ML19263B449

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IE Insp Rept 99900401/78-04 on 781113-17.Noncompliance Noted:No Procedure for Evaluation & Reporting of Evaluation Model Changes or Input to the CESSAR Sys 80 FSAR
ML19263B449
Person / Time
Issue date: 11/28/1978
From: Donna Anderson, Lauben G, Sheron B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19263B437 List:
References
REF-QA-99900401 NUDOCS 7901180264
Download: ML19263B449 (8)


Text

U. S. NUCLEAR REGULATORY C0t< MISSION OFFICE OF If;SPECTION AND ENFORCEMENT REGION IV Report No.

99900401/78-04 Program No.

51100 Company:

Combustion Engineering, Inc.

1000 Prospect Hill Road Windsor, Connectic :

06095 Inspection Ccnductod: flovember 13-17, 1978 jl Inspectors-

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D. G. Anderson, Principali Inspector, Date

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B. W. Sgr,on, Nuclear Engfineer, DSS /NRh_

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G. N. Laupery, Nuclear,< Engineer, DSS /NRR Date I

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P. E. Norian, Section,Leyder, DSS /NRR Date I

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Aoproved by:

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N C. J. Hales Chief, Vendor'Prograr& Evaluation Date Section,'7srdor !nsosction Branch

_ Summary Special Inspection conducted on November 13-17, 1973 (99900401/73-04)

Areas Insoected:

i0 CFR 50, Appendix B, and Topical Report CENPD-210-A as applied to the establishment and implementation of procedures to control 790118 oM4

.. the development and revision of safety analysis computer codes.

The inspection involved thirty (30) inspector hours on site by one (1) U$tiRC

". ajion IV in spector.

Results:

In the area inspected one deviation and one unresolved item were identified as follows:

Deviation:

10 CFR 50, appendix B, Criterion V, proceaures 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 ilotice of Deviation, Enclosure.)

Unresolved Item:

Verification had not been completed on two (2) calculations which resulted in input to the CESSAR System 80 FSAR (See Details Section paragraph C.2.b.).

DETAILS SECTICN (prepared by D. G. Anderson)

A.

Persons Contacted

  • W. C. Coppersmith, Manager, Design Transier.ts Safety Analysis F. L. Carpentino, Section Manager, ECCS Analysis Group
  • J. Goldberg, Supervisor, Standard Plant Licensing
  • F. G. Harvey, Engineering Quality Acsurance Auditor
  • C, L. Kling, Acting Supervisor, CESEC Development Group J. Longo, Jr., Manager, ECCS Analysis Group H. T. Melcher, Engineering Jaecialist
  • R. R. Mills, Supervisor, Pro.ac. and Generic Licensing
  • J. C. Packard, Supervisor, Group Quality Systems 4

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  • Denotes those present at the exit meeting.

B.

Introduction This report covers a special inspection conducted to exanine the establishment and implementation of procedures controlling safety analysis computer code development.

The objectives of thi inspec-tion were:

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.

C.

Control of Safety Analysis Comcuter Codes 1.

Establishment of Procedures a.

Inscection (1) The Combustion Engineering, Inc., Topical Report CEilPD-210-A, requires in Section 17.3, Design Control, that "The QADM procedures implement design quality assurance requirements... provide specific require-ments for all safety related work accomplished...

provide design controls to applicable activities such as; reactor physics, seismic, stress, thermal, hydraulic, radiation and accident analysis... contains an iden-tification systera for analyses and/or calculations

. prapared for each NSSS project within the section.

This indicates how calculation sheets will be ccm-plesad.

"ethods af analyses in the form ci ccm: uter programs are controlled by the procedure. The computer programs that are used for safety-related analyses are certified for accuracy, method, and internal censistency prior to verification of the analysis in which it is used."

These comitments ara implemanted by the following Combustion Engineering, Inc., procedures:

QADP 5.2, Cesign Inalysis QADP 5.4, Design Verification (2) An examination of procedure QADP 5.2 revealed th.:;

there are detailed requirements for the preparation, review, and verification of analyses and computer codes.

Requirements for documentation of this ',erifica-tion are also included in the procedure. Changes to analyses or ccmputer programs shall comply with the requirements for initial preparation of the analyses or computer programs.

A Computer Code Certificate is the permanent file identification for computer codes that have been certified by Combustion Engineering, Inc.

(3) An examination of procedure QADP 5.4 revealed that Combustion Engineering, Inc., utilizes three distinct methods of design verification: Design Reviews, Al ter-nate Calculations / Analyses, and Testing. A list of qualified revisers is maintained by each Supervisor /

Manager and independent review of analyses / calculations is conducted by reviewers selected from this list.

b.

Jindi~ngs QADP 5.2 and GADP 5.4, which are procedures used to imolement CENPD-210-A, appear to meet the requirements of ANSI N45.2.ll as appropriate to verification, and documentation of this ver1fication, as applied to Safety Analysis Computer Codes.

During the examination of these implementing procedures and the documentation generated as a result of following the procedures, the following items were identified and manage-ment of Combustion Engineering, Inc., indicated that they would consider further action, as appropriate. Any action taken by Combustion Engineering, Inc., will be examined during a future inspection.

. In addition to the items listed below, one (1) deviation fron commitment was identified (See Notice of Deviation, Enclosure).

No unresolved items wer identified in this area of the inspection.

Items for consideration by Combustion Engineering, Inc.,

Management:

(1) There does not appear to be any central index to define what constitutes the code design file, or a project desig, file.

(2) Procedures do not address how modifications to NRC-approved codes are reported to NRC.

(3) The "ECCS Licensing Analysis Verification Checklist" was found in the system 80 CEFLASH calculation input file, but not in other files.

We encourage the use of such a checklist for all calculations and its inclu-sion in the design files.

s ;) There appears to be no information in the ECCS code files regarding verification by comparison to test data.

Such comparisons are available through programs such as the standard problem program. We believe this form of verification to be applicable to parts of evaluation model codes and should be included in the code verification files.

(5) On the ECCS Licensing Analysis Verification Checklist, item 25 was checked "yes," indicating ;xperimental data was employed.

No evidence of how the experimental data was employed was found.

(6)

Procedures do not address how errors identified in codes are dispositioned.

(7) A chronological listing of development, review, approval, and changes to codes had not been documented.

(8)

Procedures do not address the process to be followed when existing codes are used in applications other than those for which the code was originally developed.

(9) Procedures do not address how documenta*. ion is maintain-ed for the following items:

(a) Comparison of Codes with previous results.

6-(b) Review of Computer Code Quality Assurance Folders.

(c)

Changes to Computer Coces.

(10) Departmental level procedures do nct exist woich address code development, review, approval, and control of computer codes.

(11)

CESSAR/FSAR/Systen 80 LOCA Analysss were submitted to NRC prior to the completion of inaependent review of the analyses.

QA review and verification of all docu-ments should be completed prior to submittal to NRC.

(12) Procedures do not address how individual codes are to be used in an overall analysis model or package.

Also, there are no requirements for assuring that integral results developed frem more than one code are indepen-dently reviewed.

2.

Implementation of Procedures a.

Insoection The development and revision of the following computer programs was evaluated for meeting the requirements of QADP 5.2 and QADP 5.4 related to development, veri fica tion,

and control of:

STRIKIN II: A Cylindrical Geometry Fuel Rod Heat Transfer Program.

The STRIKIN II code is a Fortran IV digital program which is used to calculate the core hot spot transient clad temperature during the blowdown, refill, and reflood portions of the loss-of-coolant accident.

CESEC:

Digital Simulation of a Combustion Engin'ering Nuclear Steam Supply System.

Simulates coppler and moderator reactivity feedback, point kinetics neutron behavior, boron and CEA reactivity ef fects, multi-node average and hot channel reactor core thermal hydraulics, reactor coolant pressurization and mass transport, reactor cool-ant system safety valves, steam generation, steam generator water level, main steam bypass system, safety and turbine valves, as well as alarm, control, protection and Engineered Safety Feature Systems.

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. The inspector examined the documentation contained in the Quality Assurance Folder on these two (2) computer codes which consistad of fourtaen (14) ccmputar ccda Tocical Reports, thirty-one (31) copies of interoffice correspondence twenty-four (24) calculations, seven (7) computer code certificates, ten (10) lists of qualified reviewers, six (6) analysis cover sheets, one (1) ECCS licensing analysis checklist, one (1) listing of the STRIXIN II code version 77036, and two (2) film cassettes of computer code verification runs.

b.

Findings In this area of the inspection, no deviations were identified.

The following finding has been identified as an unresolved item and will be forwarded to NRC/NRR for resolution:

During a review of ;ne verification of two (2) calculations that resulted in input to the CESSAR System 80 FSAR, sections 6.2.1.5 and 6.3.3., the inspector noted that the verification process had not been completed even though the FSAR has been submitted to NRR/NRC for docketing. Upon discussion of this item with Combustion Engineering representatives, it was noted that design input for these calculations had not as yet been received and therefore the calculations could not be completed and consequently could not be verified.

10 CFR 50.b.(4) requires that for Final Safety Analysis Reports that 'A final analysis and evaluation of the design and performance of structures, systems and components with the objective stated in (a)(4)* of this section and taking into account any pertinent information developed since the submittal of the preliminary safety analysis report."

  • (a)(4) refers to preparation of preliminary analyses.

The inference above to " final analysis" indicates that informa-tion should not be submitted to NRR/NRC which is " preliminary" in nature.

As noted before, this item will be forwarded to NRR/NRC for resolution of what constitutes " final analysis" for purposes of FSAR submittals.

D.

Exit Meeting An exit meeting was conducted with Combustion Engineering management personnel

. the conclusion of the inspection.

Those individuals indicated by an asterisk in Section A of the Details Section of this report were in attendance.

In addition, the following were present:

. J. M. Cicerchia, Licensing Engineer E. P. Flynn, Director, Plent Apparatus and Engineering Quality Assu.anca C.

',J. Ho.-fman, Director, Group Quality Assurance G. J. Huba, Manager, Engineering Quality Assurance Ti.e inspector discussed the special nature of this inspection, scope, and findings identified during the inspection.

Management representa-tives of Combustion Engineering acknowledged the statements by the inspector with respect to the one (1) deviation presented.

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