ML20209F553
| ML20209F553 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/26/1987 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20209F518 | List: |
| References | |
| NUDOCS 8704300315 | |
| Download: ML20209F553 (23) | |
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COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: III.a.5
Title:
Preoperational Test Review and Approval of Results REVISION 1 O
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h E . ' ? O,1 3 3-26-9 7 I sue Coordinator Date w E Q. 0. . .. Je. ,.c.a.,,
- R iew Team Leader Date l
M O. Lt JohW W. Beck, Chairman CPRT-SRT 2h<.h r Dat'e I
r iO i
8704300315 870427 i
Ravision: 1 Pags 1 of 22 bi V RESULTS REPORT ISAP III.a.5 Preoperational Test Review and Approval of Results
1.0 DESCRIPTION
OF ISSUE I
In a Memorandum dated December 21, 1984, the Atomic Safety and Licensing Board (ASLB) described the issue as follows:
Testimony indicates that system performance did not meet the acceptance criteria, both because of obvious calculational errors and because the acceptance criteria were exceeded.
2.0 ACTION IDENTIFIED BY THE ASLB The information required by the ASLB is as follows:
We need to know how this occurred and to be assured concerning the frequency of similar errors in startup test results.
3.0 BACKGROUND
.O The ASLB conducted a companion hearing to the CPSES Operating License proceedings during mid-1984. The subject of the hearing was the alleged harassment, intimidation, and threatening of QA/QC inspectors. The portion of this hearing related to testing activities was conducted in camera, and is the subject of,a protective order issued by the ASLB. The ASLB's Memorandum resulted from TU Electric's presentation of an approved preoperational test data package, 1-CP-PT-02-02, "118 VAC RPS Inverters," as evidence in this companion ASLB hearing. The approved test data package for these inverters contained recorded test data that did not meet the stated acceptance criteria.
The function of the inverter system is to assure an uninterruptable AC power supply to the reactor protection system instrumentation.
This function is accomplished by having the inverters supplied from an AC and a DC power source, and transferring upcn loss of one source to the other without interrupting the output. The results of the first preoperational test of this system were reviewed and approved by the Joint Test Group (JTG) in January 1983. Durfcg subsequent operation of the system, ferroresonant transformers, a major component of the system, exhibited in-service failures.
I ASLBP No. 79-430-06 OL, Memorandum (Standards Applicable to Pending
, Motions) l
Rsvision: 1 Page 2 of 22
/3
- V ) RESULTS REPORT ISAP III.a.5 (Cont'd)
3.0 BACKGROUND
(Cont'd)
Investigation of the failures led to the filing of a notification to the NRC pursuant to the requirements of 10CFR50.55(e). The transformers were repaired and reinstalled. The retest requirement specified for the system was total reperformance of the original preoperational test procedure. During preparations for performing the retest, the responsible System Test Engineer, who had not performed the original test, identified the unacceptable data in the criginal test data package. Subsequently, the original test data package was presented as evidence in the companion ASLB hearing in order to impeach testimony given by an individual. A chronology of events related to this issue is presented in Attachment 1.
The preoperational test program is conducted in accordance with written administrative and test procedures. The administrative procedures are reviewed by the Lead Startup Engineer and Manager, Operations Quality Assurance, and approved by the Manager, Startup.
- The test procedures are reviewed and approved by the JTG, an N
organization whose membership reflects the major CPSES design, testing, and operating organizations. The administrative procedures establish the methods for preparation, format, review, approval and performance of test procedures, for documentation and resolution of test exceptions, and for review and approval of test results. Test procedures are prepared and performed by the Startup organization. Startup also prepares the test data package containing all the information relevant to the test results for subsequent JTG review and approval. A System Test Engineer (STE) from the Startup organization performs each of these activities (preparation, performance, and documentation) for the systems to which he is assigned. During the course of testing, one STE may perform all activities for a system or several STEs may be involved in a test. The STEs may be assigned both preoperational and acceptance tests. Preoperational tests are tests of safety-related systems and components as distinct from acceptance tests, which are the same type of tests performed on non-safety-related systems and components.
While the NRC-TET was at CPSES, they reviewed fifteen of the twenty-two preoperational test data packages associated with hot functional testing and, also, the preoperational test data package for the containment leak rate test. These reviews were documented in an NRC letter of September 18, 1984 that subsequently formed the l
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Ravision: 1 Pags 3 of 22 i
RESULTS REPORT NJ ISAP III.a.5 (Cont'd)
3.0 BACKGROUND
(Cont'd) basis, in part, of the CPSES Safety Evaluation Report, Supplement No. l 7, dated January 1985. The NRC-TRT requested additional information related to preoperational test data packages; this was the basis for the test program related action plans. Sho';tly after receipt of the NRC letter dated September 18, 1984, the Joint Test Group initiated a reevaluation of the preoperational test data packages it had previously approved. This reevaluation effort was l performed in accordance with Startup Administrative Procedure CP-SAP-11. " Review, Approval and Retention of Test Results "
augmented by additional criteria approved by the JTG. The additional criteria were specifically related to the NRC-TRT's request for additional information. A Test Deficiency Report (TDR) was issued in accordance with CP-SAP-16, " Test Deficiency and Nonconformance Reporting," to document the conduct of each reevaluation and, if necessary, to document corrective actions and retesting. The scope of the reevaluation program consisted of the three preoperational hot functional te *: data packages in which the
(]
V NRC-TRT expressed a specific concern; the seven hot functional test data packages not reviewed by the NRC-TRT; and a sample of the 139 other preoperational test data packages that had been approved by the JTG as of September 17, 1984. (The JTG continued to review and i
approve test data packages subsequent to that date.) This sample consisted of twenty preoperational test data packages considered by the JTG to be the most safety-significant. The JTG completed its reevaluation in April 1985. One reevaluation criterion, as stated in the original Startup Administrative Procedure CP-SAP-11, was to verify that the stated acceptance criteria had been met in each preoperational test data package reviewed. The JTG's review did not identify any additional acceptance criteria that had not been met.
l 4.0 CPRT ACTION PLAN The objective of this Action Plan was two-fold: a) to identify the factors that contributed to the approval of test data that did not meet specifications; and b) to provide reasonable assurance there were no similar errors made in the review of other preoperational test results.
4.1 Scope and Methodology The scope of the evaluation included the examination of the O circumstances that led to the approval of test results that U did not meet specifications, and the remaining test data packages to determine if similar errors had occurred.
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e Ravision: 1 Page 4'of 22 b'
If .
'RESULTS REPORT >
[,
ISAP'III.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
! 4.1.1 1-CP-PT-02-02, "118 VAC RPS Inverters" The original test data package was reviewed to determine the reason (s) for approval of test results.
that did not meet _the stated acceptance criteria.
j 4.1.2 Preoperational Test Data Packages Test data from the preoperational test data packagee were examined to determine if there were any other instances where test data did not meet the stated acceptance criteria via a randor. sampling program as i
discussed in Section 4.4.
l 4.2 Participants Roles and Responsibilities The CPRT Testing Program Review Team Leader, Mr. J. E.
Rushwick, was responsible for the review and evaluation
! described in Sections 4.1.1 and 4.1.2. The Startup Special l
Projects Supervisor, Mr. G. M. McGrath, provided assistance by documenting the population of acceptance criteria (reviewed
- by the RTL for completeness) and by providing technical l information as requested.
j 4.3- Qualifications of Personnel
! The CPRT Testing Programs Review Team Leader met the
- qualifications as described by the CPRT Program Plan. The Review Team Leader (RTL) was responsible for ensuring th;.t other personnel providing assistance in the conduct of the Action Plan were appropriately qualified. .
4.4 Sampling Program The RTL elected to evaluate conformance to acceptance criteria in the preoperational test data packages approved by the JTG by means of a random sampling program conducted in accordance with Appendix D. "CPRT Sampling Policy, Applications and Guidelines " to the Program Plan. The purpcse of the random l sampling program was to determine if there was a programmatic problem associated with the process of review and approval of preoperational test data packages.
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Revision: 1 Pags 5 of 22
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/ (~'T RESULTS REPORT b
ISAP III.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The JTG had approved 206 preoperational test data packages.
Subsequent to the identification of problems with the original ICP-PT-02-02, unrelated to this issue, the JTG voided the test data package and removed it from the archive records center.
The tetal population of acceptance criteria associated with the 205 remaining preoperational test data packages was 3,391.
Recognizing that one example of approved test data exceeding the acceptance criteria had already been identified, the minimum sample size necessary to test for programmatic
- implications was ninety-five items per Appendix D to the Program Plan.
4.5 Acceptance Criteria For each randomly selected acceptance criteria, the results of testing or retesting meet the stated acceptance criteria and have been approved by the JTG, or if the criteria had not been
~~s met, the JTG had approved the required retest on a Test
(} Deficiency Report.
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The following presents the results of the RTL's review conducted in order to address the concerns of the ASLB as expressed in Section 2.0.
5.1 Requirements of Stsrtup Administrative Procedures The requirements with respect to acceptance criteria are specified in Startup Administrative Procedures (SAP), which are, in some cases, augumented by additional guidance presented in Startup Interoffice Memoranda (SIM).
CP-SAP-2, "Startup Program Organization and Responsibilities," delegates responsibility for preparation of test procedures to the assigned STE.
The STE assigned to perform the test, who may be someone other than the procedure preparer, also prepares the test data package. The test data package contains the test procedure with the recorded data and any related information identified during the conduct of the test. These activities are to be performed j (N
~ \s according to the SAPS. The JTG is assigned final review and approval responsibility for test procedures and test data packages.
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Revision: 1 Pagt 6 of 22 RESULTS REPORT v
l ISAP III.a.5 i
(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) t CP-SAP-7, " Format and Content of Test Instructions / Procedures," requires the STE preparing a test procedure to state acceptance criteria "against which the success or failure of the test results may be judged," and establishes the minimum level of detail at '
which acceptance criteria must be stated. Examples of the latter are provided in SIM-82106 (
Subject:
Acceptance Criteria Clarifications, dated 11/19/82).
CP-SAP-11. " Review, Approval and Retention of Test Results," specifically requires that during the review of test results, the STE shall verify that the stated acceptance criteria have been met. SIM-83019 (
Subject:
Preoperational/ Acceptance Test Data Package Checklist, dated 2/14/83) suggested the details of a review to be performed by an STE prior to submitting a test data package to the JTG.
/N h The responsibility fcr preparing a test procedure and its test data package for subsequent JTG review rests with an STE.
This responsibility specifically includes ensuring accurate statement of the acceptance criteria during procedure preparation and verifying that the results of the test meet the stated acceptance criteria prior to submitting the test data package for JTG review and approval. The JTG's responsibilities specifically include confirming the STE's evaluation and providing final approval of the test data package.
The RTL concluded that the instructions provided in the SAPS and SIMs are sufficiently clear with regard to the responsibilities of the individuals or groups involved in preparing, reviewing, and approving test procedures and test data packages. Supplementary guidance on methods of implementation of these responsibilities (SIMs above) was provided after the 1CP-PT-02-02 test was performed. This type of evolution in test program direction is normal in the initial stages of such programs.
5.2 Approval of ICP-PT-02-02 The RTL reviewed the circumstances surrounding approval of preoperational test data package 1CP-PT-02-02. This test procedure was authored by one individual, performed by another
Revision: 1 Page 7 of 22
.( RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) ,
individual, and the recorded data and calculations were reviewed by a third individual. The RTL specifically examined the following:
the style in which test procedures were written by each of the individuals involved; the manner in which they performed tests; their work load; and the JTG's activities during this period.
5.2.1 Author of 1CP-PT-02-02 Test Procedure 1CP-PT-02-02
,Q The acceptance criteria were stated in Section 2.0 of
\x_/ the test procedure as required by CP-SAP-7. Acceptance criteria were stated for measureable parameters and equipment functionality and were applicable to the four inverters tested by this procedure.
Excerpts from pertinent sections of the test procedure and a replica of a data sheet are provided herewith as Attachment 2. The information enclosed in brackets is explanatory information added by the RTL. The handwritten entries represent actual data recorded from the test.
The acceptance criteria were stated as shown on Attachment 2. The numbers enclosed in parentheses after each acceptance criterion are the procedure step numbers where conformance with the acceptance criteria would be expected to be observed. This practiet is performed in most test procedures as suggested by CP-SAP-7.
The acceptance criterion that was exceeded was the nominal value of output voltage of 118 VAC ! 4 percent, that is, acceptance criterion 2.3 on Attachment 2. All four inverters tested in the preoperational test exceeded this output voltage specification. One
-O inverter exceeded the nominal output voltage of 118 VAC by 6.44 percent, two by 5.34 percent, and one by 4.15 percent.
Revision: 1 Pags 8 of 22 f RESULTS REPORT U
ISAP III.a.5 (Cont'd) 5.0 IMPLEMESTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The instructions'in the test procedure are clear. The data sheet is not, however, because of the ambigueus voltage regulation statement marked (A]. It is not readily apparent what information was intended to be recorded at this location. As stated in the acceptance criteria, each of the first four (7.1.7, 7.1.11, 7.1.17, and 7.1.32) output voltages should be within 4% of 118. If the author intended that the percentage deviation from 118 volts be recorded, he should h' ave provided space for four entries.
Similarly, with respect to the data developed from an analysis of the recordings, the voltage regulation entry (marked (B]) also appears to be ambiguous. The recordings are very high speed recordings of alternating current and voltage waveforms and are used [
to verify that inverter output is uninterrupted when the input source is changed.
v Other Test Procedure Writing Work The author of ICP-PT-02-02 wrote two other test procedures. One test procedure was an acceptance test that involved functional verification of non-safety-related 480 volt switchgear and motor control centers (MCC). This test procedure was clearly written and the acceptance criteria vere met.
The second test procedure was a preoperational test of two inverters performing the same uninterruptable power supply function for the balance of plant (BOP) instrumentation. The acceptance criteria were written in a similar manner as follows:
Steady State Voltage regulation of each i inverter shall be within ! 2.% of nominal i 118VAC over the load range 0% to 100% (85 I amps) and over the range of possible battery input voltages of 105 VDC to 140 VDC.
(7.1.2.2, 7.1.2.17, 7.2.6, 7.2.10, 7.2.14, 7.2.19, 7.2.22, 7.2.25, 7.2.28)
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\ RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The output frequency of each inverter shall not exceed 2 0.5 Hz of nominal frequency (60 Hz) over the load range of 0% to 100%.
(7.2.5, 7.2.11, 7.2.13, 7.2.18, 7.2.21, 7.2.24, 7.2.27)
The data sheets for this test were structured differently than for ICP-PT-02-02. In this case, the author chose to have output voltages for the various loads recorded on one data sheet, output frequency recorded and verified within the body of the procedure,
' and waveform analysis verified on another separate data sheet. The final instructions in the procedure were:
a) Analyze analog recordings 02-01-01 through 02-01-06 and record data as shown on Data Sheet 3.
Data Sheet 3 indicated that the waveforms were to be continuous or intetrupted for less than 1/4 cycle.
b) Verify i 2% voltage regulation of IVIEC1 by analyzing Data Sheet 7.
Data Sheet 7 contained only output voltages recorded
' during various load combinations and numbered to correspond to the acceptance criteria statements.
Each of the acceptance criteria in this procedure was met.
System Testing Work The author of ICP-PT-02-02 was not responsible for the performance of any tests as System Test Engineer.
i, RTL Evaluation The test procedure for the BOP inverters was the first of this author's test procedures submitted for JTG review. Approximately one month later, the acceptance i test procedure for the MCCs was submitted. And finally, two months after the submittal of the first (JT) test procedure, the test procedure for ICP-PT-02-02 was submitted for JTG review. The first test procedure i
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Revision: 1 Y
Page 10 of 22
.W (j RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
(BOP inverters) was written in a style that minimized the likelihood of making errors in data entry or interpretation of results. When ICP-PT-02-02 was submitted two months later, the author exhibited a general change in his overall organization of a test procedure.
The RTL reviewed the comments prepared by the JTG during its review of the subject test procedure. There were no comments by the JTG reviewers related to what information was actually sought on the data sheet for the voltage regulation entry.
The RTL concluded that the test procedure for ICP-PT-02-02 was misleading as written, and that the JTG review of the test procedure was initially flawed in that it did not identify the procedure as being misleading, and require that it be changed.
5.2.2 System Test Engineer for ICP-PT-02-02 e
Performance of ICP-PT-02-02 The STE performed the test in an orderly manner in two days.
The data recorded are shown on Attachment 2 for one of the four inverters tested in ICP-PT-02-02. Acceptable output voltages recorded in 7.1.7, 7.1.11, 7.1.17, and 7.1.32 would be between 122.7 and 113.3 volts.
The basis of the numbers recorded in the spaces for voltage regulation is not be readily apparent. It appears that the STE performed a graphical determination of the ratio of output voltages to arrive at the numbers recorded.
l Two of the numbers recorded at the location marked B on the data sheet may be duplicated by calculating voltage regulation as the difference in output voltage at each load divided by full load output voltage, multiplied by 100. However, on the remaining three data sheets, no
- voltage regulation entries could be duplicated in this j manner.
l l
Ravision: 1 Pcg2 11 of 22 j RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
When the nominal value of operating voltage is specified, in this case 118 VAC, the output voltages l must be within 4% of 118 VAC. The nominal value of operating voltage for these inverters is specified in the purchase specifications, the specification section of the vendor's operating manual, and in the title of the test procedure.
Test Procedure Writing Work The STE wrote six test procedures. Four tests were of inverter equipment similar to that tested in ICP-PT-02-02, and two were battery load tests. Voltage regulation was a pertinent parameter in each of these tests. One of the tests authored by this individual was of the same type of equipment tested in ICP-PT-02-02 used in a non-safety-related application O as an uninterruptable power supply for a plant computer. This acceptance test had acceptance criteria written in the same manner as follows:
The steady state voltage regulation shall be i 5% from 2/3 load (41 amps) to full load (63 - -
amps). (7.56)
The STE wrote his test procedures in a style that was different from ICP-PT-02-02 in that no data sheets were used. Steps in the body of the procedure required recording test data in spaces provided at that specific step location. The acceptable range of the parameters being measured was also placed at the specific step.
For example, step 7.56 for the test mentioned above stated:
Verify output voltage recorded in Steps 7.6, 7.15, 7.32, and 7.37 to be within 118 VAC i 5 percent (112.1 to 123.9).
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Revision: 1 Paga 12 of-22
[d)
' RESULTS REPORT ISAP III.a.5 (Cont'd)-
5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Each of this STE's test procedures was written in this style; that is, the voltage regulation statements were l either the same or very similar to that described above.
Other System Testing Work The STE performed two of the inverter procedures that he authored. There were no problems identified with these test data packages. He also performed ICP-PT-02-12. " Bus Voltage and Load Survey." This STE
- observed that acceptance criteria were not met by the
' data obtained during testing. A Test Deficiency Report was processed by this STE in accordance with the SAPS.
i' The NRC-TRT identified a concern with this test regarding inadequate specification of ratests by the JTG. The NRC-TRT concern is the subject of ISAP g_, III.a.1, " Hot Functional Testing (HFT)," and is 4
addressed in that Results Report.
RTL Evaluation 1
Two weeks prior to this STE's performance of ICP-PT-02-02, he submitted the two battery tests and one of the inverter test procedures for JTG review.
Within two weeks after performing ICP-PT-02-02, he submitted two more inverter test procedures for JTG review. The final inverter test procedure was submitted five months later. Review of the JTG comments indicated that these test procedures were not i substantially changed as a result of the JTG review, and that the procedures, as drafted and implemented, were basically as described above.
I The RTL concluded that there is no acceptable explanation for not recognizing that the acceptance criteria of ICP-PT-02-02 were not met. The STE who performed the test had written six test procedures in which voltage regulation was a parameter of interest.
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Revision: 1 Page 13 of 22 (m)
,v RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) ,
Four of the tests were for inverters of the same or similar design. These tests were written in a format that minimized the likelihood of recording or approving unacceptable test data. He had also performed the bus voltage and load survey test, and had observed that the seceptance criteria were not met. He had processed the proper documentation to document this deficiency. Yet, in the 1CP-PT-02-02 procedure, the output voltage data recorded do not meet the acceptance criteria, and voltage regulation entries appear to have been either graphically determined from the recordings or miscalculated.
5.2.3 Data Reviewer for ICP-PT-02-02 1CP-PT-02-02 Review The data sheets for each of the four inverters were O- signed by the data reviewer, indicating the recorded results were satisfactory, when, in fact, they were not.
Test Procedure Writing Work This STE authored two acceptance tests and one l preoperational test. The two acceptance tests were: a) 138KV Startup Transformer XST1 Protective Relaying Performance; and b) Unit Auxiliary Transformer & 6.9KV Common & Normal Switchgear. The preoperational test was the Power Transformer Load Test.
System Testing Work This STE performed the Power Transformer Load test and the Unit Auxiliary Transformer & 6.9KV Common & Normal Switchgear test, each of which he had authored. He also perforced the preoperational test and retest for the 345KV Startup Transformer and 6.9KV Class IE Switchgear.
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,(p) v RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
The acceptance criteria in these procedures were all met.
RTL Evaluation This STE authored and directed most of the safety and non-safety-related high voltage, high capacity electrical equipment tests performed on site. He was likely to have been mislead by the test procedure as described above, perhaps because he lacked familiarity with the low voltage, low capacity equipment tested in ICP-PT-02-02.
5.2.4 STE Work Load The author of ICP-PT-02-02 wrote three test procedures and did not perform any tests. The STE who performed
(~') ICP-PT-02-02, wrote six test procedures, four on very
\s / similar equipment, and two battery load tests. . He also performed four tests. The STE who evaluated the ICP-PT-02-02 data wrote three test procedures and performed five tests. The calendar time for these activities was approximately from September 1982 through the completion of hot functional testing in June 1983. The RTL does not consider these efforts an undue burden.
5.2.5 JTG Activities Original Review and Approval Activities The JTG began holding routine meetings to approve test procedures in April 1982. The meetings were conducted approximately weekly and test procedure approval continued through 1984. Test data packages were first introduced as an agenda item in January 1983.
ICP-PT-02-02 was one of the first test data packages reviewed and approved by the JTG. The JTG had ICP-PT-02-02 in its possession for forty-five days.
The average time for JTG review and approval of acceptance and preoperational test data packages was p i approximstely twenty-two days. The average for test
( procedure review and approval was approximately 72 days. Test data package approval continued through March 1985.
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Revision: 1 Page- 15 of 22
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RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
RTL Evaluation The JTC was performing the test procedure and test data package review and approval process in an orderly manner, allowing sufficient time for a review.
The RTL reviewed the Test Deficiency Reports (TDR) issued to document the results of the JTG reevaluation effort described in the background section of this report. The RTL concurred with the JTG's disposition of each TDR. The number of acceptance criteria contained in the above population that had been reverified as.bsing met is approximately 580.
5.2.6 Identification of Unacceptable Test Results The STE assigned to reperform the ICP-PT-02-02 test O procedure on the inverters subsequent to the installation of the repaired transformers identified the unacceptable output voltage data. This was done during his review of the original test data package in preparation for the retest. He issued a Test Deficiency Report in accordance with the SAPS.
This STE had performed one inverter test approximately 12 months prior to the retest, and was familiar with the equipment.
RTL Evaluation Detection of the error in this subsequent review demonstrates that the problem was detectable even though the style in which the procedure was written tended to obscure it.
5.2.7 RTL Evaluation of Root Cause As discussed in Section 5.3 below, the untimely detection of test data failing to meet stated acceptance criteria was, in this instance, of minor significance from a safety point-of-view. Nonetheless, since attainment of the fundamental objective of a preoperational test program, which is to provide O assurance that a facility can be operated in a manner that will not endanger the health and safety of
Revision: 1 Pags 16 of 22
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b) RESULTS REPORT ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) the public, is so closely tied to the level of scrutiny test data receive in terms of acceptability, it is important to determine the root cause of the subject incident. It is clear that the JTG's performance was less-than-adequate in exercising its responsibility to assure that acceptance criteria were satisfied. It is also clear that the STEs charged with the responsibility of reviewing test data prior to submittal of same to the JTG acted with less-than-adequate diligence. The RTL's review of the level of performance of STEs and the JTG over a broad range of additional acceptance criteria as discussed below indicates, however, that a similar failure to provide
- adequate test data scrutiny is unlikely to have occurred elsewhere and that the subject case is not typical of the performance of the JTG and STEs on the CPSES Test Program.
A review of all the preoperational testing work of the STEs involved indicates that it was performed in a satisfactory manner. The results of the random sampling program described below indicate that there is l no prograrmatic weakness in the JTG review and approval process. A review of the administrative procedures and supplementary instructions indicates that they provide adequate guidance to the personnel involved.
The root cause of the failure to identify unacceptable test data was that the process, as implemented, permitted the acceptance criterion and implementing instructions to be stated in the procedure in a sufficiently ambiguous manner that reviewers did not anticipate the misinterpretation adopted by the perfcrmer and that recorded data outside the limits of acceptability were not readily apparent. That is, had the !CP-PT-02-02 test procedure been written in a ,
format similar to the majority of procedures developed at CPSES, with the range of acceptable inverter output voltage specified, the process, as implemented, would have insured detection and resolution of the unacceptable test data.
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Ravision: 1 Page 17 of 22
- RESULTS REPORT v
ISAP III.a.5 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.3 Engineering Evaluation of the Test Date At the request of the Startup organization TU Engineering performed an evaluation of the inverter output voltage data.
TU Engineering found that the inverter's performance was acceptable based on the original test, and would not have posed any significant safety concern for the equipment powered by the inverters even if the failure to meet the stated acceptance criteria had not been detected.
5.4 Results of the Acceptance Criteria Sampling Program A sample of ninety-five acceptance criteria randomly selected from the preoperational test data packages approved by the JTG was evaluated. The evaluation showed that each of these items met the following criterion:
j e3 The results of testing or retesting meet the stated i'~') acceptance criteria and have been approved by the JTG, or if not, the JTG had approved the required retest on a Test Deficiency Report.
The results of the sampling program indicate that similar errors, if any, would be random in occurrence.
6.0 CONCLUSION
S The RTL concluded that there is reasonable assurance that the acceptance criteria in the preoperational test data packages have, in fact, been reviewed and approved according to the Startup Administrative Procedures, that the requirements in the Startup Administrative Procedure are adequate to accomplish the review and
, approval process, and that the acceptance criteria in the Unit 1 i
preoperational test data packages have been met.
This conclusion is based upon a review of the Startup Administrative Procedures, events surrounding the review and approval of ICP-PT-02-02, RTL concurrence with the JTG reevaluation effort, and the demonstration through the random sampling program that there was no programmatic problem associated with the process of review and approval of test results.
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5 Revision: I
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( RESULTS REPORT ISAP III.a.5 (Cont'd) d i 7.0 ONGOING ACTIVITIES
, There are no ongoing activities related to this issue.
8.0 ACTION TO PRECLUDE OCCURRENCE 'IN THE FUTURE The JTG recognized the need to bolster the review process of test data packages. Two new groups were formulated in February 1983.
{ The first group was internal to the Startup organization and it j
provided an independent review of test data packages prior to submittal to the JTG. In addition, the JTG formed a dedicated working group to assist it in the performance of its review responsibilities and to provide approval recommendations to the
- JTC. Subsequently, these groups were additionally chartered to
- review test procedures prior to implementation.
The RTL believes that aufficient measures have been established to preclude occurrence in the future.
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Ravie ' an: 1 Pags 19 of 22
/
U} RESULTS REPORT ISAP III.a.5 (Cont'd)
Attachment 1 l- Chronology of Events Related to ICP-PT-02-02 April 1982 -
'The JTG convenes and begins formal approval of test procedures.
- September 1982 -
The test procedure for ICP-PT-02-02 is submitted to the JTG for review and comment.
4 October 1982 -
JTG approves the ICP-PT-02-02 test procedure.
j November 1982 -
The test for ICP-PT-02-02 is conducted.
The test data package for ICP-PT-02-02 is prepared and sent to the JTG for review and approval.
January 1983 -
The JTG approves the test data package for ICP-PT-02-02.
- () June 1984 -
The STE assigned to perform the 1CP-PT-02-02 retest identifies the unacceptable test data and files a Test Deficiency Report.
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August 1984 -
The test data package for the reperformance of ICP-PT-02-02 is submitted to the JTG for review
, and was approved.
September 1984 -
The original 1CP-PT-02-02 is presented as evidence to the ASLB.
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Ravision: 1 Paga 20 of 22
/*
RESULTS REPORT ISAP-III.a.5 (Cont'd)
Attachment 2 Excerpts From ICP-PT-02-02*
1.0 TEST OBJECTIVE The objective of this test is to verify the ability of the 118 VAC uninterruptible A-C power system to provide a continuous source of power to the Reactor Protection System.
2.0 ACCEPTANCE CRITERIA 2.1 The inverter shall transfer to the DC Input Source upon loss of the normal AC input voltage without interruption. (7.1.16) 2.2 The steady state running frequency shall be 60 Hz 2 0.5 Hz from 2/3 load (41 lamps) to full load (63 amps). (7.1.7, 7.1.11, 7.1.17, 7.1.32) 2.3 The steady state voltage regulation shall be t 4% from 2/3 tN load (41 amps) to full load (63 amps). (7.1.7, 7.1.11,
's,,) 7.1.17, and 7.1.32) 7.0 PROCEDURE 7.1.7 Record output voltage and frequency on Data Sheet 1. [ Interchange steps Name/Dtte loaded inverter to 2/3]
7.1.11 Record output voltage and frequency on Data Sheet 1. [ Interchange steps Name/Date loaded inverter to full lead]
7.1.14 Stop the recorder after allowing it to run for approximately 10 seconds. Name/Date Identify the recording as 02-02-2. .
Note A copy of this recording 02-02-2 is to be attached to this test as base line data.
Information in brackets "( }" added by RTL for clarity of
() illustration.
Rsvision: 1 Pags 21 of 22 RESULTS REPORT
[\v)
ISAP III.a.5 (Cont'd)
Attachment 2 l (Cont'd) 7.0 PROCEDURE (Cont'd) 7.1.15 Observe loss of AC input alarm on I-ALB-10B, 1.16. Name/Date 7.1.16 Verify that inverter is now being being powered by the battery input Name/Date by observing the DC input current meter.
7.1.17 Record output voltage and frequency on Data Sheet 1. [ Previous steps Name/Date
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simulated a loss of AC input while a recording was made of the transfer from the AC source to the DC source]
e- g 7.1.31 Stop the recorder after allowing it I
y ,) to run for approximately 10 seconds. Name/Date Identify the recording as 02-02-3.
Note A copy of this recording 02-02-3 is to be attached to this test as base line data.
7.1.32 Record output voltage and frequency on Data Sheet 1 (previous steps Name/Date simulate a loss of DC input while a recording is made of the transfer from the DC source to the AC source]
7.1.36 Analyze recordings 02-02-2 and 02-02-3 and fill in required data Name/Date on Data Sheet 1 O
Revision: 1 Page 22 of 22 l
RESULTS REPORT ISAP III.a 5 (Cont'd)
Attachment 2 (Cont'd)
Data Sheet 1 FARAGRAFI NAME/DATE 7.1.7 Output Voltage [2/3 Load] /2 Y. 3 VAC --
N M /DATE 7.1.11 Output Voltage (Full Load] // J. 8 VAC
- NAME/DATE 7.1.17 Output Voltage (DC Source] /88. VAC NAME/DATI 7.1.32 Output Voltage (AC Source] /2 - VAC NAME/DATE 7.1.7 Output Frequency (60 t .5 CPS) (d.dJ Es NAMI/DATE 7.1.11 Output Frequency (60 t .5 CPS) 89. 93 Es O 7.1.17 Output Frequency (60 2 .5 CPS) (0. 02- Es NAME/DATE NAME/DATE 7.1.32 Output Frequency (60 2 .5 CPS) 40. 7 Es NAME/DATE Voltage Regulation (2 41) (A] O.23 1 NAME/DATE Recording 02-02-2 7.1.36 Voltage Regulation (24%) (B] O.Y I NAME/DATE 7.1.36 Waveform is Continuove "
NAME/DATI Recording 02-02-3 7.1.36 Voltage Regulation (241) (B] O. Y Z NAME/DATE 7.1.36 Waveform is Continuove ""~"~2- --
NAME/DATE
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Remarks:
Recorded By: W Dates Reviewed By: Date: '