ML20198B888
| ML20198B888 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/02/1986 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20198B872 | List: |
| References | |
| PROC-860502, NUDOCS 8605220167 | |
| Download: ML20198B888 (15) | |
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COMANCHE PEAK P.ESPONSE TEAM ACTION PLAN ISAP III.a.1 f
Title:
Hot Functional Testing (HFT) Data Packages Revision No. 4 Reflecti., Comment!,
Description On Plan ,
Prepared and n Recommended b (.
Review Team N Leader Date b4 l l AN e
4 I.
I Approved by:
Senior , Q, Revi.tw Team 9
Date W m 2,/ Q Q r
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i 0605220167 060D13 5 ADOCK 0500 PDR A
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R2 vision: 4 Pegs 1 of 14 ISAP III.a.1 Hot Functional Testing (HFT) Data Packages s
1.0 DESCRIPTION
OF ISSUES The title of this Action Plan does not accurately reflect^ the scope of work which is addressed, but is utilized in order *to correspond to the specific heading in the NRC letter dated September 18, 1984.
The actual scope of work includes all preoperational test data packages and FSAR commitment compliance.
1.1 Hot Functional Testing 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 I 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. The JTG (Joint Test Group) decided a retest was not required.
(b) Hot functional test procedure ICP-PT-34-05, " Steam Generator Narrow Range Level Verification," was performed with three temporary level transmitters.
When the permanent transmitters were installed, the JTG specified only a cold calibration retest.
(c) Hot functional test procedure ICP-PT-55-05,
" Pressurizer Level Control," was performed with a defective level transmitter. When the transmitter was replaced, the JTG specified only a cold calibration retest.
(d) Hot functional tent 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 (TDR).
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 (JTC) that failed to meet all of the objectives stated in the tost procedures.
Revision: 4 Page 2 of 14 ISAP III.a.1 (Cont'd)
1.0 DESCRIPTION
OF ISSUES (Cont'd)
The NRC-TRT conclusions with regard to the issue are at Page J-76, " Conclusion and Staff Positions," as follows:
...It appeared that the overall objectives of the CPSES Unit 1 preoperational test program were being satisfactorily met, thus providing reasonable assurance that the plant is properly designed and constructed and that its operation will not pose a threat to public health and safety. While some of the allegations had valid basis, none was considered to have safety significance or generic implications.
1.2 FSAR Chapter 14.2, " Initial Test Program," Review .
As described in ISAP III.b, " Containment Integrated Leak Rate Test," Revision 4, the NRC-TRT expressed concern that there may be undocumented deviations f om testing commitments made in the FSAR.
While ISAP III.b focuses exclusively on the test which gave rise to the issue, the CPRT determined that it would be appropriate to address the NRC-TRT's concern relating to other FSAR commitments during the evaluation of approved test data packages to be undertaken in this Action Plan.
2.0 ACTIONS IDENTIFIED BY NRC 2.1 Hot Functiona'l Testing 1
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 as follows:
Review all completed preoperational test data packages j to ensure there are no instances where test objectives
, were'n6t met, or prerequisite conditions were not satisfied.' Address the four items identified by the TRT,' along'with appropriate resolution.
2.2 FSAR Chapter,14.2, " Initial Test Program," Review The action identified by the NRC-TRT in the CPSES Safety
, Evaluation Report, Supplement No. 7 at ? age J-17, Item 4.2.2,
" Containment Integrated Leak Rate Testing," as being necessary
,' . to resolve this issue is.as follows:
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- R3 vision: 4 l Page 3 of 14 ISAP III.a.1 (Cont'd) 2.0 ACTIONS IDENTIFIED BY NRC (Cont'd)
TUEC has identified deviations from FSAR commitments related to the CILRT. TUEC shall identify all other deviations from FSAR commitments which were not previously identified to NRC.
3.0 BACKGROUND
Startup Administrative Procedure, CP-SAP-16, " Test Deficiency and Nonconformance Reporting," establishes requirements for the use of Test Deficiency Reports (TDRs). TDRs are issued when unacceptable or indeterminate conditions exist in system or equipment operating characteristics, test documentation, or for any testing procedure .
noncompliance. TDRs contain a description of the specific problem, the 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 not installed, a TDR may be initiated to document the condition and to establish corrective action and/or retest requirements for the equipment. The consequence of proceeding with a test with outstanding TDRs is evaluated by CPSES management. The retests are specified by considering the objective of the preoperational test, function of the specific equipment, and the station tect schedule which determines whether other opportunities will be available for the retest.
Startup Administrative Procedure, CP-SAP-12. " Deviations to Test Instructions / Procedures," allows deviations from approved test procedures when certain approval and documentation requirements are met. The form used to document such deviations is known as a Test Procedure Deviation (TPD). The level of management approval required depends upon whether or not the TPD involves a change in procedure intent.
Both TDRs and TPDs become part of the completed test record reviewed by the JTG prior to acceptance of the test results.
The JTG consists of representatives from the major onsite organizations. TUCCO has organized the JTG to assure effective coordination of the engineering, construction, and operations activities related to the startup program.
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Revision: 4 Page 4 of 14 ISAP III.a.1 (Cont'd)
3.0 BACKGROUND
(Cont'd)
The JTG consists of the following members :
Manager, Nuclear Operations - Chairman Manager, Plant Operations - Vice-Chairman Manager - CPSES Startup Assistant Manager - Nuclear Engineering Westinghouse Representative The JTG membership is knowledgeable of the plant design, FSAR requirements, and the test program administrative requirements and procedures. The group has sufficient organizational freedom and diversity to assure that objectivity will be maintained.
The NRC-TRT reviewed all but seven of the JTG-approved preoperational test data packages associated with hot functional testing. The NRC-TRT also reviewed two of the five acceptance test data packages. These acceptance tests were non-safety-related and no concern was expressed with respect to this category of tests.
In Revision 3 and previous revisions to ISAP III.b. " Containment Integrated Leak Rate Test," the approach to the FSAR commitment compliance review was to examine additional FSAR sections if discrepancies were noted in the test program commitments. This Action Plan examines the test program related commitments. FSAR compliance considerations related to the design and construction of CPSES are being conducted under the Design Adequacy and Quality of Construction Programs described in Appendix A and B, respectively, to the CPRT Program Plan.
4.0 CPRT ACTION PLAN The objective of this Action Plan is two fold: a) to provide reasonable assurance that the CPSES preoperational testing program was and is being accomplished according to applicable Regulatory Guides, FSAR commitments, Startup Administrative Procedures, and individ".a1 test procedures; and b) to satisfactorily resolve the four specific concerns identified by the NRC-TRT.
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- 7 FSAR Amendment is currently being prepared for submittal to the NRC which changes some of these position titles. However, the same organizacions were and continue to be represented.
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Revision: 4 l Pcge 5 of 14 l ISAP III.a.1 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) 4.1 Scope and Methodology
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The scope of work includes all of the preoperational test data packages approved by the JTG as of April 1, 1986. The approach to the work is as follows: develop criteria for the evaluation of completed test data packages; evaluate the three test data packages and resolve the NRC-TRT concerns related thereto; and evaluate the remaining test data packages not reviewed by the NRC-TRT.
4.1.1 Criteria Development The evaluation of completed test data packages will be .
conducted using written acceptance criteria. (These criteria have been developed and are presented in Attachment 2, " Criteria #or Evaluation of Completed Test Data Packages.")
4.1<2 NRC-TRT Identified Ccncerns The three test data packcges cited in Section 1.0 will be evaluated. The four specific concerns identified by the NRC-TRT will be resolved.
4.1.3 Evaluation of Twenty-seven Test Data Packages Shortly after receipt of the NRC letter dated September 18, 1984, the CPRT initiated a programmatic evaluation of approved test data packages. The approach used at that time consisted of evaluating the seven HFT related packages not reviewed by the TRT and a sample of twenty other packages considered most safety-significant.
4.1.4 Evaluation of the Remaining Test Data Packages Excluding the sixteen that were reviewed by the NRC-TRT, there have been 190 preoperational tests performed to date. Each of the data packages asscciated with these tests has been reviewed and approved by the JTG at least once and, as a consequence of steps 4.1.2 and 4.1.3 above, thirty of them have undergone a second evaluation. Rhile there is no evidence thus far to indicate that a programmatic deficiency exists with respect to the Unit 1 preoperational test program, this population of 190 tests will be further examined through the application of a sampling program. Details of the program are provided in Section 4.5.
Revision: 4 Page 6 of 14 ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.5 Startup Administrative Procedures 4.1.5.1 The evaluation criteria shown in Attachment 2 will be incorporated into the Startup Administrative Procedures.
4.1.5.2 The process by which the Startup organization identifies and reports FSAR commitment deviations to TUGC0 Nuclear Licensing will be reviewed. Procedure changes or new procedures will be prepared, as necessary.
4.1.6 Corrective Action .
Identified discrepancies, if any, will be processed according to Appendix E, "CPRT Procedure for the Classification and Evaluation of Specific Design or Construction Discrepancies Identified by CPRT."
Corrective action, if required, will be implemented according to Appendix H, "CPRT Procedure for the Development, Approval, and Confirmation of Implementation of Corrective Action."
4.2 Procedures The procedures to be used are the existing CPSES procedures, augmented by checklists wh2re necessary.
As a means for documenting and tracking the evaluation of each test data package, a Test Deficiency Report will be issued prior to starting the work and dispositioned according to CP-SAP-16, " Test Deficiency and Non-conformance Reporting."
4.3 Participants Roles and Responsibilities 4.3.1 CPSES Joint Test Group (JTG)
The JTG members, or their designees, who are qualified to review preoperational test results and who did not perform the original review, will be responsible for evaluation of completed test data packages.
The JTG will be responsible for specifying corrective actions and retest requirements for the TDRs issued as a result of this evaluation effort.
Rsvision: 4 Paga 7 of 14 ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3.2 CPSES Startup Group The Startup group will provide the information necessary for the JTG to perform the work according to existing procedures.
4.3.3 Testing Program Review Team The Testing Program Review Team Leader, or his designee, will monitor the evaluation process to assure the objectives of this Action Plan are being met. He will review and concur in the evaluation criteria and the final evaluation results for each test data ,
package. The Review Team Leader will also perform the Startup Administrative Procedure review.
4.4 Qualifications of Personnel 4.4.1 The JTG consists of the following members who are qualified for review and approval of preoperational test procedures and results as specified in the FSAR Section 14.2.2.7:
Manager, Nuclear Operations - Chairman Manager, Plant Operations - Vice-Chairman Manager - CPSES Startup Assistant Manager - Nuclear Engineering Westinghouse Representative Those individuals designated by the JTG members to assist them in performance of the evaluations are also qualified for review of preoperational test results.
Prior to initiating the reviews of test data packages, the JTG and its representatives were indoctrinated in the NRC-TRT's interpretation of the regulatory position stated in Regulatory Guide 1.68, " Initial Test Programs for Water-Cooled Nuclear Power Plants," paragraph C.3 and the specific criteria in Attachment 2 " Criteria for Evaluation of Completed Test Data Packages."
4.4.2 The CPRT Testing Program Review Team Leader meets the qualifications described in the CPRT Program Plan. He
- will assure that other team members are appropriately qualified. ,
2 See Note , Page 4
Revision: 4 Paga 8 of 14 ISAP III.a.1 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Sampling Program j Each test data package is the end result of the sum of the 4 preoperational testing activities. The CPRT has deemed that a random sample of test data packages would be an appropriate method of investigation for potential programmatic deficiencies in the preoperational test program. The following describes the three specific populations to be sampled according to the guidelines contained in Appendix D of the CPRT Program Plan, "CPRT Sampling Policy, Application and Guidelines." In each case, the minimum sample size will be sixty. ,
4.5.1. Population of TDRs 4
This population is comprised of all the TDRs written in connection with the 190 test data packages.
4.5.2 Population of TPDs This population is comprised of all the TPDs written in connection with the 190 test data packages.
4.5.3 Population of FSAR Commitments This population is comprised of all the preoperational test specific commitments presented in FSAR Chapter 14.2, " Initial Test Program."
4.6 Acceptance Criteria Eacl} testing related FSAR commitment was met, or if not, the rear;on was documented and reported to the NRC.
Each test objective was not invalidated by the use of the Test
' Procedure Deviation, or, if it was, appropriate retesting had been required.
Each test objective was not invalidated by the use of the Test Deficiency Report, or, if it was, appropriate retesting had been required.
J The Startup Administrative Procedures will be acceptable to the Review Team Leader if measures have been established to preclude having undocumented FSAR deviations.
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Revision: 4 Page 9 of 14 ISAP III.a.1 (Cont'd) 4.0 CPRT ACTI)N PLAN (Cont'd) 4.7 Decision Criteria If eay acceptance criterion is not met, the sample evaluated wil; be expanded in the appropriate population according to App 2ndix D, "CPRT Sampling Policy, Applications and Guidelines."
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Ravision: 4 Page 10 of 14 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 completed 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 package.
These instances were: .
(a) Preoperational test procedure ICP-PT-02-12, " Bus Voltage and Load Survey," 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 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 he 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," 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 l
Joint Test Group (JTG) approved the completed test package l
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. 4 Page 11 of 14 ISAP III.a.1 (Cont'd)
Attachment 1 (Cont'd) containing data tahen with temporary transmitters. The only retest required after inetallation of the .etectors 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," intended to demonstrate the 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 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 (paragraph 7.1), the System Test Engineer (STE) noted that a level detector (1-LT-461) was registering marginal 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 placed in service.
(d) Additionally, during the conduct of Procedure ICP-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.
Revision: 4 Page 12 of 14 ISAP III.a.1 (Cont'd)
Attachment 1 (Cont'd)
The TRT discussed these findings with startup management, including the Ste.rtup Manager, who is a JTG member. The Startup Manager inforzed the TRT that with respect to ICP-PT-34-05 and ICP-PT-55-05, the JTG had made a conscious decision not to require hot calibrations on the instruments in question since the accuracy of their calibrations could be determined during a subsequent plant heatup. While the TRT understood this, it pointed out that the JTG had not specified in the retest requirements that these hot 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 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, r
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1 Ravision: 4 !
Page 13 of 14 l ISAP III.a.1 (Cont'd)
Attachment 2 Criteria for Evaluation of Completed Test Data Packages The following guidelines shall be used for reevaluation of completed 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; 2.0 That the test objectives were not invalidated as a result of Test Procedure Deviations (TPDs) that were issued during conduct of the 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 review.
NOTES:
(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 configuraticn.
(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 test.
(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.
(4) Regulatory Position C.3 of Regulatory Guide 1.68, 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
' pressures, and thus decrease the probability of failures,
- Revision: 4 Psg2 14 of 14 ISAP III.a.1 (Cont'd)
Attachment 2 (Cont'd) including "run in" type failures, from occurring during plant 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.
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