ML20198F248
| ML20198F248 | |
| Person / Time | |
|---|---|
| Issue date: | 12/18/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Nordahl J SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| REF-QA-99900081 99900081-97-01, 99900081-97-1, NUDOCS 9812280077 | |
| Download: ML20198F248 (9) | |
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j NUCLEAR REGULATORY COMMISS!ON WASHINGTON, D.C. SneeH001 l
December 18, 1998 o
Mr. James H. Nordahl Senior Vice President and General Manager Siemens Power Corporation - Nuclear Headquarters 2101 Hom Rapids Road P.O. Box 130 Richland, WA 99352-0130
SUBJECT:
REVIEW OF RESPONSE TO NOTICE OF NONCONFORMANCE (INSPECTION REPORT 99900081/97-01)
Dear Mr. Nordahl:
We have completed our review of the Siemens Power Corporation (SPC)latters of February 24, 1998, "Siemens Power Corporation - Nuclear Division Responses to the Dernand for Information, Notice of Nonconformance, and Unresolved items (Inspection Report 99900081/97-01)," and " Reply to a Notice of Nonconformance (Inspection Report 99900081/
97-01)," and March 20,1998, "Supplernental Reply tc a Notice of Nonconformance (Inspection Report 99900081/97-01). Our review included an evaluation of other documents related to fuel design and PWR loss-of-coolant accident (LOCA) analysis submitted by SPC.
The staffs review of SPC's responses to the Notice of Nonconformcnce and Unresolved items j
identified in Inspection Report 99900081/97-01 is discussed in the enclosure to this letter. The staff's review of SPC's response to the Demand for Information will be discussed in separate correspondence.
j The staff has identified deficiencies in the SPC's corrective actions in response to Nonconformances 97-01-02 and 97-01-04, related to computer code modifications, verification and validation (V&V), and the schedule for revising and updating computer code documentation and V&V. The staff requests that SPC provide ad6tionalinformation to address those deficiencies, as indicated in the enclosure. These issues were discussed with your staff in a telecon on November 23,1998, and SPC agreed to provide the additionalinformation.
l The staff has also considered SPC's position that Nonconformance 97-01-03 should be withdrawn. After eva!uating the additionalinformation provided by SPC, the staff concurs with SPC's position, and has withdrawn the nonconformance. This item has, accordingly, been l
closed.
l SPC submitted the documentation required to close Unresolved items 97-01-06,97-01-09, and l
97-01-11 in August 1998. The staff is reviewing this information and expects to complete its
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f review by the end of this calendar year. Therefore, we will continue to maintain those issues i
i open until the staffs review is completed. Resolution of these items will be accomplished by issuance of safety evaluation reports (SERs) on Siemens' topical reports.
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Please provide the additional information requested to address the staff's concems within 60 days of receipt of this letter. ' Also, please note that full implementation of your corrective J actions may need to be evaluated during a future inspection.
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC's Public Document Room.
Sincerely, Sa/s/
muel J. Collins, Director -
Office of Nucleer Reactor Regulation -
Docket No.: 99900081 1
Enclosure:
As stated-4 cc: Mr. James F. Mallay, Director
~ Regulatory Affairu Siemens Power Corporation - Nuclear Division P.O. Box 130 Richland, WA 99352-0130 Distribution:
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC's Public Document Room.
Sincerely, Samuel J, Collins, Direct Office of Nuclear Reac r Regulation Docket No.: 99900081 i
Enclosure:
As stated cc: Mr. James F. Mallay, Director Regulatory Affairs
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1 Enclosure 1
Review of Siemens' Response to inspection Report 99900081L97-01 l 1: SPC-ND's Reolv to the Notice of Nonconformance 1.
Nonconformance 97-01-01-ANFB Correlation (Closed) l SPC identified the root causes for this nonconformance as: (1) lack of a sufficiently rigorous systematic process to identify and evaluate design changes that could affect fuel assembly performance or U.S. regulatory issues; (2) lack of a correlation development guideline to ensure a robust correlation development process; and (3) lack of a sufficiently l
rigorous systematic process for clarifying SER restrictions. The staff considers the root causes identified in SPC's response to this nonconformance to be accurate.
SPC has proposed several corrective actions to address this nonconformance. For the ATRIUM-10 design, SPC has developed an interim methodology using conservative l
assumptions, and has developed a revised critical power correlation specifically for this fuel design, which included additional testing. The new correlation and testing results have l
been submitted as SPC Topical Report EMF-1997 and Supplement 1 to EMF-1997. For ATRIUM-9, SPC submitted, in Topical Report ANF-1125, Appendix D, an interim methodology to establish a larger uncertainty for the ANFB correlation than had previously existed. Additional testing to expand the ANFB database for ATRIUM-9 has been performed and is under review by the NRC. A new correlation development guideline has also been completed and issued. Further planned corrective actions include development of a systematic process to identify and address new fuel design features that could produce behavior not covered by the current databases for SPC's methodologies.
The corrective actions proposed by SPC with regard to both ATRIUM-9 and ATRIUM-10 fuel designs are acceptable to the staff for addressing the nonconformance.
Please note that the above addresses only process issues. Specific technical issues are addressed separately as part of Unresolved item (URI) 97-01-09.
2.
Nonconformance 97-01-02-Software V&V (Open)
SPC identified the root causes for this nonconformance as: (1) lack of a sufficiently l
comprehensive goveming document addressing the software development record (SDR) form and its contents, including software validation and verification (V&V) requirements; (2) l vague and less-than-adequate governing documents addressing software development and validation requirements, which did not provide sufficient guidance regarding the form and content of SDRs; and (3) requirements for software V&V were not clearly spelled out, resulting in inconsistent V&V among development projects. The staff finds the root cause identification for this nonconformance to be comprehensive.
1
l The improvement in procedures to document code changes and V&V addresses one part j
of the nonconformance. However, the information supplied still fails to discuss how code V&V is to be performed. For example, there is no discussion of the establishment of standard test problems designed to confirm proper code functionality following code modifications. There also is still not an adequate definition of what constitutes a " major" code modification as compared to a " minor" modification. These observations are supported by the lack of a work practice document relating specifically to code V&V, as shown in Table 1.5-1 (p.18 of Attachment I, entitled " Work Practice Index"). The staff thus
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concludes that the proposed corrective actions do not fully address this nonconformance, i
and additional information from SPC is needed to demonstrate that corrective actions will address these concerns. The staff notes that the corrective actions described for Nonconformance 97-01-03 appear to indicate that a procedure has,in fact, been developed to help guide SPC's implementation of 10 CFR 50.46 reporting requirements. If this document also addresses V&V related to these two classes of changes, those procedures should be reflected in the response to this nonconformance, as well.
In addition to the above, the staff notes that SPC has provided a schedule for revising / updating code documentation and V&V. Some of the activities are scheduled for l
completion as late as 2005. The staff believes that such a protracted schedule may be l
inconsistent with Appendix B requirements for prompt corrective actions. Therefore, SPC l
should provide additional information to address the staff concerns with regard te the code documentation schedule. This information should provide assurance that licensees using SPC's LOCA evaluation models and referencing SPC's documentation can meet regulatory requirements as delineated in Part 11 of Appendix K to 10 CFR Part 50.
i 3.
Nonconformance 97-01-03-10 CFR 50.46 Reporting (Withdrawn)
The staff has reviewed SPC's' response to this item, and in light of the additional information provided by SPC, has decided to withdraw the nonconformance. The staff commends SPC for recognizing that the manner in which the effects of code changes or l
errors are evaluated and reported should be improved, and for undertaking improvements in these areas. SPC has formalized procedures for reporting the effects of changes to or errors in acceptable evaluation models, including distinguishing between " major" and
" minor" code changes and preparation of 30-day and annual reports on code changes and errors per the requirements of 10 CFR 50.46. The staff believes that the improvements in procedures should address the factors underlying the problems identified for this item in the inspection report. With the withdrawal of the nonconformance, this item is closed.
4.
Nonconformance 97-01-04-Code Control Requirements (Open)
This nonconformance, to some degree, overlaps the findings in 97-01-02; this is indicated in SPC's response as well, since the first root cause identified for this item is the same as for 97-01-02. The deficiencies noted in the response to that nonconformance are l
applicable here, as well.
L l
The other issues related to this nonconformance have been appropriately identified and characterized as to root cause, which is indicated by SPC as deficiencies in guidance 2
1
document EMF-608, Revision 14, specifically (1) failure to meet industry standards on the level of V&V required; (2) lack of a requirement to establish a baseline for each code from the original V&V performed for the code; and (3) failure to include, by either reference or discussion, the existing SPC-ND processes for code archiving, code modification, or code error reporting. SPC's corrective actions for these deficiencies have included revision of procedures for computer code control (EMF-608, Revision 16, issued February 1Nd) to be consistent with industry standards, which includes sections related to software V&V requirements and results. The new procedures also support establishment of a baseline for each code against which future modifications can be assessed. An earlier revision of EMF-608 (Revision 15, issued November 1997) addressed the issucs of code archiving, modification, and error reporting. Additional improvements to SPC's code control activities include issuance of a new guideline on BWR LOCA core reflood analysis, institution of periodic reviews of software control requirements, and a planned (December 1999 implementation) automation of data transfer between the codes used for BWR LOCA analyses to improve consistency of reflood calculations. Except for the deficiencies noted in the first paragraph of this item, the corrective actions related to this part of the nonconformance are acceptable to the staff.
5.
Nonconformance 97-01-05-Engineering Training (Closed)
SPC identified the root causes for this nonconformance as: (1) failure of Engineering management to establish a standard policy or administrative control requiring each department to define qualification standards needed by analysts to perform work; (2) failure to define standards related to the means by which an analyst should obtain necessary qualifications; and (3) failure to establish assessment or documentation requirements to demonstrate analysts' proficiency to perform assignments. SPC acknowledged its dependence on an experienced staff to perform engineering tasks, with development of new employees through on-the-job-training and mentoring by experienced staff. SPC failed to update its training philosophy to reflect changes in: (1) how engineering tasks are performed; (2) makeup and skill level of the workforce; and (3) licensing requirements.
SPC has implemented corrective action by issuance of a new work practice, P104,105,
" Personnel Training and Qualification," issued January 1998, which provides a method and requirement to (1) determine tasks assigned to engineers; (2) define the knowledge, skills, and abilities (qualification requirements) needed by analysts to perform engineering-related tasks; (3) design a training program to qualify an analyst to perform an engineering task; and (4) establish a procedure for evaluating and recording the effeciiveness of such training. The work practice also specifies training implementation as a function of an employee's current proficiency. The resolution plan appears to be appropriate. Of particular interest to the staff will be evaluations by SPC of Engineering and Research &
Technology staff to determine what training they should receive, and determination of qualification requirements for software developers and engineers.
s 3
i 11: SPC-ND's Response to Unresolved items (URI) 1.
URI 97-01-06-Semiscale Pump Data (Open)
The NRC requested additional information from SPC regarding the use of data from testing in the Semiscale facility to model pump performance during LOCAs, rather than data from 1
i actual (large-scale pumps), as required by 10 CFR 50, Appendix K. This open item will be addressed by modifications to SPC's LOCA model, implementing an advanced pump model verified using large-scale pump data. The modified model was submitted for staff review in August 1998. This item remains open pending review of the modifications. The l
review is scheduled to be completed by the end of this calendar year.
2.
URI 97-01-07-15 x 15 Scaling (Closed) l SPC's reflood heat transfer model in its PWR LBLOCA methodology was based on testing l
in SPC's Fuel Cooling Test Facility (FCTF) in simulated (electrically heated) 17 x 17 PWR l
fuel bundles. The NRC requested additionalinformation to demonstrate that the model based on FCTF testing, combined with a scaling methodology developed by SPC, produces conservative results for PWR fuel bundle geometries other than 17 x 17. SPC l
has submitted a comparison of the 17 x 17-based FCTF correlation with the scaling i
methodology applied, to CCTF reflood data, which uses a 15 x 15 fuel rod simulator i
bundle. The resuit's of this comparison indicate that the FCTF correlation and the SPC scaling methodology conservatively predict CCTF heat transfer data, and verify that the SPC methodology can be applied to fuel types other than SPC 17 x 17 fuel. The staff therefore considers this item to be closed.
3.
URI 97-01-08-FCTF Heat Transfer Correlation (Closed)
The NRC was unable to verify during its inspection that the data from the 17 x 17 test data (see URI 97-01-07 above) was analyzed using a valid daia analysis code. Additional information was requested to demonstrate the data analysis code had been properly validated, or alternatively, SPC could perform a complete reanalysis of the data using a validated code. SPC has reanalyzed the FCTF heat transfer data that comprise the basis of the heat transfer correlation with a data reduction code that is documented and verified.
The results show that the original data reduction cooe gaVE. Correct results. The staff therefore considers this item to be closed.
4.
URI 97-01-09-ANFB Correlation (Closed)
The NRC requested additionalinformation to demonstrate the adequacy of SPC's application of the ANFB correlation to new fuel designs, namely ATRIUM-9 and ATRIUM-10. This technical issue is related to Nonconformance 97-01-01, discussed previously. As discussed in the corrective actions taken for Nonconformance 97-01-01, reports have been submitted to address application of the ANFB correlation to ATRIUM-9 and ATRIUM-10 fuel c'esigns. The NRC staff has completed its review of the reports on ATRIUM-9 and ATRIUM-10 applications and has determined the new correlation to be j
acceptable. The staff therefore considers this item to be closed, i
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5.
URI 97-01-10-St. Lucie Cycle 14 Analysis (Closed)
This issue involves the use by Florida Power & Light (FPL), the licensee for St. Lucie Unit 1, of an approved Wectinghouse neutronics methodology to supply input parameters to the approved SPC safety analysis methodology. FPL evaluated this issue under 10 CFR 50.59 and concluded that there were no resulting unreviewed safety questions (USQs) conceming this approach. SPC has committed to develop a formal procedure to create a casign interface document to define this process for future reloads. Since the actions in question were those of the licensee and not SPC, the staff considers this issue closed for the purposes of this inspection report.
6.
URI 97-01-11-Resinter Density Treatment (Open)
The NRC requested additional information to describe how SPC's Tonical Report 3
XN-NF-81-58(P)(A), conceming the RODEX2 computer code, and the associated safety evaluation report (SER), address the use of the average resinter densification value rather than the largest mean resinter densification value when determining the resinter density to be used when modeling fuel behavior during LBLOCAs. SPC has committed to submit a revised version of the RODEX2 computer code, which implements resinter density and cladding creep models that conform to Regulatory Guide 1.126 recommendations. The staff received this submittalin August 1998. The staff considers this approach to be acceptable; however, this item remains open pending completion of the staff's review of the revised RODEX2 code. The staff expects to complete its review by the end of this calendar year.
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