ML19263B366
| ML19263B366 | |
| Person / Time | |
|---|---|
| Issue date: | 10/05/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19263B352 | List: |
| References | |
| REF-QA-99900404 99900404-78-3, NUDOCS 7901180109 | |
| Download: ML19263B366 (1) | |
Text
{{#Wiki_filter:. Westinghouse Electric Corporation Docket tio. 99900404/78 fl0TICE OF DEVIATION Based on the results of an t1RC inspection conducted on September 25-28, 1978, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below: Criterion V (Instructions, Procedures, and Drawings) of Appendix B to 10 CFR Part 50 states in part, " Activities affecting quality shall be prescribed... and shall be accomplished in accordance with these instructions, procedures, or drawings." The corresponding applicable Section,17.1.5 (Instructions, Procedures, and Drawings) of the Westing-house Topical Report, WCAP 8370, states in part, "The Quality Assurance Program provides that activities affecting quality will be accomplished in accordance with documented instructions, procedures and drawings...." Contrary to the above, procedures do not exist describing the method by which changes to the evaluation model are reported in amendments submitted to the f1RC as required by paragraph 1.b. of Section II of 10CFR50, Appendix K. (See Section D. 2.b.) N [ 7so.tiso/g. Summary Special Inspection conducted on September 25-28, 1978 (99900404/78-03) Areas Inspected: 10 CFR 50, Appendix B, and Topical Report WCAP 8370 as applied to the establishment and implementation of procedures to control the development and revision of safety analysis computer codes. The inspection involved fifty-six (56) inspector hours on site by two (2) USNRC Region IV inspectors. Results: In the area inspected there were no unresolved items and one (1) deviation identified as follows: Deviation: 10 CFR 50, Appendix B, Criterion V, and Section 17.1.5 of Topical Report WCAP 83/0-procedures do not exist for the evaluation and reporting of significant changes in the evaluation model as referenced in Criterion II.b. of 10 CFR 50, Appendix K. (See Notice of Deviation, Enclosure. )
DETAILS SECTION (Prepared by D. G. Anderson and R. H. Brickley) A. Persons Contacted
- L. A. Campbell, Senior Engineer
- R. A. Dannels, Manager, Methods Development
- V. J. Esposito, Manager, Safeguards Engineering S. M. Hendley, Advisory Scientist
- R. A. Margolis, Senior Engineer
- J. J. McInerney, Senior Quality Assurance Engineer P. T. McManus, Senior Quality Assurance Engineer
- R. A. Muench, Manager, Safeguards Analysis
- R. W. Steitler, Manager, Reactor Protection Analysis
- Denotes those present at the exit meeting.
B. A tion on Previous Inspection Findings l 1. (0 pen) Deviation (Report No. 77-02): Records which were not yet in the permanent storage facility were not being maintained in duplicate sets in separate geographical locations. Corrective action on this item is still in progress. Westinghouse has commited to the completion of filming, jacketing, and transfer of all equipment descriptions, system descriptions, and QA specifications to the Boyers Records Center by the end of December, 1978. This item will be inspected when corrective action is completed. 2. (Closed) Deviation (Report No. 78-02): Several computer program abstract forms (55374) had not been approved by the immediate manager. The inspector reviewed the corrective actions described in the Westinghouse letter of response dated September 15, 1978, and confirmed that the computer program abstract forms identified in the inspection report had been signed by the immediate manager. The inspector also reviewed a memorandum dated August 18, 1978, which instructed all personnel in Configuration Control (Methods Development) to only accept forms which has been completed as required. C. Introduction This report covers a special inspection conducted to examine the establishment and implementation of procedures controlling safety analysis computer code development. The objectives of this inspection are:
_4 1. To determine that adequate procedures to minimize the potential for analysis errors to go undetected have been established for control of the development and revision of these codes. 2. To determine that these procedures were fully implemented during the development and revision of selected codes. D. Control of Safety Analysis Computer Codes s 1. Establishment of Procedures a. Inspection (1) The Westinghouse-PWRSD Topical Report, WCAP 8370, requires in Section 17.1.3, Design Control that "Where computer programs are used in design analysis, these programs are verified and their usage is controlled." These commitments are implemented by the following Westinghouse Electric Corporation-Nuclear Energy Systems-Water Reactor Divisions Policy and Procedures: (a) OPR-WRD-300-1, Verification and Qualification of Computer Programs Used in Engineering Analysis, Design, or Safety Analysis (Policy). (b) OPR-300-5, Configuration Control of Computer Programs (Procedure). (2) An examination of OPR-300-1 revealed that there are requirements for verification of computer programs and documentation of that verification for inclusion in a Central Program File Package which is then maintained by the Configuration Control Section of Methods Development. Appendix A of this Policy outlines nine (9) alternatives for verification of a computer program and ten (10) alternatives for qualification of a computer program. (3) An examination of OPR-300-5 revealed that requirements for the submission of new computer programs and the modification of existing computer programs are estab-lished along with the definition of responsibilities of individuals in the verification chain. The computer program forms which make up a portion of the verifica-tion documentation are included as Appendix C. (4) The Nuclear Safety Procedures Manual contains the implementing procedures to be used at the departmental
, level. Since this special inspection was restricted to computer codes used in safety analyses, the applicable group procedures within the Nuclear Safety Department were as follows: (a) General; Procedure 1.1, Configuration Control of Computer Programs. (b) Reactor Protection; Procedure 4.5, Preparation of SAR Analyses; Procedure 4.6, Preparation and Review of Calculation flotes; Procedure 4.12, Qualification of Computer Codes Used by Reactor Protection. (c) Methods Developnent: Procedure 6.2.1, Quality Assurance of Reactor Code Systems (QUARCS) Benchmark Library; Procedure 6.2.2, Quality Assurance of Reactor Code Systems (QUARCS) Testing Programs with Benchmarkt.; Procedure 6.3, Preparation / Preservation of Verification Documentation. (d) Safeguards Engineering: Procedure 5.2, Preparation of Design Analyses; Procedure 5.3, Preparation of Calculation iketes; Procedure 5.4, Generation of Safeguards Engineering Standards. b. Findings The procedures used to implement WCAP 8370 appear to meet the requirements of ANSI N45.2.11 as appropriate to verifica-tion, and documentation of this verification for safety analysis computer codes. During the examination of these implementing procedures, the following items were identified and Westinghouse management indicated that they would consider further action, as appropriate. Any action taken by Westing-house will be examined during a future inspection. (1) Procedures do not address how errors identified in computer programs are reported to the USNRC. (2) Procedures do not address how warning statements regarding restrictions on code use are resolved. (3) Microfische records used in engineering analysis are not always legible. (4) Documentation did not specify which codes constituted the LOCA/ECCS evaluation model.
. (5) The meaning of inc': pendent verificatien is not clearly identified on the Computer Program Change Request Form (55375). (6) Procedures do not require the reexamination and reevaluation of procedures in the event of code errors. (7) Ancillary codes referred to in computer program doc-uments are not described or referenced adequately. (8) Procedures do not address the correction of errors identified in computer program WCAP documents. (9) Safety Analysis Standards do not sufficiently identify code input options. (10) Procedures do not address comparison of new versions of codes against the same data used to verify the original version. (11) Standard No. 19 of the Safety Analysis Standard references an out-of-date version of a computer code. (12) Procedures do not address updating of Safety Analysis Standards. 2. I plementation of Procedures f a. Inspection The development and revision of the following computer programs was evaluated for meeting the requirements of OPR-300-1 and OPR-300-5 related to verification and control: LOCTA IV: A computer code designed to calculate the wall temperatures of the fuel rod, average pellet temperature, average clad temperature, and fluid temperatures during the loss of coolant accident (LOCA). LOFTRAN: A digital computer code which calculates the detailed transient behavior of a one loop pressurized water reactor system. The inspectors examined the documentation contained in the Central Program File Package on these two (2) computer programs which consisted of five (5) memoranda transmitted
- between Westinghouse and the USNRC, twelve (12) internal memoranda transmitted between departments in Westinghouse, twelve (12) computer code topical reports contained in WCAP documents, twenty-nine (29) calculation notes, one (1) Safety Review Committee meeting minutes, four (4) Computer Configuration Control Fonns, twenty-two (22) Computer Code Change Request forms, three (3) Safeguards Engineering Standards, one (1) copy of the Safety Analysis Standards, nineteen (19) computer program runs on microfilm, and three (3) Chronological Code Change Index forms. b. Findings In this area of the inspection, no unresolved items were identified. One (1) deviation from cocinitment was identified (See Notice of Deviation, Enclosure). Additional information related to this deviation was noted during the review of calculation notes for the :f rconium-water reaction error analysis. These calculation notes reported that after modifications had been made to LOCTA IV, recalculated values for tge peak clad temperature resulted in a temperature increase of 24 F. It was further noted that no followup action on this item had been performed nor were model changes identified in the resubmitted topical report (WCAP 9220). With respect to this item, paragraph 1.b. of Section II of 10CFR50, Appendix K, requires that "The description (of the evaluation model) shall be sufficiently detailed and specific to require significant changes in the evaluation model to be specified in amendments of the description. For t%, purpose, a significant change is a change that would result fn a calculated fuel cladding temperature different by more that 20 F from the temperature calculated (as a lunction of time) for a postulated LOCA using the last previously accepted model." DSS /NRR will followup on this item to determine if reporting requirements have been met by Westinghouse. E. Exit Meeting An exit meeting was conducted with management representatives at the conclusion of the inspection on September 28, 1978. In addition to those individuals indicated by an asterisk in Section A. of the Details Section of this report, the following were in attendance: T. M. Anderson, Manager,fJuclear Safety J. A. Burgess, Manager, Quality Assurance E. S. Hampton, Manager, Product Assurance Programs G. G. Harkness, Systems Analyst
- K. R. Jordan, Manager, Reactor Protection E. J. Kreh, Manager, Product Assurance D. C. Richardson, Manager, Reactor Protection Analysis R. A. Wiesemann, Manager, Regulatory and Legislative Affairs The inspector summarized the outstanding items and the corrective action which was reviewed during this inspection. The inspector discussed the scope and findings identified during this inspection. Management representatives acknowledged the statements by the inspector with respect to the one (1) deviation presented. .ew~.e emsewy.w----ene- --m .=e
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