IR 05000315/1985005

Insp Repts 50-315/85-05 & 50-316/85-05 on 850708-12.No Violations or Deviations Noted.Major Areas Inspected: Previous Insp Findings,Lers & Independent Insp of Detector, Burnup & Crunch Computer Codes

ML20133C745
Person / Time
Site:	Cook
Issue date:	08/01/1985
From:	Mccormickbarge, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133C714	List: IR 05000315/1985005 ML20133C711
References
50-315-85-05, 50-315-85-5, 50-316-85-05, 50-316-85-5, NUDOCS 8508070127
Download: ML20133C745 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-315/85005(DRS); 50-316/85005(DRS)

Docket No. 50-315; 50-316 License No. DPR-58; DPR-74 Licensee: American Electric Power Service Corporation Indiana & Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Facility Name: D. C. Cook Nuclear Plant. Units 1 and 2 Inspection At: American Electric Power Service Corporation (AEPSC)

Columbus, OH, Inspection Conducted: July 8-12, 1985

' >'r Inspector: M. L. McC nick-Barger [WI Date Approved By: , Chief Test Programs Section Date Inspection Summary Inspection on July 8-12, 1985 (Report No. 50-315/85005(DRS);50-316/85005(DRS))

Areas Inspected: Special announced inspection of licensee action on previous inspection findings; Licensee Event Reports; and independent inspection. The inspection involved a total of 32 inspector-hours onsite at the corporate headquarters and 6 inspector-hours offsit Results: No violations or deviations were identifie r 8500070 A $5000315 PDR PDR O

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DETAILS 1. Persons Contacted

• P. Alexich, Vice President Nuclear Operations

• M. Cleveland, Manager of Nuclear Materials and Fuel Management (NMFM)

• Neymotin, NMFM Scientist

• A. Saum, NMFM Section Engineer

• M. Bounds, NMFM Section Engineer

• F. Kroeger, Manager of Quality Assurance

• Barrett, Lead Cortpliance Engineer

• Denotes those attending the exit interview on July 12, 198 Additional plant technical and administrative personnel were contacted during the course of the inspectio . Licensee Action on Previous Inspection Finding (0 pen)UnresolvedItem(315/85007-02;316/85007-02): Timeliness of corrective actions for AEPSC internal audit QAVP-84-01 of the Nuclear Material and Fuel Management Section. Audit QAVP-84-01 was performed by the licensee's quality assurance personnel at the request of the Manager of the Nuclear Material and Fuel Management Section. The audit findings were transmitted to the Manager of the NMFM Section via AEPSC QA Audit Corrective Action Request Forms on August 29, 1984. The proposed corrective actions for the QAVP-84-01 findings comprised the revision or developent of approximately thirty NMFM Section procedure These were divided into administrative and qual'ity related procedure In the course of developing the procedures, one procedure which was originally designated as an administrative procedure (AP) was redesignated as a quality related procedure (QP) and one procedure which was originally designated as a QP was redesignated as an AP. At the time of this inspection, 16 procedures were designated as being quality related, of these, the following had been completed:

NMFM-QP-3.0, " Review of Safety Analysis Reports," Revision 0, dated March 21, 193 NMFM-QP-3.2, " Preparation and Control of Input to Safety Analyses,"

Revision 0, dated April 1, 198 NMFM-QP-3.5, " Preparation of BURNUP Data Set," Revision 0, dated April 1, 198 NMFM-QP-3.10, " Changes to the Detector Code," Revision 0, dated April 1, 198 NMFM-QP-3.12, " Documentation of Calculations," Revision 0, dated March 21, 198 ,

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NMFM-QP-7.0, " Procurement of Uranium, Conversion and Enrichment,"

Revision 0, dated April 2, 198 NMFM-QP-17.0, " Collection, Maintenance and Storage of Quality Assurance Records," Revision 0, dated April 1, 198 '

NMFM-QP-18.0, " Audits of Vendors," Revision 0, dated March 18, 198 The following quality assurance related procedures were scheduled to be completed and issued by October 31, 1985:

NMFM-QP-2.2, " Personnel QA Training" NMFM-QP-3.4, " Preparation of DETECTOR Data Set" NMFM-QP-3.9, " Updating DETECTOR Code Engineering Data Sets" NMFM-QP-3.11, " Calculation of BURNUP and Isotopic Composition of Nuclear Materials in Fuel Assemblies" The remaining quality assurance related procedures (which were not scheduled to be completed and issued until after October 31,1985)were:

NMFM-QP-2.0, " Scope of Quality Program"

• NMFM-QP-7.1, "SNM Accountability and Preparation of 741, 742, and 742c Forms" NMFM-QP-7.6. " Evaluation of Contractors Bids Exclusive of Uranium, Conversion and Enrichnent" NMFM-QP-16.0, " Corrective Action" ,

• Although NMFM-QP-7.1 was listed as an AP procedure on the corrective action request forms, at the time cf this

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inspection, the licensee anticipated changing this proposed procedure from an AP to a Q With regard to NMFM-QP-2.0, although it is not scheduled for issuance within the next few months, the schedule proposed by the licensee appeared to be adequate since many aspects of this proposed procedure j were encompassed by other procedure For example, NMFM-AP-2.5, J Revision 0, "Section Computer Codes," identifies the computer codes used by the NMFM Section which are considered to be safety-relate With regard to NMFM-QP-7.1, although the amount of Special Nuclear Material (SNM) must be accurately calculated and reported to the NRC, the safety significance of this activity is such that an extended time i frame for completion of the activity appears to be acceptable.

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With regard to NMFM-QP-7.6, the licensee indicated that the NMFM Section will not get involved with procurement of safety-related items intended to be governed by this procedure until such time as this procedure (or an equivalent procedure) is issue With regard to.NMFM-QP-16.0, the licensee stated that corporate level procedures were in existence to govern corrective actions and, therefore, this section level procedure may not be issued. The inspector reviewed the index of general corporate level procedures and noted that the following procedures existed related to corrective action AEPSC General Procedure No.15.0, "Nonconformance/ Noncompliance and Corrective Action" AEPSC General Procedure No.15.1, " Noncompliance and Corrective Action" Although the four NMFM Section procedures discussed previously were not scheduled to be completed by October 31, 1985, it does not appear that issuance of these four procedures under an extended time frame will have an adverse effect on plant cafet Unresolved Item 315/85007-02; 316/85007-02 will remain open pending issuance of the quality related procedures scheduled to be completed by October 31, 198 (0 pen) Open Item 315/84-14-01(DRS): Implementation of Corrective Actions for LER 315/83-98 and LER 315/84-07. (Refer to the discussion contained in Paragraph 3 of this inspection report.)

No violations or deviations were identifie Licensee Event Report (LER) Fellowup

~ In Inspection Report 50-315/85014, an item was opened (0 pen Item 315/84-14-01(DRS)) to follow implementation of corrective actions for LER 315/83-98 " Incorrect Data Used for Cycle 7 Ep(Z)" and LER 315/84-07

" Discovery of Error in the DETECTOR Code." LER 315/83-98 was closed in Inspection Report 50-315/84-23. The following discussion pertains to implementation of corrective actions to prevent recurrence of errors in the DETECTOR Code as identified in Revision 2 of LER 315/84-0 Background The DETECTOR Code analyzes raw flux map data to determine compliance with power distribution technical specifications. On May 22, 1984, the licensee discovered an error in the DETECTOR Code and subsequently reported it via voluntary LER 84-07. The licensee also notified Shandstrom Nuclear Associates (SNA), the company that developed the DETECTOR Code, and SNA submitted a 10 CFR 21 repor .

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Corrective Actions to Prevent Recurrence of DETECTOR Code Errors In the course of developing corrective actions to prevent recurrence of errors in the DETECTOR Code, the licensee reviewed the SNA recommendations. The licensee chose not to implement SNA's recommendation related to increasing the technical specification edits. The justification for this was given in an analysis entitled,

" Analysis of Shandstrom Recommendation 1 for DETECTOR," (LER 84-07),

Document N-6992.7, File VIIIC 3000, performed on July 25, 1984, and approved on August 13, 1984. The inspector reviewed this analysis and, based on this review, had no concerns with the licensee's decision not to implement the SNA recommendatio Shandstrom Nuclear Associates' other recomendation dealt with performing hand calculations to verify changes made to DETECTO In place of this recommendation, the licensee proposed five alternative corrective actions. The inspector compared the SNA recommendation to the licensee's proposed corrective actions and had no concerns related to the licensee's decision to utilize an alternative means of corrective action. In the discussion of the five proposed corrective actions that follows, the wording of the corrective actions was taken verbatim from LER 315/84-07, Revision "AEPSC has changed their source library disk file management system on the corporation computer system from ' source' to " LIBRARIAN."

" LIBRARIAN" offers a much more thorough method of maintaining an accurate audit trail of changes made to a program than previously existed with ' source.' It is believed that this software enhancement will reduce the possibility of future code modifications being in error."

The inspector reviewed the following computer printouts and noted that each of them indicated that the computer run utilized

" LIBRARIAN."

Unit 1, Cycle 8, Full Core Flux Map 108-35, Job 1084, dated March 23, 198 Unit 1, Cycle 8, Full Core Flux Map 108-36, Job 2148, dated April 2, 198 Unit 1, Cycle 8, Full Core Flux Map 108-37, Job 1728, dated April 3,198 "MNFM Procedure No. 7, Changes to the DETECTOR Code, was revised by December 31, 1984, to assure that not only are test cases run, but that an independent line-by-line review of the coding changes will be performed."

The inspector reviewed NMFM-QP-3.10, Revision 0, dated December 28, 1984, " Changes to the DETECTOR Code," which superseded hMFM Procedure No. NMFM-QP-3.10 required that test cases be prepared

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and run (Steps 6.4 and 6.7) and that an independent line-by-line review of the coding changes be performed (Step 6.5). Some other areas addressed by NMFM-QP-3.10 that were not addressed in NMFM Procedure No. 7 included the requirement for an independent verification of each major step of the procedure and a checkoff sheet to document the verification, the requirement that the reasons for code modifications be made in writing, the requirement for more extensive documentation, and the specification of procedure NhFM-AP-2.6, " Records Management - Computer Output," to be used to govern computer output documentation filing methods. Since no changes were made to the DETECTOR Code following the date that NMFM-QP-3.10 was issued, the inspector was not able to review the actual implementation of this procedur c. "A detailed analysis of all ' DETECTOR' changes from August 1983 to October 1984 was completed by October 31, 1984."

The inspector reviewed the analysis titled, " Analysis of DETECTOR Changes Since August 1983, dated October 31, 1984 and approved on November 2,1984," and discussed the differvices between the two versions of the code identified in this analysis with the license During these discussions the licensee indicated their intent to make three additional changes to the DETECTOR Cod (The change to correct the error that was reported in LER 84-07 had already been completed. ) The inspector had no concerns related to the review of the licensee's analysi d. "A standard input model generator program will be developed to provide a command benchmark for all future versions of ' DETECTOR.'

The models generated by this program will be used to verify the chanSes made to 'DE1ECTOR' since August, 1983. We will also perform comparisons with past benchmarks performed during Unit 1 Cycle 1 between. 'DETECTCR' and Westinghouse's 'INCORE' code. We currently anticipate that this effort will be completed by October 31, 1985."

This corrective action had not been completed at the time of this inspectio e. "A ' DETECTOR' post-processing code will be developed to more closely and efficiently monitor " DETECTOR" performance and results. We currently anticipate that this code will be developed, tested, debugged and documented by December 31, 1985."

This corrective action had not been completed at the time of this <

inspectio The inspector had no concerns regarding the three corrective actions that have been completed. Open item 315/84-14-01 (refer to Paragraph 2 of this report) remains open pending completion of the two remaining corrective action No violations or deviations were identifie _ . . _ _ _ . . . _

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4. Independent Inspection The inspector asked several members of the NMFM Section whether or not the OETECTOR Code and the NFMFPT2 Code (which processes raw flux data for use in the DETECTOR Code) were safety-related. Although each individual that the inspector spoke with indicated that DETECTOR was safety-related, some individuals indicated that NFMFPT2 was safety-related and some indicated that it was not safety-related. The inspector discussed this with the licensee and subsequently the licensee issued NMFM-AP-2.5, "Section Computer Codes," Revision 0,

-dated July 12, 1985, which identified those codes used by the NMFM Section that are safety-related and, in addition, contained a definition of the term " safety-related."

^ The inspector reviewed NMFM-4, " Calculation of BURNUP and Isotopic Composition of Nuclear Material in Fuel Assemblies," Revision 0, dated August 1, 1979. (This procedure is subject to 10 CFR Part 70 rather than 10 CFR Part 50.) During the review of this procedure, the inspector noticed that Section 4 of the procedure referred to the CRUNCH computer code and also, that the CRUNCH computer code was not listed in NMFM-9, "Section Computer Codes," Revision 2, dated March 21,1984. In discussions with the licensee, the licensee explained that they no longer use the CRUNCH code and that Section 4 of NMFM-4, which deals with preparation of BURNUP code data, has been replaced by procedure NMFM-QP-3.5, " Preparation of BURNUP Data Set," Revision 0, dated April 1,1985. Although the inspector had no concerns with the use of NMFM-QP-3.5 in place of Section 4 of NMFM-4, the inspector did express concern that NMFM-4 did not identify the fact that NMFM-QP-3.5 should be used in place of Section 4. In response to the inspector's concern, the licensee issued a temporary procedure change for NMFM-4, dated July 11, 1985,

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which states that the requirements of Section 4, " Input Data," are f to be replaced with the requirements contained in NMFM-0P-3.5,

" Preparation of BURNUP Data Set." Also, by October 31, 1985, the

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licensee has scheduled the completion of procedure NMFM-QP-3.11,

" Calculation of BURNUP and Isotopic Composition of Nuclear Materials in Fuel Assemblies," which, along with NMFM-QP-3.5, will replace NMFM-4 in its entirety. Finally, since the situation discussed above is related to the broader issue of following procedures, the licensee committed to reemphasize the need to follow procedures in a training session for NMFM Section members scheduled for July or August, 1985 and, in response to a previous NRC-inspection finding, a letter signed by M. P. Alexich, Vice President Nuclear Operations,

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titled, " Resolution of Quality Problems and Adherence to Approved Procedures," dated July 11, 1985, was in the process of being routed to NMFM Section members at the close of the inspectio No violations or deviations were identified.

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5. Exit Interview i The inspector met with licensee representatives (denoted in Paragraph 1)

on July 12, 1985, to discuss the scope and findings of the inspection and the likely informational content of the forthcoming inspection report. The licensee acknowledged the statements made by the inspector and stated that the computer codes used by the NMFM Section are considered proprietary; however, references to them within an inspection report would not be. The licensee did not identify any other documents

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