ML20215B736
| ML20215B736 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/27/1986 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20197E251 | List:
|
| References | |
| FOIA-86-272, FOIA-86-454 ISAP-III.D, PROC-860227, NUDOCS 8610080470 | |
| Download: ML20215B736 (12) | |
Text
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COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.d
Title:
Preoperational Testing i
Revision No. 4 Reflects Comment!
Description On Plan Prepared and -
Recommended by* ,3p Review Team Leader /
Date 5 A I' Approved by:
Senior Review Team b_d d. kt _
D e. i h, /n.
esioopgvo862 l,,
PhDE06-272 F-5._
Rsvicion: 4 Pcgs 1 of 11 ISAP III.d Preoperational Testing
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described the issues in the CPSES Safety Evaluation Report, Supplement No. 7, as follows:
"In TP Category 5, the TRT found that System Test Engineers (STEs) were not on controlled distribution for design changes applicable to systems to which they were assigned; rather, they were required to obtain this information on their own initiative from the document control center prior to starting a test and were then required to incorporate that information, as applicable, into the test procedure. While the TRT did not identify any specific problems as a result'of this practice, it considers this practice to be weak since it relies too heavily on the motivations and initiatives of test personnel to ensure that they have current design information when they are developing test procedures and before conducting tests.
Typically, these are periods when they could be under more than normal pressure. Additionally, because of the number and nature of the problems found in the document control system by I the TRT QA/QC Group, the TRT could not reasonably conclude that the document control system problems identified did not affect testing activities." Page J-13, Item 3.2.3, " Findings for Test Program Issues."
"The TUEC Startup Group relies heavily on the accuracy and completeness of the design documents, which are included in the document control system, in its preparation of test procedures and during the conduct of testing. A number of problems were identified in the document control system by the TRT QA/QC Group during its review. While the TRT Test Program Group did not find that these problems adversely affected those portions of the testing program that it included in its review, the TRT cannot conclude with reasonable assurance that the document control system problems had no adverse effect on testing activities." Page J-14. Item 3.2.4, "Overall ,
Assessment and Conclusions." l 2.0 ACTION IDENTIFIED BY NRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-18, Item 4.2.4, .
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' "Preoperational Testing," as being necessary to resolve this issue are as follows:
" Establish measures to provide greater assurance that STEs and 3
other responsible test personnel are provided with current controlled design documents and change notices.
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R3visirn:
4 Pcg2 2 of 11 ISAP III.d
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(Cont'd) 2.0 ACTION IDENTIFIED BY NRC (Cont'd)
Provide NRC with reasonable assurance that the document control system problems identified by the TRT QA/QC Group did not affect the testing activities."
3.0 BACKGROUND
The Startup Administrative Procedure CP-SAP-21, " Conduct of Testing," as reviewed by the NRC-TRT, stated that the STE was required to: ,
" Review the system drawings and applicable design changes to determine that the as-built' component / system will be adequately tested by the current procedure revision to demonstrate proper component / system operation."
The TRT reviewers' concerns were twofold: (1) that this requirement may rely too heavily on an STE's motivation and initiative at the time when he is under more than normal job pressure and is expected to start testing activities and that he may not have the latest design information in his possession, and (2) that the problems identified by the NRC-TRT QA/QC Group with the Document Control Center (DCC) for construction activities may have adversely affected the testing program.
The NRC-TRT QA/QC Group's findings were specifically addressed in CPSES Safety Evaluation Report, Supplement No. 11 at Page 0-10, Item 3.2.2, " Document Control Issues," as follows:
"The QA/QC Group found that prior to l'84,9 there were numerous recurring administrative and procedural deviations in the document control function. Many of these recurring deficiencies were identified by internal and external audits.
But there was little follow up or verification by TUEC management that effective corrective actions were taken, until early in 1984 when the document control center (DCC) monitoring team began reporting to senior management. The current document control program, with an estimated error rate of one percent or less, was found to be adequately staffed and effective. The problem of incorrect and incomplete drawing packages appears to have been corrected.
In summary, the QA/QC Group found the current documentation control program to be acceptable. However, prior to 1984, as identified by CAT (Construction Assessment Team] and TUEC, there was a document control breakdown. Although many of the a
Ravisien: 4 Peg 2 3 of 11 a
i ISAP III.d (Cont'd)
3.0 BACKGROUND
(Cont'd) ;
j document control deficiencies have been corrected, the 2 implication of past inadequacies on construction and l inspection have potential generic significance which has not
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yet been fully analyzed by TUEC."
i j Subsequent to TUEC submitting Revision 2.of the CPRT Program Plan l
and ISAP to the NRC, sampling from the population described below i
in Section 4.1.2.4, " Prerequisite Test Population Definition," has 4
proceeded. The original intent was to prepara one population to be
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sampled, screened, and evaluated for impact on both the j prerequisite and preoperational test programs. The original J
population identified proved adequate for prerequisite testing but j not for preoperatiional testing. The CPRT, with SRT concurrence,
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proceeded to prepare a separate population for the preoperational
- test program evaluation. The additional population prepared for i the preoperational test program evaluation is described below in j Section 4.1.2.5, "Preoperational Test Population Definition."
j The action plan presented in Section 4.0 was developed to include a review of past and current administrative requirements for use of design documents during testing; a review of the technical test procedures utilizing the design documents; and a random sampling and evaluation program to determine the effectiveness of the administrative requirements.
4.0 CPRT ACTION PLAN l
$ 4.1 Scope and Methodology j The objective of this action plan is to resolve the two design
- document related issues identified by the NRC-TRT. The first i issue'will be investigated to determine any additional measures required to insure that STEs and other responsible test personnel are efficiently and effectively provided with i current design documents for use in their testing activities.
l The second issue will be investigated to determine if the problems with DCC identified by the NRC-TRT QA/QC Group had an adverse affect on the testing program activities.
l The individual objectives and tasks for each issue are
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discussed separately below. . ,
. l I 4.1.1 STE's Access to Current Design Documents !
I This task will determine if administrative procedures l and work practices by the Startup and DCC organizations are adequate to provide for the use of current design documents in the performance of testing activities, and l j
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Rsvicion:
4 Paga 4 of 11 ISAP III.d (Cont'd) 4.0 CPRT-ACTION PLAN (Cont'd) to identify additional requirements, if any, which need to be established to ensure compliance with this requirement.
The steps required to complete this task are: reviewing the Startup Administrative ?recedures as they relate to use of current design documents; reviewing the organizational interface and work practices between the Startup and DCC organizations; and interviewing individual STEs.
4.1.1.1 Startup hdministrative Procedure Review Review Startup administrative procedures to determine if practices are likely to lead to a programmatic discrepancy. The procedures will be reviewed to determine when administrative requirements need to be applied to the use of design documents, that
- the requirements are clearly stated, and indicate the timeliness for use of current design documents. The CPRT will perform this review.
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4.1.1.2 Startup and DCC Interface Review the organizational interfaces and work practices between the Startup and DCC organizations which are applicable to the acquisition and use of current design documents. Determine the adequacy of past and present practices in meeting the requirements of the testing program.
Identify and implement improvements if required. The CPRT will perform these reviews.
4.1.1.3 System Test Engineer Interviews Interview Systen Test Engineers to determine eneir methods of complying with the current design document requirement and to further assess the need to upgrade existing procedures and methods. The CPRT will conduct these interviews.
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Revision 4 l Pcge 5 of 11 ISAP III.d (Cont'd)
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4 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Potential.for DCC Problems to Adversely Affect the Testing Program This task will evaluate the effect of DCC problems ,
identified by NRC-TRT QA/QC Group on the testing program by determining the Startup organization's l 1
response to properly authorized design changes
- initiated by Engineering, processed through the DCC organization, and requiring a testing response by Startup.
1 The Startup organization utilizes drawings as a primary resource in the preparation of technical test procedures and the execution of testing. Other resources are used, however they are not controlled by the DCC. Startup responds to three methods of changing I the design by Engineering. The three Engineering
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design change procedures are: -direct issuance of a j revision to a design drawing which does not incorporate the other two methods; issuance of a Design Change-
'j Authorization (DCA) which is a design drawing change I described in approved documents issued temporarily a until the actual design drawings may be updated and 3
issued; and issuance of a Component Modification Card l (CMC) which is similar to the DCA.
An evaluation program will be developed and performed which will focus on opportunities for a DCC error to begin a chain of events which results in a testing i error. Error opportunities involve design changes, communicated by way of changes to design documents i distributed and controlled by DCC, where the design change created a need to change's test procedure, perform retesting, or perform additional testing.
i This type of evaluation was designed to preclude the nature of DCC errors from affecting the results.
The Startup organization utilizes only a fraction of
- the design documents prepared for the project. This subset of design documents and the changes to them are
} easily identified and.the'houndaries of a valid population of design changes readily established.
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The CPRT decided that's sampling program to resolve this issue would be appropriate because there are no i programmatic deficiencies identified to date, the
- criteria by which they will be evaluated in'this study l
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Ravioicn: 4 Pcg2 6 cf 11 ISAP III.d (Cont'd) 4.' O CPRT ACTION PLAN (Cont'd) .
I will be the same, the population of items to be sampled j is homogeneous (i.e., the process by which these items
- are handled by the DCC is the same), and thus a i sampling program in accordance with Appendix D will aid j in determining whether or not systematic discrepancies i exist.
The potential adverse effect of the DCC problems identified by the NRC-TRT QA/QC Group on the testing programs will be evaluated by: determining a calendar j interval when DCC problems could have adversely affected startup; identifying and reviewing procedures i and instructions which utilized DCC controlled design
] documents; defining the population of changes to the
- design documents; random sampling the population of changes; and evaluating the sempled design changes for adverse effects on the prerequisite and preoperational test programs.
l - The steps which are required to accomplish this task j are described below:
- 4.1.2.1 Period of Interest i
Determine the period of interest during which. i i Startup could have been adversely affected by DCC problems. This period will begin at the
, . start of prerequisite testing by Startup and the end date will be based on the results of
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CPRT review and assessment of CPSES Monitors j Team monitoring reports of DCC performance.
i These same reports were utilized by the NRC-TRT in their evaluations.
l j 4.1.2.2 Prerequisite Test Instruction Review All prerequisite test instructions will be- !
reviewed to determine the types of design i documents controlled by DCC which were used l during the execution of prerequisite testing.
All design documents of this type will be !
included in the prerequisite test population.
- The CPRT will perform this review.
4.1.2.3 Preoperational Test Procedure Review
! All preoperational test procedures performed during the period of interest and not i
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- Ravisient 4 l Pag 2 7 of 11 l r
ISAP III.d (Cont'd) j 4.0 CPRT ACTION PLAN (Cont'd)'
completely reperformed thereafter will be reviewed to identify the design documents l referenced by the test procedures and 4l controlled by DCC. The design documents
! identified will be included in the j prerequisite test population. A j
preoperational test sub-population will be
- identified from this list of referenced l design documents. This review will be performed by the CPRT.
4.1.2.4 Prerequisite Test Population Definition
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I The population of all design drawing i revisions, all DCAs, and all CMCs issued during the period of interest and used by the
)' Startup organization in the preparation of j test procedures or during the execution of
! testing will be identified. The CPRT will i identify the prerequisite population with assistance from TUGC0 Nuclear Engineering.
l Preliminary estimates indicate that the population will include approximately 75,000
- items.
4 4.1.2.5 Preoperational Test Population Definition I The preoperational test population will be
! identified from the design document reference list created by Section 4.1.2.3 which j includes only the flow diagrams and control 4
circuit schematic diagrams. In the hierarchy of engineering design documents, these two classes of drawings will have the most '
significant influence on preoperational testing. -This population will be identified l*
by the CPRT. Pre _liminary estimates indicate i that the population'will include i approximately 1,100 items.
4.1.2.6 Population Screening Criteria Each document change in the prerequisite and
! preoperational test populations will be' l screened until it meets the following criteria f
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- R vicitut 4 Pag 3 8 cf 11 ISAP III.d (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd)
- The change is to a design document.
- The change is~ issued through DCC. ,
- The document is referenced by a test procedure or is used during the
- performance of a specific test.
- The test procedures which reference or utilize the affected documents were performed during the period of interest and were not completely reperformed following the period of interest.
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- The document change occurred prior to performance of the test.
- The change would require a test or retest.
The CPRT will perform the evaluations with assistance from TUGC0 Startup.
4.1.2.7 Sample Evaluation After random selection and screening, testing records will be examined for each sample item l
to determine the folicwing:
- Whether a test was conducted by Startup per the change, or
- Whether Startup documentation demonstrated they were aware of the change.
A negative finding in both cases will constitute a discrepancy. The CPRT will perform the evaluations with assistance from TUGC0 Startup.
4.1.3 Identified discrepancies, if.any, will be processed according to Appendix E. "CPRT Procedure'for the Classification and Evaluation of Specific Design or Construction Discrepancies Identified by CPRT."
Corrective action, if required, will be implemented
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. Rsvicisnt 4 Peg 2 9 ef 11 ISAP III.d (Cont'd)
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i- 4.0 CPRT ACTION' PLAN (Cont'd) i according to Appendix H. "CPRT Procedure for the Development, Approval, and Confirmation of Implementation of Corrective Action."
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- 4.2 Participants Roles and Responsibilities ,
j 4.2.1 Organizations involved f 4.2.1.1 CPSES Startup Group i
4.2.1.2 TUGC0 Nuclear Engineering Group '
} 4.2.1.3 CPRT Testing Programs Review Team !
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! 4.2.2 Scope for each Organization j 4.2.2.1- CPSES Startup Group
- Revise Startup Administrative Procedures and instruct STEs on new procedure requirements,
- Implement corrective actions i resulting from the CPRT i
investigation into the effect on testing due to DCC problems, and t
- -Provide qualified personnel to j assist in the screening and sample evaluation.
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! 4.2.1.2 TUGC0 Nuclear Engineering Group I - Provide engineering drawing history data for sample preparation.
- 4.2.2.3 CPRT Testing Programs Review Team i i
- Evaluate the CPSES document '
] control program and applicable i Startup Administrative Procedures and control methods,
- Review and concur with applicable l Startup Administrative Procedures
! revision, i j l
! 1
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- - R; vision:
. 4 Pega 10 cf 11 ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
- Determine whether the testing program has been adversely affected by DCC problems and specify corrective actions, if nacessary, and
- Overview the work performed by other organizations oisisting CPRT.
4.2.3 Lead Individuals 4.2.3.1 Mr. S. M. Franks CPSES Startup Group 4.2.3.2 Mr. J. E. Rushwick CPR1 Testing Programs j
Review Tea
- Leader 4.3 Personnel Qualifications 4.3.1 The CPRT Testing Programs Review Team leader meets the qualifications as described by the CPRT Program Plan.
4 4.3.2 The Startup personnel participants will be qualified in accordance with CP-SAP-19, " Training / Qualification Requirements for Startup Personnel."
4.3.3 The Review Team Leader assures that other personnel providing assistance are qualified.
4.4 Procedures The following procedures will govern revision of Startup Administrative Procedures:
CP-SAP-1, Startup Administrative Procedures Manual CP-SAP-21 Conduct of Testing 4.5 Acceptance Criteria The acceptance criteria for the two investigated issues are discussed below:-
, 4.5.1 STEs Access to Current Design Docurents The procedures and methods are adequate to the satisfaction of the Testing Programs Review Team Leader to assure that STEs and other responsible test
< personnel are cognizant of and are provided with
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- R;vicicat
= 4
,j Pcg2 11 of 11 I
ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) current design documents. This finding must be supported by the results of random sampling and evaluation of the use of design change documents.
4.5.2 Potential for DCC Problems to Adversely Affect the Testing Program In order for DCC problems identified by the NRC-TRT QA/QC Group to be judged to have had no adverse effect on preoperational or prerequisite testing, a properly selected, screened, and evaluated design change
., document sample must meet the following criteria: .
i 4.5.2.1 Prerequisite Test Program i
The design change was tested as evidenced by i
approved test data or was documented as being l monitored by Startup as an open item.
4.5.2.2 Preoperational Test Program A preoperational test dure incorporated the design change or sd umented as being monitored by Startup as an open item.
4.6 Decision Criteria 4.6.1 STE's Access to Current Design Documents The administrative procedure (s) are satisfactory or, if necessary, are revised to the satisfaction of the Testing Programs Review Team Leader and concurred with by the Senior Review Team.
4.6.2 Potential for DCC Problems to Adversely Affect the Testing Program The objective of the random sampling and evaluation program is to provide reasonable assurance that the problems identified by the NRC-TRT did not, in fact, adversely affect the test program. If one or more discrepancies are found to have adversely affected the test program an expanded investigation will be undertaken in accordance with Appendices D and E.
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