ML20149G940

Responds to NRC Re Violations Noted in Insp Repts 50-254/87-30 & 50-265/87-30.Requests Conclusions Be Reconsidered.Disagrees That Computer Programs Cited in Notice of Violation Not in Noncompliance w/10CFR50,App B

ML20149G940
Person / Time
Site:	Quad Cities
Issue date:	01/22/1988
From:	Butterfield L COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20149G930	List: ML20149G926 ML20149G940
References
4119K, NUDOCS 8802190024
Download: ML20149G940 (4)

Text

__

', N CommonweeMh Edloon  !

/ One Fr.1 National Plaza, CNeago thros O J Address Repy to Post Omco Boa 76F pj g pgt$

v Cheogo,innos 60690 0767 -- p ph__,Q6<g,7 ,

Janua4y 22, 1988 *

, i Q._ .w ,

4G 4A- / 6 d.__i _u .

Mr. A. Bert Davis  :

Regional Administrator fg .

U.S. Nuclear Regulatory Commission i Region III  !

799 Roosevelt Road Glen Ellyn, IL 60137 subject: Quad cities Station Units 1 and 2 Response to Inspection Report Nos.

50-254/87030 and 50-265/87030 BC Docket Wos. 50-254 and 50-265

Reference:

J.J. Harrison letter to Cordell Reed dated December 17, 1987, transmitting the subject Inspection Report.

Dear Mr. Davis:

This letter is in response to the inspection conducted by Messrs. T.

Tella and R. W. Sutphin from October 26 through November 5, 1987 of activities at Quad Cities Nuclear Power Station. The referenced letter indicated that certain activities appeared to be in noncompliance with WRC requirements. The Connonwealth Edison Company response to the Notice of Violation is provided in the Attachment. On January 19, 1988, Mr. J.J. Harrison granted an extension for this response from that date to January 22, 1988.

For reasons discussed in the Atachment, Ccessonwealth Edison does not agree that the computer programs cited in the Notice of Violation are in noncompliance with 10 CFR 50, Appendix B, Criterion V. We, therefore, request that you reconsider your conclusions in light of the information provided in this response.

If you have any further questions regarding this matter, please direct them to this office.

Very truly yours, L. D. Butterfield Wuclear Licensing Manager la Attachment ec: T. Ross - WRR WRC Resident Inspector - Quad Cities 1

4119K g 2 9 933 88021,o024 8s0211 PDR ADOCK 05000254 g DCD

I i

I

+ ,

ATTACHMENT t

s .

{ COMMONWEALTH EDISON COMPANY  !

(  !

4 WESPONSE TO NOTICE OF VIOLATION

- l As a result of the inspection conducted October 26 through November 5,  !

! 1987, the following violation was identified.  !

p 4

6 l

ITRM or VroLATroN

{ .

l 10 CFR 50, Appendix B, Criteria V, as implemented by Commonwealth Edison l Company (CECO) Topical Report CE-1-A, requires in part, that activities

~

q affecting quality shall be prescribed by documented instructions, j i procedures or drad ngs of a type appropriate to the circumstances. i

[

] Contrary to the above, the licensee failed to provide procedural and (

) quality controls that ensure consistence with the design, software  !

, security, and configuration management for the computer software and i l documentation developed prior to 1986 and still used to cateulate i

reactivity ancealies which satisfy technical specification requirements.  !

i l l  !

VIOLATION APPEAL AND ADDITIONAL INFORMATION  ;

}  !

Quad Cities takes exception to the stated violation because of the  !

l significant procedural and quality checks that the referenced cceputer j i software underwent before being implemented. It is Commonwealth Edison's ,

! belief that the concerns raised about software control were properly  ;

i addressed and that, in fact, there were appropriate procedural and quality l 4 controls for the cceputer sof tware "ANOM" and "ANOMVP" developed in 1981.  !

i The procedures governing the implementation of this software, although not  !

i as sophisticated as the present computer r,0ftware control program, were  ;

j adequate for the control and quality check necessary in 1981, and l

. certainly adequate for the simple, short programs referenced in the  !

{ violation that had previously existed on a Monroe calculator. These j j calculations are performed by the computer programs for convenience only, i

A manual method is part of the Ceco BWR nuclear engineer ttaining arv*. [

] certification program and prior to implementation of the computer and i j calculator programs, it was routinely used. )

l I

The current software control program in place at the station reflects the j

! requirements of the Quality Assurance Manual, Quality Procedure No. 3-54 j

! (QP3-54). Design Control for Operations - Digital computers and software. ,

) This Quality Procedure was developed to provide company-wide standards and I j practices for all applicable new soft-ware and changes to existing I software. It applies standards for desi.gn, verification, validation, i

1 i

i i

i

{.

l

. l i

testing and implemention of new computer programs and changes to existing cceputer programs. The implementation of QP3-54 at the station was an i l enhancement of existing quality verification methods and documentation for  ;

computer software, not a corrective measures program for erroneous  ;

) computer software created before QP3-54.

l The programs "ANoM" and "ANoMVP" were developed in 1981 under Station l procedure QTP 1113-2, Revision 1 - April 1978, Control and Documentation l of New and Modified Nuclear Fuel Performance Safety-Related Calculations  !

and Data. This procedure required an engineering review of the documenta- [

tion of the program specification, the list.ing of the program and data, 1 the program procedure, and the benchmark testing which was performed. It (

, also required that an on-site review (OS9) be performed prior to approval  ;

for use. All of the requirements of QTP 1113-2 were satisfied for "ANoM" [

j and "ANOMVP" and the documentation has been made available for review.  ;

] And although the new QP3-54 requirements differ greatly in specific l l content frs. OTP 1113-2, the activities performed in 1981 for "ANoM" and

[

f "ANoMuP" are consistent with the general intent of assuring an acceptable  :

] end product. The programs as they exist today are correct and their  !

j accuracy has been ensured through the review performed under QTP 1113-2 in  !

j 1981 which Ceco believes was "appropriate to the circumstances".  !

l Quad Cities Station fully intends to comply with the requirements of  !

QP3-54 in the future as it has in the past. That is, any applicable new (

or revised software will be handled according to the requirements of i QP3-54 and the stations implementing procedures.

l CENERAL DISCUSSION.OP Ceco SOFTVARE CONTROL Although Ceco believes that the reactivity anomaly programs and other l fuel-related software developed and documented per QTP 1113-2 were  ;

controlled properly, Quad Cities station will initiate a review to assure i

that other pre-QP3-54 software which may still be used for Technical l Specification surveillance has also been treated with a reasonable level  ;

of verification and validation, similar reviews will be performed for l other Ceco nuclear stations with the 1.ssistance of appropriate supporting i departments. In scue cases this type of review has already been performed  !

as a part of the initial startup testing program (Byron and Braidwood) or I is partially complete as a result of previous initiatives (zion and l Dresden). If any application programs that are currently being used to  !

assure Technical specification compliance are found deficient with respect  :

to a reasonable level of documented quality verification, supplemental  ;

work will be performed to address any such deficiencies. l In general, a "reasonable level" for these older applicatiod programs l would have included (as a minimum) documented verification that the code '

produced results equivalent to a hand calculation or other verified method. Ceco believes that such basic bench testing has been performed on all sof tware still used to demonstrate ecapliance with Technical specifications.

I l

i I

i

)

!o 1 .

l l

I Due to the acceptable performance of all such software to date, this l effort will be performed on a priority below that of more critical I

computer support activities, including compliance with QP3-54 for new software or changes to existing software. Our estimated schedule for completion of these reviews is the fourth quarter, 1988.

In the past four years, CECO has devoted significant resources to the implementation of an effective software quality assurance program for new i codes and changes to existing codes. The development of QP3-54 and

! procedural implementation alone required well over eight person-years.

l This excludes the significant additional resources expended to actually apply QP3-54's more rigorous standards to post-1985 software. Ceco does not believe that attempting to fully upgrade all software generated in the previous 15 to 20 years to these current standards is required by existing regulations: nor would the resultant diversion of substantial resources be prudent or justified to achieve the small incremental benefit for software which has withstood the test of time and is currently functioning properly, f

Commonwealth Edison requeste your reconsideration of this issue for the reasons stated above.

i i

i 1

4119K j l

l . _ _ .

_ _ - .