ML20141N183
| ML20141N183 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/28/1986 |
| From: | Wooldridge R WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K, Mccolom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-262 OL, WFT-74, NUDOCS 8603040457 | |
| Download: ML20141N183 (36) | |
Text
_ , . . - . . . . - - -
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- eA**CYC L. 4%!Mumf te CECEb5A J. SRW*sER JOE A.OAveS EssC M. *CTC1950N Peter B. Bloch, Esq. Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing Board Dean U.5, Nuclear Regulatory Commission Division of Engineering, Washington, D.C. 20555 Architecture and Technology Oklahoka State University Dr. Walter H. Jordan Stillwater, Oklahoma 74074 Administrative Judge 881 West Outer Drive Elizabeth B. Johnson -
Oak Ridge, Tennessee 37830 Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37330 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50 %5 and 50-446Il-
Dear Administrative Judges:
Applicants have this date delivered *o Mr. Vincent 5. Noonan the testing issue-specific action plans USAPs) Ull.a.2 through III.d) with the exception of ISAP III.a.1 which will be provided in March 1986, developed by the Comanche Peak ,
Response Team.
We are enclosing four copies of each ISAP. These documents e.re not being offered into evidence at this time, and are provided for information only.
Respectively, f
M 4; A :
Robert A. Wooldridge 5
RAW /klw Enclosures 9603o40457 860 2 PDR ADOCK O 4j0 cc: Service List 0 m
3)Sc3
SERVICE UST Mr. Peter B. Bloch, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom Dean, Division of Engineering, Architecture and Technology
- Oklahoma State University Stillwater, Oklahoma 74074 Elizabeth B. Johnson Oak Ridge National Laboratory P. O. Box X, Building 3500 ,
Oak Ridge, Tennessee 37830 l' Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 Mrs. Juanita Ellis President, C ASE 1426 South Polk Street Dallas, Texas 75224 Renea Hicks, Esq.
Assistant Attorney General Environmental Protection Division P. O. Box 12548, Capitol Station Austin, Texas 78711 Nicholas S. Reynolds, Esq. '
William A. Horin, Esq. ;
Bishop, Liberman, Cook, .
Purcell & Reynolds 1200 Seventeenth Street, N.W. -
Suite 700 Washington, D.C. 20036 Mr. W. G. Counsil Executive Vice President Texas Utilities Generating Company Skyway Tower,25th Floor ,
400 N. Olive Street Dallas, Texas 75201 1 (
i Mr. Thomas G. Dignan, Jr.
Mr. R. K. Gad, III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Mr. Roy P. Lessy, Jr.
Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C. 20036 Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin Christic Institute 1324 North Capitol Street Washington, D.C. 20002 Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. William L. Clements Docketing & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stuart A. Treby, Esq.
Office of the Executive Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman Atomic Safe.ty and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Ellen Ginsberg, Esq.
U.S. Nuclear Regulatory Commission 4350 East /' Vest Highway,4th Floor Bethesda, Maryland 20814 Billie Pirner Garde Citizens Clinic Director Government Accountability Project 1555 Connecticut Avenue, N.W.
Suite 202 I Washington, D.C. 20036 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, Californla 94111 i
David R. Pigot Orrick, Herrington & Sutcliffe 600 Montgomery Street San Francisco, California 94111 Mr. Shannon Phillips Resident Inspector Comanche Peak SES c/o U.S. Nuclear Regulatory Commission P. O. Box 38 Glen Rose, Texas 76043 Anthony Roisman, Esq.
Executive Director irial Lawyers for Public Justice 2000 P. Street, N.W., Suite 611 Washington, D.C. 20036 Joseph Gallo, Esq.
Isham, Lincoln & Beale 1120 Connecticut Ave., N.W.
Suite 840 Washington, D.C. 20036
_3
LOG NO. TXX-4719 FILE.NO. 10068-k~ LED TEXAS UTILITIES GENERATING COMPANY ~OORRESPog3!$q
~
SKYWAY TOWER . 400 NORY18 OLIVE STREET. L.B. S t . DALLAS TEXAS 'FS3O R February 28, 1986
- 2?:h?2?.2'h , s CPRT-278 8 recu. @Q-t g-MAR 3 - 1986a8 DOCEIring g 7 D VICSERAny EEcY4;5c .V..
Mr. Vincent S. Noonan 4~
g
. Director, Comanche Peak Project 4 .- t' Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20599
SUBJECT:
Comanche Peak Steam Electric Station Submittal of the Testing Issue-Specific Action Plans of the Comanche Peak Response Team (CPRT) Program Plan
Dear Mr. Noonan:
Transmitted herewith are the revised Comanche Peak Response Team Testing Issue-Specific Action Plans (ISAPs) with the exception of ISAP III.a.1 which is still being reviewed and revised by the Review Team Leader. The enclosed ISAPs are a complete reprint and replace'those in Revision 2. Recipients are asked to replace all previous revisions of the testing ISAPs with the enclosed ISAPs. These ISAPs are to be placed behind the " Appendix C, Testing" tab in the Revision 3 Program Plan binders. Substantive text changes are indicated by change bars placed in the page margins of affected sections.
We anticipate submittal of ISAP III.a.1 " Hot Functional Testing (HFT) Data Packages" by late March 1986.
Should you have any questions please do not hesitate to call either John Beck or myself.
Yours very truly, M]OA.
/
W. G. Counsil WGC:tj Enclosure A unvism.y or rexas ursurtes zz.ecraic courAnr
(:q COMANCHE PEAK RESPONSE TEAM
[J] ACTION PLAN ISAP III.a.2
Title:
Joint Test Group (JTG) Approval of Test Data Revision No. 0 1 2 3 Revised to Reflect Incorporates Reflects Comments Description Original Issue NRC Comments SSER On Plan
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'6/s784 Prepared and Recommended by:
Review Team Leader ,[ a.g(
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Rsvisiont 3 Psg3 1 of 2 ISAP III.a.2
.[v} Joint Test Group .(JTG). Approval of Test Data
1.0 DESCRIPTION
OF ISSUE The NRC-TRT originally described this issue in NRC-letter, D. G.
Eisenhut to M. D. Spence, dated September 18, 1984 Enclosure 1 at Page 13, as follows:
"The TRT noted during a review of HFT completed. test data that the JTG did not approve the data until after cooldown from the test. The tests are not considered complete until this approval is obtained. In order to complete the proposed post-fueling, deferred preoperational HFT, the JTG, or a similarly qualified group, must approve the data prior to proceeding to initial criticality. The TRT did not find any document providing that TUEC is committed to do this."
2.0 ACTION IDENTIFIED BY THE NRC The NRC-TRT originally identified the action required to resolve this issue in NRC letter, D. G. Eisenhut to M. D. Spence, dated
-g September 18, 1984 Enclosure I at Page 13, as follows:
\ _/ "Accordingly, TUEC shall commit to having a JTG, or similarly qualified group, review and approve all post-fueling preoperational test results prior to declaring the system operable in accordance with the technical specifications."
and subsequently modified in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-77, as follows:
"TUEC has informed the TRT that the Station Operation Review Committee (SORC) will review deferred preoperational test data. Since the review of data obtained from the deferred preoperational tests is a function of the SORC, TUEC shall amend the FSAR to reflect their commitment to the TRT that the SORC and not the JTG will perform these reviews. This requirement, not included in the September 18, 1984 letter to TUEC, is necessary because the current version of the FSAR states that the JTG is responsible for reviewing preoperational test data."
F
3.0 BACKGROUND
The NRC-TRT expressed concern that formal Joint Test Group approval of the preoperational hot functional test results occurred after
/~')/ cooldown from operating pressure and temperature i.e., after
\~ proceeding through a major testing evolution. With this concern and being aware that TUEC had NRC-NRR approval to defer some l
)
R: vision: 3 i
P gg 2 of 2 j' ~') ISAP Ill.a.2 1_,/ (Cont'd)
3.0 BACKGROUND
(Cont'd) preoperational testing into the interval between fuel loading and
~
initial criticality, the NRC-TRT examined TUEC's FSAR commitments related to post-fuel load testing. The FSAR indicated that TUEC had committed the SORC to review and approve post-fuel load test results and that it was appropriately qualified to perform the review and approval. The FSAR had not specifically addressed the situation of deferred tests which were classified as preoperational. TUEC amended the FSAR to clarify the specific situation with preoperational tests which may be deferred beyond fuel load but prior to initial criticality.
4.0 CPRT ACTION PLAN TUEC filed Amendment 54 to the CPSES FSAR on January 21, 1985 which provides the information identified as necessary by the NRC-TRT. The CPRT considers the action required of TUEC for this issue complete.
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i COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.a.3
Title:
Technical Specification For Deferred Tests i
Revisior ~.Jo . 0 1 2 3 Revised to Reflect Incorporates Reflects Coments Description Original Issue NRC Coments SSER On Plan An?J
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Prepared and 3 Recommended by:
Review Team Leader J$ /h (.[;u r
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-[ ISAP III.a.3 Technical Specifications For Deferred Tests
1.0 DESCRIPTION
OF ISSUE The NRC-TRT originally described this issue in NRC letter, D. G.
Eisenhut to M. D. Spence, dated September 18, 1984, Enclosure 1 at Page 13, as follows:
"The TRT pointed out that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel l load, certain limiting conditions of the proposed technical ~1 specifications cannot be met, e.g., all snubbers will not be i operable since some will not have been tested."
2.0 ACTION IDENTIFIED BY NRC The NRC-TRT originally identified the following action in NRC letter, D. G. Eisenhut to M. D. Spence, dated September 18, 1984, Enclosure 1 at Page 13, as being necessary to resolve this issue:
"Accordingly, TUEC shall evaluate the required plant conditions for the deferred.preoperational tests against Ci limiting conditions in the proposed technical specifications end obtain NRC approval where deviations from the technical specifications are necessary."
and subsequently modified in CPSES Safety Evaluation Report, Supplement No. 7 at Page J-18, that the ar, tion identified cited above:
"...is no longer applicable since the TRT has been informed by TUEC that these tests to d be conducted prior to fuel load."
~
3.0 BACKGROUND
Following completion of preoperational hot functional testing, the results of certain tests indicated that the deficiencies identified would require design modifications, component repair or replacement, or initial installation and subsequent testing. The nature of the retesting would require the primary plant to be at
]
normal operating pressure and temperature. The next planned primary plant heatup was scheduled in the interval between fuel load and initial criticality. Therefore, TUEC sought and received NRC-NRR approval to defer these retests until the primary plant heatup following initial fuel loading.
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! Rnvision 3 g
Psgi 2 of.2
/~' ISAP III.a.3
(,,)) (Cont'd)
3.0 BACKGROUND
(Cont'd)
TUEC had prepared administrative controls to address the review and appi val process in preparation of its request to defer seven preoperational tests to NRC-NRR. Formal approval of this request was received in NRC-NRR letters dated June 19, and August 17, 1984.
The processing of this request was in accordance with Station Administrative Procedure STA-805, " Deferred Preoperational Testing," which is briefly described as follows. During this process, technical specification requirements are evaluated and the need for technical specification exceptions considered. The evaluation addresses the operability requirements of the technical
. specifications and the impact of incomplete preoperational testing on equipment operability. The required plant conditions for conducting deferred preoperational tests are assessed against the CPSES technical specifications including the limiting conditions for operation.
1 Subsequently, TUEC planned a second heatup to operating pressure s and temperature and would attempt to complete the deferred In correspondence dated
) preoperational testing before fuel load.
Septenber 30, 1985 to NRC-NRR, TUEC reported the results of the second plant heatup conducted during the interval from October 1984 to January 1985 in which the deferred preoperational tests were performed. Although many of the individual testing items were completed, there remain four items open pending completion of satisfactory testing and one item opien pending NRC approval of a proposed technical specification change.
4.0 CPRT ACTION PLAN Although TUEC has five remaining open items in the current NRC-approved preoperational test deferral, the methods by which TUEC identifies'and obtains NRC approval for technical specification deviations is, in the judgment of the CPRT, adequate to address the concerns identified by the NRC-TRT.
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l ) COMANCHE PEAK RESPONSE TEAM
\ J ACTION PLAN ISAP III.a.4
Title:
Traceability of Test Equipment Revision No. 4 Reflects Commento Description On Plan
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Prepared and Recommended by:.. I Review Team [_
Leader Date 2 ' E I' 0 4 Approved by:
Senior Review Team (k4 d ,
9 Date A/z7[ft
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R;vicion: 4 P;g2 1 of 4 ISAP III.a.4 s
Traceability of. Test Equipment
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-72 and 73, Item 4, " Assessment of Safety Significance," as follows:
"...although temperatures were taken and logged during the test [lCP-PT-55-11, " Thermal Expansion,"), the specitic
[ temperature) measuring device used at each monitored location was not logged. As a result the calibration of the measuring device could not be traced to the monitored location with the information contained in the test data packages. The TRT found that the completed test data packages did contain the calibration data for the measuring devices used, but as alleged, the devices could not be traced directly to specific monitored locations. While pursuing this matter, the TRT intersiewed TUEC personnel who participated in the testing and found that a test coordinator maintained a log which tied the devices to the specific monitored locations; however, the log was not made a part of the test data package. The TRT pointed
. -)
t out to TUEC that while the diract connection was not required by the test procedure as written, the data must be included as part of the test data package."
2.0 ACTION IDENTIFIED BY NRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-17, Item 4.2.1, " Hot Functional Testing," as being necessary to resolve this issue are as follows:
" Incorporate the information necessary to provide traceability between thermal expansion test monitoring locations and measuring instruments. Also establish administrative controls to assure appropriate test and measuring equipment traceability during future testing and plant operations."
3.0 BACKGROUND
The traceability between the calibration of temperature measuring instruments and the monitored locations was not documented in the ICP-PT-55-11, " Thermal Expansion," test data package. The approved test procedure used for conduct of the test did contain
,, requirements for recording pertinent data relating to the
( calibration of temperature measuring instruments.
)
I Rsvicion: 4 s P;ga 2 of 4 ISAP III.a.4 (Cont'd)
3.0 BACKGROUND
(Cont'd)
The requirements of the approved test procedure were not complied with during conduct of the test as required by CP-SAP-21, " Conduct of Testing." The data was readily available but not in the format required by the approved test procedure. The personnel responsible for conduct of the test elected to create a separate log which related the temperature measuring instruments to the monitoring teams that used the instruments. The monitoring teams were assigned specific test packages which identified the locations that were monitored. Therefore, the instrumentation used could be correlated to the location by the known assignments of monitoring teams and specific test packages. The data obtained by the temporary temperature measuring instruments was used for information only and was not used to judge acceptability of the test or to substantiate any engineering calculations.
The cause of this error is attributed to the engineering personnel temporarily assigned to Startup for thermal expansion testing not being thoroughly indoctrinated in Startup administrative requirements for conduct of testing. The individuals were not f'"3 adequately familiar with processing Test Procedure Deviations as
( -
) required by CP-SAP-12 when they desire to deviate from approved procedural requirements. Possible generic implications are that other test personnel may have deviated from approved test procedures without complying with Startup administrative procedure requirements to document approved deviations from those procedures.
The test data package in question was incomplete and had not received final approval by the Joint Test Group. One of the objectives of the review process is to assure the test data package is complete in accordance with administrative procedure l requirements.
4.1 Scope and Methodology The objective of this action plan is to ensure that ICP-PT-55-11 has traceability of measuring and test equipment and that administrative controls are in place to assure such traceability during future testing and plant operation.
The following tasks were or will be implemented to achieve the above objective: l l
4.1.1 Test Procedure Deviation (TPD) No. 36 was issued to include information that related specific test p_
instrument identification numbers to the locations j
/ '
where the test instruments were used in the test data l
'- package. Test Deficiency Report No. 3418 and TPD No. l 37 were issued to provide traceability to calibration 1
R;vi; ion: 4 6 Page 3 of 4 m
ISAP III.a.4 (Cont'd) 4.0 CPRT ACTION PLAN of the instruments and to include the required calibration data relating to the instrument identification numbers in the test data package for ICP-PT-55-11.
4.1.2 All Startup personnel responsible for conduct of l testing were reinstructed on the existing Startup administrative requirements applicable to the traceability of measuring and test equipment.
4.1.3 Startup personnel responsible for conduct of testing I were reinstructed on the existing Startup administrative requirements applicable to the use of Test Procedure Deviations.
4.1.4 Administrative controls applicable to documentation requirements for measuring and test equipment which have been established for the Initial Startup Test program will be reviewed for adequacy and improved if
(~S necessary.
- i. !
4.1.5 Administrative controls applicable to documentation requirements for measuring and test equipment which have been established for station operation and maintenance activities will be reviewed for adequacy and improved if necessary.
4.1.6 Startup Administrative Procedure requirements for indoctrination and training of Startup personnel will be reviewed to ensure that lessons learned from this activity, if any, are incorporated. If procedure changes are made, applicable Startup personnel will be reinstructed on the changes.
4.1.7 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 Participant's Roles and Responsibilities I ) 4.2.1 The Startup Special Projects Group Supervisor was responsible to ensure that the information on measuring
R;vigion: 4 P ga 4 of 4 ISAP III.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) and test equipment used for thermal expansion testing is included in the completed test data package for l ICP-PT-55-11.
4.2.2 The Startup Manager was responsible for ensuring that I all Startup personnel had been adequately reinstructed on the requirements for measuring and test equipment traceability and proper utilization of test procedure deviations.
4.2.3 The CPRT Testing Programs Review Team Leader is responsible for reviewing existing administrative controls for documenting the traceability of measuring and test equipment used for Preoperational Testing, Initial Startup Testing, Operation and Maintenance activities and assuring necessary corrective actions are taker..
4.3 Qualifications of Personnel I ) 4.3.1 The CPSES Startup Manager and Startup Special Projects
'~'
Group Supervisor are qualified to the highest level provided in CP-SAP-19, " Training / Qualification Requirements for Startup Personnel."
4.3.2 The CPRT Testing Programs Review Team Leader meets the qualifications as described by the CPRT Program Plan.
4.3.3 The Review Team Leader assures that other personnel providing assistance are appropriately qualified.
4.4 Acceptance Criteria Administrative control for measuring and test equipment truceability will be acceptable if applicable administrative procedures require identification and calibration information j for measuring and test equipment used to obtain acceptance l data be entered on the permanent test results record.
4.5 Decision Criteria The action plan will be considered complete when the CPRT determines that applicable administrative procedures are adequate to control measuring and test equipment traceability documentation and there is reasonable assurance that measuring and test equipment information is being properly handled.
4
- v COMANCHE PEAK RESPONSE TEAM ACTION PLAN ISAP III.b
Title:
Containment Integrated Leak Rate. Test (CILRT) 4 Revision No. 4 Reflects Comments Description On Elan O- Prepared and Recommended b - - h
- Review Team Leader Date 2 ~2l~ OS Approved by:
Senior Review Team ha d f. J Date g/n/a.
2 O
(3.
R; virion 4
, P;ga 1 of 2
(~'h ISAP III.b Lj Containment Integraced Leak Rate Test (CILRT)
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described these issues in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-14, Item 3.2.3, " Findings for Test Program Issues," as follows:
"The Group [TRT] found no safety significance for the allegations in TP Category 3 (Containment Integrated Leak Rate Testing), but concluded that a generic problem could exist because when the CILRT leakage rate was calculated by a method different from that which was committed to in the FSAR, the FSAR had not been amended to reflect that change. The TRT auestioned the TUEC procedure for documenting and identifying FSAR deviations to the NRC. The TRT also questioned that method of calculation, which was not endorsed by the NRC, Additionally, the TRT found that the preoperational CILRT was conducted with three isolated electrical penetrations, a condition which did not provide the configuration that the Containment Building would have during normal operation.
These items were considered unresolved on the TRT and were fs forwarded to the NRC Office of Nuclear Reactor Regulation for
('-) action. The latter two have since been resolved to the satisfaction of the NRC as reflected in Item (36) in Section 1.7 of Comenche Peak SSER 6."
2.0 ACTION IDENTIFIED BY NRC The action identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-17, Item 4.2.2, " Containment Integrated Leak Rate Testing," as being necessary to resolve this issue is as follows:
"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
During the NRC-TRT investigation of an allegation concerning the conduct of the CILRT, two discrepancies involving test methodology were identified. The two discrepancies were technical in nature and concerned the method of calculation of leakage rate and the containment physical configuration during testing. The NRC-TRT forwarded the technical discrepancies to NRC-NRR for evaluation.
/} The two technical issues were resolved and documented by NRC-NRR in V
_ . ,- - 4 ai--E
-g R vicient 4 pig 2 2 of 2 ISAP III.b
[(,,)s (Cont'd)
3.0 BACKGROUND
(Cont'd)
CPSES Safety Evaluation Report, Supplement No. 12 at Page 6-1, Item 6.2.5, " Containment Leakage Testing Program," as follows:
" ..By a letter dated December 21, 1984, the applicant informed the staff that the use of the mass-plot method of calculating the containment leakage rate and the isolation of the three electrical penetrations were the only deviations from FSAR commitments; by Amendment 54 the applicant revised FSAR Sections 14.2 and 3.8 to reflect these revised practices.
The staff found these limited deviations acceptable because the effect on the results of the ILRT were negligible.
On the basis of its findings in the above review, the staff concludes that the resolution of the outstanding issues regarding the ILRT methodology is acceptable and Outstanding Issue (36) in Section 1.7 of this supplement has been resolved."
The NRC-TRT expressed concern that there may be other undocumented testing deviations from FSAR commitments. Therefore, NRC-TRT is requiring TUEC to identify any other undocumented testing
[\/ deviations from FSAR commitments and to examine the process by
) which it provides information on FSAR testing deviations to the NRC.
The action identified by the NRC-TRT required to resolve the III.a.1 " Hot Functional Test" issue includes reviews of preoperational test data packages and administrative controls implementing the test program. The specific technical i discrepancies for the CILRT have been resolved, therefore the CPRT {
will resolve the NRC-TRT's remaining concerns in conjunction with j resolution of III.a.1, " Hot Functional Testing."
i
, 4.0 CPRT ACTION PLAN a
Based upon the above information published by the NRC, its concerns with containment leak rate methodology have been resolved. ,
i The NRC-TRT concern regarding additional undocumented FSAR testing desiations will be investigated, resolved and reported via Action Plan III.a.1, " Hot Functional Testing."
i l
1
I
-i COMANCHE PEAK RESPONSE TEAM ACTION PLAN i
I ISAP III.c i
Title:
' Prerequisite Testing
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1 1 Revision No. 4 i Reflects Comments Description On Plan Prepared and Recommended bv:
y Review Team L i Lecder j Date 2' '
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1 i
Approved by:
Senior Review Team bu d,N- /
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- D te sh,/rs i
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P&ga 1 of 4 ISAP III.c Prerequisite Testing
1.0 DESCRIPTION
OF ISSUE The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7, as follows:
"....the.TRT review found that craft personnel verified and signed for initial conditions on some prerequisite test data sheets, contrary to Section 4.10.9 of CP-SAP-21, ' Conduct of Testing,' which requires that this be done.by the STE (System Test Engineer). Further investigation revealed a memorandum issued by the Lead Startup Engineer on March 31, 1983,-
countermanding this requirement of CP-SAP-21. The subject of the memorandum (STM-83084) was 'ETG Personnel Schedule Change,' but it also indicated that craft personnel (ETG)
(Electrical Test Group] may verify prerequisite conditions for Prerequisite Test Instructions XCP-EE-1 and XCP-EE-14.
Issuing auch a memorandum in lieu of executing a properly approved change to CP-SAP-21 is in violation of CP-SAP-1,
'Startup Administrative Procedures Manual,' Section 4.4.3.1, which requires a permanent or interim change to be approved o and issued to all manual holders in accordance with CP-SAP-1.
It appears that as a result of the memorandum, 24 of the 35 t] tests reviewed by the TRT had prerequisite conditions improperly verified by craft support personnel. Fifteen were XCP-EE-14, but nine were XCP-EE-24, ' Fixed Battery Pack Operated Emergency Lighting Units,' which were not authorized by the memorandum." Page J-87, Item 4., " Assessment of Safety Significance."
and summarized the issue:
"...the TRT found that TUEC startup ranagement authorized, by memorandum, test support craftsmen to verify initial conditions for certain prerequisite test procedures in violation of Startup Administrative Procedure CP-SAP-21,
' Conduct of Testing.'" Page f-13. Item 3.2.3, " Findings for Test Program Issues."
2.0 ACTION IDENTIFIED BY NRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7'at Page J-17. Item 4.2.3,
" Prerequisite Testing," as being necessary to resolve this issue, are as follows:
" Rescind the startup memorandum (STM-83084), which was issued
/ in conflict with CP-SAP-21, and ensure that no other memoranda were issued which are in conflict with approved procedures.
Also, conduct a review of all other prerequisite test records to determine those that had prerequisites signed by craft personnel, and assess the impact of those improperly verified on subsequent testing activities."
i R2 vision: 4 4
Pcg2 2 cf 4
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ISAP III.c (Cont'd)
3.0 BACKGROUND
Startup Administrative Procedure CP-SAP-1, "Startup Administrative Procedure Manual," authorizes the Startup Manager to issue interim procedure changes or other necessary instructions on a temporary basis. These changes are required to be issued with specific instructions concerning their applicability and use. Instructions issued in this manner are required by CP-SAP-1 to be followed with a permanent procedure revision.
Startup Interoffice Memorandum (SIM-83084) authorized electrical test-group personnel to validate prerequisites / initial conditions for Prerequisite Test Procedures, XCP-EE-1, "Megger Testing," and XCP-EE-14, " Molded Case Circuit Breaker and Thermal Overload Relay / Heater Testing." Startup Administrative Procedure CP-SAP-21 requires System Test Engineers verify prerequisites prior to conducting the test. The NRC-TRT identified other prerequisite tests which had prerequisites / initial conditions signed by unauthorized craft personnel.
/"'s 4.0 CPRT ACTION PLAN U 4.1 Scope and Methodology The objective of this action plan is to identify Startup Interoffice Memoranda which may be in conflict with approved Startup Administrative Procedures, identify prerequisite test records which may have prerequisite / initial conditions signed as complete oy craft personnel, and to evaluate the impact of these actions upon subsequent testing. .
4.1.1 SIM-83084 was rescinded by issuance of SIM-84220 dated September 25, 1984.
4.1.2 System Test Engineers were instructed that SIM-83084 was rescinded and that it is their responsibility to verify test prerequisite / initial conditions for the affected test.
4.1.3 All craft test support personnel were instructed that they shall not verify test prerequisite / initial conditions nor shall they conduct aay tests without supervision of a System Test Engineer.
4.1.4 Startup Interoffice Memoranda were reviewed to determine if any other directives have been issued
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which conflict with requirements of the Startup Administrative Procedures.
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' (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.5 All prerequisite test records were reviewed to identify other cases where craft personnel signed initial conditions for prerequisite tests.
4.1.6 All prerequisite test / instructions were analyzed to determine the consequences of improper prerequisite / initial conditions verifications.
4.1.7 The results of the SIM and prerequisite test records and instructions review will be evaluated to assess the impact on subsequent testing activities.
4.1.8 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 Participants Roles and Responsibilities 4.2.1 The Startup Manager was responsible for rescinding SIM-83084 and reinstruction of all STEs and craft support personnel with regard to their responsibilities relating to verification of initial conditions for prerequisite testing.
4.2.2 Startup Interoffice Memoranda were reviewed by the Startup Manager and the Startup Special Projects Group Supervisor.
4.2.3 The Startup QA Specialist was responsible for reviewing prerecuisite test / instructions and records.
4.2.4 The Startup Special Projects Group Supervisor and the CPRT Test Programs Review Team Leader will perform the SIM and prerequisite test record review evaluations.
4.2.5 The CPRT Test Programs Review Team Leader will overview the tasks performed by startup personnel.
4.2.6 The CPRT Testing Programs Review Team Leader will be responsible for evaluating the overall results of this O action plan.
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ISAP III.c
(_) (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.3 Qualifications of Personnel 4.3.1 The Startup personnel participants will be qualified in accordance with CP-SAP-19. " Training / Qualification Requirements for Startup Personnel."
4.3.2 The CPRT Testing Programs Review Team Leader meets the qualifications as prescribed by the CPRT Program Plan.
4.3.3 The Review Team Leader assures that other personnel providing assistance are appropriately qualified.
4.4 Acceptance Criteria 4.4.l FSAR Sections 14.2.3, " Test Procedures," and 14.2.4, "Ccaduct of Test "rogram," will be used to determine if the Startup Administrative Procedures and Prerequisite Test Instructions are adequate to properly implement the commitment to control the performance of r
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prerequisite testing.
4.4.2 The Startup Administrative Procedures and Prerequiefte i Test Instructions will provide the acceptance criteria for the evaluation of the impact, if any, of improper '
verifications of prerequisite / initial conditions on subsequent testing.
4.5 Decision Criteria The action plan will be considered complete when it has been determined to the satisf action of the CPET that there has been no adverse impact on the accomplishment of the prerequisite i and preoperational testing programs as prescribed in the FSAP.,
or, if necessary, when corrective actions have been properly implemented.
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ACTION PLAN ISAP III.d
Title:
Preoperational Testing Revision No. 4 Reflects Comments
,, Description On Plan
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Prepared and 1 f Recommended by* , .g et, Review Team i.eader /
Date 5'S' Approved by:
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1.0 DESCRIPTION
OF ISSUE I The NRC-TRT described the issues in the CPSES Safety Evaluation Report, Supplement No. 7, as follows:
"In TP Category 5, the TRT found that System Test Engineera j (STEs) were not on controlled distribution for design changes i applicable to systems to which they were assigned; rather, they were required to obtain this information on their own i
j initiative from the document control center prior to starting a test and were then required to incorporate that information, 4 as applicable, into the test procedure. While the TRT did not identify any specific problems as a result of this practice, <
j it considers this practice to be weak since it relies too j heavily on the motivations and initiatives of test personnel i
to ensure that they have current design information when they
- are developing test procedures and before conducting tests. ,
4 Typically, these are periods when they could be under more l than normal pressure. Additionally, because of the number and
- l nature of the problems found in the document control system by l the TRT QA/QC Group, the TRT could not reasonably conclude
! that the document control system problems identified did not ,
affect testing activities." Page J-13, item 3.2.3, "Firdings j for Test Program Issues." ;
"The TUEC Startup Group relies heavily on the accuracy and
] completeness of the design documents, which are included in .
- the document control eystem, in its preparation of test !
i procedures and during the conduct of testing. A number of problems were identified in the document control system by the ,
) TRT QA/QC Croup during its review. While the TRT Test Program ;
Group did .ot find that tt.ese problems adversely affected i
those portions of the tenting program that it included in its l' review, the TRT cannot conclude with reasonable assurance that the document control system problems had no adverse offeet on !
testing activities." Page J-14. Item 3.2.4, "Overall l l Assessment and Conclusions."
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2.0 ACTION IDENTIFIED BY NRC !
The actions identified by the NRC-TRT in the OPSES Safety Evaluation Report, Supplement No. 7 at Page J-18. Item 4.2.4, l "Preoperational Testing," as being necessary to resolve this issue ;
- are as follows
2 " Establish measures to provide greater assurance that STEs and w other responsible test personnel are provided with current I controlled design documents and change noticen, i
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\s_,) (Cont'd) 2.0 ACTION IDENTIFIED BY NRC (Cont'd)
Provide NRC with reasonable assurance that the docurent control system problems identified by the TRT QA/QC Group did not affect the testing activities."
3.0 BACKGROUND
The Startup Administrative Procedure CP-SAP-21. " Conduct of Testing," as reviewed by the NRC-TRT, stated that the STE was required to:
" Review the system drawings and applicable design changes to detercine that the as-built component / system will be adequately tested by the current procedure revision to demonstrate proper component / system operation."
The TRT reviewers' concerns were twofold: (1) that this requirement may rely too heavily on an STE's motivation and initiative at the time when he is under more than normal job pressure and is expected to start testing activities and that he may not have the latest (q
) design information in his possession, and (2) that the problems identified by the NRC-TRT QA/QC Group with the Document control Center (DCC) for construction activities may have adversely affected the testing program, The NRC-TRT QA/QC Group's findings were specifically addressed in CPSES Gafety Evaluation Peport. Supplement No. 11 at Page 0-10, Item 3.2.2, " Document Control Isnues," as follows:
"The QA/QC Group found that prior to 1984, there were numerous recurring administrative and procedural deviations in the document control function. Many of these recurring deficiencies were identified by internal and external audits.
But there was little follow up or verification by TUEC management that effective corrective actions were taken, until early in 1984 when the document control center (DCC) monitoring team began reporting to cenior management. The current document control program, with on estimated error rate of one percent or less, was found to be adequately staffed and effective. The problem of incorrect and incomplete drawing packages appears to have been corrected, In summary, the QA/QC Group found the current documentation control program to be acceptable. However, prior to 1984, as
\_ identified by CAT [ Construction Assessment Team) and TUEC, there was a document control breakdown, Although many of the ,
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(Cont'd)
3.0 BACKGROUND
(Cont'd) (
- docunent control deficiencies have been corrected, the l
implication of past inadequacies on construction and ,
inspection have potential generic significance which has not 1 yet bewn fully analyzed by TUEC."
I i Subsequent to TUEC submitting Revision 2 of the CPRT Program Plan and ISAP to the NRC, sampling from the population described below in Secti6n 4.1.2.4, " Prerequisite, Test Population Definition," has ,
proceeded. The original intent was to prepare one population to be sampled, screened, and evaluated for impact on both the prerequisite and preoperational test programs. The original population identified proved adequate for prerequisite testing but not for preoperational testing. The CPRT, with SRT concurrence, ;
proceeded to prepare a separate population for the preoperational
, test progrcm evaluation. The additional population prepared for the preoperational tent program evaluation is described below in Section 4.1.2.5, "Preoperational Test Population Definition."
4 The action plan presented in Sectiun 4.0 was developed to include a review of past and current administrative requirements for use of l
O design documents during testing; a review of the technical test procedures utilizing the design documents; and a random sampling and evaluation program to determine the effectiveness of the administrative requirements.
4.0 CPRT ACTION PLAN 4.1 Scope and Methodology The objective of this action plan is to resolve the two design document related issues identified by the NRC-TRT. The first issue will be investigated to determine any additional measures required to insure that STEs and other responsible test personnel are efficiently and effectively provided with current design documents for use in their testing activities. l The second issue will be investigated to determine if the problems with DCC identified by the NRC-TRT QA/QC Group had an '
adverse affect on the testing program activities.
The individual objectives and ta.sks for each issue are ;
discussed separately below.
4.1.1 STE's Access to Current Design Documents This task will determine if administrative procedures and work practices by the Startup and DCC organizations are adequate to provide for the use of current design j documents in the performance of testing activities, and i
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/~"T ISAP III.d
( ,) (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) to identify additional requirements, if ar.y which need to be established to ensure compliance with this requirement.
The steps required to complete this task are: reviewing the Startup Administrative Procedures as they relate to use of current design documents; reviewing the l
organizational interface and work practices between the l
Startup and DCC organizations; and interviewing l
individual STEs.
4.1.1.1 Startup Administrative Procedure Review l
l l Review Startup administrative procedures to l
determine if practices are likely to lead to a programmatic discrepancy. The procedures will be reviewed to determine when l
administrative requirements need to be applied to the use of design documents, that
! s the requirements are clearly stated, and 7
('-) indicate the timeliness for use of current design documents. The CPRT will perform this l review.
l l 4.1.1.2 Startup and DCC Interface l
l Review the organizational interfaces and work l practices between the Startup and DCC l organizations which are applicable to the j acquisition and use of current design
! documents. Determine the adequacy of past and present practices in meeting the requirements of the testing program. .
Identify and implement improvementa if required. The CPRT will perform these reviews.
l 4.1.1.3 System Test Engineer Interviews l
l l Interview System Test Engineers to determine their methods of complying with the current i
design document requirement and to further assess the need to upgrade existing 1 procedures and methods. The CPRT will )
conduct these interviews. i
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(_,) (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.1.2 Potential for DCC Problems to Adversely Affect the Testing Program This. task will evaluate the effect of DCC problems identified by NRC-TRT QA/QC Group on the testing program by determining the Startup organization's response to properly authorized design changes initiated by Engineering, processed through the DCC organization, and requiring a testing response by Startup.
The Startup organization utilizes drawings as a primary resource in the preparation of technical test procedures and the execution of testing. Other resources are used, however they are not controlled by the DCC. Startup responds to three methods of changing the design by Engineering. The three Engineering design change procedures are: direct issuance of a revision to a design drawing which does not incorporate the other two methods; issuance of a Design Change
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Authorization (DCA) which is a design drawing change described in approved documents issued temporarily until the actual design drawings may be updated and issued; and issuance of a Component Modification Card (CMC) which is similar to the DCA.
An evaluation program will be developed and performed which will focus on opportunities for a DCC error to begin a chain of events which results in a testing error. Error opportunities involve design changes, communicated by way of changes to design documents distributed and controlled by DCC, where the design change created a need to change a test procedure, perform retesting, or perform additional testing.
This type of evaluation was designed to preclude the nature of DCC errors from affecting the results.
The Startup organization utilizes only a fraction of the design documents prepared for the project. This subset of design documents and the changes to them are easily identified and the boundaries of a valid population of design changes readily established.
The CPRT decided that a sampling program to resolve this issue would be appropriate because there are no
(N3 programmatic deficiencies identified to date, the
( ,/ criteria by which they will be evaluated it, this study
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ISAP III.d (Cont'd) 4.0 CPRT PCTION PLAN (Cont'd) will be the same, the population of items to be sampled is homogeneous (i.e., the process by which these items are handled by the DCC is the same), and thus a sampling program in accordance with Appendix D will aid in determining whether or not systematic discrepancies exist.
The potential adverse effect of the DCC problems identified by the NRC-TRT QA/QC Group on the testing programs will be evaluated by: determining a calendar interval when DCC pr0blems could have adversely affected startup; identifying and reviewing procedures and instructions which utilized DCC controlled design documents; defining the population of changes to the design documents; random sampling the population of changes; and evaluating the sampled design changes for adverse effects on the prerequisite and preoperational test programs.
The steps which are required to accomplish this task I) are described below:
V 4.1.2.1 Period of Interest Determine the period of interest during which Startup could have been adversely affected by DCC problems. This period will begin at the start of prerequisite testing by Startup and the end date will be based on the results of CPRT review and assessment of CPSES Monitors Team monitoring reports of DCC performance.
These same reports were utilized by-the NRC-TRT in their evaluations.
4.1.2.2 Prerequisite Test Instruction Review All prerequisite test instructions will be reviewed to determine the types of design documents controlled by DCC which were used during the execution of prerequisite testing.
All design documents of this type will be included in the prerequisite test population.
The CPRT will perform this review.
4.1.2.3 Preoperational Test Procedure Review h !
(\_,~/ All preoperational test procedures performed j during the period of interest and not l
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's ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
, completely reperformed thereafter will be reviewed to identify the design documents referenced by the test procedures and i controlled by DCC. The design documents identified will be included in the prerequisite test population. A preoperational test sub-population will be identified from this list of referenced design documents. This review will be performed by the CPRT.
4.1.2.4 Prerequisite Test Population Definition 5
The population of all-design drawing j revisions, all DCAs, and all CMCs issued during the period of interest and used by the Startup organization in the preparation of test procedures or during the execution of testing will be identified. The CPRT will identify the prerequisite population with O- assistance from TUGC0 Nuclear Engineering.
Preliminary estimates indicate that the population will include approximately 75,000 items.
I 4.1.2.5 Preoperational Test Population Definition
[ The preoperational test population will be identified from the design document reference list created by Section 4.1.2.3 which
! includes only the flow diagrams and control circuit schematic diagrams. In the hierarchy of engineering design documents .these two 4
. classes of drawings will have the most significant influence on preoperational j testing. This population will be identified by the CPRT. Preliminary estimates indicate that the population will include approximately 1,100 items.
4.1.2.6 Population Screening Criteria
. Each document change in the prerequisite and preoperational test populations will be screened until it meets the following j criteria:
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ISAP III.d
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- The change is to a design document.
- The change is issued through DCC.
- The document is referenced by a test procedure or is used during the performance of a specific test.
l The test procedures which reference or utilize the affected documents ,
) were performed during the period of interest and were not completely j reperformed following the period of i interest.
- The document change occurred prior j to performance of the test.
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- The change would require a test or retest.
The CPRT will perform the evaluations with assistance from TUGCO Startup.
j 4.1.2.7 Sample Evaluation After random selection and screening, testing records will be examined for each sample item to determine the following:
- Whether a test was conducted by Startup per the change, or Whether Startup documentation demonstrated they were aware of the change.
A negative finding in both cases will constitute a discrepancy. The CPRT will perform the evaluations with assistance from TUCCO Startup.
4.1.3 Identified discrepancies, if any, will be processed according to Appendix E "CPRT Procedure for the Classification and Evaluation of Specific Design or Construction Discrepancies Identified by CPRT."
Corrective action, if required, will be implemented
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(,, (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) according to Appendix H. "CPRT Procedure for the Development, Approval, and Confirmation of Implementation of Corrective Action."
4.2 Participants Roles and Responsibilities 4.2.1 Organizations involved 4.2.1.1 CPSES Startup Group 4.2.1.2 TUCCO Nuclear Engineering Group 4.2.1.3 CPRT Testing Programs Review Team 4.2.2 Scope for each Organization 4.2.2.1 CPSES Startup Group es
- Revise Startup Administrative
() Procedures and instruct STEs on new procedure requirements.
Implement corrective actions resulting from the CPRT investigation into the effect on testing due to DCC problems, and Provide qualified personnel to assist in the screening and sample evaluation.
4.2.1.2 TUGC0 Nuclear Engineering Group Provide engineering drawing history data for sample preparation.
4.2.2.3 CPRT Testing Programs Review Team Evaluate the CPSES document control program and applicable Startup Administrative Procedures and control methods,
- Review and concur with applicabla Startup Administrative Procedures
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s,, (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)
- Determine whether the testing program has been adversely affected by DCC problems and specify corrective actions, if necessary, and
- Ovarview the work performed by other organizations assisting CPRT.
4.2.3 Lead Individuals 4.2.3.1 Mr. S. M. Franks CPSES Startup Group 4.2.3.2 Mr. J. E. Rushwick CPRT Testing Programs Review Team Leader 4.3 Personnel Qualifications 4.3.1 The CPRT Tes;ing Programs Review Team Leader meets the !
s qualifications as described by the CPRT Program Plan.
\-- 4.3.2 The Startup personnel participants will be qualified in i
accordance with CP-SAP-19. " Training / Qualification Requirements for Startup Personnel."
4.3.3 The Review Team Leader assures that other personnel providing assistance are qualified.
4.4 Procedures The following procedures will govern revision of Startup Administrative Procedures:
1 1 CP-SAP-1, Startup Administrative Procedures Manual CP-SAP-21, Conduct of Testing 4.5 Acceptance Criteria The acceptance criteria for the two investigated issues are discussed below:
4.5.1 STEs Access to Current Design Documents The procedures and methods are adequate to the O
satisfaction of the Testing Programs Review Team Leader to assure that STEs and other responsible test-personnel are cognizant of and are provided with
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['\d) ISAP III.d (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) current design documents. This finding must be supported by the results of random sampling and evaluation of the use of design change documents.
4.5.2 Potential for DCC Problems to Adversely Affect the Testing Program In order for DCC problems identified by the NRC-TRT QA/QC Group to be judged to have had no adverse effect on preoperational or prerequisite testing, a properly selected, screened, and evaluated design change document sample must meet the following criteria:
4.5.2.1 Prerequisite Test Program The design change was tested as evidenced by approved test data or was documented as being monitored by Startup as an open item.
4.5.2.2 Preoperational Test Program O A preoperational test procedure incorporated the design change or was documented as being monitored by Startup as an open item.
4.6 Decision Criteria 4.6.1 STE's Access to Current Design Documents The administrative procedure (s) are satisfactory or, if necessary, are revised to the satisfaction of the Testing Programs Review Team Leader and concurred with by the Senior Review Team.
i 4.6.2 Potential for DCC Problems to Adversely Affect the Testing Program
- The objective of the random sampling and evaluation program is to provide reasonable assurance that the problems identified by the NRC-TRT did not, in fact, adversely affect the test program. If one or more discrepancies are found to have adversely affected the test program an expanded investigation will be undertaken in accordance with Appendices D and E.
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