ML20214K656
| ML20214K656 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/06/1986 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20214K654 | List: |
| References | |
| NUDOCS 8608220014 | |
| Download: ML20214K656 (15) | |
Text
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O COMANCHE PEAK RESPONSE TEAM RESUI.TS REPORT ISAP: III.a.4
Title:
Traceability of Test Equipment REVISION O i
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! Issue Coordinator Date /
(' C. J. 2 9- Q (
ew Team Leader Date O n a.2-i John 54 Seck, Chairman CPRT-SRT 3]~shs Date O
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. 'Page 1 of 14 RESUI.TS REPORT ISAP III.a.4 Traceability of Test Equipment
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-72 and 73, Item 4. " Assessment of Safety Significance," as follows:
...although temperatures were taken and logged during the test
[ICP-PT-55-11. " Thermal Expansion,"), the specific (temperature] asasuring device used at each monitored location was not logged. As a result the calibration of the measuring device could not be traced to the monitored location with the
- information contained in the test data packages. The TRT found that the completed test data packages did contain the calibration data for the measuring devices used, but as alleged, the devices could not be traced directly to specific monitored locations. While pursuing this matter, the TRT interviewed TUEC personnel who participated in the testing and found that a test coordinator maintained a log which tied the O devices to the specific monitored locations; however, the log was not ande a part of the test data package. The TRT pointed out to TUIC that while the direct connection was not required by the test procedure as written, the data must be included as part of the test data package.
l 2.0 ACTION IDENTIFIED BY NRC The actions identified by the NRC-TRT in the CPSRS 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 Incorporate the information necessary to provide traceability
- between thermal expansion test monitoring locations and measuring instruments. Also establish mAministrative controls to assure appropriate test and measuring equipment traceability during future testing and plant operations.
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3.0 BACKGROUND
The preoperational test program is conducted according to written procedures approved by a Joint Test Group (JTG), whose membership reflects the major CPSES design, testing, and operating organisations. The preoperational tests are conducted by the
e Revision: 0 Page 2 of 14 RESULTS REPORT ISAP III.a.4 (Cont'd) i j
3.0 BACKGROUND
(Cont'd)
Startup organization according to the JTG approved procedures. The ,
- System Test Engineer (STE) responsible for performing a particular test also prepares the final test data package for subsequent l review and approval by the JTG. The test package for ICP-PT-55-11
" Thermal Expansion," had been prepared and was in the process of being reviewed by Startup prior to JTG review when the NRC-TRT reviewed the package. When the concern described in Section 1.0 was expressed by the NRC-TRT, the Startup organization revised the test package to include the requested information.
As referred to in various standards, the word " traceability" defines a requirement that asasuring and test equipment (M&TE) shall be calibrated utilizing reference standards whose calibration has a known valid relationship to nationally recognized standards such as those maintained by the National Bureau of Standards. The traceability requirement referred to by the NRC-TRT is established when METE exhibits a nonconformance, that is, when a calibration check indicates the equipment was out-of-calibration. This latter O requirement is discussed fully in Section 5.1,
" Standards / Commitments Review."
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).
' CP-SAP-16, " Test Deficiency and Nonconforssace 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 correceive action required, and/or the retesting necessary to resolve the
' problem. Both TDRs and TPDs become part of the completed test record reviewed by the JTG prior to acceptance of the test results.
4.0 CPRT ACTION PLAN 4.1 Scope and Methodolosy The objective of this action plan was to ensure that ICP-PT-55-11. "Theras1 Expansion," had traceability of M&TE to the degree requested by the NRC-TRT, and that administrative controls are in place to ensure required traceability during future testing and plant operation.
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- Page 3 of 14 RESULTS REPORT ISAP III.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
The following tasks were implemented to achieve the above
, objective:
4.1.1 Industry standards and TUGCO commitments were reviewed to ascertain the degree of traceability documentation for M&TE which should be included in applicable procedures.
4.1.2 Test Procedure Deviation (TPD) No. 36 was issued to include information requested by the TRT in the test data package that related specific test instrument ,
identification numbers to the locations where the test instruments were used. Test Deficiency Report (TDR)
No. 3418 and TPD No. 37 were then issued to include j traceability (required by TUGCO) to calibration of the 4 instruments and the required calibration data relating to the instrument identification numbers in the thermal expansion test data package for ICP-PT-55-11.
4.1.3 All Startup personnel responsible for conduct of testing were reinstructed on the Startup administrative requirements applicable to the traceability of M&TE.
1 4.1.4 Startup personnel responsible for conduct of testing were reinstructed on the Startup administrative i requirements applicable to the use of Test Procedure Deviations.
4.1.5 Administrative controls 89plicable to documentation requirements for M&TE which have been established for the Initial Startup Test program were reviewed for adequacy.
i 4.1.6 Administrative controls applicable to documentation requirements for M&TE which have been established for station operation sad maintenance activities were reviewed for adequacy.
4.1.7 Startup Administrative Procedure requirements for -
indoctrination and training of Startup personnel were reviewed to ensure that lessons learned from this activity had been incorporated.
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- RESULTS REPORT l ISAP III.a.4 (Cont'd) d 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Participants' Roles and Responsibilities 4.2.1 The Startup Special Projects Group Supervisor, Mr.
S. M. Franks, was responsible for ensuring that traceability information on M&TE used for thermal expansion testing as requested by the TRT had been included in the completed test data package for ICP-PT-55-11.
l 4.2.2 The Startup Manager, Mr. R. E. Camp, was responsible l
for ensuring that all Startup personnel had been adequately reinstructed on the administrative ,
requirements for M&TE traceability and proper utilisation of test procedure deviations.
4.2.3 The CPRT Testing Programs Review Team Leader Mr. J. E.
Rushwick, and the Issue Coordinator, Mr. T. M. Broad, were responsible for reviewing existing administrative O controla for documenting the traceability of M&TE including training requirements used for Preoperational Testing, Initial Startup Testing, Operation and Maintenance activities, and assuring necessary corrective actions were taken.
4.3 Qualifications of Personnel 4.3.1 The CPSES Startup Manager and Startup Special Projects Group Supervisor are qualified to the highest level provided in CP-SAP-19, Training / Qualification Requirements for Startup Personnel."
4.3.2 The CPRT Testing Programs Review Team Leader meets the qualifications as described by the CPRT Program Plan.
4.3.3 The Review Team Leader was responsible for ensuring that other personnel providing assistance in the conduct of the Action Plan were appropriately qualified.
4.4 Acceptance Criteria Administrative controls for M&TE traceability are acceptable if applicable administrative procedures are used. These procedures are acceptable if they require that identification O and calibration information for NATE used to obtain acceptance data be entered on the permanent test results record.
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. Revision: 0 Page 5 of 14 O RESULTS REPORT ISAP III.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Decision Criteria The action plan will be considered complete when the CPRT has determined that applicable administrative procedures are consistent with the commitments to be identified during the conduct of this ISAP with regard to control of M&TE traceability documentation, and there is reasonable assurance that METE information is being handled in accordance with these procedures.
t 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The CPRT reviewed this issue by examining the specific test data package in question, and performing the reviews requested by the NRC-TRT and described in Section 4.1 above. The following presents c'.no results of the review.
4 5.1 Standards /Connicaents Review TUGCO's commitment relative to M&TE traceability is presented in Section 17.2.12 of the CPSES FSAR:
When test and asasuring devices utilized in activities i affecting quality are found to be out of calibration, i
an evaluation is ande and docuented concerning the validity of previous tests and the acceptability of items previously tested since the last valid calibration.
The above couaiteent is consistent with the requirements of industry standards and guidelines which address M&TE use, control, sad calibration. In particular, IEEE Standard 498-1980, " Standard Requirements for the Calibratica and Control of Measuring and Test Equipment Used in the Construction and Maintenance of Nuclear Power Generating Stations " and ANSI N45.2.8-1975, " Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," discuss this subject.
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Revision: O Page 6 of 14 RESULTS REPORT ISAP III.a.4 (Cont'd) 4' 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
Specifically, ANSI N45.2.8-1975 states:
When measuring and test equipment is found to be out of calibration, an evaluation shall be made of the validity of previous inspection or test results and the acceptability of mechanical items inspected or tested since the last calibration check.
and IEEE 498-1980 contains the following:
M&TE and reference standards found to be out of .
calibration or which have not been properly maintained, or calibrated, or which have been subjected to possible damage, shall be identified as nonconforming and removed from service until such time as corrective measures have been taken. All equipment tested or calibrated by the item since the last calibration shall be identified and sufficient investigations performed O to either reestablish the acceptability of the equipment or to confirm a nonconformance.
TUGCO's specific testing-related commitment concerning MATE is established in Regulatory Guide 1.68 " Initial Test Programs for Water-Cooled Nuclear Power Plants," paragraph 1
" Documentation of Test Results," of Appendiz C, " Preparation of Procedures," which states the following:
Records should identify each observer and/or data recorder participating in the test, the type of observation, the identifying numbers of test or asasuring equipment, the results, the acceptability, and the action taken to correct any deficiencies.
The recording of calibration data for M&TE for preoperational testing is addressed in two Startup Administrative Procedures.
CP-SAP-7, " Format sad Content of Test Instruction / Procedures,"
establishes the following requirement for NATE used in preoperational tests:
A space will be provided in this section (Section 4.0,
" Test Equipment,"] or on the appropriate data sheet to record the test equipment identification number, calibration due date. . .
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. O Page 7 of 14 RESUI.TS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESUI.TS (Cont'd)
CP-SAP-21, " Conduct of Testing," establishes the following requirement:
The STE shall ensure that the test equipment identification number and calibration due date for test equipment used to measure and record acceptance data is recorded on the test data sheet or provided in the body 2 of test procedures.
Based on the above, it was concluded that compliance with the traceability requireagnts for a nonconforming situation say be achieved by various methods as long as sufficient information
' is available to perfore the required evaluation. For example, compliance any be achieved by requiring traceability of M&TE use to a building, a room within a building, or an elevation within a building. Recognizing that various options are available, TUCCO's Startup organisation established two i
' alternatives for M&TE traceability compliance. The M&TE used may be traced to the specific test procedure by recording the l
calibration and identification information in Section 4.0,
" Test Equipment " of a test procedure. The M&TE used say also be traced to specific locations when the calibration and identification information is recorded on the data sheets used to record test data. Both methods are acceptable and achieve compliance with industry codes and standards.
With traceability only to a test procedure, an entire test any have to be repeated if M&TE used is . subsequently found to be out-of-calibration. Por that reason, providing traceability for M&TE to each monitoring location can prove to be useS11 when performing the required evaluation after identifying a nonconformance. However, this degree of tracambility, as requested by the NRC-TRT for ICP-PT-55-11, is not a requirement; it is a ar.cter of convenience and economics in order to minimize the amount of ratesting which may be
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required to be performed.
5.2 Test Data Packane.1CP-PT-55-11. "Theras1 Expansion" _
This test data package had been amended by the Startup organisation to include the information requested by the NRC-TRT and was subsequently reviewed and approved by the JTG.
The CPET Third-Party reviewed the JTG approved test data package for M&TE traceability conformance with TUGC0 O commitments.
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RESULTS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.1 Observations During this review, the following were observed:
a) Two pages of Table II. " Digital Thermometer Calibration Record," which were designated to contain the information required to meet TUGCO's M&TE traceability commitment, were !
blank at the time of the NRC-TRT review.
b) The specific instrument calibration data l
sheets which contained the information necessary to complete Table II were in the data package in Section 5.0 " Miscellaneous Information."
c) The STE had failed to fill out Table II when the test equipment was checked out from the TUGC0 I&C group although the information was included in Section 5.0.
d) All that we,s required at the time of the TRT review to be in complete compliance with Startup administrative procedures and TUGC0 l
commitments was to transfer the unique test -
equipment identifier and calibration due date from the es11bration data sheets which were in the test data package to Table II.
e) Temperature and thermal movement data were recorded and analysed at specific steady-state temperature plateaus during the rise to normal operating temperature and pressure. At each plateau and at normal operating conditions, the actual recorded
- temperature and therasi movement data were correlated with those movements predicted by the stress analyses. It should be noted that L previous ISAFs for III.a.4 mentioned in the background information section that the temperature data obtained from this test was used for information only and was not used to judge acceptability of the test or to substantiate any engineering calculations.
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i RESULTS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) f) Subsequent to its use in ICP-PT-55-11, calibration checks were performed on all M&TE utilized, and no items of nonconformance were identified.
g) The los that is referred to in Section 1.0 i
was, in essence, a test planning document developed by the STE to coordinate the ef'ucts of more than 120 data collectors for tnis preoperational test. The additional information which it contained was utilized by the Startup group in responding to the NRC-TRT's request.
h) During the conduct of ICF-PT-55-11 and subsequent consolidation of data and results, i
thirty-eight TFDs and 636 TDRs were properly -
generated. The TPDs were generated to add l new design information to data sheets, and most of the TDRs were generated due to supports not being installed, support modifications required during conduct of test, or failure of supports to meet acceptarae criteria. The TDRs identified th'e specific discrepancy and established retest requirements.
- 1) All items which failed to meet the test acceptance criteria were either resolved by engineering action or left as open items which were transferred to Plant Operations for ratesting and scheduled as part of the Initial Startup Program.
5.2.2 Conclusions l
Based on the above observations it was concluded that the appropriate information required by CP-SAP-7 and CP-SAP-21 was included in the test data package for ICP-PT-55-11, and only an oversight on the part of the STE resulted in his failure to completely fill out Table II.
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Rovision: 0 Page 10 of 14 RESULTS REPORT ISAP III.a.4 (Cont'd)
- 5.0 IM?LEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)
To provide an added sessure of assurance that the applicable requirements concerning M&TE were being properly implemented, a review of other test data i packrges was undertaken. In conjunction with that implementation of Action Plan III.a.1, "Not Functional i Test Data Packages," twenty-seven preoperational test data packages were reviewed for proper M&TE documentation. In all of the tests, provisions for M&TE were found to have been made in accordance with i requirements of CP-SAP-7 and data were entered in accordance with the requirements of CP-SAP-21.
5.3 M&TE Reindcetrination Startup personnel were reindoctrinated in the M&TE requirements established in CP-SAP-7 and CP-SAP-21.
5.4 Test Procedure Reindoctrination Startup personnel were reindoctrinated in the requirements of CP-SAP-21. " Conduct of Testing," which establishes i
- requirements applicable to the use of Test Procedure Deviations.
5.5 Initisi Startus Procedures i
l A review was conducted of the Initial Startup procedures l
listed in Attachment 1 to this Results Report, and it was l
determined that MATE traceability requirements were adequately addressed in accordance with the criterion in Section 4.4.
l 5.6 Station Procedures A review was conducted of the Station administrative procedures listed in Attachment 2 to this Results Report, and it was determined that M&TE traceability requirements were adequately addressed in accordance with the criterion in Section 4.4.
As an additional indication of the adequacy of the M&TE program at CPSES, it should be noted that an evaluation was conducted by the Institute of Nuclear Power Operations (INPO) of the entire CPSES Instrument and Control Program in April and May, 1985, and no discrepancies were identified. The
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I RESULT 3 REPORT , -
5 i ISAP III.a.4 (Cont'd)
J 5.0 IMPLEMENTATION OF ACTION 'PL M AND DISCUSSION OF RESULTS'(Cont'd) evaluation stated that stric'c.-Jatailed adherence =tc the program as detailed in CPSES Precedure STA-608;'" Control of Measuring and Test Equipment," was noted as well as-couprehensive incorporation of.the recossendations of INPO Good Practice MA-303, "Concrol/ pod Calibretic.n of Measuring and Test Equipment (M&TE)." ,
5.7 Training Requirements The administrativa procedure which addresses personnel
' training, CP-SAP-19. " Indoctrination / Training /Qu11fication .
Requirements for Startup Personnel," defines the indoctrination and ednimum qualifications that are required for Startup personnel assigned to perform testing and related activities and provides a method of documenting personnel indoctrination and qualification. The review of this procedure and the personnel training files indicated that indoctrination'in the requirements of CP-SAP-7 and CP-SAP-21 was required, c'onducted, and documented.
5.8 Root Cause and Generic Implicattons No testing deviation or deficiency was, identified and no I
generic condition exists which indicates that there are inadequate controls on M&T3 tracsability in preoperational f
testing, initisi startu) tening, or station procedures at CPSES. Accordingly, no root cause determination is required.
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6.0 CONCLUSION
S Based on the discussion presented in Section 5.0 abovo,ait was
- concluded that:
- 1. The M&TE' traceability inforestion requssted by the NRC-TRT is
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included in the 1CP-PT-55-11. " Thermal Expensioc," test data package.
- 2. Requirements exist in Startup and Station implementing procedures to ensure compliance with TUGCO's M&TE traceability l coenitaants.
7.0 ONGOING ACTIVITIES There are no ongoing activities.
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- Page 12 of 14 RESULTS REPORT ISAP III.a.4 (Cont'd) 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE No action was required as a result of this issue, but it should be noted that subsequent to the identil!ication of this issue by the NRC-TRT, CP-SAP-19 was revised to provide more specific requirements for training of personnel involved in various levels of testing activities, and reindoctrination of personnel was conducted as described in Sections 5.3 and 5.4.
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RESULTS REPORT ISAP III.a.4 (Cont'd)
Attachment 1 l
- Initial Startup Procedures Reviewed STA-801 Initial Startup Program ISA-001' Initial Startup Test Procedures ISA-004 Conduct of Initial Startup Testing ISA-005 d Initial Startup Test Package Preparation, Review, and Approval O
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Attachment 2 CPSES Station Procedures Reviewed 2 '
STA-202 Preparation, Review, Approval, and Revision of Station Procedures STA-209 Preparation, Review, Approval, and Revision of Station Instructions STA-608 Control of Measuring and Test Equipment i STA-702 Surveillance Test Program EDA-105 Engineering Department Surveillance Test Procedures EDA-112 Results Engineering Testing Guidelines EDA-113 Conduct of Results Engineering Test Procedures ODA-206 Preparation of Operations Test Procedures and Equipment '
Test Procedures ODA-207 Guidelines for the Preparation and Review of Operations Procedures MDA-201 Electrical and Mechanical Maintenance Procedures and Instructions MDA-204 Maintenance Engineering Instructions INC-107 I6C Scheduled Calibration Maintenance Program l
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O TO: CPRT SENIOR REVIEW TEAM FROM: Chairman, Results Report and Working File Review Committee DATE: July 24, 1986
SUBJECT:
Working File Verification Report for ISAP No.III.a.4, Rev. O The Working File review and verification team has completed its review of the Working File for ISAP No. III.a.4, Rev. O. Our conclusions and (if applicable) any remaining unresolved comments are presented below.
NO YES X The ISAP was implemented as defined and approved by the l
SRT.
X The content of the Working File is complete and organized in a manner consistent with the requirements of the CPRT Program.
X The work reported in and conclusions reached in the
' Results Report for the ISAP are substantiated by the information contained in the Working File.
Review Co M ttee Comments:
I Comment Continutation Sheets Attached: Tes _ No X No. of Sheets
_-_ f - g&A _ k. &~g Chairman, Results Repq t and-3 pview Team Leader, O ISAP No. III.a.4 Working File Review Committee TRT2MS i
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