ML20148S063
| ML20148S063 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148R990 | List: |
| References | |
| REF-QA-99900400 NUDOCS 7812010141 | |
| Download: ML20148S063 (7) | |
Text
j The Babcock & Wilcox Company Nuclear Power Generation Division Docket No.
99900400/78-03 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on August 29-31, 1978, it appears 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 50 and the corresponding Section 5 of the Babcock & Wilcox topical report BAW-10096A (B&W NPGD Quality Assurance Program For Nuclear Equipment) state that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circum-stances and accomplished accordingly.
Section 5 of BAW-10096A further states that these procedures are implemented by publication in the NPGD Administra-tive Manualr.
Contrary to the above, certain activities were not accomplished in accordance with your procedures as follows:
1.
Step 11 of Exhibit B (Certification of Computer Programs) to published procedure NPG-0902-06 (Computer Program Development and Certification) states in part, "... File original documentation in certification files." Further Step 1 defines a typical program package to consist of the request, program, and program manual.
Contrary to the above, the original documentation for the Conditional Certifications for Version 4 of TRAP 2 issued January 24, 1978, and Version 4.1 of TRAP 2 issued February 9,1978, were not filed in the Certification Files for the TRAP program.
2.
Step 12 of Exhibit B to NPG-0902-06 states in part, "... Initiate Program Abstract and insert in NPGD-TM-338."
Contrary to the above, the Program Abstract for Conditional Certifi-cation of Version 3 of TRAP 2 issued on December 20, 1977; Version 1B of TRAP issued on March 3, 1978, and Version 4.1 of TRAP 2 issued on February 9,1978, were not inserted in NPGD-TM-338.
3.
Section IV (Program Abstract) of NPG-0902-06 states in part, ".
This (Program Abstract) is a computerized format... that describes certain aspects of the program (i.e.... Responsible Engineer and P rog ranme r,.... "
Contrary to the above, the latest revision (14) to NPGD-TM-338 does not describe (identify) the Responsible Engineer and Programmer.
7832039343
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. Results:
In the area inspected there were no unresolved items and one deviation identified as follows:
Deviation:
10 CFR 50, Appendix B, Criterion V and Section 5 of Topical Report BAW-10096A - three (3) exampler, of a failure to follow procedures in the development and revision of safety analysis computer codes.
(See Notice of Deviation enclosure. )
1 J
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. DETAILS a
A.
Persons Contacted
- J. J. Cudlin, Manager, LOCA Methods Unit
- B. M. Dunn, Manager, ECCS Analysis Unit
- D. W. La Belle, Manager, Safety Analysis Unit
- C. D. Morgan, Manager, Technical Staff K. C. Shich, Principal Engineer, ECCS
- Denotes those present at the exit interview.
B.
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 inspec-tion are:
1.
To determine that adequate procedures to minimize the potential for analysis errors to go ndetected have been established for control of the development and revision of these codes.
To determine that these procedures were fully implemented during the development and revision of selected codes.
C.
Control of Safety Analysis Computer Codes i hment of Procedures s
action nn examination of the Nuclear Power Generation Division (NPGD) Administrative Manual, which contains procedures implementing topical report BAW-10096A (B&W NPGD Quality Assurance Program for Nuclear Equipment), revealed that procedure NPG-0902-06 (Computer Program Development and Certification) is the principal document governing this I
activity.
Procedure NPG-0903-03 (Internally Developed j
Computer Program Manuals) governs the preparation and l
issuance of the " user" manual.
The examination of procedure NPG-0902-06, Revision 1 dated January 26, 1978, revealed that it requires certification of all computer codes, except those not used for contract work, employed in the performance of calculations for non-safety related items consisting of 100 or less Fortran statements, prepared and used prior to September 28, 1973, 1
. but no longer employed at the performance of design verification calculations, and nonproduction computer programs that do not solve a mathematical equation.
- However, the procedure requires that the programs not subject to certification be independently reviewed and documented in accordance with their intended application.
There are four (4) levels of certification required:
Full Certification, Conditional Certification, Prior Certification and Interim Use.
Full Certification applies to programs which have been subjected to careful examination for programming and modeling accuracy, to verification of results using analytical and/or experimental data and to production testing (execution of sampling cases which typify production usage) prior to use.
Conditional Certification applies to new programs or modified versions of production programs, when the new or modified program must be released for production work prior to the completion of the full certification process.
Prior Cei tifica-tion applies to programs which have been superseded by new or revised programs but which must be retained for further analysis on those contracts where analyses are in progress or have been completed.
Interim Use applies to all programs which have been submitted for use but for which verification /
documentation only exists in contract records, Computer programs which are verified and certified for contract use are identified as production programs. These programs are jointly developed and documented by Computer Services and Technical Staff and are programs approved for use.
Exhibit A of this procedure is a flow diagram identifying, by title, the individuals involved in computer program development and the requitc; rents for each step of the process.
Exhibit B of this procedure is a flow diagram identifying, by title, the individuals involved in computer program certification and the requirements for each step of the process.
The examination of procedure NPG-0903-03, Revision 3, dated May 2,1977, revealed that fully certified computer programs are required to have a Program Manual when they are released for use.
Those programs released with a conditional certifi-cation are required to have a Conditional Program Manual defined as consisting of a Program Abstract, input instructions, and output information, b.
Findings During the examination of the B&W administrative procedures the following items were identified and B&W management stated they would consider further action, as appropriate.
Any action taken by B&W will be examined during a future inspection.
_ _ _ _ _ - _ _ _ _ (1)
Procedure NPG-0902-06 does not require a specific time limit on how long a computer program can remain in a conditional certification status before it must undergo the full certification process.
(2)
Procedure NPG-0902-06 does not appear to specify a method for termination of a version of a code which is found to contain an error and/or has been superceded i
by a new version.
(3)
Procedure NPG-0902-06 does not require that users of a code, that subsequently was found to contain an error, be notified of the error and requested to evaluate its effect on past analysis.
In addition, the procedure does not require that the corrective actions taken to correct an error found in one version of a code be applied to other versions.
(4)
Procedure NPG-0903-03 does not require that the computer program manual be a controlled document similar to the B&W Administrative Manual even though these manuals are used in safety analysis work.
(5)
Procedure NPG-0902-06 does not specify a method that provides traceability between Form P05-21177 (Computer Program Certification), Form PDS-21186 (Request for Programming Services), Program, and Program Manual (Revision) submitted for Full and Conditional Certification.
(6)
Procedure NPG-0902-06 does not specifically define the revision / version notation of the computer programs, i.e.
Is it Version A of TRAP 1 or Version 1A of TRAP; Version 2 of TRAP or Version 0 of TRAP 2, etc.
(7)
Stop 8 of Exhibit B to NPG-0902-06 states that the
" Technical Staff Engineer" (B&W representatives stated that this meant Technical Staff Manager) " Assign Technical Staff Engineer to evaluate the program."
Since a Technical Staff Engineer can initiate the request for certification it is not clear that the same person can perform this evaluation.
(8) There appears to be some confusion as to the extent of the applicability of procedure NPG-0402-01 (Processing of NPGD Prepared Calculations) with respect to the independent verification review and documentation of the development, revision, and certification of computer program.
. (9)
Procedure NPG-0902-06 does not require the docu-mentation of evaluations when detected program errors are determined not to have any safety significance.
2.
Implementation of Procedures a.
Inspection l
The developiaent and revision of the B&W computer program TRAP (Transient Reactor Analys:s Program) was selected by AB/NRR personnel for examination.
The inspector examined the official files maintained on this program i.e. twenty-five (25) 10Ms, ten (10) Form PDS-21186 (Request for Programming Services), eighteen (18) Form PDS-21177 (Computer Program Certification), program manual NPGD-TM-414 (TRAP 2-FORTRAN Program for Digital Simulation of the Transient Behavior of the Once-15 rough Steam Generator and Associated Reactor Coolant S stem), and NPGD-TM-338 (Computer Program Abstracts).
3 b.
Findings (1) The 10Ms examined covered a variety of subjects concerning the TRAP program e.g.
Basis for Conditional Release
~
of TRAP dated September 27, 1973; Conditional QA for TRAP dated April 26, 1974; TRAP Digital Simulation Comparison with Oconnee 1 Transient Data, May 6,1975; Problems with TRAP 2 dated November 25, 1975; Change needed in TRAP 1B dated June 28, 1976; Request for TRAP 2 Code Modification dated March 30, 1977; Errors in TRAP 1 & 2 dated January 12, 1978; etc.
(2) The forms PDS-21186 that were examined are part of a package (Request, Program, and Program Manual) submitted for Full and Conditional Certification.
This form requires a statement of the Program Parameters /Specifica-tion which shall contain a general description of the calculation to be evaluated, the actual equations and a suggested solution technique (if known), a description of the necessary program input and output, and sample test data sufficient to test the options requested (Section V of NPG 0902-06).
.. (3) The Forms PDS-21177 that were examined were for the Conditional Certification of various versions of the TRAP code i.e.
Version 1 of TRAP, Version 1A of TRAP, Version IB of TRAP, Version 2 of TRAP, Version 3 of TRAP 2, Version 3.2 of TRAP 2, Version 4 of TRAP 2, and Version 4.1 of TRAP 2.
Some of these versions had their Conditional Certification reissued several times.
(4) Three (3) examples of a single deviation were identified.
(See Notice of Deviation).
D.
Exit Interview An exit interview was held with management representatives on August 31, 1978.
In addition to those individuals indicated by an asterick in paragraph A, those in attendance were:
J. D. Agar, Manager, Contract Licensing i
C. A. Armontrout, Lead QA Engineer L. L. Barinka, Manager, Applieel Mathematics Unit P. N. Calpo, Manager, Engineering Applications Program Unit A. L. MacKinney, Manager, QA Department J. H. MacMillan, Vice President P. J. Motiska, Principal QA E'gineer W. E. Patscheider, QA Enginee D. H. Roy, Manager, Engineering Department R. H. Standt, Manager, Thermodynamics Unit B. W. Whitaker, Manager, General Services Department E.
A.. Womack, Manager, Plant Design The inspector sumnarized the scope and findings of the inspection.
Management comments were generally for clarification only, or acknowledgrant of the statements by the inspector.
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