ML20236C725

Rev 2 to RCS Cold Hydrostatic Test Rept

ML20236C725
Person / Time
Site:	Comanche Peak
Issue date:	02/24/1989
From:	Skaggs M TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20236C708	List: ML20236C706 ML20236C725
References
ER-ME-01, ER-ME-01-R02, ER-ME-1, ER-ME-1-R2, NUDOCS 8903220291
Download: ML20236C725 (14)

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j REACTOR COOLANT SYSTEM COLD HYDROSTATIC q TEST REPORT ER-ME-01 REVISION 2 FEBRUARY 24,-1989 j

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TU ELECTRIC COMANCHE PEAK ENGINEERING 1

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ABSTRACT This report describes the activities associated with the comple- i tion of the Comanche Peak Steam Electric Station, Unit 1 Reactor  !

Coolant System Cold Hydrostatic Test and presents the results .of j an assessment and the adequacy of the RCS Cold Hydrostatic- Test. i The results indicate that the RCS Cold Hydrostatic Test . was adequately performed in accordance with approved procedures which ,

complied with ASME Section III. j l

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v I. INTRODUCTION 1

(_/ The purpose of the CPSES Reactor Coolant System (RCS) Cold Hydrostatic Test completed on July 30 and 31, 1982, was to verify the integrity of components and welded joints wl thin the RCS test boundary. The test boundary included :Jode Class 1 piping and portions of Code class 2 piping. The test was implemented by Brown and Root (B&R) and TU Electric Startup Department (S/U) and verified by Authorized Nuclear Inspectors. B&R, as the ASME Section III NA Certificate Holder, was responsible for installation, testing, inspec-tion, and certification of the CPSES Code Class piping systems. TU Electric S/U was responsible for ~ establishing the test boundary, test parameters and -achieving the re-quired test pressures for the B&R inspection. The RCS Cold Hydrostatic Test was performed to the requirements of ASME l Section III, Division 1, 1980 Edition through the Summer l 1981 Addenda.

The CPSES site specific procedures used by B&R to implement' i this test were: ,

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CP-CPM-6.9I, Rev. 5, DCN 2, " Pressure Testing" I CP-QAP-12.1, Rev. 3, " Inspection Criteria and Documenta- i tion Requirements Prior to Release for Pressure Testing" l CP-QAP-12.2, Rev. 3, " Inspection Procedure and Accep-tance Criteria for ASME Pressure Testing"

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CP-QAP-18.2, Rev. 2, " Quality Assurance Review of ASME III Documentation" The following procedure was used by TU Electric S/U to conduct the test:

1 1CP-PT-55-01, Rev. O, " Reactor Coolant System Cold Hydro-static Test" II. HYDROSTATIC TEST METHODOLOGY Included in the implementation of the overall test program were provisions and requirements for performance and verifi-cation of documentation reviews, preparation of test pack-ages, test performance, and documentation of test results. l In accordance with procedure CP-CPM-6.9I, " Pressure Test-l ing," the Startup Test Engineer initiated the Cold Hydro Pressure Test- Data Package, 1CP-PT-55-01, and a Pressure Test Data Sheet indicating test parameters. In doing so, he established the test boundaries and then delineated them by l

highlighting the applicabic system flow diagrams. After review and concurrence by Texas Utilities Services, Inc.

(TUSI) Engineering, the test package was sent, as required by CP-CPM-6.9I, to the B&R Site QA Manager for a QA documen-tation review and to obtain Authorized Nuclear Inspector l

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To ensure all ASME construction documentation was complete r"s and satisfactorily reconciled with code and- specification

( requirements, B&R Quality Engineering performed a documenta -

tion review -per procedure CP-QAP-18.2, " Quality Assurance Review-of ASME III Documentation". 'In preparation for the test, the' B&R Completions Quality Engineering Group wa's required. toi verify and status the completion of the CP-QAP-18.2 documentation review in accordance with proce-dure CP-QAP-12.1, " Inspection- Criteria and Documentation Requirements Prior to the Release for Pressure Testing". A

" Documentation Status Form", Attachment 1 to CP-QAP-12.1, was completed for each drawing (BRP) associated with .the test. Additionally, the' B&R Completions Quality Engineering Group reviewed vendor NPP-1 Code Data Reports and piping spool documentation packages;for all piping subassemblies included in the test boundary to assure the acceptability of that documentation and to . identify the presence or absence of any vendor base metal repairs. It:was also.the responsi-bility of the B&R Completions Quality Engineering Group to-walk down the test boundary-prior'to.the hydrostatic testing to confirm the results of the' documentation reviews'and 1to assess the acceptability of the piping system for testing (including removal of insulation as required by CP-CPM-6.9I) as required by CP-QAP-12.1.

The results of these pre-test reviews were then transferred to the hydrostatic test copies of the BRPs.- Because BRP3 O were not revised during this timeframe to incorporate all information required for test performance, notes were written in red ink on the test BRPs indicating the presence or absence of base metal repairs involving welding and hangers involving integrally welded attachments. Other processes that were accomplished by- performing grinding operations may also have been termed base metal repairs by B&R; however, if the minimum design wall thickness- as delineated in the design specification and ASME;Section 'III' was not violated and no weld. buildup was performed, these areas were not identified in' red ink cM1 the test BRPs as 'a specific inspection location. Inspection of these non-welded base metal repairs is not required by ASME-Section III during hydrostatic testing. Copies of Component Modification Cards (CMCs) and vendor spool fabrication drawings were attached to'the test BRPs to identify welds which were not shown directly on the test BRPs.

The highlighted test BRPs, with reference drawings and other applicable information attached, were then incorporated into the Pressure Test Data Package along with a Quality Check-list,-which was completed by the QC inspector witnessing the test as required by procedure CP-QAP-12.2, " Inspection a Procedure and Acceptance Criteria for ASME Pressure Test-ing." Due to the size and time considerations associated with the RCS cold hydrostatic test, the single Pressure _ Test O Data Sheet, initiated by Startup, was supplemented with

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eleven (11) Pressure Data Sheet Attachments each covering a specific portion of the total test boundary. These O (11) supplemental attachments were used by B&R ASME Control as the basis for the approval signature eleven Quality on the Quality Checklist.

The personnel who performed the Quality control witnessing of the test were qualified and certified to perform such duties under a qualification and certification program which was subjected to the checks and balances inherent in an ASME program (i.e., ANI monitoring and ASME surveys). The Comanche Peak Response _ Team (CPRT) reviewed implementation of the program by reviewing Brown and Root ASME certifica-tion records. The certification records of each inspector whose signature or notation appears on test documentation and of each inspector listed as being available for the test have been evaluated in detail and did not reveal any matters of concern regarding qualification or certification. Each was certified to the correct area of qualification (MIFI:

Mechanical Inspector, Fabrication Inspector) . Based on the acceptability of the certification records and other fac-tors, the CPRT concluded that the Brown and Root QC inspec-tion certification program was satisfactory.

The performance and inspection of the RCS cold hydrostatic test met the requirements of CP-CPM-6.9I, CP-QAP-12.2 and 1CP-PT-55-01. After pressurizing the test boundary to 1.25

('7) times the BCS design pressure, satisfying the required hold

\_/ times and reducing to inspection pressure, as documented by signatures within 1CP-PT-55-01, inspection teams inspected their designated area. Each Pressure Data Sheet attachment contains the signatures of an ANI'and of a member of QC inspection team attesting to the successful inspection of the areas described in the Pressure Data Sheet attachment.

The B&R Quality Control inspectors were also verbally instructed to examine the entire piping system for leaks while giving particular attention, as required by CP-QAP-12,2, to areas of welded joints, connections, base metal repairs involving welding and regions of high stress.

Acceptance of the test to the applicable inspection require-ments was documented on each of the Pressure Test Data Sheet Attachments by Quality Control and ANI Fi '"sture. Accept-ance of the pressure test for the entire _sid hydrostatic test boundary, as defined by the highlighted flow diagrams contained in the test package, was documented by Test Engineer, B&R Quality Assurance, ANI and TU Electric ap-proval signatures on each flow diagram, as required by CP-CPM-6.9I (Figure 6.9I-2). Documentation of acceptance was also provided on the overall Pressure Test Data Sheet and Quality Checklist as required by CP-CPM-6.9I and CP-QAP-12.2 respectively. Acceptance of the pressure test, as required by CP-CPM-6.9I and CP-QAP-12.2. of vendor compo-nonts, such as O the pressurizer, steam generators, coolant pumps and portions of the reactor vessel, was reactor

' documented by approval signature on the components code Data f-s Report by the manufacturer and the manufacturers' ANI.

i After all post-test reviews were complete, the final test results were then reviewed and approved:by the Lead Startup Engineer, Manager of Plant Operations, Westinghouse Site Manager, TUSI Engineering, Construction Manager and- the Manager of Nuclear Operations, as documented by approval signature on the 1CP-PT-55-01 cover sheet.

III. TU ELECTRIC ASSESSMENT Based on issues expressed by the NRC'and Texas Department of.

Labor and Standards (TDLS) with the Unit 1 Cold Hydrostatic Test,'TU Electric, initiated an assessment of the-adequacy of- I the hydrostatic test _ including an evaluation of the issues expressed by the NRC and TDLS. This assessment included:

i Determination of -design pressures, . l Calibration accuracy of pressure standards, .)

Test pressure of 1.25 vs. 1.5 times design pressure, and ]

1 the following items related to IR 85-07/05: 1 Hydrostatic related procedures (including practices),

ASME Section III programmatic hydrostatic testing requirements, Hydrostatic testing related records. l Each of the specific areas that was included in this assess-ment is discussed separately below.

l A. Determination of Design Pressures A potential deficiency concerning the determination . and application of design pressures as related to CPSES hydrostatic test programs was identified on SDAR CP-88-03.

This potential deficiency was evaluated and deemed not-reportable under the provisions of 10CFR50.55(e), as documented in letter no. TXX-88121.

B. Calibration Accuracy of Pressure Standards A potential deficiency concerning the calibration accuracy of pressure standards was identified on -SDAR CP-87-08.

This potential deficiency was evaluated and deemed not reportable under the provisions of 10CFR50.55(e), as documented in letter no. TXX-88208.

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C. Test Pressure of 125% vs. 150% of Design Pressure b

g ,/ CPSES applied a test pressure of 1.25 times system Design Pressure instead of. 1.5 times system Design Pressure as invoked by subsubarticle NC-6221, 1974 Edition, Summer Addenda'of ASME Section III. The 1974 Edition, Summer Addenda is the CPSES Unit 1 piping system Code of Record (ref. NA-1140(c)).

Specification / Code Requirements ASME Section III,' 1974 Edition subparagraph NA-1140(f) states:

Code Editions, Addenda, and Cases . which have not become mandatory on the contract date for a component may be used by mutual consent of owner.or his agent and Manufacturer or Installer on or after.the dates permitted by.(a) through (d) above. It is permitted to use specific provisions within an Edition or Addenda provided that all related requirements are met.

FSAR Table 5.2-1 delineates the applicable ASME Section III Editions and Addenda for Reactor Coolant System Components.

l FSAR 3.9N.1.1 specifies that the primary and secondary l hydrostatic tests of the Reactor Coolant System are to l be conducted at 1.25 times the design pressure.

FSAR 3.9B.3 states that:

" ... as permitted by paragraph NA-1140 of the 1974 Edition of the Code, more specific paragraphs in I

recent editions and addenda of the'ASME Code have been invoked."

, 2323-MS-100,Section II, Item 15 specifies.that the l testing of Class 1, 2 and 3 pressure retaining mate-rials is to meet the requirements of the 1980 Edition, Summer 1981- Addenda. 2323-MS-200 provides the same  ;

requirements for testing of Class 1, 2 and 3 pressure '

retaining materials.

Confirmatory Action No action for this item is required. As allowed by ASME Section III, FSAR and referenced Design Specifications, hydrostatic testing of Code Class 1, 2 and 3' piping systems was conducted in accordance with the 1980 Edition, Summer 81 Addenda. This' specific edition and i addenda defines the minimum hydrostatic test pressure to O be 1.25 times the design pressure.

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l D. Hydrostatic Testing Related Procedures

) Applicable revision levelslof. procedures :CP-QAP-12.1,t CP-QAP-12.2, CP-QAP-18.2, CP-CPM-6.9I AND CP-PT-55-01 )

were reviewed to determine if:-

~they provided the appropria te . criteria for performing the applicable purpose,.

the requirements, stated w!. thin,'were fulfilled.by.the responsible organization (s) and '

the. applicable. practices used to implement .the RCS cold hydrostatic test were delineated within~Tthe procedures.

The following- items: were noted as a result :of the procedure. review:

Item 1 l

CP-QAP-12.2, Paragraph 3.4 states in part:.

"The Quality Engineering- Review Group shall verify.

that all documentation within the subject' tent- bound-ary is- complete and . reviewed in' accordance with CP-QAP-18.2. All documentation pertaining to- the subject test boundary shall be statused on a Documen-tation Status Form..."'

l The Documentation Status Form was used by B&R to1 status documentation pertinent' to the ' subject test' boundary.

This' form was not retained as.a permanent plant ~ record.

CP-QAP-18.2 did not. specifically direct B&R to1 review-vendor documentation (e.g., spool. sketches, ' repair process records, etc.) for the-identification ^of vendor welds and vendor base metal repairs.

Procedure / Code Requirement (s)

ASME Section III, NA-4932 allows the. owner to designate U which records are to be mainta'ined as permanent- plant records. The retention of1these records was not' desig-nated by B&R or TU Electric.  :

ASME Section III . ( re f . NX-6121,- NX-6224). addresses welded joints and connections and does not differentiate between welded connections performed;by various organi- ,

zations. '

Confirmatory Action - Verify through a records review that all applicable information was appropriately statused on the hydrostatic test' isometric.  :

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Item 2 CP-QAP-12.2 or- other ' applicable procedures did' not require that~ the l vendor base ' metal repairs,.. vendor-welds,_B&R base metal-repairs-and attachment welds be indicated on the test . hydrostatic isometric drawing or "<

to have,the appropriate: spool sketches attached. 'The applicable procedures did not- provide _the_directioni or. ,

criteria to specifically highlight'or annotate on the  !

isometric for the presencetor absence of welded repairs l and attachments. 1 Procedure / Code Requirement (s)-

CP-QAP-12.2, Paragraph 2.3 states in paht:

" Pressure tests shall';be documented lwith a Pressure Test Data Package .which shall include...a' Pressure q Test Data' Sheet, applicable' drawings < marked to show the test boundaries..." 1

-1 CP-QAP-12.2, Paragraph 4.0 states in part:

"No_ leaking shall'be" allowed.at .all welded joints, )

connections, base _ metal repairs involving welding, and-  ;

all regions of high stress." l l

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t O ASME Section III, NA-4420 states in part that, dures shall include appropriate quantitative or.qualita-tive criteria for determining that important . activities "proce-i have been' accomplished." ,

l Confirmatory Action Verify through a records review of all RCS Cold Hydro-static Test documentation that- test -isometrics were.

appropriately highlighted and annotated and the vendor spool sketches identifying welded base metal repairs and welds were attached.

Item 3 Some test isometrics' indicate with notes written in' red 'i ink that no welded base _ metal repairs were present.

After review of applicable installation documentation  !

and spool packages,. base' metal repairs involving welding were identified. These base metal repair welds identi-fled are located in the regions'of.circumferential butt welds. These base metal repair. welds 1were made at the spool fabricator's shop and at the CPSES site. ,

t Additionally, three of these test isometrics contained conflicting notes written in black ink _ indicating _ base O metal repairs were located as shown. However, spool ,

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documentation packages verify that the base metal repairs identified by black ink were cosmetic and did O not include welding. These repairs did not violate the minimum design wall thickness as delineated in the design specifications and ASME Section III.

Procedure / Code Requirement (s)

ASME Section III NX-6121 and NX-6224 state in part, respectively:

"All joints, including welded joints shall be ...

exposed for examination during the test."

" ... all joints, connections, and regions of high stress ... shall be examined for leakage."

Inspection of non-welded base metal repairs is not required by NX-2000 and NX-4000 during the hydrostatic test.

Confirmatory Action Determine through a fabrication, installation and hydrostatic test records review where all welded base metal repairs are located and initiate appropriate-retesting for repairs involving welding that are located

} outside the inspection zone of any field or shop welds.

Item 4 The " Pressure Data Sheet Attachment" was the cover sheet used by B&R ASME Quality Control to document inspector acceptance of a specific portion of the ASME hydrostatic test. Although not addressed in any of the applicable B&R/ construction procedures, the data sheet was used to document the individual acceptance of a specific portion of the system hydrostatic test by the applicable B&R ASME Quality Control inspector and ANI. The Pressure Data Sheet Attachment lists the following categories and compliance statement:

Area (boundary)

Prints (applicable isometrics which delineate the area / boundary)

Inspectors (B&R ASME Quality Control)

Lead / Alternate Inspectors "All welded joints, connections, base metal repairs involving welding, and all regions of high stress as shown on attached Isos have been hydrostatic tested and found acceptable."

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. -10 Procedure / Code Requirement (s)

( CP-QAP-12.2, Paragraph 4.1 states in part, "Upon comple-tion of the pressure test the quality control. inspector shall complete the Quality Checklist and check either the accept or reject space and sign and-date the form."

Confirmatory Action No action for this item is required. The Pressure -Data Sheet Attachment was used by B&R as the basis of accep .

tance for signing the Quality Checklist. The Quality Checklist is the acceptance of the Hydrostatic Test in accordance with CP-QAP-12.2.

l E. ASME-Section III Programmatic Hydrostatic Testing Requirements i A review of ASME Section III programmatic requirements l

(e.g., NX-6000) compared the specific Code hydrostatic test related requirements to the Unit 1 Hydrostatic Test Program procedure requirements. The matrix documenting this review is Attachment 1 to this report. The results of this review indicate no issues.

F. Hydrostatic Test Related Reocrds l

(~') The RCS Cold Hydrostatic Test related records were

\d reviewed to verify the completeness and. accuracy of the pre-CPSES Unit 1 Cold Hydrostatic Test documentation review and test package preparation processes performed by B&R. All piping documentation within the RCS Cold

, Hydrostatic Boundary was reviewed, including that l associated with piping in the Reactor Coolant, Residual Heat Removal, Safety Injection and Chemical and Volume Control systems, as identified on seven (7) highlighted flow diagrams originally supplied by the Startup Test Engineer. The piping involved is detailed on 85 differ-ent BRPs (isometric or installation drawings) all of i which are contained in the original test package. These BRPs identify the construction piping welds and piping subassemblies (spools) which were included in the test.

The vendor and construction documentation packages-associated with each spool were reviewed to determine the following:

the piping spool number, if the spool fabrication drawing, which identifies all fabricator welds, was attached to the BRP in the test' o

package, if vendor or B&R base metal repair welds or integrally welded attachments existed and if so, the location on I

Os the line, and

if the presence or absence of these base metal repair welds or integrally welded attachments were identified G by a note, in red ink, on the BRP in the original test package.

The documentation review summarized in Attachment 2 was recorded on checklists categorized by BRP and piping spool number. Attachment 3 provides a list of items and their respective Deficiency Report (DR) or Nonconformance Report (NCR) number noted during the review. The following conclusions resulted from the documentation review:

1. All spool sketches identifying base-metal repairs involving welding and welds for piping spools supplied by organizations (i.e., ITT Grinnell, Southwest Fabricators) were attached to the hydro-static test isometric.

2. All base metal repair welds were located in the inspection zone of a shop or field circumferential butt weld inspected during the hydrostatic test weld inspection.

3. No vendor base metal repair welds existed on the primary loop piping.

4. The notes written on the test isometrics (BRPs) which stated, "no major base metal RPSs could be located," were correct (considering 2. above).

G 5. Fabricator documentation, relative to base metal repair welds, had been adequately reviewed to identify the subject areas.

6. Integrally welded attachments were consistently identified and located on the hydrostatic test isometric. The hydrostatic test isometrics and attached supporting documentation adequately iden-tify the areas within the test boundary that were required to be inspected. ,

This review verified that the pre Cold Hydrostatic Test documentation review and test package preparation performed by B&R was completed and adequate.

IV.

SUMMARY

As a result of TU Electric's assessment of the RCS Cold Hydrostatic. Test the following conclusions to those actions required by NE-19869 are provided. Those actions identified are represented below by the following five objectives.

Obiective #1 Determine the extent to which the Unit 1 RCS Cold Hydrostatic Test demonstrated system integrity and satisfied

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Conclusion The CPSES RCS Cold Hydrostatic Test was completed by Brown and Root and TU Electric Startup utilizing procedures which meet the requirements of ASME Section III, through the Summer 1981 Addenda and 1980 Edition .

adequate to control the activities. therefore which were The RCS cold hydro-l static test documents (e.g., hydrostatic test j

i B&R installation documentation, and applicable isometrics, Code Data Reports) were initiated, developed, processed and maintained in accordance with Quality Assurance Programs / Manuals which were accredited under the auspices of the ASME.

ally, the Addition-activities performed by B&R, to satisfy the requirements of ASME Section III, were monitored, or witnessed by an Authorized Nuclear Inspection verified Agency representative. The RCS cold hydrostatic test records and relatedprovide report documentation as delineated the necessary assuranceinthat Section III.F of this the hydrostatic test was completed and inspected adequately.

Obiective #2 Determine the extent to which procedures controlling the Unit 1 RCS Cold Hydrostatic Test provided necessary guidance for preparation, conduct, and reviews of the test.

Conclusion The TU Electric assessment of Hydrostatic Testing Related Procedures report. is discussed The confirmatory in Section III.D of this engineering actions for this portion of the assessment verified that the pre Cold Hydrostatic Test documentation review and test package preparation including the test isometrics performed by B&R were completed and were adequate. 0 '

The RCS cold hydrostatic test records and related documentation hydrostatic test also provide the necessary assurance that the was completed and inspected adequately.

Therefore, was completedthe procedures were adequate in that the activity satisfactorily.

Obiective #3 Determine the extent to which QC personnel acceptance inspections were qualified performing inspections. to conduct those Conclusion As described in Section II of this report, the certification records of each inspector whose signature or appears on test documentation and of each inspector notation as being available for the test have been listed evaluated detail and did not reveal any matters of concern regarding in qualification or certification.

obiective #4 Identify and propose resolution of any potentially discrep-ant conditions.

conclusion Attachment 3 of this report provides a list of Deficiency Report (DR) or Nonconformance Report (NCR) numbers noted l during the review. Each of the identified DRs and NCRs are l i

closed and the resolution did not result in any additional c testing. i obiective #5 Identify any areas where program enhancements could contrib-ute to more definitive and comprehensive test packages.

Conclusion The procedures involved have been changed such that conver-sion of data packages is no longer required. Our current procedures require the as-issued BRP drawings to identify base metal repairs involving welding, untested vendor welds, and permanent attachment welds. It is no longer necessary to mark up BRP drawings for use during hydrostatic testing.

Also, the procedures now require that QC inspector and ANI -

sign off on the applicable BRP drawing examination of the inspection points notedto document their on the subject drawing.

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