ML20199E285

Insp Rept 99900404/97-02 on 971117-21.Noncompliance Noted. Major Areas Inspected:Quality Assurance Program of Record in AP600 Ssar

ML20199E285
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U. S. NUCLEAR REGULATORY COMMISSION  !

OFFICE OF NUCLEAR REACTOR REGULATION Report No.: 99900404/97 02-Organization: Westinghouse Elcetric Corp, ration Nuclear and Advanced Tecnnology Division Pittsburgh, Ponnsylvania 15230

Contact:

Mr, Nicholas J. Liparuto, Manager Nuclear Safety end Regulatory Activities Nuclear Indust,y Nuclear steam suppfy system design, components and Activity: services Date: November 17 21,1997 Inspectors: Rober1 Pettis, Jr.,HOMB/DRCH Je9n Peralta, HOMB/DRCH Edward Throm, SCSB/DSSA Ralph Landry, SRXB/DSSA Summer Sun, SRXB/DSSA ,

Joseph Staudenmeier, SRXB/DSSA Lambros Lois, SRXB/DSSA Alan Levin, SRXB/DSSA -

William Huffman, PDST/DRPM Approved: Robed A. Gramm, Chief Quality Assurance and Safety Assessment Section Quality Assurance, Vendor inspection, and Maintenance Starch .

Division of Reactor Controls and Human Factors 9902020121 990128 PDR GA999 EMWEST 99900404 PDR ,,

.- i 1 INSPECTION

SUMMARY

The purpose of the inspection was to determine if quality activities performed as part of the dsgn of the AP600 Advanced Light Water Reactor (ALWR) were conducted under the appropriate provisions of the Westinghouse 10 CFR Part 50, Appendix B, quality assurance program of record in the AP600 SSAR.

The inspection bases were as follows:

Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of the Code of Federal Reaulatlos (10 CFR Part 50).

ANSI /ASME NOA 1 1989," Quality Assurance Program Requiremenst for Nuclear Facilities,"

Edition through NCA 1b 1991 Addenda.

WCAP 8370, Westinghouse Electric Corporation Energy Systems Business Unit / Power Generation Businces Unit - Quality Assurance Plan," Revision 2 (April 1992).

AP600 SSAR,Bevision II, Section 17.3, " Quality Assurance."

WCAP 12600, Revision 2, dated December 1993,"AP600 Quality Assurance Program Plan."

During the inspection, the NRC inspection team Identified the following instances where Westinghouse failed to conform to NRC requirements:

1,1 Nonconformances Nonconformance 99900404/97 02 01 was identified and is discussed in Section 3.2,3.3 and 3.5 of this report.

Noncoaformance 99900404/97 02 02 was identified and is discussed in Section 3.4 and 3.6 of this report.

1.2 Unresolved item Unresolved item 99900404/97-02 03 was identified and is discussed in Section 3A and 3.6 of this report.

2 STATUS OF PREVIOUS INSPECTION FINDINGS 2.1 Nonconformance 99900404/35-0101 (closed)

Contrary to the provisions of Engineering Procedure AP 3.11. "AP600 Testing," of Westinghouse Electric Corporation AP600 Program Operating Procedures Manual .

(WCAP 12601), Revision 1, dated April 1,1995, Section 5, " Instrumentation Requirements," of L 2

Test Specification: Largo Scale Past vo Containment Cooling Tost, AP600 Document Number PCS T1P 002 (WCAP 13267), Revision 1, dated December 1991, did not occurately reflect the ins'mmentation that was procured and installed in the PCCS Largo Scale Test Fac;lity.

The team reviewed Section 5 of WCAP 13267 and determined thr t the instrumentation listed was not an accurato reflection of what was procured and installed in the test facility. The test I specification had not boon revised sinco December 1991. Westinghouse revised PCS T1P 002  !

to reflect the final configuration of the Largo Scale Test Facility. As proventivo actions, I WestMghouse revised lost specifications for subsequent losts (including the Core Make Up, Long Torm Cooling, and Full-Height / Full Power tests) to reflect the final configuration of the respectivo facilitios. The team vorified that thoso actions had boon completed and documented.

2.2 Nonconformanco 99900404/95 0102 fclosed)

Contrary to procoduro DP 5.0, Revision 3, " Instructions, Procedures and Drawings," of Westinghouso Electric Corporation Nuclear and Advanced Technology Division (NATD) Quality Assuranco Program Manual (WCAP 9565), Reviskm 1, no proceduto or instruction was available or utilized for dolormining the as built olevaAns arn. dimensions of the PCCS Largo-Scalo Tests. The critical dimensions of the Largo Scale Test Facility were to be identified by the Containment and Radiological Analysis group. No records of identification of the critical dimensions by this group woro available.

Although critical dimensions for the CMT test woro verified using AP600 Document No.

MT01 T1P 003,"AP600 CMT Test Facility Piping Dlmonsional Characterization Proceduro,"

Revision 0, dated April 20,1993, no such proceduro existed for the dimensional characterization of the Largo Scalo Test facility. The Largo Scalo Test critical dimensions were taken prior to April 20,1993. Thorofore, thoto was no record of how the dimensions were taken or if the Containment and Radiological Analysis group had approved the critical dimensions.

t Specified critical dimensions woro re-measured by Westinghouse in accordance with written procedurcs. As proventivo actions, AP600 Proceduto AP 3.11. "AP600 Testing "was revised to requito that a written proceduro be used to obtain the specified critical dimensions of safety-related AP600 test facilities in uso subsequent to tho PCCS Largo Scale Tests. The team verified that these actions had boon complotcd and documented.

P. 3 Nonconformance 99900404/95-0103 fclosod)

Contrary to Program Operating Proceduto AP 7.1," Supplier Evaluation, Audit and Approval,"

Revision 2, of WCAP 12601 and Proceduto DP 7.0,

• Control of Purchased items and Services,"

Revision 7, of WCAP 9565, the audit conducted by Westinghouse at Alden Research Laboratory, Inc. (Alden Rosearch) on March 4,1992, and lator confirmed as acceptable for AP600 design cortification activities by the Energy System Business Unit (ESBU) Projects Quality Assurance organization on October 20,1994 (Report / File No. PQA 94-0032, dated October 14,1994) did not provido adequato objectivo evidence that Alden Research was a supplior of calibration services as a Basic Component (as defined and used in Part 21 to Title 10 of the Codo of Fedotal Rooulations (CFR)) nor did it demonstrate the acceptability of Alden Rosearch's technical and quality program capabilitios with respect to 10 CFR 21 requirements.

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Westinghouso performed an audit of Alden Roscarch on May 25,1995. The audit found that while implomontation of Aldon's quality assuranco program nooded improvement in sevr ral areas, no findings woro identified that would impact the calibration activities performed iv support the AP600 testing program. Based on intomal and custorner audits, Westinghouse considorod this issue to be an isolated occurrence for which continued implomontation of the ESBU OA program is relied upon to provent recurrence. Findings from the audit of Alden woro followod to resolution through the existing ESBU supplier audit process. The team verified that thoso actions had boon completed and documented. Based on the limited scope of calibration .

services as a basic componont performed by Alden Research, and based on Westinghouse's conclusions that no audit findings identified impacted the calibration activities performod to support AP600 tosting, the team agrood that correctivo actions taken by Westinghouse woro appropriato.

2.4 Nonconformanco 99900404/95-02 01 fclosod)

Contrary to Section 9.0, 'Ouality Assuranco Requiromonts' of WCAP 14112, ' Automatic Doprossurization System Test Specification (Phase B1),' Revision 2, and Section 7.0, 'As Built Rorords" of ENEA document AP600 GO9402," Quality Assuranco Plan

Description:

AP600 Test Program Conducted at the VAPORE Plant in ENEA Cassacia (Phaso B)," Revision 2, as built drawings, portaining to the ADS Phaso B tosts ihat characterize the features which influence thormal hydraulic and structural paramotors for code validation and calculation methodology vorification efforts, had not boon generated for AP600 ADS Phase B testing at VAPORE.

Modifications to the VAPORE test facility, necessary to support AP600 ADS design cortification testing, woro performed by ANSALDO S.p.A. under contract to Westinghouse. On November 29,1994, Westinghouso placed a contract with ANSALDO to provido as built documentation of the ADS test loop at the ENEA's VAPORE test facility. Westinghouse stipulated that ANSALDO provido one full set of as built drawings (comprising P&lD,line list of principal flow paths, valve list, ADS loop layout drawings, ADS loop isornetric drawings, ADS loop platform, and ADS loop support drawings) covering both ADS Phasos B1 and B2 configurations. Westinghouse intended to include those drawings as part of the as built records packago for AP600 VAPORE Phaso B testing.

During the inspection, however, the team found that as-built drawings, as defined and stipulated in WCAP 14112, and in AP600-GO9402, had not been generated for AP600 ADS Phase B testing at VAPORE.

Westinghouso had identified this issus during a June 6 9,1995 audit of ENEA. However, since ANSALDO was responsiblo for generating the as built documentation for the facility, Westinghouse initiated additional actions to resolvo this issue accordingly. A Westinghouso review of all documentation at ANSALDO officos in Genoa, Italy, on July 19 and 20,1995, revealed that ANSALDO had used a combination of shop drawings and field measurements to croato their as-built drawings. Based on an assessment of the olements used to define the as-built configuration of the ADS test facility as well as the supporting documentation on the procuromont and fabrication of the piping sections, Westinghouse concluded that the as built documentation was in compliance with AP600 project rnquirements and that the requirements of AP600-GO9402, Revision 2, had boon satisfied. Westinghouse added that the process of ostablishing the final test configuration dimensional characteristics had been performed in a controlled manner by ANSALDO. Westinghouse completed this assessment in August 2,1995.

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The team reviewed a summary of Westinghouse's assessment activities at ANSALDO and concluded that appropriate actions had been taken to resolve this nonconformance.

2.5 Unresolved item 99900404/95 02 02 (closed)

During the inspection, the team reviewed the VAPORE test facility calibration records which provided evidence of traceability to the appropriate ENEA controlled SIT certified standards.  !

This review also provided evidence of the adequacy of the facility instrumentation calibration

, status during each is..ing phase. The team found, however, that the ENEA OA program did not include adequate measures to offectively control the calibration status of reference instruments or standards used for instrument calibration, as no provisions were in place to require re-calibration by SIT at the requisite intervals. This may have resulted in the introduction of uncertainties in the adequacy of calibration of test facility instrumentation which relled on these standards to establish and maintain their eccuracy. '

. Pending confirmation by Westinghouse that this lapse in the SIT certified calibration interval for the ENEA standards did not undermine or adversely impact the VAPORE ADS test results, this issue remained unresolved.

In order to achievo resolution of this item, ENEA submitted the seven instruments invo!ved in AP600 test instrument calibration to a nationally certified calibration laboratory in Italy .

(ERG /ING/PITER Division). Test results confirmed that VAPORE ADS test results had not been adversely impacted. During the inspection, the team verified that these actions had been completed and documented accordingly.

! 2.6 Nonconformance 99900404/97 0101 (closed)

Contrary to Criterion XVI, ' Corrective Action," of Appendix B to 10 CFR Part 50, WCA. ' 12600,

'AP600 Quality Assurance Program Plan," Revision 2, dated December 15,1993, Section 16 -

" Corrective Action.

• and WCAP 8370, Quality Assurance Plan (OA Topical Report),

Revision 12A, dated April 1992, Section 16, ' Corrective Action," Westinghouse (1) did not identify, analyze, document, and correct conditions adverse to quality as required by the AP600 Quality Assurance program when such conditions were identified to Westinghouse d'Jring a July 1994 NRC structural audit of the AP600 nuclear Island foundation mat, and (2) did not adequately determine and document the root cause of INITEC's basemat calculation errors nor j

ovaluate the impact of such a condition adverse to quality on completed or related INITEC AP600 design deliverables and activities.

On July 11 through 14,1994, the NF1C performed an audit of the structural design of the AP600 at the Bechtel ottices in San Francisco, Califomia. The rest " 3 of this audit were documented in a letter to Westinghouse dated August 24,1994," Summary of Audit of the AP600 Structural Design."

One of the key issues identified during the audit were errors found by the audit team in design calculations performed by INITEC (Calculation No.1010 CCC-001, Rev. A). The NRC audit team identified the following deficiencies: (1) errors in shear and flexural reinforcement assessment,in the use of punching shear formula, and in the use of finite element dimension; (2) no consideration of accident pressure loads, and loads from. construction sequence, and .

(3) out of phase overtuming moment from shield and containment buildings.

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e in its August 2,1994, letter to the NRC, Westinghouse acknowledgod its commitment to: (1) perform an indopondent review of the basemat design calculations, (2) verify the adequacy of INITEC's in house post process computer programs used for the foundation mat design, (3) perform simpilfied analysos as appropriate to confirm the existing design results, and (4) provido the results of this independent review to the NRC. (This issue was identified by the NRC in the AP600 DSER as DSER Open item 3.8.5 21).

On April 17,1997, the inspectors reviewed an INITEC letter to Westinghouse (INI/FOK0175),

dated February 15,1995, in which INITEC provided its responso to address the root causes of the quallty issue relativo to the Nuclear Island Basomat Calculation, identified by NRC in its July 1994 structural design audit, as well as the measures taken by INITEC ln order to avoid the occurrence of similar situations during the performance of present and future structural analysis.

The inspectors notod that INITEC's response had boon formulated almost contemporaneously with the trionnial audit bolng conducted by Westinghouse on February 20 through 22,1995, at INITEC's facilities. Yet Westinghouse's triennial audit report (OLA/IN;0007) did not provido any evidence that INITEC had identified this issue as a condition adverse to qua ity requiring root c

cause dolormination or corroctive actioris in accordance with INITEC's Westlag"ouso approved quakty assuranco program. During the inspectir n, the inspectors inquired as to Mother Westinghouso had initiated any root causo dotorminations or corrective actions, as required by WCAP 12600, Section 16, ' Corrective Action," sinen this issue was first identified by the NRC in July / August 1994 or whether Westinghouso had formally accepted or rejected INITEC's proposed corrective actions identified in INITEC's February 1995 letter. Westinghouse responded that, as of April 17,1997, this issue had not boon identified as a condition adverso to quality requiring a root cause dotermination or correctivo actions in accordance with WCAP 12600 nor had Westinghouse formally responded to INITEC's February 1995 letter.

In its June 9,1997, response to NRC Irispection Roport 99900404/97 01, Westinghouse provided information related to corrective actions initiated at Westinghouse and INITEC associated with the basemat calculation. Areas noted included an identification of the error, cause, dolormination of the extent of the error, correctivo action, action to provent recurrences and Westinghouse oversight Two of those areas, cause and determination of the extent of the error, woro identified for further ovaluation in a Westinghouse audit of INITEC in May 1997.

Additional calculations woro checked in the Westinghouse overview. This check confirmed that the units error was an isolated occurrence. The May 1997 audit confirmed that INITEC followed through on their correctivo action which consisted of revising the calculation and strengthening their vonfication ellorts by adding experienced personnel to their staff as well as providing additional training. The Westinghouse audit team concluded that INITEC had implomonted an improved independent verification program.

1 in order to provido further assuranco that conditions adverso to quality are being properly controllod and corrected on the AP600 program, Westinghouse initiated the following correctivo actions.

1. Design deficiencies (errors) will be subject to the criteria for initiation of a corrective action document requiring quality assuranco participat;on in the corrective action process.

2. The criteris for initiating a corrective action document requiring quality assurance participation in the corrective action process will be clarified and expanded to address the following conditions:

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a. External audit issuo a finding or observation identified by an external organization during an audit or inspection, that requires a responsc.

b. External toch 'calissuo a finding or observation. ,dontified by an external organization during a technical audit or review, that requires a responso, and which, upon further Westinghouso review, Indicated an error or deficioney in the dosign,

c. Internal assessment finding a finding identified by an intomal assessment that requires a responso,

d. Licensing basis document inconsistoney an error or doficioney that impacts the GSAR, PRA or CDM which, upon further Westinghouse review, indicated an error or deficloney in the design.

o. Deviations related to quality proceduros recurronce of deviations in relation to approved quality proceduros and/or lingering absenco of appropriato procedures or work practicos which should be performed in accordanco with applicablo quality standards.

f. Condition adverso to quality for which it is desired to dotormino the causo and Idontify action to procludo recurronco.

3. A specific AP600 Program Operating Procedure on correctivo action will be gonorated.

4. The now correctivo action procedure will be extended to all program participants.

5. Training in the correctivo action proceduto will bo providod to program participants.

Tho inspection team verified that a now Westinghouse proceduro, AP 16.2," Corrective Action for Design Deficiencies or Errors,

• Revision 0, (offectivo on August 18,1997) had boon implomonted by Westinghouso to address items 1 through 3, above. For items 4 and 5, the team verified that thoso actions had been completed and documented accordingly.

2.7 Nonconformance 99900404/97 0102 (closed)

Contrary to Critorion Vil, ' Control of Purchased Material, Equipment, and Services,' of Appendix 0 to 10 CFR P'rt 50, WCAP 12600, 'AP600 Quality Assuranco Program Plan,' Revision 2, dated Decembt 15,1993, Section 7, ' Control of Purchased items and Services,' and WCAP-8370, Quality Assuranco Plan (OA Topical Report), Revision 12A, dated April 1992, Section 7, ' Control of Purchased items and Services," Westinghouse (1) failed to adequately ovaluate or assess INITEC's annual performance for a supplier of AP600 design deliverables that had boon the subject of an adverso NRC audit finding, and (2) failed to conduct an evaluation of INITEC's response to Westinghouse's August 3,1994, lotter, and any associated corrective actions taken, in ita February 1995 trionnial audit of INITEC.

On April 17,1997, the inspectors loamed that on August 3,1994, Westinghouse had cent a lotter to INITEC (FOR/IN10181) requesting that INITEC provide its response to the NRC inspection findings. However, it appeared that Westinghouse did not considor the results of the NRC findings and concorns in its January 1995 ennual review of INITEC's performance.

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Additionally, tho inspectors reviewed Westinghouse's Audit Report OLA/INIDOO7, dated March 20,1995, that documented a triennial audit conducted on February 20 through 22,1995, at INITEC's facilities in Madrid, Spain. Upon reviewing the report, the inspectors found that: (1) an ovaluation of INITEC's response to Westinghouse's August 3,1994,lettor had not boon included in the audit scope, and (2) the audit did not identify any evidence to suggest that INITEC had initiated any internal root cause analysis, and ovaluation Further, the inspectors dolormlnod that no correctivo actions had boon formally identified by INITEC's OA organization to datormino the causo, and document the impact of the design deficienclos identified in Westinghouse's August 3,1994, lotter, on INITEC's AP600 design deliverablos.

On those bases, the inspectors concludod that Westinghouse (1) failed to adequatoly evaluate or assess INITEC's performanco, as required by WCAP 12600, for a supplier of AP600 design delivorables that had boon tho subject of an adverso NRC audit finding, and (2) failed to conduct an ovaluation of INITEC's response to Westinghouse's August 3,1994,lottor, and any associated correctivo actions taken thoroof, in its June 9,1997, response to inspection report 99900404/97 01, Westinghouse stated that the annual performance of INITEC was reviewed by Westinghouso Qualit'/ Assuranco and the responsible Westinghouso engineering manager as part of the reviews of the performanco of all activo AP600 design organizations during the wook of January 2,1995. During those reviews, Quality Assuranco identifies suppliers who are due for re audit based on the triennial audit requi omont, and solicits input from Engineering about the status of all activo AP600 suppliers, their quality and scopo of work, and any other factors that would justify more frequent audits. At that Jmo,it was dotormined that an audit of INITEC should be performed in 1995. INITEC was duo in 1995 for a supplio, audit, having been previously audited in March 1992 The audit (WES 95 211) was performed in February,1995.

In preparation for the February 1995 audit, the AP600 manager of Plant Engineering noted that -

NRC had (Nhnical questions about the nuclear island basemat analysis. Sinco concerns regarding this analysis had boon identified, the Plant Engincoring group identified an action plan to addross thoso concerns, including performing an Indopondent and export technical ovaluation of the calculation. Dased on review of the issues involved and the understanding that this issus was already being addressed in the technical arena, it was determined that the mview of the analysis would assess whether there were any deficiencies inhoront in INITEON design control measures that contributed to the concerns identified. During audit WES 95 211, no deficienclos within INITEC's design control program or in mooting the requiroments of NOA 1 woro identified.

At the time of the audit, Westinghouso Quality Assurance had not received INITEC letter IN!/FOK0175 documenting INITEC's response to Westinghouse's August 3,1994 letter, nor did it surfaco during the audit.

A follow up Westinghouse audit of INITEC was conducted in May,1997, This audit ovaluated the correctivo action outlined in INITEC letter INl/FOK0175. The audit team consisted of a tocienical specialist, two members of the Energy Systems Business Unit Quality Systems organization, and an engineer from the AP600 project group. The audit included a comprohensive review of basemat calculations. The audit team noted that INITEC had implomonted an improved verification program with the addition to their staff of a qualified technical expor1 devoted solely to indopondent verification. Based on the audit team's review of the conditions surrounding the error,it was found to be an isolated occurrence. INITEC was roquestod to document their own ovaluation of the extent to which the error may exist in other 8

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calculations. Westinghouse concurred, based on INITEC's documentation, that this error was an isolated occurrenco, in order to further assure the adequacy of suppiler performanco ovaluations and improve tho integration of the performanco evaluation results with the audit planning process, Westinghouse took the following actior,s for the AP600 program:

1. A comprohonsivo supplier performanco ovaluation checklist was developed to enhance implomontation of the procedure requirements for performance evaluations. The chocklist includos the following:

Results of open items from prior Westinghouse audits Results of technical ovorsight of the supplior including identification of design errors Results of audits of the supplier from other sources (if availablo)

Status of other committod correctivo actions

2. The performance of all activo suppliers was reassessed for 1997 using the now performance ovaluation chocklist.

3. Training on the subject of performance ovaluation and audit planning was provided to AP600 project personnel.

The inspection toam verified that those actions had been completed and documented accordingly.

2.8 Unrosolved item 99900404/97 0103 (closod)

Based on the nonconformancos identified in NRC Inspection Report 99900404/97 01, the NRC was concerned that thoso quality assuranco deficiencios may have introduced a lovel of uncertainty on the acceptability of design deliverables provided by AP600 tachnical cooperation aDroomont participants. Of particular concern to the NRC, was Westinghouse's failure to recognizo and appropriately address a condition adverse to quMity, requiring a root cause ovaluation and determination and appropriato correctivo actions, even when such condition was identified by an NRC audit and resultod in re design of the AP600 foundation basemat.

Westinghouse's failure to address this design and quality assurance program deficioney in a timely manner raised the issue of whether this was an Isolated case and whethor other design delivorables provided by AP600 technical cooperation agroomont participants did in fact possess the lovel of integrity in design verification and quality assurance necessary to satisfy the design cortification provisions of 10 CFR Part 52.

Accordingly, the NRC requestod that Wostinghwso: (1) determino and evaluate tne impact <

, these nonconformancos on completed or related design deliverables and/or activities performed by all AP600 technical cooperation agrooment participants; (2) identify the steps that it has l taken, or intends to take, to demonstrato that other design deliverables provided by AP600

technical cooperation agroomont participants do in fact achieve the lovel of integrity in design l verification and quality at,suranco necessary to satisfy the design certification provisions of l 10 CFR Part 52; and (3) provido a list of all AP600 technical cooperation agreement participants,

! including a description of their AP600 program work scope and involvement. To address the NRC's concerns Westinghouse undertook the following activities:

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1. Based on recent INITEC performance findings and the findings of the quality assurance audit, Westinghouse performed a detailed management review of the INITEC activities on June 3,1997. The purpose of the review was to evaluate whether the actions identified for INITEC woro appropriato for the conditions. The reviewing group included the team that audited INITEC in May 1997, Westinghouso OA management, Westinghouse engineering management, and the Westinghouse lead reviewer for INITEC structural deliverables. There woro two areas reviewod whore improvements were noodod: Improving the accuracy of their verification process and initiating and following up on correctivo actions. The verification process has boon significantly augmented with additions to their staff and additional training, improvements in the correctivo action portion of the INITEC program will be defined in response to the May 1997 Westinghouse audit findings and will be monitored by a Westinghouso QA ongineer. The review concluded that the actions completed, plus those identified for INITEC from the audit, were sufficient actions at INITEC, and some additional activities would bo initiated at Westinghouse.

2. Wostinghouse commissioned an independent audit of the Westinghouso Quality Program and quality assurance oversight of technical cooperation participants as applied to AP600 dosign activities. This audit, completed on May 30,1997, was performed by individuals completely Indopondent of the AP600 quality assurance function with the load auditor being an outsido contractor . The audit identified 'broo findings and four recommendations for program improvement which are current., _ sing addressed. The overall assessment of the audit was that the oversight of design activities on the AP600 was offectivo both from a quality assuranco standpoint and from a technical standpoint and in accordance with WCAP-8370,10CFR50 Appendix B and NOA l.

3. A comprohonsive ovaluation was conducted of the methods and degree of oversight provided for all technical cooperation agrooment participants performing engineering tasks at their facilitlos.

4. A design assuranco review was initiated to assess a samplo of safety related design work which is part of the AP600 licensing basis from each of the international design participants.

The purpose of this review is to demonstrato, with reasonable assurance, that the design delivorablos provided, achlove the required levol of integrity in design vcrincation and quality assuranco. As part of the assessment, technical specialists performed an independent check for accuracy of deliverablos supplied, in addition, an assessment was made of the adoquacy and integrity of the original design and the design verification provided by the document originator. Conclusions reached by Westinghouso as a result of this design assurance rovlow woro documented in a summary report," Response to NRC Inspection Roport No. 99900404/97 01 of AP600," dated October 16,1997 The inspection team verified that thoso actions had been completed and documented accordingly.

3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 AP600 Ovality Assuranco Proarem Chapter 17 of the AP600 standard safety analysis report (SSAR), Revision 18, describes the Westinghouse Electric Corporation quality assurance (QA) program for the design phase of 10 l

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the AP600 Advanced Light Water Reactor (ALWR) Plant Program. In Revision 5 to SSAR Chapter 17, Westinghouso stated that effective March 31,1996, activities affecting the quality of items and services for the AP600 Project during design, procuremont, fabrication. l Inspection, and/or testing would be performed in accordartco with the quality plan described in Westinghouse's *Enorgy Systems Business unit - Quality Management System,"(OMS)

Revision 1.

The staff's review and approval of Revision 1 to the Westinghouse OMS was documented in a lotter from Suzanne Black (NRC) to N. J. Liparulo (Westinghouso), dated February 23, 1996. Activities performod prior to March 31,1996, woro performed in accordance with the quality assurance plan described in Westinghouse topical report WCAP 8370, ' Energy System Business Unit - Power Generation Business Unit, Quality Assurance Plan," Revision 12a, dated April 1992. Also, activities performed prior to November 30,1992, woro performed in accordance with the quality assurance plan described in topical report WCAP.

8370/7800. Energy Systems Business Unit Nuclear Fuel Business Unit, Quality Assuranco Plan, Revision 11 A/7A. Both versions of WCAP 8370 applied to all Westinghouse activities affecting quality of items and services supplied to nuclear power plants and established Westinghouse's compliance with the provisions of Appendix B to 10 CFR Part 50.

WCAP 12600, 'AP600 Quality Assuranco Program Plan,' dated January 1997, a project-specific QA plan, was developed by Westinghouse to enhance the OMS in specific areas and to establish additional commitments needed to support the AP600 Design Cortification and First Of A Kind (FOAKE) program. WCAP 12600 establishes the responsibility of the Nuclear Projects Division of the Energy Systems Business Unit for AP600 Design Cortification and FOAKE programs and for control of the technicat interfaco betwoon Westinghouse and engincoring groups and suppliers providing engineering services under such programs. WCAP 12600 also addressos Westinghouse's commitments to the provisions of ANSl/ASME NOA 1 1989 Edition through NOA 1b 1991 Addenda for the AP600 project.

3.2 Review of Calculation Documents for SSAR Chaotor 15 Analysos

a. insocction Scope During this portion of tho inspection, the team reviewed and assessed the adequacy of the design input documents that provide the bases for the analyses presented in Chapter 15 of the AP600 SSAR.

b. Observations and Findinas 1, Review',f Deslan Calculation Files During the inspection, the team reviewed the following Westinghouse design calculation filos:

SSAR GSC 390 (Rev.1),'AP600 Foodwater Malfunction Analysis with Loss of Offsite Power at Reactor Trip."

. SSAR-GSC 391 (Rev. 0), 'Excessivo Load increase with LOOP."

SSAR-GSC 335 (Rev. 0), 'AP600 Steam Line Break - Coro Response."

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SSAR GSC 335 (Rov.1), 'AP600 Steam Line Break - Core Responso with LOOP at Start of Events."

SSAR GSC 389 (Rev. 0), 'AP600 Loss of Load Analysis with Loss of AC Power."

SSAR GSC 336 (Rov. 0), 'AP600 Loss of AC Power for SSAR."

SSAR GSC 183 (Rev. 0), *AP600 Loss of Flow / Locked Rotor Analysis "

SSAR GSC 188 (Rev. 0), 'AP600 Boron Dilution Analysis."

SSAR-GSC 189 (Rev. 2), 'AP600 SSAR Inadvertent ECCS Analysis".

SSAR GSC 337 (Rev. 0), ' Revised SGTR Analysis for AP600 SSAR."

SSAR GSC 337 (Rev.1), 'SGTR Analysis for AP600 Assuming a LOOP at Start of Events."

CN TA 96 39,' Revision 7 of AP600 Reference input Data for Non LOCA Analysos."

CN TA 96155," Revision 8 of AP600 Rolorenco input Data for Non LOCA Analyses."

The team's review consisted of verifying that input data and assumptions were properly documented and that an indopondent review was performed. The methods used by the team involved review of the calculational methods, review of values for randomly selected design paramotors used for the computer input, examination cf analytical results for accuracy, consistency check of calculational results and SSAR writeups, and discussion with Westinghouse technical staff for document rotrieval and control.

As a result of the review, the team found that the majority of materialincluded in the calculational files reviewod by the team was typed while information presented in a hand-written form was clearly written. For each calculational file, WP 4.5, " Design Analysis,"

Revision 0 (8/31/96), requires the author and the reviewer to meet the following documentation requirements via a check list:

The purposo of the design analysis. is clearly stated.

The required inputs and their sources are provided.

The assumptions are clearly identified and justiflod.

The methods and units are clearly identified.

The limits of applicability have been identified.

The results of literature search, if conducted, or other background data are provided.

All the pages are sequentially numbered and identified by the calculation filo number.

The required computer calculation information havo boon provided.

The computer codes used were under configuration control.

The computer code (s) used were applicable for modeling the physical and/or computational problems contained in this calculation filo.

The results and conclusions are clearly stated.

Open items are properly identified and resolved.

Approved design controlled practices were followed without oxception.

Computer input files have been transferred to the data Dock Library.

If any of tho above requirements are deviated, provido adequate justification.

The team found that each calculation c!oarly identified both the calculation author and the reviewer who completed the check list. The team also found that the calculational filos contained sufficient information to support the Chapter 15 analyses presented in the 12

9 AP600 SSAR. The information included input paramoters to computer codes, technical bases for the values selected for the computer input, discussion of the assumptions and methods used for analysoc, summary of analytical results including sequences of events, and SSAR writeups to reflect the results of tho analysos.

The team noted that the assumptions for analyses were consistent with appropriate Standard Roview Plan guidanco, the values for input parameters used in the analyses and the associated technical bases could be traced to and found to be consistent with the Westinghouse reference input data sources and the proposed technical specifications for AP600, and the computer codes used in tho analyses were listed. The team found that the computer codes were either previously approved by the NRC or used in the licensing applications previously approved by the NRC, The analyses documented in calculational flies were accurately reflected in the wnteups of the AP600 SSAR.

2. Increaso in the RCS Inventory Events (SSAR 15.5)

Upon reviewing SSAR GSC 189, the inspector found that operator actions had been credited in the analysos of increased RCS inventnry events (Westinghouse submittal, NTD NRC 94 4175). However, Westinghouse had not addressed the following:

Availability of (1) unambiguous alarms or indications for increased RCS Inventory evonts, and (2) clear procedural instructions to operators to take appropriate actions within the timo-frame assumed in tne analyses.

10 CFR 50.36, " Technical Specifications," $50.36(c)(2)(li)(C).

Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) to verify the capacity of the system including the RV head vent valves that would be used by operators to prevent pressurizer overfill from occurring as assumed in the analyses.

SSAR text providing detail of the analyses that credited the requisite operator actions.

This issue was identified as part of Nonconformance 99900404/97-02-01.

3. Boron Dilution Analysis (SSAR 15.4.6)

The team found that Westinghouse had relied on the boron mixing testing data ducumented in EGG-LOFT-5867 (Project No. P 394) to establish the required RCS circulation flow rate of 1000 gpm in TS 3.4.9 and to support its complete boron mixing model assumed in the boron dilution analyses (SSAR 15.4.6 and SSAR-GSC-188).

However, the team noted that the AP600 design is different from the test facility configuration and conditions discussed in EGG-LOFT 5867. For example, the injection loca' ion of the unborated CVS flow is at the DVI line for AP600 while the test facility simulated a cold leg injection. For AP600, the maximum boron dilution flow rate assumed in the analysos is 200 gpm and the required TS RCS circulation rate is 1000 gpm to assure complete mixing; of the unborated water, while the test facility simulated conditions with unborated flow rate of 300 gpm and RCS circulation rates greater than 3000 gpm. The team concluded that Westinghouse had not reconciled the applicability 13

J j

4 of the boron mixing testing data to the AP600 design nor had Westinghouse validated the complete boron h ung model assumed in the boron dilution analysis. This issue was identitled as part of Nonconformance 9990040497-02 01.

c. Conclusions With the exception of the items identified above, the inspector concluded that calculation files prepared by Westinghouse and reviewed by the inspection team were technically adequate and supported the analysen presented in Chapter 15 of the AP600 SSAR. _}

However, Westinghouse needs to evaluate the Impact of the nonconformances identified above on other Chapter 15 analyses, not reviewed by the inspection team, to establish the adequacy of the design review process and integrity of the AP600 design.

3.3 QA Review of Larae Break Loca: Lona Term Coolina Methodoloav and Analysis

a. Insocction Scope During this part of the inspection, the team reviewed various technicalissues regarding documentation, technical accuracy, and validation and verification regarding large break LOCA methodology, long term cooling methodology and SSAR Section 15.6.5.4C on the AP600 long term cooling analyses results. While the inspector reviewed _several

- documents during the inspection, these represent a small fraction of the total population of documents that provide the bases for the AP600 long term cooling analyses results,

b. Observations and Findinas .

During this part of the inspection, the inspector reviewed documents dea!,ng with ,

- analyses related to the following areas: (1) the large break LOCA methodology based on t WCOBRArrRAC, (2) WCOBRATTRAC validation for long term cooling (LTC) and (?)

SSAR section 15.6.5.4C on LTC. The document selection for the large break LOCA methodology was based on code modifications, the analyses of the CCTF and UPTF experiments and the preparation of the LBLOCA input. The LTC document selection - i was based on the window mode calculation documentation, WCOBRA/ TRAC inpu. -

generation, the calculation of the collapsed liquid level and an example of test to _ test input changes. Finally, the SSAR document selection was based on: AP600 window i

' mode calculations, the AP600 WCOBRA/ TRAC input model generation, input changes from case to-caso and a sample computation of the AP600 vessellevel and DVI flow rates with one ADS-4 valve failed. The following documents were reviewed during the inspection.

LTCT-T2C-413, "WCOBRA/ TRAC Code Modifications Regarding Check Valves,"

Revision 3.

SSAR-GSC 205,"WCOBRA/ TRAC Modification for Vessel Collapsed Liquid Level Sharpening," Revision 2.

SSAR GSC 325," Analysis of the CCTF Experiment," Revision O.

. MT01 T2C 260," Geometric Data for the AP600 CMT Test."

1 14 1

4

[ .

SEC APS-4746 CO,"WCOBRA/ TRAC Long Term Cooling."

• SSAR GSC 028, *CMT implementation in WCOBRA/ TRAC," Revision 0.

SSAR GSC 287 (SEC APS-4964 CO),"UPTF Analysis."

SSAR GSC 355," Input Parameters AP600 SSAR Revision 3, LBLOCA," Revision 0.

LTCT T2C 417, "WCOBRA/ TRAC Geometrical Input Data for the OSU Testing,"

Revision 0.

LTCT-T2C 418,"OSU LTC Comparisons with WCOBRA/ TRAC," Revision 1, SSAR GSC 356,"Two inch Break LOCA, LTC," Revision O.

SSAR OSC 377, *SBLOCA Long Term Cooling " Revision 0.

The inspector identified discrepancies associated with the following calculation notes.

As a result, these issues were Identitled as part of Nonconformance 990004007- '

02-01.

SEC APS-4746 CO,"WCOBRA/ TRAC Long Term Cooling."

The calculation note stated in the concluding section that "... variations in the inillal conditions are expected to have relatively unimportant effects on the analysis results," and "Results of changing ICHP is noticeable but not large..." The inspection :

team noted that no basis for these conclusions was provided in the calculation note.

LTCT T2C 417, "WCOBRA/ TRAC Geometricalinput Data for the OSU Testing," '

Revision 0, and LTCT T2C 418, *OSU LTC Comparisons with WCOBRA/ TRAC,"

Revision 1, in LTCT T2C-417, pages 1801, Figures 6 and 7, the calculation acknowledged the failure to fit DP vs (flow)', However, the basis provided was that "...despite the failure to match overall agreement is reasonable." Additionally, this unquantified anomaly was used as input in LTC T2C-418. Specifically, on page 16 of LTCT T2C-418, a bias was applied of 0.2 psia to the atmospheric pressure (14.5 > 14.7 psia) to compensate for the disparity in DP vs (flow)' in LTCT T2C-417 - LTCT T2C-418 did not provide an explanation or justification for the use of this bias.

. SSAR GSC 356,"Two-Inch Break LOCA, LTC," Revision 0.

In an effort to determine single phase flow resistance, a solution of DP vs. flow was preconted. The objective of the calculation was to determine the asymptotic part of the solution. The author of the calculation note observed that a harmonic oscillation  !

- was built in to the solution, and therefore, he proposed to take the average value. >

The inspector, however, could not determine if the average value is equal to the asymptotic solution had the oscillation not been present. T' erefore, the calculation l 15

did not address the following: (1) impact of oscillation in the asymptotic soluDon, (2) impact of oscillation on the flow resistanco, and (3) presence of oscillation in tho  ;

vossol flow, DP, and vossol collapsod liquid level solutions.

SSAR GSC 377, *SBLOCA Long Term Cooling" The inspector identified the following discropaneles in this calculation:

The author made inappropriato use of the term " containment leakago"in place of vossol leakage arid in several solutions, negativo (reverse) DVI flow was calculated with no corresponding physical explanation provided.

A break of 0.264 ft' was assumod on a two sidod open break. However,it did not agroo with a two inch pipo break cssumed in the calculation. It appears that the break should be considorod a cold log toar.

On pagos 114115, a significant amount (about 3000 lbs) of liquid was calculated to havo leakod from the ADS 13 but the problem initial conditions assumed an empty pressurizer and IRWST. Tho inspector noted that this outcomo contradicts the initial conditions specified but no explanation or clarification was provided in the calculation note.

c. Conclusions The issues identified above represent technical deficienclos found by the inspector while performing a limited review of a larger population of analysos/ calculations. The safety significanco of these doficiencies noods to be addressed by Westinghouse and an ovaluation of their impact, with respect to tho overall long term coo!ing analysos results providod to the NRC in the AP600 SSAR, noods to be performed.

3.4 Review of Westinahouse Softwaro Ouality Assuranco

a. Insocction Scopo Tho inspectors reviewed the technical and quality oversight of Westinghouso reactor systom and containment safety analysis computer programs, in particular, the inspectors reviewed documentation for the NOTRUMP, WCOBRA/ TRAC, and WGOTHIC computer programs. The documents were reviewod against the requirements of Westinghouso QA procedures,10 CFR Part 50, Appendix B. NOA 1 1989, and 10 CFR 50.46 where applicable,

b. Observations and Findinas NOTRUMP NOTRUMP is used by Westinghouse for small break LOCA analysis. The inspector reviewed documents related to model changes, error tracking and error correction required for the AP600 analysis program and interviewed the NOTRUMP cognizant engineer. The inspector reviewed SEC APS-4838-CO,' Software Design Spoolfications 16

of AP600 NOTRUMP Usor Externals Cyclo 2,' NTD SOD STD 95 087, an error report l on Cyclo 2 SSAR GbC 301, *Softwaro Change Specification of Vorsion 3,' and SSAR-GSC 322," Validation Packago for Version 3." The inspector noted that the documentation was clear, comploto and errors woro tracked and corrected. The validation testing was clearly specified and expected lost results woro given.

WCOBRA/ TRAC WCOBRA/ TRAC is used for LOCA analysis by Westinghouse. The inspectors reviewed documents related to modo! changos, orror tracking and error correction required for the AP600 analysis program. The inspectors also interviewed the cognizant engineer in charge of WCOBRAfrRAC.

Tho vorsion of WCOBRA/ TRAC used for AP600 analysis is version MOD 7A Revision 1 A, which is based on operating reactor version MOD 7A, Revision 1. Soveral AP600 specific changos are added to this version to croato MOD 7A, Revision 1 A. The software changos to create Re'/ision 1 are specified in SEC APS 5037 C0 and the verification of thoso changos are documented in SEC SAll 5063-CO. The verification report for the AP600 spocific changes to WCOBRA/ TRAC did not give reasons for the specific tests chosen or for the paramotors chosen for comparison in the tests.

The inspector also reviewed the codo error report for MOD 7A, Revision 1, contained in NTD NSA sal 96 332 and the release lotter for the current operating reactor version MOD 7A, Rovision 2, which contains 10 CFR 50.46 reporting information. Ono error was listed that affects code timestop control n a WCOBRA/ TRAC run has to be restarted.

Tho orror impact on PCT was assossed as O degrees F for both operating reactors and AP600 becauso the largo break LOCA methodology does not use restarts. Although the oporating reactor analysos do not contain restarts, the AP600 largo break LOCA analysos do in fact contain restarts. The code cognizant engineer thought that tho imoact of this error would probably be small on AP600 analyses. Thore was no evidenco that the error list was ovaluated for the specific caso of the AP600.

The inspector also discussed the codo failures with the AP600 analyst and the WCOBRA/ TRAC cognizant engineer. Although the analyst discussed the failures with one of the WCOBRA/ TRAC developers, the cognizant engineer stated that he was not aware of the failuto. The inspector found that the code failure was not tracked in the WCOBRA/ TRAC orror tracking system and thorofore, no official code error report was filod. This issue was Identitled as part of Nonconforrnance 99900404/97-02-02.

WGOTHIC WGOTHIC is used by Westinghouse to perform design basis peak pressure calculations for the AP600. The WGOTHIC code is somewhat different than the Westinghouse safoty analysis codes used for reactor systems analysis in that part of WGOTHIC is developed and maintair.ed by Numerical Applications Incorporated (NAl). Westinghouse then makes modifications to the code to implomont special models that are used in AP600 containment calculations as WGOTHIC. Since the GOTHIC foundation of WGOTHIC is commercial software, it must go through a dodication process when it is brought into Westinghouso before it can be used in safety related applications. The 17

\

dodication, containod in CN SMA 91 192 RO, contains descriptions of the testing process and shows acceptanco by comparison to the NAl results. Although the inspector did not perform a fullindopondent review of the dedication process, there was evidence that an indopondent OA review had boon performed.

Westinghouso updated their GOTHIC base code to GOTHIC version 4.0 as a result of codo deficienclos identified during the AP600 review, but no explanation was given in the documentation for code changes. Thcro was also no reference to NAl documentation that would have glvon documentation of the code changes and Westinghouse did not run all NAl test casos to verify that the updato was correct. Tho Westinghouso document reviewer questioned why all tost casos woro not run. The author responded that some of tho lost casos tako a long time to run and that the casos run woro more than enough to verify the code. There was no documentation of what functionality was tested by the test casos or whether they covered all uses of GOTHIC by Westinghouse. Stating that some tost casos take a long timo to run is not adoquato justification for not running them. The inspector concluded, however, that tho test casos used by Westinghouse woro adequato to test the cojo functionality.

The main chango modo to GOTHIC by Westinghouse to make WGOTHIC is the film heat transfor packago used in modeling the AP600 containment shell which Westinghouso refers to as the climo model which is a large and complicated model change. The inspector reviewod CN CRA-93 219 R0 which is the design specification of the clime model. The bogk .ng of the document describes what is called a complete and correct mathematical and physical model of the film onergy transport but the equations are not mathematically and physically comploto and correct. A completo and correct description would start out with mass, momentum and onorgy balancos on the film and then show what terms can be noglected to obtain the final mathematical model.

Soveral terms are obviously missing from tho equations including condensation and ovaporation terms which appear about 60 pages after the original *completo" model equations are discussed. Thoro are also terms missing that depend on the timo rato of chango of the film thickness that result from the application of Leibniz's rule to the integral balanco equations for a moving boundary problem. These missing terms may be negligible if the film thickness is changing slowly, but the assumptions incorporated into the completo equations should be clearly stated in the documentation.

in addition, related to Equation 8, an artificial thermal capacitanco equal to half the thormal capacitance of the film is added to the thermal capacitance of the wall nodo adjacent to the film for numerical stability reasons. Adding this artificial term introduces an error in onorgy conservation. The term should either be removed from the equations orjustification provided that the error introduced is negligible. This issue was identitled as part of Unresolved item 99900404/97-02-03.

The inspector reviewed NAl GOTHIC errors identified after GOTHIC 4.0. The inspector noted that the lettor for the latest release of WGOTHIC had a list of more than 100 uncorrected NAl GOTHIC orrors. NAl had determined that some of these errors could affect safoty dolorminations and may be reportable under 10 CFR Part 21.

Westinghouso Proceduro WP-4.19.3, " Software Error Reporting and Resolution,"

requires that the impact of errors must be reviewed on all work activities where the program was used during the timo period the error oxisted and documented on an Error 18

Impact Review shoot within 60 days of recolving the error report. However, Westinghouso could not provido documentation to support performanco of this review.

This Issue was Identitled as part of Nonconformance 99900404/97-02 02.

c. Conclusions The NOTRUMP code appeared to be adoquately documented from the standpoint of softwaro quality assuranco, however soveral weaknessos were identified with WCOBRA/ TRAC and WGOTHIC. The documentation of code changos in WGOTHIC did not allow an Indopondent reviewer to understand why the code changes woro mado in all casos and the documentation of tost casos for EGOTHIC and WCOBRA/ TRAC did not spocity why tho test casos woro boing run or the expected results of the testing.

Westinghouse also implomonted major model changes into WGOTHIC with a poorly documented mathornatical and physical model. The tracking and documentation of computer code errors and their impacts for WGOTlilC and WCOBRA/ TRAC as applied to AP600, was not performed in accordance with the requirements of Westinghouso Proceduro WP 4.19.3.

3.5 Review of NOTRUMP Small Break LOCA Code

a. Insocction Scope The inspector reviewed selected calculation no'*s to dolormino the acceptability of the quality assuranco provisions being implomonted by Westinghouse for developing the codo and calculation notes pertaining to the AP600 version of the NOTRUMP small break LOCA computer program.

b. Observations and Findinas SEC APS 4838-CO," Software Design Specifications of AP600 NOTRUMP User Externals Cycle 2.*Rovision 0, dated September 9,1995.

This calculation disclosed that the authors responso to the reviewofs comment indicating numerous errors in code paramotors was that the errors woro not viewed as significant and would be corrected in a later code revision. However, no basis was given to justify the conclusion that the errors woro insignificant.

SEC APS-4837 CO, Revision 0, dated September 9,1995,"Softwaro Chango Specification of NOTRUMP Cycle 32."

The calculation identified that the author in response to a reviewors comment wrote that ho, "doesn't know enough about void propagation methodology of flow link property determination to determine whether unphysicalinterphase velocities have significant impact.' The author does not glvo any indication of attempting to find a resource who is capable of responding to the reviewers concerns, thus there is no evidence that the reviewofs concern was addressed.

The deficie eles discussed in the above examples were identified as part of Nonconfort.. .r.4 n9900404/97-02-01.

19

- i r  ;

i

c. Conclusions With the exception of the items identified above, the inspector concluded that calculation j

files prepared by Westinghouse and reviewed by the inspection team were technically adequate and supported the use of the NOTRUMP computer code for application to the AP600 design. However, Westinghouse needs to evaluate the impact of the nonconformances identified above on other calculation notes pertaining to the AP600 version of the NOTRUMP small break LOCA computer program, not reviewed by the inspection team, to establish the adequacy of the AP600 design review process and integrity of the AP690 design.

3.0 OA Review of WGOTHIC Computer Code

a. Inspection Scope The inspection team reviewed selected documents to determine the acceptability of the quality nssurance provisions being implemented by Westinghouse for developing the computer program t.nd calculation notes portaining to the validation, verification and use of the Westinghouse WGOTHIC computer program. WGOTHIC is used to perform the design basis accidents analyses for peak containment pressure to support the AP600 design certification.

b. Observations and Findinos

. CN CRA 95-089,

• Validation and Verification of INPUT SmallInternal Use Computer Program," Revisions 0 and 1.

The document disclosed that the authors response to the reviewer comment concerning an incorrect value for an area as used in the calculation was not considered to be of sufficient consequence to warrant a code revision No specific evaluation to support the conclusion was provided and the inspector c ould not assess the impact without recourse to the originator, it was also noted by the author that if other changes were found to be necessary then this error should be corrected.

in reviewing the independent verification of the calculation performed by the reviewer, it was noted that in one case an equation was written with a '+' sign to add two terms.

The reviewers equation contained a * " sign but the computed value was based on a summation. The FORTRAN coding for this specific equation was inspected and found to be correct. Westinghouse informed the team that the area error had been corrected and that the conclusions derived from the study remained unchanged.

. CN CRA 94147,

• Phase 2/3 Large Scale Test Lumped Parameter WGOTHIC Base Case Deck," Revisions 0 and 1.

The review of this document disclosed that the reviewers comments and the authors responses were imbedded in the document, in general, the authors responses were found to laclude sufficient details to assess the responses. The inspection team noted that errors in the model were found after the computer analyses hed been performed.

20

In one caso, the author's responso Indicated that a k loss factor was lik91y acceptable if other specific conditions woro mot. There was no statement as to the expectation of the condition being mot or verified.

• CN TA 96153 AP600,"Steamline Break Mass and Energy," Revision 0.

The review disclosed that errors existed in the analyses that wero identified after the computer runs had boon completed. The inspection team dotormined that some errors would be conservativo and that some would be non-conservative. The author's assessment was that there was no impact associated with the errors. it was also noted that the specific orrors did not occur in the limited analyses that support design cortification. The inspection also disclosed that the computer program used to calculato the SSAR mass and energy releases for the steamline breaks is LOFT 4AP Version 1.8 and that the values presented in the SSAR are consistent with this supporting calculation.

1100 SOC-001, "Containmont Volumes and Heat Sinks," Revisions 0 through 4.

Tho review of Revisions 2 through 4 disclosed that the development of the containment volumes and heat sinks woro developed and updated based on the nuclear island general arrangement drawings starting with Revih 6 and ending with Revision 8. Rev. O was a preliminary scoping document that was completely revised in Rev. 2. No specific review comments woro identified however each page contained a sign oil block with the author and verifier (reviewor's) signatures. Minor deviations woro identified such as use of ' estimated" and ' assumed' dimensions for non-critical components and diagrams without units or dimonsions clearly identified.

The inspector also found a summary table with an incorrect value for a surface area in Revision 0. The error was also contained in Revision 1, however the correct value was found in the curront version, Revision 4.

The inspector also determined that the thermal Insulation surrounding piping and components was not considered in the development of containment volumes and flow paths (olther betwoon compartments in the below operating deck regions or between the below operating dock regions and the above operating dock region). No justification for the treatment of insulation was found in any document, in addition to concoms regarding the lack of margin to design pressure in the current licensing analysos presented in SSAR 6.2.1.3 and 6.2.1.1(the MSLB limiting case with a peak pressure of 44.8 psig and the LOCA with a poek pressure of 44.0 psig as compared to the 45 psig design pressuro), there are other design analyses areas that may bo impacted by the insulation issue. For example, the subcompartment loads analysos provided in SSAR 6.2.1.2, and the evaluation of flooding levels within compartmonts and which compartments may be subjected to flooding.

21

. . _ , . . _ _ ,.m.

- - - - _ . . - - - - - - _ - . _ - - - . ~

I i

- l With respect to SSAR 6.2.1.3 and 6.2.1.4, Westinghouse needs to:

a. Evaluate the significance of the insulation on the free volume used to determine the peak containment pressure. Provide adequate justification, as appropriate, that the free volume is conservative.

b. Evaluate the significance of the insulation on the. flow path characterizations used to determine the peak containment pressure, including flow areas and form ,

losses, for both paths connecting below operating deck cornpartments as well as i flow paths connecting below operating deck regicns to above operating deck regions. Assess the effects for each of the 4 LOCA phases as well as the MSLB.

With respect to SSAR 6.2.1.2, Westinghouse needs to:

l Evaluate the significance of the insulation on the flow path characterizations used to i determine the differential pressures across subcompartment walls, including flow l areas and form losses, for both paths connecting below operating deck cortpartments  ;

as well as flow paths connecting below operating deck regions to above operating deck regions.

With respect to the flooding issues, Westinghouse needs to:

Evaluate the significance of the insulation on compartment f50 ding, address both timing and levels, as well as which compartments would be aN eted.

. CN CDBT 92 233,"AP600 y(GOTHIC Input Deck Development," Revisions 2 and 3.

The review disclosed that errors existed in the analyses that were identified after the computer runs had been completed. The specific errors identified by the reviewer in Revision 3, dated May 22,1997, concerning errors in areas and k loss factors, .5ere determined to have negligible impact on the analyses and therefore reanalyses were not performed. No discussion on how this conclusion was reached was provided.

Similar statements were found in CN CDBT-92 233, Rev. 2, concerning an error in the calculation of a hydraulic diameter (although in this specific case the AP600 nodalization was modified after the error was found, however the inspection review was not detailed enough to determine if the error was promulgated into the revised model). It is also noted that to follow this nodalization change from Rev. 2 to Rev. 3, a third document, CN CRA 97 034 Revision 1, had to be reviewed by the team since the specific justification for the change was not included in the CN CDBT 92 233 series of reports.

CN CRA 97-034 was not reviewed to determine if there were any errors identified in the model. The specific nodal change addressed a concem with the computed steam concentrations near the ADS. Considering the lack of margV, the potential that there are other " negligible" errors is a concern. As a resuit, Westinghouse needs to:

a. Provide justification that the impact of these errors and incorrect loss coefficients are conservative, or that the cumulative impact of known errors would not result in a change in the pressure calculation greater than 0.2 psig. The loss factors 22

I' selected were considorod to be applicable to ' natural circulation" but, for the flow paths in question, the loss factors should not have boon appliod. Assess the olfocts for each of the 4 LOCA phases as well as the MSLB.

b. Provido justification for allowing known errors to romain in the licensing analysos that support design certification, includo the supporting knowledge base employed by Westinghouse that is used to assess errors to datormino that, in considoration of the 0.2 psig (h of 1%) margin in the calculated allowanco to the design prossure, known orrors have a negligiblo impact (for examplo only conservativo errors romain, or that the cumulativo impact of known errors would not result in a chango in the pressuto calculation greater than 0.2 psig).

Considoration should be given to both accumulation of otrots as well as the impact of errors in consideration of the different phenomena and charactorizations for each of the four LOCA phases and the MSLB.

In each of the examplos discussed, additionalinformation is required to assess the impact of the errors identifiod. This issue was identitled as part of Unresolwditem 99900404/97-02-03.

c. Conclusions With the exception of the items identiflod above, the inspector concluded hat calculation files prepared by Westinghouse and reviewed by the inspectbn team woro technically adoquato and supported the use of the Westinghouse WGOTHIC computer program for AP600 design cortification. However, the impact of the issues identified in the unrosolved itom noods to be ovaluated by Westinghouse with respect to the adequacy of the AP600 design verification process and integrity of the AP600 containmont design.

3.7 Roviov'of items Relatel'o AP600 Procram Audits and Procuremont issues

a. Insocction Scopo Tho inspector selected several AP600 purchase orders and audit reports to ascertain Wostinghovso's implomontation of tho appropriato provisions in WCAP 2000 with respect to procuromont document control, control of purchased services, audits, and associated correctivo actions,

b. Observations and Findinog

• Dosion Assuranco Review of AP600 Vondors Westinghouse letter NSD NRC 97 5370, dated October 16,1997, documented the results of a ddgn assuranco review of vendors used by Westinghouse for the AP600 program, items 16,17, and 19 of Tablo 1 (enclosed with the above Westinghouse letter) noted additional actions that woro required by Westinghouse's vendors. As a result, the Inspector reviewed the following actions:

Item 16: ENUSA (Empresa Nacional del Uranio, S.A.) FS02-VDAQ-001, Revision 1, dated October 28,1997, related to fuel storago criticality analysos. The document 23

- _ - = _ . . . _ - - _ - - --- _

?

was corrected as committed and associated changes made to the AP600 SSAR in revision 17. The document did not cuntain a revision page documenting the specific nature or purpose of the revision howevor the cover letter did provide some Information on the reason for the chango.

Item 17: A review cf the root causo analysis and correctivo actions associated with a draft response from INITEC on orrors contained in document 1200 CCC 102, dated October 31,1997, appeared reasonable. Westinghouso requested that INITEC provido a formallottor documenting its conclusions on November 13,1997. The Westinghouse action appears to be appropriato.

Item 19: The team reviewod Westinghouse document SSAR GSC 379, Revision 1 dated November 3,1997, documenting the origin of the initial and boundary conditions used in the calculations. The document was originally prepared by Westinghouse vendor NNC, however Westinghouso prepared the revision as committed and appears to have provided the appropriato information.

. Servico Contract Purchase Ordor Review The inspector reviewed the following Westinghouse initiated purchase orders during the inspection.

Penn State Subcontract No. MB24124H This contract was initiated to add non-condensibios to WCOBRA/ TRAC calculations and to assess boron dilution transients. The subcontract required the establishment of an NOA 1 equivalent quality assurance program for the b rk '

performed and a quality assuranco project plan was preparod. Westinghouse audited the subcontractor on October 1011,1995, with no problems noted.

. ANSALDO Subcontract No, MB23889 for AP600 Lona Term Coolino Analyses The contract required that work performed by ANSALDO at Westinghouse be performed under Westinghouse OA WCAP 12601, and that work performed in ANSALDO's otuce be performod in accordance with ANSALDO QA program description ABP 001 POEX OP001000. Work under the contract work was formally audited by Westinghouse in 1991,1993, and 1995.

NNC Subcontract No. MA72217 H <

The contract was initiated to help support WCOBRA/ TRAC code verification of noding of experiments UPTF Tod 21 phases A and B; and CCTF Test 58. The contract required conf ormanco to NNC OA manual OAM 1, Issuo A, as audited and accepted by Wectinghouse during their 1992 and 1997 audits.

OSU Subcontract No. MA02824 H This contract was initiated for the design and scaling of the OSU f acility. The contract required OSU to implomont a quality assurance program in accordance 24

4 0 with NOA 1 and to submit long term cooling test project quality plan LTCT GAH-001 to Westinghouse. OSU was audited by Westinghouse in 1993 and 1994.

• Review of Westinohoure AP600 Internal Quality Audits The inspector reviewed Westinghouse Internal Audit ESBU 94 38, *AP600 FOAKE Design Control," dated October 24 28,1994 (including assessment report dated December 8,1994), which identified 13 findings, and intemal Audit ESBU 95 49, "AP600 FOAKE Design Control," dated December 11 15,1995 (including assessment report dated January 5,1996), which identified 7 .,atively minor findings related to design and document control. Westinghouse concluded that none of the findings identified indicated a significant breakdown of the design control process.

c. Conclusions

. Based on the above, the inspector concluded that Westinghouse was effcctively implementing its AP600 QA program provisions with respect to procurement document control, control of purchased services, audits, and associated corrective actions.

3.8 Entrance and Exit Meetinas An entrance meeting was held on November 17,1997, in which the scope of the inspection was discussed with Westinghouse management and staff. On November 21,1997, an exit meeting was held with Westinghnuse management and staff to diNuss the inspection findings.

4 PERSONNEL CONTACTED The following represents a partiallist of persons contacted during the inspection:

Westinohouse Electric Corooration Ed Cummins, General Manager, New Plant Projects Division David Alsing, AP600 Quality Systems Manager Rao Mandava, Manager, APS00 Plant Engineering Bob Vujuk, Manager, AP600 Projects Brian McIntyre, Manager, Advanced Plant Safety and Licensing Jim Gresham, Manager, Containment and Radiation Analysis Earl Novenstem, Consultant to Westinghouse Eugene Piplica, Lead Engineer, AP600 Test Programs Robert Tupper, Project Engineer

. Ken Kloes, Projects Quality Assurance Engineer 25

(*

5 ITEMS OPENED AND CLO8ED

-Opened 99900404/97 02 01 NON AP600 calculations Inadequate design review 99900404/97 02 02 NON Failure to review GOTHIC code errors 99900404/97 02 03 URI EGOTHIC calculation deficiencies Closed 99900404/95-01 01 NON Reactor Systems Design Certification Test Program 99900404/95 01 02 NON Reactor Systems Design Certification Test Program 99900404/95 0 003 NON Reactor Systems Design Certification Test Program 99900404/95 e . 01 NON As Built Drawings for VAPORE Test Facility 99900404/95 02 02 URI VAPORE Test Facility Calibration Records 99900404/97 01 01 NON Inadequate corrective action 99900404/97-01 02 NON Inadequate quality and technical oversight of INITEC 99900404/97 01 03 URI Acceptability of AP600 design deliverables 26