ML20212E053
| ML20212E053 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/23/1987 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20212E000 | List: |
| References | |
| NUDOCS 8703040261 | |
| Download: ML20212E053 (9) | |
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COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: III.b
Title:
Conduct of the CILRT REVISION O 4
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2-/9-87 Date I)sueCoordinator 1l n- 2-l9'8?
Roview Team Leader Date
. c.d A/% 3 Sl John W(/ Beck, Chairman CPRT-SRT Date 1
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(\ RESULTS REPORT V ISAP III.b Containment Integrated Leak Rate Test (CILRT) i
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described this issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-14, Item 3.2.3, " Findings for Test Program Issues," as follows:
The Group [TRT] found no safety significance for the allegations in TP Category 3 (Containment Integrated Leak Rate Testing), but concluded that a generic problem could exist because when the CILRT leakage rate was calculated by a method different from that which was committed to in the FSAR, the FSAR had not been amended to reflect that change. The TRT questioned the TUEC procedure for documenting and identifying FSAR deviations to the NRC. . . .
2.0 ACTION IDENTIFIED BY NRC j The action identified by the NRC-TRT in the CPSES Safety Evaluation
[A_s Repart, Supplement No. 7 at Page J-17, Item 4.2.2, " Containment 7ategrated Leak Rate Testing (CILRT)," as being necessary to resolve this issue is as follows:
TUEC has identified deviations from FSAR commitments related
, to the CILRT. TUEC shall identify all other deviations from l FSAR commitments which were not previously identified to NRC.
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3.0 BACKGROUND
1 During the NRC-TRT investigation of an allegation concerning the conduct of the CILRT, the NRC-TRT reviewed the CILRT test data package. Two discrepancies involving test methodology were identified that suggested the possibility of a generic problem concerning test program commitments in the FSAR. The two discrepancies concerned the method of calculation of leakage rate and the physical configuration of the containment system during testing. The NRC-TRT forwarded these items to NRC-NRR for evaluation, and the resolution of them is documented in CPSES Safety Evaluation Report, Supplement No. 7 at Page J-18 as follows:
This title corresponds to the specific heading of the paragraph l /'~') that identified this issue in the NRC letter dated September 18,
\j 1984 and does not accurately reflect the scope of the review. The review considers FSAR commitments associated with preoperational testing.
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, Page 2 of 8 N RESULTS REPORT ISAP III.b (Cont'd)
3.0 BACKGROUND
(Cont'd)
TUEC was also required in the September 18, 1984, letter to
" justify to NRC the conduct of preoperational CILRT (Type A Test) with penetrations isolated and leakage rate calculation in accordance with ANSI /ANS 56.8 rather than ANSI N45.4-1972" and to " identify to NRC any other differences in the conduct of the CILRT as a result of using ANSI /ANS 56.8 rather than
- ANSI N45.4-1972." These issues have been resolved (see page J-83); accordingly, the actions are no longer required.
In addition to the CILRT data package, the NRC-TRT reviewed fifteen of the twenty-two preoperational test data packages associated with hot functional testing. These reviews were also addressed in the CPSES Safety Evaluation Report, Supplement No. 7. No additional FSAR deviations were reported by the NRC-TRT.
l l The preoperational test. program is conducted in accordance with i written administrative control procedures and test procedures. The l administrative procedures are reviewed by the Lead Startup Engineer and the Manager, Operations Quality Assurance. These procedures are approved by the Manager, Startup. The test procedures are reviewed and approved by a Joint Test Group (JTG),
the membership of which reflects the CPSES design, testing, and operating organizations, as well as the NSSS supplier. The administrative procedures establish the methods for preparation, l review, approval, conduct, and results review of each test procedure. Test procedures are prepared and executed by the Startup organization, which also prepares the test data packages for subsequent review and approval by the JTG.
Shortly after receipt of an NRC letter dated September 18, 1984, in which the findings of the NFC-TRT were initially reported, the JTG initiated a reevaluation of the preoperational test data packages it had previously approved. 'Ihis reevaluation effort was performed in accordance with Startup' Administrative Procedure CP-SAP-11, l " Review, Approval and Retention of Test Results," augmented by additional criteria approved by the JTG. The scope of the reevaluation included the three hot functional test data packages in which the NRC-TRT expressed a concern regarding test objectives; the seven hot functional test data packages that were not reviewed i
by the NRC-TRT; and a sample of the remaining 139 preoperational test data packages that had been approved by the JTG as of September 17, 1984. The sample consisted of twenty test data
[ packages considered by the JTG to be the most safety-significant.
The JTG completed its reevaluation in April 1985. One reevaluation l
O criterion, among others, was to reverify FSAR conunitment compliance as it applied to each of the test data packages. The JTG did not identify any additional undocumented deviations from FSAR connaitment s.
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RESULTS REPORT ,
ISAP III.b (Cont'd) '
3.0 BACKGROUND
(Cont'd)
In Revision 3 and previous revisions to ISAP III.b, " Containment
- - Integrated Leak Rate Test," the approach to the FSAR ccmmitment L compliance review was to examine additional FSAR sections if discrepancies were noted in the test program commitments. This Action Plan examines the test program rel.ated commitments. FSAR compliance considerations related to the design and construction of
, CPSES are being conducted under the Design Adequacy and Quality of Construction Programs described in Appendix A and B, respectively, to the CPRT Program Plan. 't 4
4.0 CPRT ACTION PLAN The objective of this Action Plan was to provide reasonable
, assurance that the preoperational testing program has been, an,d is being, conducted in accordance with commitments made in the-FSAR.
l 4.1 Scope and Methodology The following tasks were implemented to achieve the objective:
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- 4.1.1 Startup Administrative Procedures The administrative process by which the Startup organization identifies and reports FSAR commitment deviations was reviewed.
4.1.2 FSAR Commitments
! The CPRT reviewed preoperational testing commitments i
presented in Table 14.2-2, "Preoperational Tests -
i Summaries," of Section 14.2, " Initial Test Program." i The relevant preoperational test data packages were { v reviewed to determine if commitments in the FSAR had ,
been met. The review was based on a sampling program
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discussed in Section 4.4, " Sampling Program." '
i 4.2 Participants' Roles and Responsibilities 7<,
The CPRT Testing Program Review Team Leader, Mr. J. E. '
Rushwick, was responsible for the reviews and evaluations j described in Sections 4.1.1 and 4.1.2. The Startup Special Projects Supervisor, Mr. G. M. McGrath, provided assistance with the sampling program.
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Revision: 0 Page 4 of 8 RESULTS REPORT ISAP III.b (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) 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 that other personnel providing assistance in the conduct of the Action Plan were appropriately qualified.
4.4 Sampling Program Commitments pertaining to the preoperational testing program are discussed in various sections of the FSAR. These commitments are shown in summary form in FSAR Table 14.2-2, "Preoperational Tests Summaries."
Since previous reviews by the JTG and NRC-TRT had not led to the identification of any additional deviations from FSAR
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commitments, the RTL elected to examine compliance with FSAR commitments via a random sampling program, as a means to (s-'/)
s determine if a generic problem existed. The population of FSAR commitments examined consisted of the 254 specific tests listed in the Test Methods section of FSAR Table 14.2-2.
Recognizing the FSAR commitment deviation identified by the NRC-TRT as an item in the population of interest, the minimum sample size necessary to achieve the basic objective of L
Appendix D. "CPRT Sampling Policy, Applications and Guidelines," of the CPRT Program Plan, was ninety-five items.
4.5 Acceptance Criteria 4.5.1 Startup Administrative Procedures The Startup Administrative Procedures were acceptable if measures were established to assure the identification and reporting of FSAR commitment deviations.
4.5.2 FSAR Commitments Each preoperational testing-related FSAR commitment sampled was met, or if not, the reason had been documented and reported to the NRC.
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(N RESULTS REPORT ISAP III.b' (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The following presents the results of the review of the Startup organization's administrative procedures as they relate to FSAR commitment adherence, and the results of.a review of a random sample of FSAR commitments for compliance.
5.1 Startup Administrative Procedures The Startup organization's Startup Administrative Procedures (SAP) were reviewed. The following procedures were identified as establishing requirements pertinent to the issue of FSAR commitment adherence prior to the NRC-TRT review:
CP-SAP-2, "Startup Program Organization and Responsibilities," delegates responsibility for FSAR commitment compliance during test procedure
., preparation, review, and approval to the Startup and TU Engineering organizations. The Manager of Startup is specifically identified as being responsible for assuring that all preoperational testing is identified and performed according to the requirements of the FSAR.
CP-SAP-7, " Format and Content of Test Instructions /
Procedures," provides guidelines for preparing each section of a test procedure. The test procedure preparer is directed to use appropriate references in the FSAR when establishing the objective of a test procedure. References used in preparing a test procedure are required to be identified.
CP-SAP-8, " Review, Approval and Revision of Test Instructions / Procedures," directs the test procedure
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reviewers to an attachment that provides guidance for the JTG review. The attachment directs the reviewers to assure that the stated acceptance criteria are consistent with FSAR commitments.
A review of the evolution of the above-noted procedures was j conducted. It was determined that the need to address FSAR testing-related commitments had been recognized since the inception of the CPSES Startup Program. The findings described abov: with respect to the current revision of SAP Nos. 2, 7 and 8 are equally valid for all of the preceding revisions as far back as late 1979. The first Unit 1 O preoperational test was started in July 1982.
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, RESULTS REPORT ISAP III.b (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
It should also be noted that subsequent to hot functional testing, the JTG recognized that some preoperational testing commitments described in the FSAR would not be met. These commitments related to performing tests at normal operating temperatures and pressure. At that time, the next heatup was l scheduled in the interval between fuel loading and criticality. A program of deferred preoperational testing was i
organized. The program consisted of evaluating preoperational test commitments, evaluating the consequences of deferring preoperational tests with the requirements of the Technical Specifications, and, where necessary, seeking approval of NRC-NRR. This program was in place and operating prior to the i.
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NRC-TRT review. (See Results Reports for issues III.a.2, "JTG Approval of Test Data " and III.a.3, " Technical Specifications for Deferred Tests.")
, The following additional SAPS were modified subsequent to the i
NRC-TRT review to include explicit reference to FSAR commitments:
CP-SAP-11. " Review, Approval and Retention of Test Results," provides guidance in an attachment for the '
JTG's use during its review of test data packages. One l
criterion tc that the " test satisfied applicable FSAR '
commitments."
CP-SAP-12. " Deviations to Instructions / Procedures,"
requires that Test Procedure Deviations (TPD) that change the intent of a test procedure be evaluated by the Startup organization's Technical Support /Startup Special Projects (TS/ SSP) Group for FSAR testing commitments compliance and approved at the next JTG meeting. The SAP defines a " change of intent" as a procedure deviation that " includes changes to the test objective, acceptance criteria or the test methods which prevents verification of the test objective or j acceptance criteria or FSAR commitments." All TPDs become an integral part of the test data packages subsequently reviewed and approved by the JTG.
CP-SAP-14. " Design /FSAR/ Technical Specification Change l Request Processing," requires that FSAR changes, among other changes, be tracked as to the status of each change, and provides instructions for initiating l changes to the FSAR.
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V RESULTS REPORT ISAP III.b (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Preoperational testing generally occurred prior to NRC-TRT review. Although the Startup organization did not have a specific written admir.istrative procedure for processing an FSAR change until after the NRC-TRTs review, the practice was for Startup to complete a standard FSAR Change Request form.
This form was generally available throughout Startup's facilities, as well as those of Operations and Engineering.
The RTL reviewed approximately one-hundred FSAR Change Requests submitted by the Startup group using this form.
These forms were available in a TS/ SSP historical file. The purpose of this review was to determine the types of changes that Startup was requesting, and the depth of detail in which they were reviewing the FSAR prior to the revision of CP-SAP-14. The majority of these changes were requested during test procedure development, and consisted of necessary clarifications due to design changes or of corrections due to inconsistencies between FSAR sections. The changes reouested h
\m) by the Startup organization were found to be very detailed in nature, indicating that a thorough review of the FSAR had been performed as it relates to testing activities.
5.2 FSAR Commitment Compliance Review As described in Section 4.4, ninety-five preoperational testing-related FSAR commitments were randomly selected and evaluated for compliance. In each case, the FSAR commitment was found to have been met as evidenced by supporting documentation in the associated test data package. No deviations were found, and no adverse trends were identified.
5.3 Root Cause and Generic Implications No testing deficiency'was identified through the implementation of this Action Plan. Accordingly, no root cause and generic implications analyses were required. With respect to the FSAR deviation identified by the NRC-TRT, the RTL found no evidence to substantiate the existence of a generic problem.
6.0 CONCLUSION
S s Based on its review of established administrative procedures and y ) practices, and the results of the sampling program conducted to provide a statistical measure of commitment compliance, the RTL
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, RESULTS REPORT ISAP III.b (Cont'd)
6.0 CONCLUSION
S (Cont'd) concluded that there is reasonable assurance that the preoperational test program has been, and is being, conducted in accordance with the commitments presented in the FSAR.
7.0 ONGOING ACTIVITIES There are no ongoing activities.
8.0 ACTIONS TO PRECLUDE OCCURRENCE IN THE FUTURE No actions to preclude occurrence in the future were required.
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