ML20148F479

Summary of 970513 Meeting W/Licensee to Present Findings of Insp of Licensee Facility in Richland,Wa in Feb - Apr 1997. List of Attendees & Licensee Response Encl

ML20148F479
Person / Time
Issue date:	05/30/1997
From:	Wang E NRC (Affiliation Not Assigned)
To:	Matthews D NRC (Affiliation Not Assigned)
References
NUDOCS 9706040277
Download: ML20148F479 (12)

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UNITED STATES g

j NUCLEAR REGULATORY COMMISSION o

WASHINGTON D.C. 20066 4 001

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May 30. 1997 MEMORANDUM TO:

David B. Matthews, Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM:

Egan Y. Wang, Reactor System Engineer Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUBJECT:

MEETING

SUMMARY

OF MAY 13, 1997, SIEMENS INSPECTION EXIT MEETING On May 13, 1997, representatives of the Nuclear Regulatory Commission (NRC) met representatives of Siemens Power Corporation (SPC) to present the findings of an inspection of Siemens facility in Richland, WA, in February through April, 1997.

The NRC inspection team leader discussed several issues identified during the inspection.

In particular, the NRC staff discussed Atrium *-9 and Atrium *-10 fuels.

For Atrium *-10 fuel, the NRC inspection team found that the fuel bundle design may not meet the requirements of general design criteria as defined in 10 CFR, Part 50, Appendix A.

For Atrium *-9 fuel, the inspectors noted that the data sets for the upskew and downskew power profiles in any test bundles modeling 9x9 fuel designs and the intended range of application of the Atrium *-9 fuel design were insufficient to justify the uncertainty values for the additive constants used in the safety limit determinations.

The NRC inspection team also determined that SPC had not fulfilled a i

commitment in the 1986 pressure water reactor (PWR) large break loss of

((j coolant accident (LBLOCA) safety evaluation report (SER) to validate the scaling methodology used to extend the fuel cooling test facility (FCTF) reflood heat transfer correlation to geometries other than 17x17 fuel.

For FCTF 17x17 testing data analysis, the computer code used to derive heat

() h transfer coefficients from bundle temperature data in the 17x17 tests was never brought under the Company's quality assurance (QA) program.

The NRC inspection team found that, in general, the~SPC's documentation on its thermal-hydraulics computer codes, including " approved" methodologies for PWR and boiling water reactor (BWR) LOCA calculations, was inadequate. The team also determined that there was insufficient guidance in SPC's computer code control procedures to ensure that adequate verification and validation (V&V) was performed on codes after modifications had been made.

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D. Matthews

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May 30, 1997 i

Based on the findings of this inspection, the NRC staff noted that overall NRC confidence in SPC's engineering is degraded.

The NRC staff also discussed some of SPC's strengths during the meetirg.

These strengths are effective self-assessment, proactive managment, and SPC action plans. Also, SPC is very responsive to cycle-specific plant issues.

The inspection team determined the QA process has been improved in fuel manufacturing as a result of SPC's self-assessment activities.

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SPC acknowledged the significance of the inspection findings identified during the four-week review. SPC committed to enhance its performance in the applications engineering and development areas to eliminate the j

nonconformances and weaknesses discussed during the meeting.

SPC i

representatives noted that SPC accepts the conclusions of the NRC's j

assessment; however, SPC believes that broader credibility questions need to be addressed directly and openly.

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SPC representatives also discussed several management' initiatives.

SPC is fully supportive of resolving NRC's concerns related to SPC's critical heat flux correlation.

For Atriume-9 fuel designs, SPC developed a methodology to establish increased uncertainties for use in safety limit analysis. SPC stated it will perform additional dryout testing on its Atrium

• designs to permanently address concerns raised with regard to uncertainties and dry out performance of part-length fuel rods.

SPC has begun to implement changes in its management systems to adequately address-weaknesses in areas of procedural i

guidance, training, and SER compliance. As a part of SPC's own self-discovery process, SPC had identified and begun to programmatically address code documentation and V&V weaknesses.

List of Attendees.

SPC Response Attachments: As stated cc w/att: Mr. H. D. Curet, Manager Product Licensing Siemens Power Corporation 2101 Horn Rapids Road P. O. Box 130 Richland, WA 99352-0130 i

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D. Matthews May M), 1997 Based on the findings of this inspection, the NRC staff noted that overall NRC confidence in SPC's engineering is degraded.

The NRC staff also discussed some of SPC's strengths during the meeting.

These strengths are effective self-assessment, proactive managment, and SPC action plans. Also, SPC is very responsive to cycle-specific plant issues.

The inspection team determined the QA process has been improved in fuel mar:ufacturing as a result of SPC's self-assessment activities.

SPC acknowledged the significance of the inspection findings identified during the four-week review. SPC committed to enhance its performance in the applications engineering and development areas to eliminate the nonconformances and weaknesses discussed during the meeting.

SPC representatives noted that SPC accepts the conclusions of the NRC's assessment; however, SPC believes that broader credibility questions need to be addressed directly and openly.

l SPC representatives also discussed several management initiatives.

SPC is fully supportive of resolving NRC's concerns related to SPC's critical heat i

flux correlation.

For Atriume-9 fuel designs, SPC developed a methodology to j

establish increased uncertainties for use in safety limit analysis.

SPC stated it will perform additional dryout testing on its Atrium

• designs to permanently address concerns raised with regard to uncertainties and dry out performance of part-length fuel rods. SPC has begun to implement changes in its management systems to adequately address weaknesses in areas of procedural guidance, training, and SER compliance. As a part of SPC's own self-discovery process, SPC had identified and begur to programmatically address code documentation and V&V weaknesses.

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List of Attendees.

SPC Response Attachments: As stated i

cc w/att: Mr. H. D. Curet, Manager Product Licensing

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Siemens Power Corporation 2101 Horn Rapids Road l

P. O. Box 130 Richland, WA 99352-0130 DISTRIBUTION:

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Document name: 970513MT. SUM A

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NRC/SIEMENS POWER CORPORATION MEETING NRC TEAM INSPECTION EXIT MEETING LIST.OF ATTENDEES May 13, 1997 M8liE CRGANIZATION Spadaro, John PP&L Kulik, John PP&L Peteraski, Daniel CP&L Choe, Whee TU Electric Banstian, Gregory Consumer Energy Lacy, Patrick Parameters /3RA Reynolds, Roger Siemens Curet, D. H.

Siemens Federico, Larry Siemens Adkisson, Doug Siemens Femreite, Bernal Siemens Powers, Chris Siemens Nordahl, Jim Siemens McAlees, David Siemens Matthews, Steven NRC/NRR/PSIB Kopp, Larry NRC/NRR/SRXB Gillespie. Frank NRC/NRR/ DISP Gallo, Robert NRC/NRR/PSIB Cwalina, Greg NRC/NRR/PSIB Poslusny, Chet NRC/NRR/DRPE Polich, Timothy NRC/NRR/DRPW Levin, Alan NRC/NRR/SRXB Phillips, Larry NRC/NRR/SRXB Lyons, Jim NRC/NRR/SRXB Le, Tommy NRC/NRR/DRPE Landry, Ralph NRC/NRR/SRXB Staudenmaire, Joseph NRC/NRR/SASG Thomas, Georger NRC/NRR/SRXB Donohew, Jack NRC/NRR/DRPW Huang, Tai NRC/NRR/SRXB Cant, Geoffery NRC/0E Ulses, Anthony NRC/NRR/SRXB Kendrick. Edward NRC/NRR/SRXB Petrosino, Joseph NRC/NRR/PSIB Holahan, Gary NRC/NRR/DSSA Arndt, Steven NRC/AE00 Wang, Egan NRC/PGEB ATTACHMENT 1

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SPC Response Statement to the NRC Core Performance Action Plan inspection

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Siemens Power Corporation acknowledges the significance of the inspection findings identified 4

l uuring the 4 week review. The deficiencies and programmatic weaknesses included in the

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findings are serious challenges.

We will enhance our performance in the applications er.gineering and development areas.to eliminate the nonconformances and weaknesses

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4 discussed today. Furthermore, I am confident we can satisfactorily respond to the broader i

NRC concems expressed.

i I would like to broadly outline our managemsnt initiatives which will address the issues j

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discussed today.

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We have always been committed to being a responsive, capable vendor and active participant

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in this industry. Many of the concems identified in the review stem from work performed 10 years ago to then applicable standards. However, I am confident that our more recent efforts 4

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demonstrate our ability to peiform to the more rigorous standards applicable today and affirm our willingness to identify and correct our shortcomings.

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As acknowledged by this assessment team, by our customers, and by audits under our Part 70 l

license and our Part 50 processes as applied to fabrication, we have achieved significant improvements in our manufacturing and quality systems. Following identified shortcomings in j

. the 1993-1994 period, our staff undertook comprehensive training, procedure upgrades, self.

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assessments, and set important goals for improved processes and quality, i

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Within our manufacturing activities, significant progress has been made in work practice definition, process control, shortened cycle times, higher quality yleids, as well as procedural l

compliance. Capital investments have been made to improve production, administrative work, j

and quality control. We have enabled our staff to become more careful, demanded a high level of workmanship and eliminated workarounds. Self-assessment and performance metrics have become an important part of our work.

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a 05/13/97 SPC Response Statement to the NRC Core Performance Action Plan inspection We have begun a similar strategy for our engineering and methods development activities.

Our own assessments as well as those of our customers have identified shortcomings that have challenged the quality of certain aspects of our engineering work. Your assessment will be an important factor in our continued improvement of our engineering processes.

i i can assure you that this management team and Siemens will achieve the needed changes.

SPC Perspectives SPC accepts the conclusions of the NRC's assessment and in a moment, I will summarize our commitments to respond as promptly and constructively as possible. However, we believe that broader credibility questions need to be addressed directly and openly. With that in mind, we would ask that the results of the assessment be considered in the context of what our perspective was prior to the assessment.

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1. in the late 1980's SPC's (Exxon Nuclear's) fuel reliability was differentiated as being the i

best in the U.S. experience. Although overall industry fuel reliability has generally improved, we believe that our fuel reliability track record remains exemplary.

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contributes to lower outage doses, fewer issues for spent fuel storage and lower costs for our customers.

2.' During our 29 year history, SPC has designed,_ supplied and supported the licensing analyses for fuel vendor transitions in 28 reactors in the U.S. and another 20 foreign reactors. In addition we have transitioned through a series of evolving SPC fuel design features constituting 21 design changes in the U.S. and another 18 in foreign reactors.

Prior to the startup delay at Susquehanna Unit 2 which resulted from resolution of issues arising from this assessment, SPC had accomplished these vendor and design feature transitions with no adverse impact on reactor operations. That is not to say that SPC has not experienced operational difficulties with utility customers. In each of these cases, SPC responded quickly and appropriately to minimize the impact on our customers and to 2

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I, 05/13/97 SPC Response Statement to the, NRC Core Performance Action Plan inspection s

provide a sound regulatory basis for recovery.

We estimate the sevings resulting from these SPC managed transitions to be greater than $2 billion for the benefit of the ultimate electrical customers

3. Throughout our experience as a NRC Materials Licensee, under Part 70, and a vendor to j

j plant licensees, under Part 50, we have, what we believe, has been an overall good

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record of constructive working relationships with the NRC based upon open f

communications and a demonstrated concem for safety and compliance issues. We have loamed from this NRC assessment that the past is not an adequate basis for judging i

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current regulatory requirements.

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4. We entered this inspection with relatively new NRC approved methodology for BWR reload analysis and believed we were applying it consistent with the applicable SER's.

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We felt there was room for engineering judgment and interpretation in these applications.

However we leamed, in some cases, our engineering Judgments and interpretations were j

not accepted by the review team under today's conditions.

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5. We did not fully recognize the changing emphasis on compliance and more prescriptive

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regulatory standards. We believed we had achieved significant progress through our f

revised QA Program which was approved by the NRC in 1996 and included qualification under ISO 9001.

We have been audited numerous times by tens of U.S. as well as foreign utilities and regulatory agencies; none has ever suggested SPC's degree of i

compliance was inconsistent with expectations, i

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6. SPC has' been an innovative organization with highly qualified and experienced personnel, i

Except for administrative positions, the entire management team is also comprised of technically qualified and highly experienced personnel. We have relied on the engineering and scientific expertise of our senior people, subject to the purview of their management and all of the requirements of our QA Program.

Thus, we have not had a highly proceduralized system that would be required with less senior, less experienced people.

We have leamed a difficult lesson that we must change our approach to be more 3

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SPC Response Statement to the NRC Core Performance Action Plan inspection

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systematic, to complement the knowledge and judgment of our individual scientists, engineers and managers.

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7. SPC has significant initiatives underway to correct systematic deficiencies as measured by today's regulatory environment; we will augment these with new actions deemed necessary i

in response to the NRC assessment or our own continuing self assessments.

8. Siemens, our parent company, is committed to the future of nuclear power and knows well the absolute necessity of nuclear safety as a prerequisite for the survival of the industry worldwide. ' Siemens supports SPC's goal to be a world-class vendor of nuclear fuel and related technology and services; there is no question as to parent company support for SPC to take the actions necessary to remedy the shortcomings determined by the NRC's assessment.

9. The NRC team expressed concern about weaknesses in processes by which we implemented the ATRIUM 10 design. We have had considerable dialog and believe we have fully addressed the technical issues raised.

Consistent with programmatic deficiencies we have already discussed, SPC failed to effectively communicate the extensive design effort and experience base which underlies the ATRIUM 10 program.

This includes both the international lead fuel assembly programs and our choice to utilize cold worked / stress relieved cladding, a process consistent with our extensive US experience. In the case of a new design such as this, we have learned the need to I

compile a comprehensive information package in order to support the design basis, even though many components and specifications are the same as those already in use in the U.S.

In closing I will summarize those commitments that we have already determined to be appropriate in response to the assessment.

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SPC Response Statement to the NRC Core Performance Action Plan Inspection i

i SPC Mananoment initiatives i

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As indicated earlier, SPC self identified a number of the same problems brought forward as part of this NRC inspection. As a result, we are already well underway in a broad program of management initiatives. The NRC inspection has been key in broadening our efforts with even more urgency.

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Of immediate importance is fully supporting and resolving your concems related to our critical heat flux correlation. Due to the impact on our customers, SPC appreciates the NRC's l

willingness to allow us the opportunity to address each of the issues you raised. With your

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l cooperation, we were able to resolve many questions you and your team raised and establish l

a near term action plan.

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However, we recognize both the important technical and programmatic implications of this issue and have already taken significant actions to go well beyond the Staff's requirements. In l

response to concems about application to our existing ATRIUM 9B designs, we developed a methodology to establish increased uncertainties for use in safety limit analysis. Further, until l

the Staff has sufficient time to review this revised methodology, we proposed, and the Staff l

accepted as reasonable, the concept of doubling the safety limit uncertainty adder. This J

l approach allows operation of the involved plants with more restrictive safety limits until such

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time as the Staff is satisfied with SPC's revised methodology.

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I SPC will perform additional dryout testing on its ATRIUM designs to permanently address i

j concems raised with regard to uncertainties and dry out performance of part length fuel rods.

l This part length rod issue was self identified by SPC when results from a recent upskew critical 1

power test on the ATRIUM 10 did not adequately agree with dryout correlation predictions t

based on cosine tests. In November,1996 as an interim resolution, SPC initiated work to invoke sufficient conservatism into the methodology which we believed at the time was l

adequate.

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j However, through our interactions with you, we refined this interim approach to more directly i

address the concems in the safety limit. As a final resolution, we will develop and submit a

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05/13/97 SPC Response Statemen't to the NRC Core Performance Action Plan Inspection new correlation with more data sets to address the technical concems raised during this inspection. The testing program and correlation development has been initiated and is being given the highest priority of all our development projects.

You acknowledged our new global Quality Assurance program which goes beyond both Appendix B and ISO 9001 requirements. We have implemented the more stringent conditions from either set of regulations in order to form a program which serves as a basis for future Quality leadership in our industry. This program will serve as the framework to address and resolve the other concems you have pointed out to us.

Your inspection team was complimentary on the performance of individual analysts associated with SPC's engineering functions. We are pleased that you found our staff motivated and professional. You noted the quality of the documentation of our engineering analyses despite l

programmatic deficiencies.

We will focus on improving the identified programmatic deficiencies without compromising the successes we have already achieved in the quality of our engineering personnel and analyses.

We have begun to implement change in our management systems to adequately address weaknesses in areas of pror edural guidance, training and SER compliance. We understand that it is essential that our technical staff be provided a consistent set of management expectations regardless of the organization in which they work. This will be addressed through j

development and implementation of work practices, a program that is already well under way.

These practices bridge the gap between broad contractual and regulatory requirements and the mechanics of performing engineering analyses.

It is important that our engineers understand that the process by which work is performed is as important as the end result. Individuals in all our engineering organizations will be provided a consistent set of management guidelines to clearty communicate "how we want our business to be run." Specifically there will be consistency between organizations in areas such as:

design control, development, documentation, validation & verification, nonconformance control and personnel qualification to name a few. We will also more directly address customer interface requirements in th9se same areas.

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05/13/97 SPC Response Statement to the NRC Core Performance Action Plan inspection t

As part of our own self discovery process, we ha<l already -identified and begun to programmatically address code documentation and verif' cation and validation (V&V; weaknesses. We agree with your inspection team that inadequate direction has been given to Individuals in our engineering functions and as a result code development V&V has been inconsistent. We have already put in place infomal procedures to expand on the directions given to engineers for determining V&V requirements and now require better documentation of the decision criteria. However, we will go beyond this and establish a more systematic approach to V&V such as providing guidance to engineers to establish V&V parameters and standardized case libraries.

t We will be innovative as well as self critical as we implement the necessary changes in response to this inspection. We are considering establishing an engineering safety oversight function, similar to many nuclear plant safety committees. This would be comprised of a team of outside experts which would periodically and critically review our processes and progress.

Over time, we believe this would help assure the continuous improvement which we are committed to achieve.

In addition to the points mentioned above, it is necessary for us to rethink our organizational l

structure to emphasize and facilitate better communication on these critical licensing issues.

We will not ignore the fact that many of these same programmatic weaknesses were found through our own self discovery processes. However, we also recognize that we did not implement changes in a manner aggressively enough to meet the mandates of today's regulatory environment. It is essential to us to rebuild our credibility with the NRC and we believe that a visible commitme.'t to open communication is a comerstone in this effort.

I hope my comments clearly indicata that we have heard your message, are taking it seriously and are implementing actions aimed at s;wific issues and broader cultural change. If there is any question in your minds about our commitnv.,nt, we would appreciate further communication i

immediately or as soon as sud1 questions arise.

i Thank you.

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