View source for TXX-4952, Forwards Action Plan for Isap III.a.5, Preoperational Test Review & Approval of Results, for Inclusion in Facility Response Team Program Plan & as Response to ASLB 841221 Memorandum

{{Adams
| number = ML20214J995
| issue date = 08/11/1986
| title = Forwards Action Plan for Isap III.a.5, Preoperational Test Review & Approval of Results, for Inclusion in Facility Response Team Program Plan & as Response to ASLB 841221 Memorandum
| author name = Beck J
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Noonan V
| addressee affiliation = NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-4952, NUDOCS 8608150260
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}

=Text=
{{#Wiki_filter:CPRT-S98                                                                            Log # TXX-4952 xy,                                                                                       File # 10068 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 400 NORTH OtJVE STREET. I.B. 8 8 . DALLAN. TEXA8 78201 August 11, 1986
  .MNE!i??E.".*,h Director of Nuclear Reactor Regulation Attn: Mr. Vince S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 SUBMITTAL OF ISSUE-SPECIFIC ACTION PLAN OF THE COMANCHE PEAK RESPONSE TEAM (CPRT) PROGRAM PLAN

==Dear Mr. Noonan:==

In our {{letter dated|date=May 13, 1986|text=May 13, 1986 letter}} TXX-4797 it was indicated that Revision 3 of the CPRT Program Plan was complete. However, an additional ISAP has been developed by the CPRT to further address ASLB concerns as described in Board Memorandum dated December 21, 1984.
As such, transmitted herewith is Comanche Peak Response Team Issue-Specific Action Plan (ISAP) III.a.5 "Preoperational Test Review and Approval of Results" (Revision 0). ISAP III.a.5 should be placed behind the " Appendix C, Testing" tab in Revision 3 of the Program Plan. Also enclosed is a replacement page for the list of Testing ISAPs. This page should be placed l
immediately behind the " Appendix C, Testing" tab in the Revision 3 Program l          Plan.
l Should you have any questions please do not hesitate to call either John Beck or myself.
Very truly yours, W. G. Counsil By:               M.           G J    W. Beck V ce President WGC/arh i          Enclosures 8600150260 860811                                                                                    A0 PDR A
ADOCK 05000445 PDR hV I-  g l l
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         'a Testing ISAPs-III.a.1-            Hot Functional Testing (HFT) Data Packages III.a.2             JTG Approval of Test Data III.a.3             Technical Specification For Deferred Tests III.a.4             Traceability of Test Equipment III.a.5             Preoperational Test Review and Approval of Results III.b               Conduct of the CILRT III.c               Prerequisite Testing III.d               Preoperational Testing IV.                 Reserved for Protection Coatings, however, SSER-9 declassified protective coatings and negated the need for a protective coatings ISAP. Paint quality concerns are being addressed under the Quality of Construction Program.
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_                                       COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.a.5

==Title:==
Preoperational Test Review and Approval of Results Revision No.                    0 Original Description                 Issue Prepared and         g                  {I Reconumended by:     ,'
Review Team
;            Leader               d Date                   7- / / - 86 Approved by:
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ISAP III.a.5 Preoperational Test Review and Approval of Results

==1.0 DESCRIPTION==
OF ISSUE In a Memorandum , dated December 21, 1984, the Atomic Safety and Licensing Board (ASLB) described the issue as follows:
Testimony indicates that system performance did not meet the acceptance criteria, both because of obvious calculational errors and because the acceptance criteria were exceeded.
2.0 ACTION IDENTIFIED BY THE ASLB The information required by the ASLB is as follows:
We need to know how this occurred and to be assured concerning the frequency of similar errors in startup test results.

==3.0 BACKGROUND==

The preoperational test program is conducted according to written procedures approved by a Joint Test Group (JTG), whose membership reflects the major CPSES design, testing, and operating organizations. The preoperational tests are conducted by the Startup organization according to JTG approved procedures. The System Test Engineer responsible for performing a particular test I                                               also prepares the final test data package for subsequent review and approval by the JTG.
The ASLB's Memorandum resulted from TUEC's presentation of a JTG approved preoperational test data package, 1-CP-PT-02-02, "118 VAC RPS Inverters," as evidence in the companion ASLB hearings. The test data package contained recorded test data which did not meet the stated acceptance criteria. The function of this system is to provide an uninterruptable power supply to the Reactor Protection System instrumentation. The first preoperational test of this system was approved by the JTG in January, 1983. During subsequent operation of the system, ferroresonant transformers, a major component of the system, exhibited in-service failures.
Investigation of the failures led to filing a notification to the ASLBP No. 79-430-06 OL, Memorandum (Standards Applicable to Pending Motions)

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O                                                                                   ISAP III.a.5 i
(Cont'd)

==3.0 BACKGROUND==
(Cont'd)
NRC pursuant to 10CFR50.55(e). The transformers were replaced.
The retest requirement specified for the system was total reperformance of the preoperational test. During preparations for performing the retest, the responsible System Test Engineer, who did not perform the first test, identified the unacceptable data in the original test data package. Subsequently, the original test data package was presented as evidence in the companion ASLB hearing in order to impeach testimony given by others.
4.0 CPRT ACTION PLAN The objective of this Action Plan is two fold                                                                     a) to identify the factors which contributed to the approval of test data which did not meet specifications; and b) to provide reasonable assurance there are no similar errors in other test data packages.
4.1 Scope and Methodology The scope of the evaluation includes all 205 preoperational test data packages that have been approved by the JTG to date.
There remain several tests associated with the Unit 1 test program which have not yet been performed. JTG approval of these test data packages. is not anticipated before this evaluation is complete.
l The evaluation will be conducted by examining the circumstances which led to the approval of test results which did not meet specifications; and reviewing the re.maining test data packages to determine the frequency of similar errors.
4.1.1              1-CP-PT-02-02, "118 VAC RPS Inverters," Revision 0.
The original test data package will be reviewed to determine the reason (s) for approval of test results which did not meet the stated acce.ptance criteria.
4.1.2 Remaining Test Data Packages Test data in the 205 test data packages will be examined to determin. if there are any other instances where test data does not meet the stated acceptance l
'                                                                 criteria. The review will be conducted through a sampling program as discussed in Section 4.5.
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Pega     3 of 4 O                                                                                  ISAP III.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) l 4.1.3    Corrsctive Action                                             '
Identified discrepancies, if any, will be processed according to Appendix E, "CPRT Procedure for the Classification and Evaluati;n of Specific Design or Construction Discrepancies Identified by CPRT."
Corrective action, if required, will be implemented according to Appendix H, "CPRT Procedure for the Development, Approval, and Confirmation of Implementation of Corrective Action."
4.2 Procedures A checklist will be developed to guide and document the CPRT review. In any cases where the acceptance criteria of Section 4.6 are not met, the CPSES Startup Group will issue a Test j                                                                  Deficiency Report according to CP-SAP-16, " Test Deficiency and Non-conformance Reporting," in order to provide a full JTG
!                                                                  review. In such cases, the CPRT will expand the review according to Section 4.7, " Decision Criteria."
,                                                             4.3 Participants Roles and Responsibilities
: i.                                                                 4.3.1    CPSES Startup Group The Startup organization will provide support personnel to augment the CPRT third-party review.
4.3.2 CPRT Third-Party The CPRT Testing Program Review Team Leader is responsible for the actions identified in Section 4.1.
4.4 Qualifications of Personnel 4.4.1 CPSES Startup Group Startup personnel assigned to augment the CPRT               '
third-party staff will be qualified to a minimum of Level II in accordance with CP-SAP-19. " Training /
Qualification Requirements for Startup Personnel."
4.4.2 CPRT Third-Party O                                                                   The CPRT Testing Programs Review Team Leader meets the qualifications as described in the CPRT Program Plan and assures that other personnel are qualified.
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Rsvisien        0 t   .                                                                         Page     4 of 4 ISAP III.a.5 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Samplina Program Each test data package is the end result of the sum of the preoperational testing activities. The CPRT has deemed that a random sample of acceptance criteria in the test data packages would be an appropriate method of investigation for potential programmatic deficiencies of the nature described herein.
The acceptance criteria population will be sampled according to the guidelines contained in Appendix D of the CPRT Program Plan, "CPRT Sampling Policy, Application and Guidelines." The recorded test results will be reviewed to ensure that stated acceptance criteria are met. The minimum sample size will be                  .
sixty. The total population of acceptance criteria contained in the 205 Test Data Packages is 3,391.
4.6 Acceptance Criteria The results of testing or ratesting meet the stated acceptance criteria and have been approved by the JTG, or if not, the JTG O                 had approved the required retest on a Test Deficiency Report.
4.7 Decision Criteria If the acceptance criterion noted above is not met, the evaluation will be expanded according to Appendix D "CPRT Sampling Policy Applications and Guidelines."
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