associated storage and maintenance records. The following are typical review attributes:
1 Verify item was inspected for damage prior to I
off-loading.
Verify item was inspected for packaging, marking and shipping requirements.
Verify that all Records Review Checklist items were addressed.
0 Verify that item was inspected for physical attributes, if the material / equipment was not inspected at the source.
l Verify proper storage and maintenance.
Deviations identified will be documented as either a construction deviation or a QA/QC program deviation and evaluated in accordance with CPRT program requirements.
l 4.2 Participant's Roles and Responsibilities l
The organizations and personnel that will participate in this i
effort are described below with their respective scopes of work.
4.2.1 Evaluation Research Corporation (ERC) 4.2.1.1.
Scope ERC is charged with the overall responsibility for performing this evaluation and preparation of the results.
4.2.1.2 Personnel Mr. J. L. Hansel Review Teaa Leader Mr. C. W. Vincent Issue Coordinator
. e Ravision:
0 Page 5 of 6 ISAP VII.a.9 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2.2 TUGC0 4.2.2.1 TUGC0 will assist in identifying and locating applicable information and documentation to support the Review Team activities.
4.2.2.2 Personnel l
Mr. D. W. Snow TUGC0 QA/QC Coordinator Others as required.
4.3 Qualifications of Personnel All personnel associated with analysis and evaluation of the systems and findings covered by this action plan shall be qualified in accordance with the requirements of the CPRT Program Plan.
4.4. Procedures i
4.4.1 CPRT Program Plan 4.4.2 Instructions and checklists which address, as a minimum, the items in paragraphs 4.1.2, 4.1.3, 4.1.4 and 4.1.5 will be developed as an integral part of this evaluation. These checklists will be retained in the ISAP working file to support the justification of conclusions.
4.5 Standards / Acceptance Criteria Applicable standards and acceptance criteria for this evaluation are contained in 10CFR50 Appendix B, Criteria IV, VII, X, and XIII the SAR sections 17.1.4, 17.1.7, 17.1.10 and 17.1.13.
4.6 Decision Criteria This action plan will be closed if no construction deficiencies, QA/QC program deficiencies or adverse trends are identified.
Ravision:
0 Pag'a 6 of 6 D
ISAP VII.a.9 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
If a construction deficiency, QA/QC program deficiency or adverse trend is identified, root cause and generic Additional reviews implication analyses will be conducted.
and/or reinspections shall be sufficient that when the results are coupled with the root cause and generic implication analyses, there is reasonable assurance that no further unidentified deficiencies exist. The action plan will then be closed.
l s
COMANCHE PEAK RESPONSE TEAM ACTION PIAN ISAk VII.b.1
Title:
Onsite Fabrication Revision No.
0 1
2 Reflects Coments P.eflects Coments Description Original Issue On Plan on Plan Prepared and Recommended by:
Review Team Leader
/
Date A S[
/ A V !$'b
}) Nb M bl Ou J. /b bsJ,h>
e r ev
'w Team V
f [L4[fd.
3f/3[fA I
e Date 8/2./ T'[
/
(E. _.,
R; vision 2
Paga 1 of 8 ISAP VII.b.1 Onsite Fabrication 1.0. DESCRIPTION OF ISSUE IDENTIFIED BY NRC (USNRC Letter January 8, 1985, Issue 8, Onsite Fabrication)
"The TRT findings regarding onsite fabrication. shop activities indicated that:
A.
The scrap.and salvage pile in the fabrication (fab) shop laydown yard was not identified and did not have restricted access.
B.
Material requisitions prepared in the fab shop did not comply with the applicable procedure.
C.
The fab shop foremen were not familiar with procedures that controlled the work under their responsibility.
4 D.
Fabrication and installation procedures did not include i
information to ensure that Brown & Root fabricated threads conformed to design specifications or to an applicable standard.
E.
Indeterminate bulk materials that accumulated as a result of site cleanup operations were mingled with controlled safety and non-safety material in the fab shop laydown yard.
F.
Site surveillance of material storage was not documented.
G.
Work in the fab shop was performed in response to memos and sketches instead of hanger packages, travelers, and controlled drawings."
2.0 ACTION IDENTIFIED BY NRC Evaluate the TRT findings and consider the implications of these findings on construction quality.
"... examination of the potential safety implications shauld include, but not be limited to the areas or activities s
.ated by the TRT.
" Address the root cause of each finding and its generic implications...
" Address the collective significance of these deficiencies...
" Propose an action plan...that will ensure that such problems do not occur in the future."
1 I
a:
Rsvision:
2 Pag 2 2 of 8 ISAP VII.b.1 (Cont'd)
3.0 BACKGROUND
This action plan involves the fabrication shop identified as a part of the NRC item on material traceability, and addressed by Issue-Specific Action Plan VII.a.1, " Material Traceability".
CPSES Safety Evaluation Report Supplement No. 11 (SSER 11), May 1985, Appendix 0, Allegation AQ-138 (pages 0-145 to 0-153) discussed fabrication shop activities under QA/QC Category SB, Onsite Fabrication. Specifically, Allegation AQ-138 consists of 12 elements:
1.
Personnel asked to perform work without knowledge of paperwork.
2.
Paperwork illegal due to post dating.
3.
Non-safety material mixed with safety-related material.
4.
' Personnel directed not to mark indeterminate material as scrap.
5.
Electrical and iron fab shop material consolidated and mixed.
6.
Electrical personnel used undocumented material.
7.
ASME QC personnel in iron fab shop did not check Brown
& Root threads.
8.
Undocumented weld repairs made on base metal.
9.
Threaded rod cut without QC verification of heat numbers.
- 10. Arc cut done too close to cut line.
- 11. Beam clips may have been cracked during bending.
- 12. Chain and triple hook fabricated without regard to procedures.
l The NRC conclusions to Allegation AQ-138 (page 0-152) are:
Substantiated:
Item 1.
Not substantiated:
Items 3, 4, 5, 7, 9, 11.
Unable to substantiate:
Items 2, 6, 8, 10, 12.
k u.
'e Ravision:
2 Pcg2 3 of 8 ISAP VII.b.1 (Cont'd)
3.0 BACKGROUND
(Cont'd)
However, SSER 11, Appendix P lists seven (7) Allegation AQ-138 concerns or deficiencies under QA/QC program area 4 Construction and Testing (page P-14).
(Note that the QA/QC program areas of Appendix P are not the QA/QC categories of Appendix 0.)
The seven (7) AQ-138 concerns or deficiencies, referenced to SSER 11, Appendix P, are:
- 1. Parts fabricated without hanger package, traveler, or drawings.
- 2. Scrap and salvage material not marked or restricted access.
- 3. Indeterminate material mingled with safety-related material.
- 4. Fabrication procedures did not identify design standards for threads.
- 5. Material requisitions did not comply with procedures.
- 6. Random QC surveillance of storage areas not performed.
- 7. Unused material not returned to warehouse.
Concerns 1 through 6 were included in the NRC-TRT January 8, 1985 letter as Items 8G, 8A, 8E, 8D, 8B and 8F respectively (see paragraph 1.0 above also). NRC-TRT January 8, 1985 Item 8C (Shop Foreman familiarity with procedures) was identified only in SSER 11, Appendix 0 (page 0-146), but was not included in Appendix P.
Adequacy of craft training is addressed in ISAP I.d.3.
Concern 7 (above) was first identified in Appendix P, and will be addressed in ISAP VII.a.1.
Background and historical information will be obtained and evaluated as a part of the implementation of this action plan.
A preliminary investigation indicates that only a small amount of safety-related work was performed in the onsite fabrication shop prior to January 1980. The program of procedural and management controls applied to onsite fabrication shop activities has evolved with time as a result of corrective actions to problems identified by both internal and external sources. The work activities performed at the onsite fabrication shop range from simple cutting of material through the fabrication of complex items which involve fit-up, welding, and machining operations. Based upon this preliminary investigation, a directed approach for selecting fabricated items for review will provide a more effective means to assess a representative cross-section of activities over the time period than will a random sample process.
n.
Rcvision:
2 Pass 4 of 8 ISAP VII,b.1 (Cont'd) 4.0 CPRT ACTION PLAN 4.1 Scope and Methodology 4.1.1 This Issue-Specific Action Plan assesses the adequacy of the procedural and management control of fabrication shop work activities at CPSES. The evaluation will consider the evolution of procedural and management controls with time and provide an assessment of the current program.
This action plan consists of two separate areas of evaluation:
4.1.1.1 Concerns which may be evaluated by review of safety related fabrication document packages:
Material requisitions not properly completed.
Fabricated thread conformance.
Fabrication to memos and sketches.
4.1.1.2 Concerns which may be evaluated by review of procedures, survey, surveillance, and audit records to identify trends and corrective action effectiveness:
Scrap and salvage area control Safety, non-safety and bulk material segregation Site surveillance of material storage 4.1.2 The specific methodology is described below.
4.1.2.1 Identify, obtain, and review applicable material storage, fabrication, and inspection procedures in effect for both ASME and non-ASME safety related work in onsite fabrication shops.
Evaluate procedural adequacy with respect to controls for material traceability, fabrication processes and item acceptability.
i Rsvicion:
2 Pega 5 of 8 ISAP VII.b.1 (Cont'd) 4.0 -CPRT ACTION PLAN (Cont'd) 4.1.2.2 Categories of both ASME and non-ASME safety-related fabricated items will be selected for review in such a manner ao to provide a reasonable cross-section of onsite fabrication shop activities during January 1980 through December 1985.
Fabrication shop activities include the following groups of work activities:
a)
Cutting of material and material identification transfer.
b)
Fitup and welding.
c)
Machining; threading, etc.
Fabricated items nelected for review will represent at least two (2) of the above groups of work activities. A minimum of three (3) items per calendar quarter will be selected over the January 1980 through December 1985 time period for a minimum total of 72 items.
Review the" completed fabrication packages for the selected pieces for adequacy of material identification, applicable drawings and procedures used, and fabrication and inspection sign offs.
If no discrepancies are identified, document the results and close the action item.
4.1.2.3 If documentation discrepancies are identified, a visual reinspection of the selected items in situ for welds, dimensions, fasteners, material identification, component identification, etc., will be performed (to confirm or resolve the discrepancies) depending'upon the nature of the discrepancy.
t iBased upon the review in Section 4.1.2.1, and hardware reinspection checklists developed under ISAP VII.c, appropriate inspection attributes and accept / reject criteria will be developed for this reinspection.
l 4
~.__
Rsvision:
2 Pcga 6 of 8 ISAP VII.b.1 (Cont'd)
~
4.0 CPRT ACTION PLAN (Cont'd)
Deviations identified will be documented as either a construction deviation or a QA/QC program deviation and evaluated in accordance with CPRT program requirements.
4.1.2.4 Review storage and surveillance procedures and records for adequacy of requirements, identification of trends, and effectiveness of corrective action.
4.1.2.5 A detailed analysis will be conducted on the data from the reviews in paragraphs 4.1.2.1 through 4.1.2.4.
Data will be analyzed to l
determine if the shop fabrication activities have met the requirements of 10CFR50 Appendix B, Criteria V, IX, and X and the FSAR.
4.1.2.6 Provide any discrepancies related to material l
traceability to ISAP VII.a.1 Issue Coordinator for integration into that action plan.
4.2 Participant's Roles and Responsibilities The organizations and personnel that will participate in this effort are described below with their respective scopes of work.
4.2.1 TUGC0 4.2.1.1 Scope Assist the QA/QC Review Team in obtaining information regarding the identity and location of all Fabrication shops used during the life of CPSES Unit 1&2 Construction.
Assist in the identification and 1
provision of all necessary specifications, drawings, procedures and other documentation necessary for the execution of this action plan.
R:vicion 2
Pag 2 7 of 8 ne a ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
-Assist in determining the type of items fabricated onsite in the respective fabrication shops.
Process NCRs that may be generated I
due to this action plan.
4.2.1.2 Personnel Mr. D. W. Snow TUCCO QA/QC Coordinator Mr. C. R. Hooton Project Coordinator (CPPE) 4.2.2 CPRT Safety Evaluation Group 4.2.2.1 Perform evaluations for safety significance.
4.2.2.2 Personnel Mr. J. A. Adam SSEG - Supervisor 4.2.3 CPRT QA/QC Review Team 4.2.3.1 Scope All activities not identified in 4.2.1 and 4.2.2 above will be the responsibility of the QA/QC Review Team.
4.2.3.2 Personnel Mr. G. W. Ross Issue Coordinator l
Mr. J. L. Hansel QA/QC Review Team Leader 4.3 Qualifications of Personnel Where test or inspections require the use of certified inspectors, qualification will be to the requirements of ANSI N45.2.6 at the appropriate level. Third-party inspectors will be certified to the requirements of the third-party employer's Quality Assurance Program and specifically trained to the requirements of the quality procedures developed under this action plan.
)F
Rsvicien:
2 Pago 8 of 8 ISAP VII.b.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
Other participants will be qualified to the requirements of the CPSES Quality Assurance Program, or to the specific requirements of the CPRT Program Plan.
4.4 Procedures
~
Checklists, guidelines, data sheets, and flowcharts may be developed as an integral part of the evaluation. These will be retained to support justification of the conclusions.
4.5 Standards / Acceptance Criteria Acceptance criteria will be based on a review of shop fabrication procedures, QC inspection procedures, codes and standards, drawings and sketches.
Fabrication shop work activities will be accepted if all required documents are present and correctly identify drawings and process procedures used, inspection criteria satisfied, material identification and type, and authorized sign offs attesting to the adequacy of the items and documentation.
4.6 Decision Criteria
~
This action plan will be closed if no construction deficiencies, QA/QC program deficiencies or adverse trends are identified.
If a construction deficiency, QA/QC program deficiency or adverse trend is identified, root cause and generic implication analyses will be conducted. Additional reviews and/or reinspections will be conducted as required. The scope of these additional reviews and/or reinspections shall be sufficient that when the results are coupled with the root cause and generic implication analyses, there is reasonable i
assurance that no further unidentified deficiencies exist.
The action plan will then be closed.
l s