ML20198G933
| ML20198G933 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1998 |
| 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, EA-97-495, NUDOCS 9812290199 | |
| Download: ML20198G933 (5) | |
Text
,
d
[j
- WO k UNITED STATES g
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enmaa nnny y December 21, 1998 EA 97-495 Mr. James H. Nordahl Senior Vice President and General Manager Siemens Power Corporation - Nuclear Headquarters 2101 Horn Rapids Ruad P.O. Box 130 Richland, WA 99352-0130
SUBJECT:
REVIEW OF RESPONSE TO DEMAND FOR INFORMATION (INSPECTION REPORT 99900081/97-01)
Dear Mr. Nordahl:
We have completed our review of the Siemens Power Corporation (SPC) letter of February 24, 1998, "Siemens Power Corperation - Nuclear Division Responses to the Demand for Information, Notice of Nonconformance, and Unresolved items (Inspection Report 99900081/97-01)." The staff evaluation of SPC's responses to the Notice of Nonconformance and Unresolved items were discussed in our letter of December 18,1998.
This letter provides our evaluation of SPC's response to the Demand for Information (DFI).
In the U. S. Nuclear Regulatory Commission's (NRC's) letter of October 27,1997, from me to David G. McAlees, Senior Vice President and General Manager, Siemens Power Corporation -
Nuclear Division, which accompanied Inspection Report 99900081/97-01, the NRC issued a DFl requiring SPC to provide: (1) an explanation why the NRC can have confidence that SPC will comply with NRC-approved generic design criteria without prior NRC review and that SPC will identify and clearly communicate issues that should receive NRC attention, particularly as rei, ad to revisions to NRC-approved LOCA evaluation models and new fuel designs; (2) a de.nonstration that SPC accident analysis codes are verified, validated, and documented in I accordance with the requiremen's of 10 CFR Part 50, Appendix K, Section ll, and g 10 CFR Part 50, Appendix B; (3) assurance that new or revised analytical models will have adequate and appropriate quality-assured databases to support their use in SPC's analysis codes; and (4) SPC's corrective actions as appropriate to remediate the issues discussed in the inspection report.
Attschment I of SPC's February 24,1998, letter specifically concerned SPC's actions .7 (completed, in progress, and planned) to address the issues discussed in the DFl. The staff found that the information provided and actions undertaken as discussed in Attachment I, should, when felly implemented, address the staff's technical concems as discussed in the previous paragraph. With respect to item (1), these include the safety evaluation report (SER) compliance review; fuel design methodology reviews; improvements to the engineering design process and training program; and improved quality assurance (QA) oversight. For item (2),
actions include improvements to defect evaluation and reporting (per 10 CFR 21); reporting of code revisions; identifying, c!arifying, and managing issues related to SER restrictions and 9812290199 981221 PDR GA999 EMVEXXN f 99900081 PDR
-l 3f - / z w,VDNd
- S S bb&f
Mr. James H. Nordahl conditions; and improving and updating code documentation. For item (3), SPC has developed new guidelines for correlation development; instituted a peer review process, and improved the design review process. The staffs December 18,1998 letter concerning the nonconformances and unresolved items in the inspection report addresses item (4), corrective actions.
Overall, the staff observes that the corrective actions (both taken and planned) to (1) establish increased management accountability, (2) improve the error identification and evaluation process, and (3) provide more effective quality oversight, have the potential, when fully implemented, to directly address the staff's concerns. The staff believes the addition of new and separate positions for Vice President (VP)- Engineering and VP - Quality and Regulatory Affairs could, in principle, provide a more focused approach to management control and QA oversight. The establishment of other senior positions, such as Product Licensing Managers, an Engineering Quality Performance Manager, and a Director of Regulatory Affairs, could also support SPC's stated goal of achieving industry standards of regulatory compliance.
However, earlier this year, the Office of Nuclear Material Safety and Safeguards (NMSS) issued a Confirmatory Action Letter (CAL) to SPC related to QA deficiencies in activities related to fuel transportation casks, i.e., implementation of the requirements of 10 CFR 71, Subpart H. The CAL raises concerns regarding the effectiveness of SPC's actions. Although SPC implemented a separate QA program for its activities related to 10 CFR 71, the principles of QA in 10 CFR 50, Appendix B, and 10 CFR 71, Subpart H, are essentially the same. Issues discussed in the NMSS CAL are similar in nature to the deficiencies cited in NRR's inspection report and the DFI, and appear to indicate serious programmatic problems with QA at SPC.
NRR is concemed that these programmatic problems may negatively affect the ability of SPC to carry through with its implementation of the improved processes discussed above.
In view of the QA deficiencies identified by both NRR and NMSS, and the resulting need for broad, programmatic QA changes by SPC, the staff will closely monitor the progress and effectiveness of SPC's corrective actions. If major programmatic problems persist, or corrective actions are judged to be ineffective, the staff may take further action to ensure SPC's compliance with 10 CFR, Appendix B requirements.
l i .
- Mr. James H. Nordahl l 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,
/s/
Samuel J. Collins, Director Office of Nuclear Reactor Regulation Docket No.: 99900081 I
cc: Mr. James F. Mallay, Director Regulatory Affairs Siemens Power Corporation - Nuclear Division P.O. Box 130 Richland, WA 99352-0130 Distribution:
RIDS lE:09/ Central Files PUBLIC EWang SCollins Plain l DRCH R/F HQMB R/F Whitebook SCBlack WTroskoski Madams BSheron 01 GThomas ETen Eyck OGC(Longo) OE TReis JDonohew PEng EMerschoff RScarano CPaperiello WKane JThoma HThompson PMs for Millstone 2, Grand Gulf, Dresden, St. Lucie, Robinson, Fitzpatrick, Susquehanna, WNP2, Quad Cities, LaSalle, Turkey Point, Comanche Peak, Palisades, Shearon Harris 1 DOCUMENT NAME: G:\Cwalina\siemens.dfi
- See previous concurrence Ta fr.ceive a copy of this document, Indicate in the box: "C" = Copy without enclosures "F" = Copy with enclosures "N" = No copy OFFICE HOMB/DRCH lC DssAlsRXB lC DssAlsRXB lC HoMB/DRCH lC HOMB/DRCH lC NMss/sFPO lC NAME GCwahna* Alevin' TCollins' RGramm* sCBlack* sFshankman*
DATE 8/17/90 8/10/98 8/11/98 8/17/98 8/19/98 8/2f76D f A )
<NR W /
OFFICE DssA l DRCH l ADT l OL_ l - l ll NAME GHolahan* RLspessard' ll Bsheron* V' D3C51iins I DATE 8/28/98 8/20/98 9/01/98 8/A N 121%)0 /98 ll
^
OFFICIAL RECORD COPY l
l l
1 1
l l
l L Mr. James H. Nordahl l l
i in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copf M % letter will be placed in the NRC's Public Document Room.
Sincerely, I
\
\ Samuel J. Collins, Director
/
Docket No.: 99900081 '\ Office of Nuclear Reactor Regulation
/
\
\\
cc: Mr. James F. Mallay, Director 'N Regulatory Affairs ,, y Siemens Power Corporation - Nuclear Divisior)
P.O. Box 130 \
Richland, WA 99352-0130 'N 1
Distribution:
EWang 'x SCollins Plain RIDS lE:09/ Central DRCH R/F Madams HQMB R/F Files [PUBL!C Whitebook \ SCBlack WTroskoski
,' BSheron 01 '\ GThomas ETen Eyck OGC(Longo) OE TReis \JDonohew PEng EMerschoff RScarano CPaperiello Kane JThoma HThompson PMs for Millstone 2, Grand Gulf, Dresden, St. Lucie, Robinson, Fitzpatrick, Susquehanna, WNP2, Qua,d Cities, LaSalle, Turkey Point, Comanche Peak, Palisades, Shearon Harris DOCUMENT NAME: G:\Cwalina\siemens.dfi
- See previous concurrence T receive a copy of this document, indicate in the box: "C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy OFFICE HoMB/DRCH lC DSSA/SRXB lC DSSA/SRXB lC HoMB/DRCH lC HoMB/DRCH lC NMSS/SFPO lC NAME GCwalina* Alevin' TCollins* RGramm* SCBlack* SFShankman*
DATE 8/17/98 8/10/98 8/11/98 J/17/98 8/19/98 is 8/21/98
/s V IA OFFICE DSSA .o ,l DRCH l ADT h l OE\ / l "A @ R/D l ll NAME GHolaharM W RLSpessard' ll BSherg \/ MJCollins 8@8 DATE 8/20/98 )[ /98 8/ //M # 8/ /98 ll OFFICIAC RECORD COPY 4 l /
l i
i
s Mr. James H. Nordahl <
t
- in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this I tier will be placed in the NRC's Public Document Room.
Sincerely, Samuel J. Collins, Directo Office of Nuclear React ReptJation !
Docket No.: 999000F1 cc: Mr. James F. Mallay, Director ;
Regulatory Affairs Siemens Power Corporation - Nuclear Divi
- n P.O. Box 130 g gi g gp/ ;
s ibu i Nb) crf 'N E & fyd M RIDS lE:09/ Central Files PUBLI EWang SCollins Plain DRCH R/F HQ R/F Whitebook SCBlack WTroskoski Madams /NMSS Sh on 01 GThomas W kw NA SS OGC(Longo) TReis JDonohew fI. Kq /VAFF
' PMs for_ Millstone 2, Grand utf, Dresden, St. Lucie, Robinson, Fitzpatrick, Susquehanna, WNP2, Quad Cities, Las e, Turkey Point, Comanche Peak, Palisades, Shearon Harris DOCUMENT NAME: G:\Cwalina semens.dfi
- See previous concurrence To receive a copy of this document,I cate in the box: "C" = Copy without enclosures E" = Co py with encLaures "N" = No copy j OFFICE HOMS/DBCH lC DgSA/SRXJL l C DSSA/SRXB lC HOMB/DRCH l C- HOMB/DRCH l C, E NMSS/SFP@ G NAME G@is 4LeviM TCollins--7tg RGramm {l,6 SCBlack ~6h lSFShankmanMpf DATE 8/ / 7 /98 / 8// D M 8/ // /98 8/1 1 /98 8/ 14/98 l8/2/ /98 '
/ >
OFFICE DSSA / l DRC 7 l ADT l OE l NRR/D l ll NAME GHolahap' RLSdhasard l BSheron SJCollins DATE 8/ /Sif 8/k /98 8/ /98 8/ /98 8/ /98 ll
,/ oFFictAL RECORD COPY Y
l l
l
- _ _ _ _ _ _ _ . .