ML20235G485

Forwards Rev 1 to Issue Specific Action Plan III.a.1, Hot Functional Testing. Rept Should Be Placed in Sequence Behind Tab Testing in Results Repts Binders Previously Submitted.Related Correspondence

ML20235G485
Person / Time
Site:	Comanche Peak
Issue date:	07/08/1987
From:	Woolridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel
References
CON-#387-3978 OL, NUDOCS 8707140269
Download: ML20235G485 (44)

Text

_ _ _ _ _ _ - - _

N gELATs Q CORRESPONDED 9A WORSHAM, FOnstrue, S AMPELS & WOOLDRIDGE THIRTY TWO HUN D RED. FO Ol BRVAN TOW E R

^*

f E

A wCOLDR DGE DALLAS, IEXAs 75201 ees -

e v

~Em o.~ DER.ON 37 JUL 10 Pi2:44 BPENC E R C. RE k* EA h0NALD M HANSON TE LEPHONE (2ies)D79 3OOO Or COUNSEL J.LAN BOHANNAN JOS PRION WOR $ HAM T R Avi5 E. VAN DE R POOL CARL A F OR5 YTH E JUDt1H R JOHNSON

- p; ReCHARD L. ADAM S bk' D Avid C. LONE RG AN TELECOPiER (R# A)800 0011 HO AS F L LLARD l

RC BE RT K. WISE I

TIMOTH Y A MACM ROBERT M. FSLLMORE WM 5tgpMEN BoyD MARK R,WA$EM CHRISTOPHER R MIL T E N e E RG E R ROBERT P olive R MARM B C' 4W ART Z R6C H ARD G MOORE NANCVE L. BETH URE M CtCEt,A J..RvNER July 8,1987 JOE A DAvlS ERIC H PETER $0N W ALT E R W WHi?E Peter B. Bloch, Esquire Dr. Kenneth A. McCollom i

Chairman Administrative Judge Atomic Safety and Licensing Board 1107 West Knapp U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory (S

881 West Outer Drive P. O. Box X, Building 3500

()

Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50 445 and 50 446 db

Dear Administrative Judges:

TU Electric has this date delivered to the Nuclear Regulatory Commission the following SRT approved Results Report:

III.a.1 Hot Functional Testing, Revision 1 4

1 1

This report shou!d be placed in sequence behind the tab " Testing" in the i

results reports binders previously transmitted. Also enclosed is a revised Table of l

Contents reflecting the issuance of this report.

As with all previous Results i

Reports issued to date, this materialis not being offered into evidence at this time

]

but pecvided for infctmation only.

8707140269 070700 PDR ADOCK 05000445 G

PDR Robert A. Wooldr d i

I RAW /klw l

f3 1

Enclosures i

cc:

Service List i

0563 l

j

N Log # TXX-6559 e

CPRT-956

's File # 10068

=

=

TUELECTRIC July 8, 1987 1

U. S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 CPRT RESULTS REPORT Gentlemen:

We transmit herewith the following SRT Results Report:

III a.1 Hot Furictional Testing - Revision 1 This report should be placed in sequence behind the tab " Testing" in the o

results reports binders previously transmitted.

('-

The files which contain supporting documentation for this Results Report have been reproduced in their entirety and are available for public inspection in our Dallas office. Anyone wishing to inspect these files should contact Ms.

Susan Palmer (214/812-8242).

We shall issue further Results Reports on a periodic basis as they are approved by the CPRT Senior Review Team.

Very truly yours, l

undlb W. G. Counsil N', V ' Ol LO-l By:

G. S. Keeley ' N Manager,NucleayLicensing TLS/mgt l

c - R. D. Martin, Region IV Resident Inspectors, CPSES (3)

.100 N Oine ibl!.n. Icus 7520!

1 J

)

i 1

w

\\

t TABLE OF CONTENTS j

r COLLECTIVE SIGNIFICANCE REPORT

- Later -

COLLECTIVE EVALUATION REPORTS J

- Later -

RESULTS REPORTS 1

Electrical l

I a.1 Heat-Shrinkable Cable Insulation Sleeves -

Revision 1 1

I.a.2 Inspection Reports on Butt-Splices, Revision 1

)

I 1.a.3 Butt-Splice Qualification - Revision 1 1

1.a.4 Agreement Between Drawings and Field Terminations

- Revision 2 j

I a.5 NCR's on Vendor Installed Amp Terminal Lugs

- Revision 1

{

'O Q

I.b.1 Flexible Conduit to Flexible Conduit Separation I

- Revision 1 I,b.2 Flexible Conduit to Cable Separation - Revision 1 I.b.3 Conduit to Cable Tray Separation - Revision 1 1.b.4 Barrier Removal - Revision 1 Civil / Structural i

II.b Concrete Compression Strength - Revision 1 l

II.c Maintenance of Atr Gap Between Concrete Structures

- Revision 1 l

l l

em d

f l

E

l Testina l

III.a.1 Hot Functional Testing - Revision 1 l

III.a.2 JTG Approval of Test Data - Revision 0 l

l III.a.3 Technical Specification for Deferred Tests i

- Revision 0 l

1 III.a.4 Traceability of Test Equipment - Revision 0 III.a.5 Preoperational Test Review and Approval of Results, l

Revision 1 III.b Conduct of the CILRT - Revision 0 III.d Preoperational Testing - Revision 1 I

Mechanical V.a Inspection for Certain Types of Skewed Welds in NF Supports - Revision 1 V.c Design Consideration for Piping Systems Between Seismic Category I and Non-Seismic Category I r

Buildings - Revision 1 V.d Plug Welds - Revision 1 V.e Installation of Main Steam Pipes - Revision 1 VI.a Gap between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall, i

Revision 1 e

i O

)

i l

i 0A/0C I.d.2 Guidelines for Administration of QC Inspector Test Revision 1 1

I.d.3 Craft Personnel Training - Revision 1 VII.a.1 Material Traceability - Revision 1 1

VII.a.2 Nonconformance and Corrective Action System -

Revision 1 l

VII.a.3 Document Control - Revision 1 VII.a.4 Audit Program and Auditor Qualification -

Revision 1 VII.a.5 Periodic Review of QA Program - Revision 1 VII.a.6 Exit Interviews - Revision 1 VII.a.7 Housekeeping and System Cleanliness - Revision 1 VII.a.8 Fuel Pool Liner Documentation - Revision 1 i

VII.b.1 Onsite Fabrication - Revision 1 O)

\\-

VII,b.2 Valve Disassembly - Revision 1 l

VII.b.4 Hilti Anchor Bolt Installation - Revision 1 l

QJAPs l

1

- Later -

l

t 4

O COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP:

III.a.1

Title:

Hot Functional Testing (HFT)

REVISION 1 l

a O

\\m u~k c- / y-e7 Ishua Coordinator Date

(- / 3-8 7 Re iew Team Leader Date sh/2.'{f7 U.

L John (JR. Beck, Chairman CPRT-SRT Date O

i Rsvision:

1 Pags 1 of 38 e

RESULTS REPORT

(}

ISAP III.a.1 Hot Functional Testing (HFT)*

1.0 DESCRIPTION

OF ISSUE i

The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Pages J-73 through J-75, Item 4.(6),

" Assessment of Safety Significance." The full text of the NRC-TRT description of the issue is presented in Attachment 1, and is summarized as follows:

(a) Hot functional test procedure ICP-PT-02-12. " Bus Voltage and Load Survey," had been completed. ' Subsequently, changes were made to the transformer tap settings that, in the opinion of the NRC-TRT, should.have caused some portions of the test to _

be reperformed. Neither che Startup. organization nor the Joint Test Group specified a requirement for retesting.

(b) Hot functional test procedure 1CP-PT-34-05, " Steam Generator Narrow Range Level Verification," was performed with three temporary level transmitters. The retest specified by the Startup organization to be performed after installation of the permanent transmitters was a cold calibration.

In the

/'

judgement of the NRC-TRT, an additional requirement to verify proper calibration et hot, no-load conditions should have been specified. Neither the Startup organization nor the Joint Test Group documented a requirement for this type of retesting.

(c) Hot functional test procedure ICP-PT-55-05, " Pressurizer Level Control." was performed with a defective level transmitter.

The retest specified by the Startup organization to be performed after installation of the replacement transmitter was a cold calibration.

In the judgement of the NRC-TRT, an additional requirement to verify proper calibration at hot, no-load conditions should have been specified. Neither the Startup organization nor the Joint Test Group documented a requirement for this type of retesting.

(d) Hot functional test procedure ICP-PT-55-05, " Pressurizer Level Control": the speed of a chart recording device was changed without being documented on a Test Deficiency Report.

The title of this Action Plan does not accurately reflect the scope of work that is addressed, but'in utilized in order to correspond to the specific heading in the NRC lette.r dated September 18, 1984.

O B

R: vision:

1 Pags 2 of 38 RESULTS REPORT O

ISAP III.a.1

(/

(Cont'd)

1.0 DESCRIPTION

OF ISSUE (Con't)

The NRC-TRT summarized the issue at Page J-13. Item 3.2.3,

" Findings for Test Program Issues," as follows:

...the TRT found that three HFT data packages were approved by the TUEC Joint Test Group (JTG) that failed to meet all of the objectives stated in the test procedures.

4 2.0 ACTIONS IDENTIFIED BY NRC d

The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-17 Item 4.2.1, " Hot Functional Testing," as being necessary to resolve this issue are C as follows:

1 Review all completed preoperational test data packages to ensure there are no instances where test objectives were not met, or prerequisite conf 1tions were not s'atisfied. Address the four items identified by the TRT, along with appropriate resolution.

(

3.0 BACKGROUND

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 organization whose membership represents 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 suboeguent 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. When a test has a number of STEs involved because of the u.agnitude or duration of the test, one of the STEs will be identified as Test Director and he will have overall responsibility for that testo Preoperational ts.sts are tests of

R:; vision:

1 Pag 2 3 of 38 RESULTS REPORT ISAP III.a.1 C-(Cont'd)

3.0 BACKGROUND

(Cont'd) safety-related systems and components as distinguished from acceptance tests, which are the same type of teste performed on non-safety-related systems and components.

Startup Administrative Procedure, CP-SAP-12. " Deviations to Test

)

Instructions / Procedures," allows deviations from approved test procedures prior to or during the conduct of a test provided certain approval and documentation requirements are met. The fom used to document such deviations and corresponding approvals is known as a Test Procedure Deviation (TPD). A TPD may be used whenever the approved test method, sequence of testing, or test I

procedure wording is altered. A TPD provides an alternative to a "

I formal revision of the procedure when the change is relatively l

minor. For example, TPDs may be used to alter the method used to l

verify system or component functional capability or to implement a j

retest using the same test procedure but of a reduced scope.

1 The level of Startup management approval of,TPDs that is required depends upon whether or not the deviation involves a change in procedure intent. A change of intent is any change to a test p) objective, acceptance criterion, or test method that prevents l

?'

attainment of the originally intended test objective, fulfillment of the acceptance criterion, or involves a departure from the test i

method committed to in the FSAR.

Startup Mainistrative Procedure, CP-SAP-16 " Test Deficiency and l

Nonconformance Reporting," establishes requirements for the use of Test Deficiency Reports (TDRs). TDRs are issued when unacceptable or indeterminate conditions are found to exist in system or equipment operating characteristics, test documentation, or for any test procedure noncompliance. TDRs contain a description of the specific problem, the corrective action required, and/or the retesting necessary to resolve the problem.

For example, when the initial conditions described in a procedure cannot be met because permanent plant equipment is inoperable or not installed, a TDR would be initiated to document the condition and to establish l

corrective action and/or retect requirements for the subject equipment. The retests are specified by considering the objective of the preoperational test, the function of the specific equipment, and the station test schedule which governs when other opportunities will be available for the retest. The consequences of proceeding with a test with outstanding TDRs are evaluated by appropriate CPSES management.

-m

(

R vision:

1 Faga 4 of 38 RESULTS REPORT g

ISAP III.a.1 (Cont'd)

3.0 BACKGROUND

(Cont'd)

Both TDRs and TPDs beeme part of the test data package reviewed by the JTG prior to acceptacce of the test results.

The TPD process is complete prior to submit 31 of a test data package to the JTG; however, in some instances, fin.J disposition of TDRs may occur subsequent to JTG review and approval of the package.

The NRC-TRT reviewed fifteen of the twenty-two preoperational test data packages associated with het functional testing and the preoperational test data package for the containment leak rate test.

The results of these reviews were documented in an NRC letter dated September 18, 1984 that subsequently formed the basis, in part, of the CPSES Safety Evaluation Report, Supplement No. 7. '".

dated January 1985. The NRC-TRT's request for additional information related to preoperational test data packages formed the basis of the test program-related Issue-Specific Action Plans.

Shortly after receipt of the NRC letter dated September 18, 1984,

{

the JTG initiated a reevaluation of the preoperational test data packages it had previously approved. This reevaluation effort was performed in accordance with Startup Administrative Procedure O

CP-SAP-ll, " Review, Approval and Retention of Test Results "

augmented by additional guidelines developed by the JTG. The additional guidelines were specifically designed to address the concerns expressed by the NRC-TRT. A TDR was' issued 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 test data packages about which the NRC-TRT expressed a specific concern, the seven hot functional test data packages not reviewed by the NRC-TRT, and a sample from 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 approve test data packages-subsequent to that date.) The sample consisted of twenty i

preoperational test data packages considered by the JTG to be the most safety-significant. The JTG completed its reevaluation in April 1985.

1 4.0 CPRT ACTION PLAN The objectives of this Action Plan were two-fold:

(1) to address the four specific concerns expressed by the NRC-TRT and (2) to determine if the preoperational test program has been, and is being, conducted in such a maner thet instances of test objectives not being met due to inadequate specification of ratesting activitiet or prerequisite conditions not being setisfied, are identified and resolved prcperly.

I

Revision:

1 Pags 5 of 38 RESULTS REPORT 15AP III.a.I s

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1 Scope and Methodology The scope of work includes all of the preoperational test data packages reviewed and approved by the JTG to date. The approach to the work was as follows:

i 4.1.1 NRC-TRT Identified Concerns The three test data packages cited in Section 1.0 were reevaluated with a particular emphasis on the four specific concerns identified by the NRC-TRT.

4.1.2 Evaluation of Preoperational Test Data Packages There have been 205 preoperational test data packages reviewed and approved by the JTG to date. Each of the data packages had been reviewed and approved by the JTG

{

at least once and, as a consequence of the reevaluation effort described in Section 3.0',

thirty of them were subjected to a second evaluation. These'second JTG reviews found no evidence to indicate that a programmatic deficiency existed with respect to the Unit 1 preoperational test program and served to confirm, among other things, that TPDs and TDRs had been written when appropriate, and that they were properly dispositioned. The Review Team Leader reviewed the JTG's documentation for each of these thirty reevaluations. The adequacy of the 205 completed data packages was further assessed through the application of a random sampling program focussing on the populations of TPDs and TDRs applicable to these test data packages. The sampling program is discussed in Section 4.4.

4.1.3 Startup Administrative Procedures CP-SAP-7, " Format and Content of Test Instructions / Procedures," CP-SAP-8, " Review, Approval and Revision of Test Instructions / Procedures,"

CP-SAP-11 " Review, Approval and Retention of Test Results," CP-SAP-21. " Conduct of Testing," and CP-SAP-22. " Retest Control." were reviewed to ensure that adequate instructions were presented therein to guide the review and approval process, and that they provided adequate direction for the conduct of testing.

Revision:

1 Pag 2 6 of 38 RESULTS REPORT ISAP III.a.1

\\

(Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

A further review to determine compliance with the Startup Administrative Procedures for TDRs and TPDs was conducted for each of the sample items. The scope of this review included the evaluation criteria and guidelines developed by the JTG subsequent to the NRC-TRT inspection and which were incorporated into CP-SAP-ll (These criteria and guidelines are presented in Attachment 2).

4.2 Participants Roles and Responsibilities The CPRT' Testing Program Review Team Leader, Mr. J. E.

Rushwick, was responsible for the reviews and evaluations described above. The Startup Special Projects Supervisor, Mr.

G. M. McGrath, provided assistance by documenting the population of TPDs and TDRs (reviewed by the Review Team Leader for completeness) and by providihg technical information as requested.

4.3 Qualifications of Personnel O

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.

i 4.4 Random Sampling Program The RTL elected to determine if there was a programmatic i

problem with the Startup organization's and JTG's handling l

of preoperational testing TDRs and TPDs via a randoa sampling I

program conducted in accordance with Appendix D. "CPRT Sampling Policy, Applications and Guidelines," to the Program Plan.

The TPC and TDR administrative procedures are distinct processes.

Processing of either of these documents according to their respective Startup Administrative Procedures (SAP) constitutes a homogeneous work activity. Therefore, a random sample was drawn from the population of TDRs and a random sample was drawn from the population of TPDs, with each separate population consisting of all the TDRs and all the IPDs applicable to any of the 205 completed preoperational tast data packages. Evaluation of these samples was used to O

determine if progrannatic problems impacting the att&ipment of test objectives exist irr either the TPD or the TDR process.

l

)

i l

Revision:

1 Pags 7 of 38 RESULTS REPORT O

ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

There have been 205 preoperational test data packages approved by the JTG to date.

(One additional package had been approved but was subsequently voided by the JTG. The voided test data package is addressed in ISAP III.a.5, "Preoperational Test Review and Approval of Results)." For the 205 preoperational test data packages, the total number of applicable TDRs and TPDs is 1,827 and 2,343, respectively.

The investigation of the four specific concerns identified by the NRC-TRT, as reported in Section 5.1, led to the conclusion that there vas one instance where the JTG approved a TDR containing inadequate justification for not performing a :

retest. Based on this one example, the minimum sample size necessary to test for programmatic implications was extended to ninety-five items as would have been required per Appendix D to the Program Plan had the retest specification impacted attainment of the test objective.

Because no instances had been identified in which a TPD compromised a test objective, the minimum sample size necessary to evaluate the TPD process for programmatic implications was sixty items.

4.5 Acceptance Criteria Deviations from prerequisite conditions or other procedure requirements are typically documented on either TPDs or TDRs.

For each such document, the potential for subsequent impact on the attainment of test objectives was addressed to ensure program adequacy. The following acceptance criteria were applied:

Each test objective was not compromised by the use of the Test Procedure Deviation, or, if it was, appropriate retesting had been required.

Each test objective was not compromised by the use of the Test Deficiency Report, or, if it was, appropriate retesting had been required.

I Process adequacy was confirmed if each sample met the applicable criterion above.

Implementation adequacy was separately confirmed by checking the documentation for each TDR or TPD for compliance with the appropriate SAP.

U

Rsvision:

1 Pags 8 of 38 RESULTS REPORT O1 ISAP III.a.1 (Cont'd)

{

5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The following presents the results of the reviews conducted in accordance with this ISAP.

5.1 Reevaluation of the Test Data Packages about which the NRC-TRT Expressed a Concern

]

The information that follows presents the NRC-TRT description of the issue, the results of the JTG's reevaluation, and the evaluation by the RTL.

5.1.1 Test Data Package ICP-PT-02-12 " Bus Voltage and Load Survey" NRC-TRT Description of the Transformer Tap Change Issue (Attachment 1, Item (a))

Preoperational test procedure 1CP-PT-02-12,

" Bus Voltage and Load, Survey," [was] intended to demonstrate that doring all modes of plant operation, optimum current and voltage will be present at all the buses and associated equipment. After the test was completed, the STE noted in review of test data that the voltages recorded in paragraphs 7.8.2.1 and 7.8.3.1 did not meet the acceptance criteria specified in the test procedure. A test deficiency report (TDR) was initiated.

Subsequent TUEC engineering evaluation of the out-of-tolerance voltages documented in the TDR required that changes to some of the, transformer output settings used during the conduct of the test were necessary to bring the voltages within the originally specified acceptance criteria.

In accordance with the test procedure, these changes necessitated that some portions of the test be performed again. However, the JTG approved the data package without requiring these portions of the test to be performed again. Therefore, the test data package contained invalid data for that test; thus, the test objective had not been met.

O

1 Rsvirion:

l' Page 9 of 38 RESULTS REPORT

\\O ISAP III.a.1 (Cont'd) 1 l

l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

Chror. ology Prior to recording the voltage and load survey data required by the test, the STE observed that the voltages at some 480 volt motor control centers were in i

excess of the acceptance criteria stipulated in the procedure for the light load plant condition. The test procedure contained an instruction for dealing with such situations by changing transformer tap settings.

The STE had the taps on the 6900/480 volt substation transformers changed from the originally specified setting of -5% to a setting of -2.5% to bring the moto~r control center voltages within specification. The STE documented the tap setting change on a TPD and then proceeded with the test by recording the voltage and load survey data for the light load plant condition.

Approximately three months later, when the hot l

functional test provided the highest plant electrical load, survey data for the maximum available load condition were recorded, marking the completion of the test.

During the STE's evaluation of the test results, he noted that the voltages re:orded in the light load portion of the test for the two safety-related and the four non-safety-related 6900 volt switchgear buses did net meet the stated acceptance criteria. At that time, the plant distribution system was being fed via the l

alternate offsite power supply configuration from the 138 kV transmission line. He also noted that the incoming 138kV line voltage exceeded its normal operating range. A Test Deficiency Report was issued by the STE to document his actions and observations

• during the test, and to initiate an evaluation by TU Electric Engineering (Engineering). The TDR stated that the 6900 volt switchgear bus voltages did not meet the acceptance criteria. Also noted on the TDR was a reference to a conversation with a representative from Engineering, during which the STE was advised that the tap setting change he performed would cause the 480 volt motor control center voltages to fall below the acceptance criteria when the transmission line voltage was at its minimum operating voltage. The STE indicated on the TDR that after an " extensive"

Rsvision:

1 Pag 2 10 of 38 RESULTS REPORT f~

ISAP III.a.1

\\

(Cont'd) s_

5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) review of the system by Engineering no retesting would be required. The Lead Startup Engineer, however, annotated the TDR to defer determination of the retest requirements until after the evaluation by Engineering.

The TDR was forwarded to Engineering for resolution and identification of corrective action.

The corrective action specified by Engineering was to restore the tap sett1ngs for the 6900/480 volt substation transformers to the original setpoint of

-5% and to establish measures through the System Dispatchers to control the transmission line voltages !.

within the required operating ranges. The STE again specified "none" for the retesting activity following the Engineering disposition of the TDR. The Lead Startup Engineer approved the corrective action and also concurred in the STEs judgement that retesting was not required.

In a parallel effort, the JTG was conducting its review

(#')

of the test data package for ICP-PT-02-12. The test

\\~/

data package contained a copy of the TDR that had been forwarded to Engineering for evaluation. The test data package also contained the STE's Preoperational Test Summary report. The report stated'that the test results were acceptable with the exception of the voltages that did not meet the acceptance criteria.

It also stated that subsequent to the Engineering evaluation of the TDR, there would be no need for any retesting. Approval of the test data package had been on the JTG's meeting agenda for four consecutive weeks but action was consistently deferred pending Engineering's resolution of the outstanding TDR on.the out-of-tolerance voltage readings.

Shortly after Engineering's specification of the corrective action, the JTG approved the test data package. Seven months later, the JTG reviewed and approved the actual implementation of the corrective action, as well as the retest specified by the Startup organization on the TDR. The specified retest on the TDR was "none".

Consequently, the data recorded in the test data package filed in the records vault did not reflect the as-left condition of the systems involved in the test.

t l

~/

1

Rt. vision:

1 Page 11 of 38 RESULTS REPORT (Q

ISAP III.a.1

/

(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

I l

JTG Reevaluation Upon reevaluation of this test data package, the JTG decided to have the test procedure rewritten and the i

test reperformed.

In documenting this decision, the

{

reevaluators indicated that the retest was necessary I

because the basis for the original decision not to retest was not documented and because the disposition of another TDR in the test data package regarding

{

missing data was considered incorrect. Upon further investigation by the RTL, it was determined that the -

decision to retest was also influenced by several:

additional factors. Among these were the facts that:

the voltage data recorded in the procedure would require correlation to the voltages expected at the as-lef t tap settings; the prerequisite condition for the incoming voltage had not been specified or satisfied; the test objective, as stated, was unclear; the application of the acceptance criteria could be l

O misinterpreted; and retesting would provide a mechanism

}

to obtain data related to diesel generator loads (not part of the original test but were now desired to address an equipment capacity prciblem).

Each of these factors was viewed by the JTG as adversely impacting the quality and utility of the existing test data

{

package.

I At the time of the JTG's reevaluation of ICP-PT-02-12, the Project had made a decision to conduct another heatup to normal operating temperature and pressure to complete the retesting activities associated with the thermal expansion test.

In the same time frame, Startup and Engineering were analyzing bus voltage and load data from this and other tests to confirm emergency diesel loading calculations. The diesel generator loading margins had become a source of j

concern because of an NRC directive to the industry that generic problems associated with the type of l

diesels employed at CPSES necessitated a substantial derating from their nameplate capacity. The second

{

heatup, therefore, presented an opportunity to gather additional specific data that could be used to i

resolve the issue of the diesel generator loads satisfactorily, as well as the issue of ICP-PT-02-12 identified by the NRC-TRT.

Revision:

1 Paga 12 of 38 RESULTS REPORT 1

p()

ISAP III.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The modification to the test procedure consisted of j

changing the test objective to state more accurately what the test was to accomplish, of establishing the prerequisite verification of the incoming line voltages being within normal range, of deleting the instruction concerning tap setting changes because it was no longer necessary, and of preparing more detailed load survey data sheets to provide additional data to assist in the resolution of the diesel generator loading issue. The rewritten procedure contained the same acceptance criteria (which were applied correctly for the retest) and the same steps in the body of the procedure as the original, augmented with an instruction identifying the additional data necessary for the diesel generator issue.

{

RTL Evaluation of this Is' sue The origin of the commitment to' perform a Bus Voltage and Load Survey came from a series of NRC questions (FSAR NRC Questions and Responses. 40.48 through 40.53) q l

relating to the stability of the transmission system when operating normally or in a degraded mode (e.g.,

{

deliberate voltage reduction to offset high power j

demand conditions). The transmission line stability studies identified the maximum and minimum transmission line operating voltages that would be expected at the CPSES. Within the plant, acceptable ranges of distribution system voltages for the 6900 volt switchgear, 6900/480 volt substations, and 480 volt motor control centers are duermined by the.

requirements of the loads serviced from this equipment.

The power transformers are provided with taps that allow nominal adjustments in the transformer input to output voltage ratios. The transformer taps are set to provide the optimum voltage to the loads serviced. The settings consider the reduction in plant distribution system voltage occurring when the plant is brought from a lightly loaded condition, such as refueling, to the fully loaded condition when the plant is operating at one-hundred percent power, the expected voltages over the operating range of the transmission system, and the requirements of the safety-related loads serviced by the plant distribution system.

J

Rsvision:

1 Paga 13 of 38 RESULTS REPORT O

ISAP III.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The objective of ICP-PT-02-12. " Bus Voltage and Load l

Survey," was to verify that, at the specified transformer tap settings, the switchgear, substation, and motor control conter voltages would remain within an acceptable range between the lightly loaded and fully loaded plant condition through the full operating range of the transmission system.

To accomplish this verification, plant bus and motor control center voltages are recorded at a light plant load and at the highest load available (during construction, this occurs during hot functional T

testing). The data are recorded at the transmission line voltage existing at the time of the survey and are then corrected to the maximum and minimum transmission line voltages expected at the plant. These corrected voltages are compared with the acceptance criteria to ensure that the plant voltages will remain within the acceptance criteria ranges for the equipment serviced.

The acceptance criteria in the test procedure were tabulated as maximum and minimum voltages at each 6900 volt switchgear and 6900/480 volt substation, and at each 480 volt motor control center. As previously noted, these acceptance criteria were based on the requirements of the loads serviced by the plant distribution equipment.

I The RTL performed the correction of the recorded data for the 138kV and 345kV portions of the test to determine whether acceptance criteria had been properly applied. The correction consisted of determining the ratio of the incoming 138 kV line voltage that was higher than normal to that expected at the normal controlled maximum. Each recorded plant distribution system voltage was then reduced by that ratio. The RTL observed that the plant voltages for the safety-related 6900 volt switchgear met the acceptance criteria for the maximum incoming line voltage. The non-safety-related buses remained bigher than the acceptance criteria by less than 0.4%.

The STE had identified the corresponding discrepancy in the recorded data but did not report these values corrected 1

to the intended acceptance criteria. At the maximum 4

l l

I

R: vision:

1 Pegs 14 of 38 RESULTS REPORT ISAP III.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCL'SSION OF RESULTS (Cont'd) l load / minimum line voltage condition, voltages a; the 480 volt substation buses and 480 volt motor co%rol center were low when compared with the acceptanus criteria. By changing the tap settings at the 6900/480 l

substation in order to meet the acceptance criteria for l

l the light load / maximum line voltage test condition at

{

the abnormally high incoming voltage, the STE caused the maximum plant load / minimum line voltage situation

{

to be unacceptable.

I The RTL also performed the data correction for the 345kV portion of the test. The two safety-related 6900 volt switchgear buses did not meet the acceptance criteria when plant voltages were corrected to the maximum expected transmission line voltage. The bus voltages were high by less than 0.7%.

The STE did not identify this discrepan'cy. All other acceptance criteria were met.

On the TDR documenting the problem, the STE had noted

\\

that the recorded voltages at the two safety-related and at the four non-safety-related 6900 volt switchgear buses were higher than the acceptance criteria. These recorded voltages had not been corrected for proper transmission line voltage. Also~ presented was a brief summary of the STE's actions and observations vfth regard to the test. He noted that the substation taps had been changed to correct the 480 volt motor l

control center voltage at the minimum load / maximum line voltage condition prior to. initiating the test and that, subsequently, during preparation of the test data package for JTG review and approval, he had recorded incoming 138kV line voltages that were higher than

• expected. Also noted was that the STE had called Engineering to discuss the problem, at which time he was informed that the voltages at the 480 volt level had been compromised. The STE did not bring attention to the fact that the high voltage / minimum load situation for the 345kV portion of the test also failed the acceptance criteria, nor did he mention that the 480 volt substations had failed the minimum voltage / maximum load portion of the test.

O l

Rsvision:

1 Pag: 15 of 38 RESULTS REPORT

(

rx ISAP III.a.1 C

(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

The RTL concludes from the STEs incomplete evaluation 1

that the STE assigned to perform this test did not

{

realize what the objective of the test really was.

This conclusion is based upon the STE's failure to analyze the recorded plant voltage data against the range of transmission line voltages and plant load conditions (and is consistent with separate evaluations j

of this individual's performance in ISAP III.a.5).

The information presented on the TDR describing the problem was misleading and incomplete. The reviewers of the test data package were undoubtedly led to believe that j

the STE wns resolving an extensive problem with

~

Engineering and that it had been predetermined that no retesting would be required.

The RTL attributes these misunderstandings to a less-than-adequate test i

procedure. The procedure did not contain a requirement for verifying that transmission line voltages were within their normal operating range, and the j

instruction allowing changes to transformer tap j

settings did not contain sufficient guidance as to when i

or what type of a change would be appropriate.

i The RTL performed the same evaluation for the retest of ICP-PT-02-12 and confirmed the STE's statements in the Preoperational Test Summary that the acceptance criteria were met for the light and heavy plant load situations at the maximum and minimum expected transmission line voltages.

l The RTL does not concur with the JTG's finding that a retest was necessary to disposition the TDR involving i

missing data correctly. The missing data were voltage ar.d cutrent on two phases of a three phase circuit.for which local indications were not provided by the design. The affected buses were not safety-related as all safety-related buses had three phase i

instrumentation installed per the design. The JTG

)

reevaluators judged that these data were required, whereas further investigation by the RTL led to the determination that equivalent data had been previously collected. Previous tests had involved the operation of these circuits at conditions beyond the range of i

this voltage survey, at which time data pertaining to l

Rsvision:

1 Paga 16 of 38 RESULTS REPORT p

ISAP III.c.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) all three phases were recorded and phase-to-phase problems would have been identified.

The missing data did not, therefore, result in the lack of any information that was not already known.

Subsequent to the NRC-TRT's identification of this issue, and independent of the JTG's reevaluation of the test data package, the Startup Electrical Group Supervisor performed an analysis that corrected the data recorded in the test for both transmission line voltages being within normal operating range and resetting the 6900/480 volt substation taps back to that specified by Engineering. The results of this analysis indicated that the test results would have been satisfactory by maintaining transmission line voltages within the normal operating range and resetting the taps to<the position specified by j

Engineering. The analysis was not forwarded to Engineering for validation because of the Project's decision to perform another plant heatup to normal i

operating temperature and pressure.

The RTL found the l

above-described analysis illustrative of the type of calculation that could have provided justification for the original decision not to retest.

The RTL concludes that the JfG erred in accepting no retesting without documenting the basis for that decision. An analysis similar to that described above i

could have been performed and the test data package i

could have been amended to provide information correlating the as-left system configuration with the data recorded in the procedure.

Such an analysis was not provided by Engineering, however, and it was not requested by the JTG when it reviewed the test data package.

The RTL concludes that the JTG acted conservatively by j

directing the reperformance of ICP-PT-02-12. Since a j

retest was performed (even though an acceptable j

alternative was available in the RTL's judgement) the disposition of the original TDR was conservatively j

treated as a deficiency and the required sample size to i

confirm the programmatic adequacy of TDR dispositions I

was set at ninety-five TDRs.

O 4

1

)l

R: vision:

1 Paga 17 of 38 RESULTS REPORT 0

ISAP III.a.1 (Cont'd) j 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.1.2 Test Data Package 1CP-PT-34-05, " Steam Generators, Narrow Range Level Verification" NRC-TRT Description of Issue (Attachment 1, Item (b))

L Procedure ICP-PT-34-05, " Steam Generator Narrow Range Level Verification," [was) intended to demonstrate at hot, no-load conditions, that the specified narrow range level channels for each steam generator indicate properly at the upper and lower instrument taps and compare properly with each other for actual chsnges in steam generator water level. The transmitters for level detectors 1-LT-517, 518, and 529 were found defective prior to initiation of testing and, thus, temporary equipment was l

substituted. The test was performed with the r

temporary equipment and declared successful.

After the test, the specified transmitters i

were installed.

The Joint' Test Group (JTG) approved the completed test package containing data taken with temporary transmitters. The only retest required after installation of the detectors was cold I

calibration (not calibration at hot, no-load-conditions);

thus, this test objective was not met and no other requirements were imposed by the JTG to monitor performance when the transmitters are placed in service.

JTG Reevaluation l

The JTG's reevaluation of this test data package led to the conclusion that the test objectives had been met and confirmed its original decision concerning the retest requirement for these level transmitters.

RTL Evaluation of the Issue The steam generator level control system components are subjected to an individual calibration and subsequent integrated channel verification. There are O

Rcvioions 1

Page 18 of 38 RESULTS REPORT O

ISAP III.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) approximately fifteen components within the electronic circuitry associated with each of the four level transmitters used for protection functions on each steam generator.

Calibration of the level transmitters involves subjecting the transmitters to the differential pressure values calculated for the zero percent level indication and the one-hundred percent level indication that would be present at normal operating temperatures and pressures.

These calculations take into consideration the thermal growth of the steam generator and its associated level measurement column, and the specific weight of the column of water at an elevated temperature. A main objective of the test procedure is to verify that these calculations are, in fact, accurate, and that the calibration data derived therefrom may be used in future calibrations of the level transmitters.-

Toaccomplishthisverificationiprecisiondigital voltmeter test equipment is placed in parallel in the O*

circuit just prior to the main control board meters.

The level in the steam generator is adjusted from somewhere below the zero percent level tap to somewhere over the one-hundred percent level tap and, as the l

water level passes each of the'two points, a definite datum is established for each tap elevation relative to the output of the transmitter. The output from each of the loops is also verified to be within 15 percent of each other on the permanent panel meters at these two points and at other level plateaus. These test objectives were accomplished and the acceptance criteria were met.

The use of the temporary transmitters allowed the other components in the instrumentation channel to be tested as an integrated unit. The temporary transmitters were sufficiently similar in performance and calibrated to the same parameters as the permanent transmitters such that the test results for the integrated instrumentation system would be valid.

In particular, there was no impact on the data collected at each level tap that was used to confirm the calculated calibration data.

Following replacement of the temporary with the

(~

i

R; vision:

1 Pega 19 of 38 RESULTS REPORT 1

1 (3

ISAP III.a.1

(,)

(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i permanent transmitters, the specified retest was for i

calibration in accordance with an Operations I & C calibration and channel verification procedure l

performed at ambient temperature. To perform the ambient temperature calibration, the differential j

pressures that had been confirmed as accurate through performance of the test utilizing the temporary l

transmitters were set into the transmitters. When the j

permanent transmitters had been replaced and

{

calibrated, the TDRs documenting this retest were i

closed and preoperational testing was declared complete i

for this test. Upon completion of the calibration andi channel verification, the transmitters were operable and capable of performing their safety function; that l

1s, the retest conducted was adequate (For l

clarification of the basis for this conclusion, see

{

further discussion on the Startup/ Operations interfhce l

in Section 5.6).

The approved test data package was amended with the TDR closeout documentation.

1 i ( --

i Subsequent testing performed prior to fuel load under j

\\-

l the auspices of the Initial Startup Test Program and in l

accordance with the plant Technical Specifications

)

includes recalibration according to the same Operations I&C procedure. Following fuel load and heatup, these instrument channels are also to be observed and documented as operable once per shift as part of the I

routine surveillance test program.

Initial Startup Testing proceeds with a series of both similar and more exhaustive tests performed at various power plateaus.

These tests will afford further confirmation of the proper functioning of these channels.

l The RTL concluded that the Startup organization's original disposition, calling for ambient temperature calibration and channel verification for these transmitters, and the JTG's were proper. There was no need to exercise the option of deferred preoperational testing (as described in Section 5.6) to obtain l

interchannel comparison data at hot conditions. The completed test with the temporary transmitters demonstrated that a properly functioning transmitter

[ )

v l

l 1

1 i

R: vision:

1 Pogs 20 of 38 RESULTS REPORT ISAP III.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) within the channel would meet the acceptance criteria.

The calibration and channel verification of the replacement transmitter demonstrated that the as-left instrument channel was functioning properly. Future test programs, described above, were already in place to confirm these conclusions.

The STE and the Startup organization need not have provided a detailed explanation of the methods by which operations are conducted following issuance of the operating license as a basis for specifying the retest, as the personnel involved with these processes were known to be intimately familiar with these programs. Additionally the documentation of these testing activities is readily available through the Operation group's Managed 1

Maintenance Computer Program.

Nevertheless, the Startup organization modified its administrative procedures to state that an explanation of the basis for specifying the retest should be provided in the future.

The NRC-TRT's concern was based on USNRC Regulatory Guide 1.68, " Initial Test Programs for Water-Cooled

)

Nuclear Power Plants." This guide was issued to describe the general scope and depth of initial test j

programs that are acceptable to the NRC staff for light-water-cooled nuclear power plants such as CPSES.

TU Electric is committed to follow Regulatory Guide 1.68.

This issue is particularly relevant to Regulatory Position C.3 " Scope, Testing Conditions, and Length of Testing," which reads in part:

...To the extent practical, the duration of i

the tests should be suf ficient to permit -

equipment to reach its normal equilibrium conditions, e.g.,

temperatures and pressures, and thus decrease the probability of failures, including 'run-in' type failures from occurring during plant operation.

During preoperational testing at the CPSES, there were numerous examples of extended duration tests of safety-related equipment. However, the equipment

R2 vision:

1 Paga 21 of 38 RESULTS REPORT O

ISAP III.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) tested consisted principally of motors, pumps, turbines, and diesels.

The control components associated with this equipment were also involved in the corresponding extended duration testing.

In those cases, such as the steam generators, where thirteen of sixteen transmitters operated satisfactorily in their integrated channel configuration, and three temporary transmitters also operated satisfactorily within their instrument channels, there is reasonable assurance that the three properly calibrated transmitters installed later will perform satisfactorily in their channel configuration.

The RTL concluded that the Startup organization's and JTG's actions were consistent with the requirements of the Regulatory Guide.

The RTL did not observe any actions by either organization that were meant to '

circumvent requirements or prudent practices in the Preoperational Test Program.

5.1.3 Test Data Package 1CP-PT-55-05, " Pressurizer Level Control" NRC-TRT Description of the Level Transmitter Issue, (Attachment 1 Item (c))

Procedure 1CP-PT-55-05, " Pressurizer Level Control," [was] intended to demonstrate the l

control aspects of the system in conjunction with the chemical and volume control system.

{

In addition, there was a note on page 12 of

{

the procedure that stated, 'This test is j

provided to verify the capability of the pressurizer level control system to monitor pressurizer level over the range of installed instrumentation and to observe that all alarm and control functions are operational.' A i

prerequisite condition (paragraph 6.13) required the plant to be in hot standby condition.

During conduct of pressurizer level indication testing in acccrdance with I

the procedure (paragraph 7.1), the System Test Engineer (STE) noted that a level detector (1-LT-461) was registering marginal O

i

Rsvisions 1

Pags 22 of 38 RESULTS REPORT O

ISAP III.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 1 readings. He documented this and recommended a calibration check of the detector. After-the test was completed, this.was done, and it was' determined that the detector was out of calibration, and attempts to calibrate it were unsuccessful. The corrective action was to. replace the detector and perform a cold calibration (not calibration in hot standby condition); thus, this test objective was not met.

The JTG-approved test data package contained level data taken with a detector -

that subsequently proved to be out of

~/-

calibration, thereby invalidating the test data and no other requirements were imposed by the JTG to monitor the performance of the new detector when it was pieced in service.

JTG Reevaluation

()

The JTG's reevaluation of this test data package led to the conclusion that the test objective had been met and confirmed its original decision concerning the retest requirement for the level transmitter.

RTL Evaluation of Level Transmitter Issue The o-igin of the problem that caused the pressurizer level transmitter replacement was different from that of the Steam Generators.

The origin of the problem was that during the STE's review of~the test data, he identified an' anomaly in the low-range test data. The test was performed by first' raising the level to the one-hundred percent tap and finally reducing the level to the zero percent tap. The transmitter's initial calibration was performed without any problems. The transmitter functioned properly throughout the test by tracking level precisely with the other two channels except at the zero and five percent indicated levels at the end of the test; these results indicate that problem with the transmitter developed while it was in se rvice. The test acceptance criteria were, in fact, satisfied with the recorded data.

O

Ravisi'on:

1 Pags 23 of 38 RESULTS REPORT A()

ISAP III.a.1 (Cont'd) 1 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

However, the STE issued a TDR to document the resolution.of the low range non-linearity problem. The transmitter was replaced because efforts to correct the non-linearity problem in the low range of the instrument were unsuccessful. The Startup organization specified the retest as calibration in accordance with an Operations I & C calibration and channel verification procedure-performed at ambient temperature. Based on the same~ considerations described above for the Steam Generator level transmitters, the RTL concludes that the retest specified was appropriate.

NRC-TRT Description of the Chart Speed Issue (Attachment 1, Item (d))

Additionally, during the conduct of Prodedure ICP-PT-55-05 discussed in [5.1.3] above, the speed of the recording chart for the pressurizer level was changed from 2.5 O-cm/ minute, as required by paragraph 7.2.6c, to 15 cm/ hour. The TRT determined that this was done to avoid running out of chart paper during the test.

This deviation from the approved test procedure should have been documented on a TDR even though, in this case, the chart speed was inconsequential since the recorded trace data were not being f

relied upon to prove any of the system's J

performance features.

JTG Reevaluation The JTG's reevaluation of this test data package confirmed its original decision concerning the change I

of the chart speed having no impact on the attainment of the test objective. As a result of the reevaluation, tifo Startup organization did, however, issue a memorandum to all its group leaders and STEs instructing them in the SAP requirements applicable when deviating from the approved test procedures. The memorandum instructed the test personnel that strict O

i

Ravision:

1 Pags 24 of 38 RESULTS REPORT ISAP III.a.1 i

(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) compliance with the instructions in CP-SAP-12, i

" Deviations to Test Instructions / Procedures." and 1

CP-SAP-21, " Conduct of Testing," was required.

RTL Evaluation of Chart Speed Issue The portion of the test where the chart speed was changed was intended to verify that upon a change in the pressurizer water level setpoint, the Pressurizer i

Level Control System would cause the Chemical and Volume Control System (CVCS) to respond properly to the new level setpoint. The design interface between the ';

two systems is such that oscillations in level around the control system setpoint would be dampened. That is, if the setpoint was lowered, for example, it would be expected that the control system would cause the level to exhibit transient behavior for a period of I

time, with the level decreasing, initially to a point somewhat lower than that desired and then increasing to a point above that desired, and so on.

However, the O-magnitude of each actual level oscillation beyond the setpoint would be expected to decrease over a period of time, such that the level eventually reaches a steady-state condition at or near the desired level setpoint.

The method selected to document this l

observation involved the use of a strip chart recorder that provided a graphic representation of the transient behavior of the pressurizer water level.

The instructions provided in the test procedure were as follows (step 7.2.6):

Prepare the recorder chart as follows:

a.

Label the recorder chart with:

"Section 7.2 System Response, Stability, and Control Test," Time and Date.

b.

Identify chart traces with the parameter being recorded, source of signal, channel scale, and appropriate engineering units.

O a&.-

Revision:

1 Paga 25 of 38 RESULTS REPORT

/

ISAP III.a.1

\\

(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

NOTE Select test equipment scales as appropriate to provide adequate coverage for signal range.

Scaling factors are provided with Table II.

c.

Select and record chart speed i

(1"/ min or comparable).

d.

Start the recorder.

1.~

NOTE Annotate the recorder chart with

" MANUAL" or "AUT0" as appropriate with every change of [ level cbutrol modeswitchp Procedure step 7.2.6c directed the STE to select a rapid chart speed initially such as 1"/ min, which is much faster than the fixed speed of 1"/hr at which the l

permanently installed recorder operates. A fast chart speed is appropriate since the interface between the electronics of the Pressurizer Level Control System and the mechanical valve components of the CVCS had_not yet been tested and the frequency of. oscillations that might occur was as yet unknown.

The speed of the chart was subsequently changed to 6"/hr toward the end of the test by an STE who was assisting the Test Director by covering the second shift testing activities. The chart and the test log i

were annotated with the time, date, and new chart speed by the STE. The chart was annotated by the Test Director to show that the reason for the change was to prevent running out of chart paper. By the time the chart speed was changed, the Pressurizer Level Control System had been subjected to four major setpoint changes and the frequency of the oscillations was known to be so low as to be more clearly depicted at the slower speed.

In fact, when the RTL reviewed the charts recorded during this test, it was determined that if the speed of the chart had been set at 6"/hr earlier in the test, the transients involved would have been well recorded and more clearly indicated in

l Rsvicion:

1 Paga 26 of 38 RESULTS REPORT

(^

ISAP III.a.1 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) several feet of paper, rather than the approximately eighty-five feet of paper actually used at 1"/ min.

On the TDR issued to document the JTG's reevaluation prompted by the SSER, the reevaluators stated their concurrence in the NRC-TRT's finding that the chart speed was inconsequential to the test; however, each group supervisor and STE in the Startup organization was instructed that strict compliance with the SAPS for j

TPDs and Conduct of Testing was required. As to j

whether or not a Test Procedure Deviation should have been issued to document the change in chart speed,' it is the RTL's judgement that the change was not a procedural deviation of the type and significance intended as addressed in CP-SAP-21. " Conduct of Testing," or CP-SAP-12, " Deviations to Test Instructions / Procedures." Consequently, a TPD, while perhaps administrative 1y appropriate, was not necessary in this instance. The annotation provided in the~ test log assured an appropriate review and therefore q

satisfied the intent of CP-SAP-12. " Deviations to Test Instructions / Procedures." In this specific case, the judgement exercised to change the chart speed considered all the facts surrounding the circumstances bf the test and was exercised responsibly. As previously noted, the change in chart speed was made only after the frequency of oscillations had been shown to be so low as to warrant the selection of. a slower chart speed. The STE made that judgement, and it is-the RTL's opinion that judgements of that type are well within the capabilities of personnel assigned STE responsibilities and, further, that procedural step 7.2.6c was not written to constrain him from acting upon that judgement without issuing a TPD. The RTL concludes that the JTG reevaluation and resultant corrective action were adequate.

5.3 Random Sampling Program A sample of ninety-five Test Deficiency Reports randomly selected from the total number of TDRs associated with all the preoperational test data packages approved by the JTG was evaluated. The evaluation revealed that each of the TDRs met the applicable acceptance criterion stated in Section 4.5,

" Acceptance Criteria."

Revision:

1 Peg 2 27 of 38 RESULTS REPORT

]

ISAP III.a.1

(/

(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

A sample of sixty Test Procedure Deviations randomly selected from the total number of TPDs associated with all the preoperational test data packages approved by the JTG was evaluated.

The evaluation revealed that each of the TPDs met the applicable acceptance criterion stated in Section 4.5.

The evaluation of each sample item against the acceptance criteria was designed to detect errors that may have occurred in dispositioning TPDs or TDRs that would impact the attainment of test objectives. The results of the random sampling program indicate that errors of this type, if any, would be random in occurrence and of low frequency. The sampling program thus affords additional evidence that i

preoperational test data packages approved by the JTG met all of the objectives stated in the test procedures, and that prerequisite conditions significant to each test objective i

were satisfied.

I I

5.4 Startup Administrative Procedures f%

l 5

Although not part of the sampling program, the RTL checked each TPD and TDR for compliance with the appropriate SAP.

There were no instances of noncompliance identified in the implementation of the SAP for TDRs. There were, however, two minor items of noncompliance identified in the implementation of the SAP for TPDs.

I The items of noncompliance involved implementation of twenty changes that STEs had initiated by two TPDs associated with two different preoperational test data packages. On one TPD, one of thirteen entries being changed in the body of the test procedure did not have a date entered after the STE's initials and TPD number. On the other TPD, two entries in the body of the procedure did not have a TPD number entered beside the initial and date of the change. These discrepancies were corrected by the Startup organization in accordance with the SAPS, and were judged by the RTL to have had no significant impacts on the test program adequacy.

In two other instances, the original reviewers of the test data package identified similar errors and had initiated TDRs in accordance with the requirements of the SAPS.

m

Revision:

1-Paga 28 of 38 4

RESULTS' REPORT O

ISAP III.a.1

-(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) i The RTL reviewed'the Startup Administrative Procedures to j

ascertain which procedures were applicable to the subject

{

issue and to determine if the procedures contained adequate l

instructions to perform the required reviews and approvals of test procedures and the results of testing, and if the procedures contained adequate instructions for conducting a test. The RTL concludes that the procedures are adequate.

5.5 JTG Reevaluation Activities The RTL concurs in the JTG's disposition of the TDRs issued to document the reevaluation effort described in Section 3.0, L

with the exceptions noted in Section 5.1.

The JTG's reevaluation of thirty test data packages included the examination of all the TDRs and.TPDs contained therein, which numbered approximately 275 and 415, respectively. No instances were idedtified where required TDRs were not written.

The RTL also concludes that augmentation of the evaluation criteria in CP-SAP-11 with the addit ional guidelines developed by the JTG and presented in Attachment 2 is sufficient to preclude recurrence of the types of problems identified by~the NRC-TRT.

I 5.6 Startup/ Operations Interface l

Af ter construction of a system is completed, operational

)

control of that system becomes the responsibility of the plant operating organization. The operators provide support while the preoperational testing activities are performed under the direction of the Startup organization. Subsequent to the satisfactory completion of preoperational testing of a system, the plant operating organization will perform routino operation and maintenance in support of the remaining testing activities until the CPSES Operating License is issued. At that time, all activities associated with the loading of fuel and subsequent power ascension testing, and follow-on routine plant operation and maintenance activities are subject to the rigid requirements of the Technical Specifications for the plant.

In addition to the routine operation and maintenance activities, there are two test programs.

Routine testing for the life of the plant is known as Surveillance Testing. These

()

tests and confirmatory observations are required to be

{

D

Revision:

1 Pegd 29 of 38 RESULTS REPORT

^

[

ISAP III.a.1

\\

(Cont'd) l 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) j performed as frequently as once per operating shift, and are generally performed periodically (e.g., daily, monthly, quarterly). Many of these tests are routine verifications of parameters that were set or calibrated during the preoperational test phase.

The other test program is known as the Initial Startup Test Program.

These tests are generally duplicates of the system tests performed during the preoperational. testing phase, and are repeated at various power plateaus as the reactor power is escalated from zero to

)

100% power. The unique portions of the Initial Startup Tests are those associated with the measurement and control of

{

reactor thermal power.

L

]

In order to provide an orderly transition from the preoperational testing phase to the initial startup test and plant operations phases, the Joint Test Group was organized.

Membership on the Joint Test Group, as a minimum,' consists of the:

Manager, Plant Operations - Chairman r~(

Manager, Technical Support - Vice Chairman Manager, Startup Director of Engineering Westinghouse - Representative The Manager, Plant Operations is also Chairman of the Station Operations Review Committee, which is the final review / approval body for the procedures used in the Initial Startup Test Program. The Manager, Technical Support, is,

responsible for the performance of the Initial Startup Test Program and is also responsible for control of the Surveillance Test Program, which is analogous to the Manager, h artup's responsibility for the Preoperational Test Program.

The JTG forum allows a determination of the adequacy of preoperational testing relative to the activities to be performed in the Initial Startup Test Program and during routine surveillance. Vnere certain types of testing may not be completed in the Preoperational Test Program and, where one of the plant operating organization test programs already has

/^N O

Rtvicion:

1 Peg 2 30 of 38 RESULTS REPORT p)

ISAP III.a.1 I

(Cont'd) v 5.0 1 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) test procedures that duplicate the preoperational testing, it is appropriate to declare preoperational testing complete and depend on a later program for documentation of results of the activity. Tests that may be treated in this manner are those that are confirmatory or supplementary in nature to tests that have already been conducted; such tests must not provide data required to establish the operability of instrumentation and equipment governed by the Technical Specifications unless equivalent data vill be collected in a planned operating mode l

prior to the Technical Specifications becoming applicable.

Thus, in test ICP-PT-34-05, " Steam Generators Narrow Range Range Level Verification," interchannel comparisons of the

~

replacement transmitters at hot conditions could be postponed with no impact. Had the test data revealed a deficiency that required redesign of the level control system to the extent that previous testing could not be relied upon, the controlled deferral process described below would have been invoked.

Where component testing may not be completed in the Preoperational Test Program but the components must still be verified as capable of performing their intended safety function prior to proceeding with the next phase of testing, the JTG has established a Deferred Preoperational Test l

Program. This program is designed to provide a systematic I

transfer of responsibility for performing the required testing to the plant operating organization.

In this situation, the plant operating organization must prepare specific test procedures to accommodate the deferred testing and, as necessary, initiate measures to gain the approval of the NRC if a deviation from an FSAR commitment or a requirement of the i

Technical Specifications is involved.

1 In the case of the level transmitters discussed in Section 5.1, af ter the calibrations and channel verifications were completed, the integrated steam generator and pressurizer level indication and control systems would be expected to perform their safety function properly and may be declared operable as defined in the CPSES Technical Specifications.

In an Operations group surveillance procedure, the pressurizer and steam generator level indications are required to be

Revision:

.I l

Page 31 of 38 RESULTS REPORT

. O ISAP III.a.1

'(Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 1 observed and recorded once per shift when the average reactor coolant temperature is above 350'F..The acceptability of the performance is determined according to the same criteria applied in the preoperational test.

In addition, the performance of each of the systems is reverified in the Initial Startup Test Program prior to proceeding to power and at numerous plateaus along the way to 100% power.

j q

6.0 CONCLUSION

S i

The RTL concludes that there is reasonable assurance that the t

objectives of the Preoperational Test Program have been met, and' r will continue to be met, and further,'that the attainment of test objectives has not been compromised by inappropriate action by the Startup organization nor the JTG. This' conclusion is based upon a review of the Startup Administrative Procedures, an evaluation of the NRC-TRT concerns, a review of the JTG's disposition of'the TDRs issued to document its reevaluation effort,,and the random sampling program to address the implementation of th'e Test Deficiency Report and the Test Procedure Deviation processes.

The evaluation of the NRC-TRT concerns identified several-administrative weaknesses in the test program that had been corrected by the Startup organization following the JTG's reevaluation effort. The RTL's review confirmed the adequacy of the JTG's response to the NRC-TRT concerns and the adequacy of the data collected and evaluated in fulfilling test program objectives.

No programmatic problems with the TDRs or the TPDs were found by the JTG during its reevaluation or, subsequently, by the RTL.

q Therefore, none of the administrative weaknesses had a substantive impact on the adequacy of the test program conducted.

7.0 ONGOING ACTIVITIES There are no ongoing activities related to this issue.

8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE Since the NRC-TRT review of the CPSES testing activities, the Startup organization has_made numerous revisions to its Startup Administrative Procedures. A majority of these revisions were made to describe the work practices used during testing more accurately to facilitate review by outside organizations.

However, the changes described below were made specifically in response to the issues identified by the NRC-TRT.

Ravision:

1 Page 32 of 38

~

RESULTS REPORT i

O ISAP III.a.1 (Cont'd) 1 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE (Con't)

CP-SAP-11, " Review, Approval and Retention of Test Results" The specific revisions were:

CP-SAP-11 was revised to provide more precise o

instructions to the STE for his preparation of a test data package for subsequent JTG review and approval.

CP-SAP-ll was revised to provide further guidance to i

o l

the individuals performing reviews on behalf of the JTG by incorporating the guidelines developed by the JTG at 3

the onset of its reevaluation effort.

CP-SAP-ll was further revised to require the same o

individuals to document their comments and their subsequent resolution as they are offered during test

{

data package review.

This documentation and the test l

data package is presented to the JTG for final reviev

{

and approval.

i CP-SAP-12, " Deviations to Test Instructions / Procedures" CP-SAP-12 was revised to provide a broader supervisory review of TPDs as follows:

Formerly, TPDs that did not change the intent of the o

procedure had STE approval and Shift Supervisor concurrence prior to implementation. Changes of this type now require STE approval, concurrence by the Shift Supervisor, and approval by an independent STE qualified to Level IV (the highest level within the Startup organization) prior to implementation.

Concurrence by the Lead Startup Engineer that the deviation did not involve a change of intent must also be obtained, although not necessarily prior to implementation.

Previously, CP-SAP-12 required only Shift Supervisor o

concurrence and approval by the Lead Startup Engineer for a deviation that changed the intent of the test.

The SAP now requires the following additional reviews:

For this type of change to a preoperational test, the change must also be reviewed by the Technical Support 9

L__

R vision:

I Page 33 of 38 RESULTS REPORT ISAP III.a.1 O

(Cont'd) 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTURE (Con't)

Group for FSAR implications. To the extent practical, such changes must have concurrence by both the Technical Support Group and the JTG prior to implementation, but, as a minimum, not later than the next regularly scheduled JTG meeting.

l CP-SAP-16, " Deficiency and Nonconformance Reporting" j

l CP-SAP-16 was revised to require a justification of the o

basis for a retest when that retest is none. The SAP was also revised to recommend that documentation be i

provided for the basis of a retest when the specified ;

retest is different from the test by which the specific problem was identified.

The RTL reviewed the Startup Administrative Procedures to determine if the procedures contain adequate instructions to' perform the required reviews and approvals of test procedures and the results of testing. The RTL concluded that the procedures are adequate, and the revisions described above should preclude recurrence of the types of problems identified by the NRC-TRT.

O

R2 vision:

1 Pags 34 of 38 RESULTS REPORT O

ISAP III.a.1 (Cont'd)

. Attachment 1 Description of Issue Identified by NRC The NRC-TRT. described the issue in the CPSES Safety Evaluation Report.

Supplement No. 7 at Pages J-73 through'J-75, Item 4.(6), " Assessment of Safety Significance," as follows:

Final acceptance by TUEC of HFT.results.does not occur until the Joint Test Group (JTG) has conducted its review of the data and approves the completed test data package.

In a sample of 17 out of 25 completted HFT data packages, the TRT found four instances in which not all of the test objectives had been met, yet the JTG had completed their review and had approved the test data packages

~

=

These instances were:

(a)

Preoperational test procedure 1CP-PT-02-12, " Bus Voltage and Load Survey," [was] intended to demonstrate that during all modes of plant operation, optimum current and voltage will be present at all the buses and associated equipment. After the test was completed, the STE noted in review of test data that O

the voltages recorded in paragraphs 7.8.2.1 and 7.8.3.1 did not meet the acceptance criteria specified in the test procedure. A test deficiency report (TDR) was initiated.

Subsequent TUEC engineering evaluation of the out-of-tolerance voltages documented in the TDR required that changes to some of the transformer' output settings used during the conduct of the test were necessary to bring the voltages within the originally specified acceptance criteria.

In accordance with the test procedure, these changes necessitated that some portions of the test be performed again. However, the JTG approved the data package without requiring these portions of-the test to be performed again. Therefore, the test data package contained invalid data for that test; thus, the test objective had not been met.

(b) Procedure ICP-PT-34-05, " Steam Generator Narrow Range Level Verification," [was] intended to demonstrate at hot, no-load conditions, that the specified narrow range level channels for each steam generator indicate properly at the upper and lower instrument taps and compare properly with each other for-actual changes in steam generator water level. The transmitters for level detectors 1-LT-517, 518, and 529 were found defective prior to initiation of testing and, thus, temporary equipment was substituted. The test was performed with the temporary equipment and declared successful. After the test, the specified transmitters were installed. The

()

Joint Test Group (JTC) approved the completed test package

.Ravision:

1 Pags 35 of 38 RESULTS REPORT ISAP III.a.1 (Cont'd)

(Cont'd) containing data taken with temporary transmitters. The only retest required after installation of the detectors was cold calibration (not calibration at hot, no-load conditions);

thus, this test objective was not met and no other requirements were imposed by-the JTG to monitor performance when the transmitters are placed in service.

(c) Procedure ICP-PT-55-05, " Pressurizer Level Control," [was) intended to demonstrate the control aspects of the system in conjunction with the chemical and volume control system.

In l

addition, there was a note on page 12 of the procedure that stated, 'This test is provided to verify the capability of the pressurizer level control system' to monitor pressurizer level over the range of installed instrumentation and to observe that all alarm and control functions are operational.'

A-prerequisite condition (paragraph 6.13) required the plant to be in hot standby condition. During conduct of pressurizer level indication testing in accordance with the procedure O

(paragraph 7.1), the System Test Engineer (STE) noted that a 1evel detector (1-LT-461) was registering marginal readings.

l l

He documented this and recommended a calibration check of the detector. After the test was completed, this was done, and it was determined that the detector was out of calibration, and attempts to calibrate it were unsuccessful..The corrective action was to replace the. detector and perform a cold calibration (not calibration in hot standby condition); thus, this test objective was not met.

The JTG-approved test data package contained level data taken with a detector that subsequently proved to be out of calibration, thereby invalidating the test data and no other requirements were imposed by the JTG to monitor the performance of the new detector when it was placed in service.

(d) Additionally, during the conduct of Procedure 1CP-PT-55-05 discussed in (c) above, the speed of the recording chart for the pressurizer level was changed from 2.5 cm/ minute, as required by paragraph 7.2.6c, to 15 cm/ hour. The TRT determined that this was done to avoid running out of chart paper during the test. This deviation from the approved test procedure should have been documented on a TDR even though, in this case, the chart speed was inconsequential since the recorded trace data were not being relied upon to prove any of the system's performance features.

Rsvision:

1 Pags 36 of 38

)

RESULTS REPORT

.O' ISAP III.a.1 (Cont'd)

]

(Cont'd) l The TRT discussed these findings with startup management, including the Startup Manager, who is a JTG member.

The Startup Manager l

informed the TRT that with respect to ICP-PT-34-05 and 1CP-PT-55-05, the JTG had made a conscious decision not to require hot calibrations on the instruments in question since the accuracy l

of their calibrations could be determined during a subsequent plant heatup. While the TRT understood this, it pointed out that the JTG i

had not specified in the retest requirements that these hot l

calibration determinations must be made; it only specified a cold calibration. Therefore, there was no mechanism to draw attention to the fact that these instruments had not been operationally.

tested previously under hot plant conditions.

The TRT, therefore, did not consider the test objectives to have been fully met. With respect to ICP-PT-02-12, when the TRT identified the need to perform some portions of the test again as a result of the actions taken to implement TUEC's engineering evaluation of the out-of-tolerance voltages, a TDR was immediately initiated by the startup group. The need for performing portions of the test again f-was apparently overlooked by the JTG during its review. The TRT, therefore, considered that the test objectives had not been fully satisfied and that the JTG review of this data package had been less than adequate.

1 l

1 i

O

Ravision:

1 Pags 37 of 38 RESULTS REPORT, CD

~~

~

^' " '

(Cont'd)

Criteria for Evaluation of Completed Test Data Packages The following guidelines shall be used for reevaluation of complete.d preoperational test data packages as required by Action Plans III.a.1 and III.b to ensure:

1.0 That the test satisfied applicable FSAR commitments;

(

i 2.0 That the test objectives were not invalidated as a result of Test Procedure Deviations (TPDs) that were issued during conduct of ther test; and 3.0 That the test objectives were not invalidated as a result of inappropriate corrective actions or retests associated with Test Deficiency Reports (TDRs) issued during the, test or as a result of test data package revietr.

O E0TES,:

0 (1) Particular attention must be given to TPDs that were issued to modify test prerequisite (initial) conditions, or test methodology such that the stated test objectives could not have been attained under the "as tested" conditions or system configuration.

(2) Particular attention must be given to TPDs that were issued to delete the requirement to have permanent plant equipment installed for test conduct or that substituted temporary equipment for permanent plant equipment before or during the j

test.

i (3) Particular attention must be given to the specified retest requirements for TDRs which documented permanent system component (s) that were not installed for conduct of the test or unacceptable test results with respect to the stated test acceptance criteria.

I (4) Regulatory Position C.3 of Regulatory Guide 1.08, Revision 2, states in part; "To the extent practical, the duration of the test should be sufficient to permit equipment to reach its normal equilibrium condition, e.g.,

temperatures and

• O pressures, and thus decrease the probability of failures,

l a l

Ravision:

1 1

Pege 38 of 38 RESULTS REPORT ISAP III.s.1 l

(Cont'd)

(Cont'd) including "run in" type failures, from occurring during plant l

operation." For each case where permanent plant equipment was not installed for the test, the JTG must judge on a case basis the acceptability of the test or retest requirements after the permanent equipment was installed with regard to the above regulatory position.

~

a o

O

)

l l

l i

l l

O

,