ML20203J821

Summary of 980121 Meeting W/Siemens Power Corporation in Rockville,Md to Discuss Issues Related to Findings of NRC Insp Rept 99900081/97-01.List of Attendees Encl

ML20203J821
Person / Time
Issue date:	02/23/1998
From:	Wang E NRC (Affiliation Not Assigned)
To:	Essig T NRC (Affiliation Not Assigned)
References
PROJECT-702, REF-QA-99900081 99900081-97-01, 99900081-97-1, NUDOCS 9803040317
Download: ML20203J821 (32)

Text

_ - _. _ - _ _ _ _ _ _ _ - _

t

[ gono %t v

s UNITED STATES

,ya g

NUCLEAR REGULATORY COMMISSION

'f WASHINGTON, D.C. 30W-met

%'..... '/

Tebruary 23. 1998 MEMORANDUM TO:

Thomas H. Essig, Acting Chief Generic lstues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM:

Egan Wang, Reactor Engineer ON "7

Generic issues and Regulatory improvementt, Section Generic lasues and Environmenta! Projects Branc.h Division of Reacter Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF MEETING HELD ON JANUAR't 21,1998 WITH SIEMENS TO DISCUSS ISSUES IDENTIFIED DURING AN NRC INSPECTION On January 21,1998, tne staff held a public meeting with Siemens Power Corporation (SPC) at NRC headquarters in Ror/<ville, Maryland to discuss issucs related to the findings of an NRC inspection conducted in 1997. The purpose of this meeting was to infor'n the staff of SPC's intent to proceed to address concems and deficiencies that the staff documented in the NRC Inspection Report 99900081/97-01. Attachment i lists meet!ng particir.its. Attachment 2 provides a set of slides presented by SPC during the meeting.

SPC representatives presented the briefing in three categories: 1) demand for information issues,2) responses to inspection rJ.nconform&qces, and 3) responses to inspection unresolved items. SPC has established response preparation teams that are responsible in addressing the issues resulted from the NRC inspection. These teams include a SPC internal team, En utility oversight team, and a consultant oversight team. Preliminr, findings of these teams indicate the rout causes of the problems and concerns identi,'ied by NRC inspectors are:

1) too much reliance on technical competence of its staff,2) Inadequato management ovt.rsight, and 3) Inadequate attention of SPC management and staff on compliance with NRC rules and regulations.

SPC representatives also discussed corrective actions in response to the inspection findings.

SPC has initiated a retrofit software verification and validation process on its safety analysis codes to verify and ensure that these codes meet the NRC requirements. Design re review has been initiated to assess Atrium

• 9 and 10 computer codes. In addition, SPC has started a task based engin3ering qualification ar,d training program. a guidell,1e and work practice upgrade program, and a management commitment / engineering culture transformation. SPC is in the process of revising EMF-608, Engineering Software Code Control Requirements to improve methodology development, design and safety analysis process. Additional tests are in f

progress to address nonconformance and unresolved items.

,,,/+

~

9003040317 900223 c

3 i ' ' 5 } O<

PDR YOPRP EMVEXXN l { Il,1,]1,lj

,I, ll1,1 1,l ll l

F l'

llll ll

,Y, a C

PDR i,11 73n

- ; br.h u

s i

wg P R ed'

l l

j T. Essig 2

februry 23, 1998 l

)

SPC representatives stated that SPC is committed to resolve the issues identified in the NRC inspection and meet the rigorous compliance requirements by establishing additional peer j

review process, revising analysis guidelines, and implementing augmented work practice and new approaches.

The NRC staff indicated that SPC seems to be moving in the right direction in addressing the Issues raised by the staff. The staff stated that there should be more communications between SPC and NRC staff to reach a common understanding on technical and management issues, interpretations of safety analysis reports (SERs) tresst be communicated to the staff to ensure 3

consistency.

l I

i Project No. 702 l

Attachments: As stated cc:

Mr. H, Donald Curet, Manager Product Licensing Siemens Power Corporation 2101 Horn Rapid Road P.O. Box 130 Richland, Washington 99352 0130 Mr. Jerry Holm Product Licensing Siemens Power Corporat'on 2101 Horn Rapid Road P.O. Box 130 Richland, Washington 99352-0130 i

t b

i

-..~_..._,-u...

February 23 1998 T. Essig 2-i SPC representatives stated that SPC is cornmitted to resolve the issues identified in the NRC inspection and meet the rigorous compliance requirements by establishing additional peer review process, revising analysis guidelines, and implementing augmented work practice and new approaches.

1 The NRC staff indicated that SPC seems to be moving in the right direction in addressing the 1

issues raised by the staff. The staff stated that there should be more communications between SPC and NRC staff to reach a common understanding on technical and managemeniissues.

interpretations of safety analysis reports (SERs) must be communicated to the staff to ensure j

consistency.

i l

i i

Project No. 702 l

Attachments: As stated

}

cc:

Mr. H. Donald Curet, Manager Product !.lcensing Slemens Power Corporation 2101 Horn Rapid Road P.O. Box 130 Richland, Washington 99352 0130 Mr. Jerry Holm Product Licensing a

Siemers Power Corporation 2101 Horn Rapid Road i

P.O. Box 130 Richland, Washington 99302-0130 DJSTRIBUTION: See ahch page Document name: G:\\980121MT. SUM A

// G

• See previous concurrence -

SQ:[Gg 6Ch[li,[

OFC PGEB SRXB-HOMB-

[Fhulewicz MYssk j'AME EWang:sw LPhillips' GCwalina*

DATE' 02/19/98 2/20-/98 2 /23/98 dl%/98 M/b98 OFFICIAL RECORD COPY

I

.e 1

a t

DISTRIBUTION Mtg. Summary w/Siemens Dated _ February 23, 1998 Hard Cocy Preiset File PUBLIC PGEB r#

OGC ACRS 7

EWang

[

EMail t

SCollins FMiraglia RZimmerman BSheron JRoe DMatthewt GThomas GHolahan GCwalina i

LPhillips RCaruso SBlack APettis, Jr.

EKendrick l

AAttard

]

}

)

[

O i

e I

List of Attendees Nams Organization Phone Number George Thomas USNRC 301-415-1814 Egan Wang USNRC 301-415-1076 Don Curet SPC 509 375-8563 Jerry Holm SF.

509 375-8142 Althela Wyche Bechtel 301-417 4485 Gary Bones Comed 630-663 7282 Terry Rieck Comed 630-663 7687 Allen Williams Consu ner Energy 616-764 2013 Shaw Bien WPPSS 509 377-4212 Edward Kendrick IJSNRC 301 415 2891 Tony Attard USNRC 301-415 2876 Robert Pettis, Jr.

USNRC 301 415 3214 Greg Cwalina USNRC 301 415 2983 Larry Phillips USNRC 301-415 3232 Ralph Caruso USNRC 301-415 1813 Suzanne Black USNRC 301-415 1017 l

Gary Holahan USNRC 301-415 2884 Robin Feuerbacher SPC 509-375-8267 Tony Roscioli PP&L 610-774-4019 James Mal,ay SPC 509 375 8000 Brian Grimes Independent 425 787 0648 Chris Powers SPC 509 375 8004 l

John Kulick PP&L 610-774 7957 Bill Ziegler CP&L 919-M6 3372 I

Glenn Miller PP&L 610 774 7501 I

t t

l

~

~ SIEMENS c

Core Performance Action Plan inspection Response i

cc 7m

. eM

~^

1

~

p g:' W.in l

Wq$

NRC Briefing

\\

ifV,-

\\

t

\\

a%,,

w L

i January 21,1998

~

\\,

,_ m-K 9:00 a.m.

i $

j l

,' t i

C. M. Powers, Director 1

l Quality and Regulatory Affairs l

Attachwnt 2 O

ew,. co, t

i'

I

+

Ii u) u)

i*I i

6 L

o a>

e N

N b

i i

o o

D o

CL n.

O I

l O

d j

.I O

O I

d 1

I us C

E i

l 3

m m

1 Q)

O H

D D

i C

C u)

~

O O

t

• j"",

'p C

C C

,o m

o o

o l (@

• G

'O

'O M

m O

O l

@ C O

E Em E

~o O

g me e m u

CO CO CE i

CD C/)

O C

C a)

O a)

W om ow i

'T C

C

• E

.=

0 o

y3 u g3 V Oc w

o.

a) o a) W DQ U

M V

V) *C u) >

O D

C C

Co y.-

$8 0m 5

(1. o ci e

C o

E mC S2 pA O.

C Q.

O a) o a) C u

W O

EZ ED l

O

(/)

a oC a

e

i sie-s 1

i l

Core Performance Action Plan

[

Inspection Response i

SPC Response Preparation Teams SPC's Internal Team:

4 1

D. A. Adkisson, Mgr., Engineering Quality Performance R. E.

Collingham, Mgr., Safety Analysis Methods i

t

[

H. D. Curet, Mgr., Product Licensing i

l L. J.

Federico, Senior Staff Associate l

R. L.

Feuorbacher, Vice President, Engineenng (Acting)

{

R. C. Gottula, Mgr., PWR Safety Analysis i

j R. G. Grummer, Mgr., Neutronics Analysis Methods i

i J. S.

Holm, Mgr., Product Licensing T. M. Howe, Mgr., Product Mechanical Engineering l

S. E.

Jensen, Team Leader, Safety Analysis Methods L. A Nielsen, Mgr., PWR Neutronics L. D.

O' Dell, Mgr., Code Maintenance

]

onese

4 siemens L

Core Performance Action Plan Inspection Response SPC Response Preparation Teams (continued) i l

Utility Oversight Team:.

e Kevin Donovan, Commonwealth Edison John Spadaro, Pennsylvania Power & Light Al Williams, Consumers Energy i

j Bill Ziegler, Carolina Power & Light 4

l Consultant Oversight Team:

i Tom Murley Brian Grimes Dan Denver j

M99901

^

I Core Performance Action Plan l

Inspection Response Demand for Information issues

\\

l 1)

Restoration of'NRC Confidence in SPC Design I

Methodology implementation SPC's Assessment of Causal Factors r

i Safety Evaluation Report Restrictions Compliance l

Review & Affirmation l

ATRIUM

• 9 & -10 Design Re-review 5

BWR Design Methodology Review j

Design Criteria Disposition Process Changes Margin to Generic Design Criteria Assessment I

I q

• ATRIUM is a trademark of Siemens.

JC

]

~

SIEMENS Core Performance Action Plan j

inspection Response l

Demand for Information issues (continued) l 13 Restoration of NRC Confidence in SPC Design Methodology implementation (continued) l Task-based Engineering Qualification anc Training I

Program Guideline and Work Practice Upgrade Program 9

Management Commitment / Engineering Culture i

Transformation Engineering Quality Oversight i

i i

i i

l 5~.5

4 sisumus l

Core Performance Action Plan i

inspection Response l

1 i

Demand for Information issues (continued) j i

2)

Notification of Significant issues With LOCA EM Changes & New Fuel Designs SPC's Assessment of Causal Factors i

Condition Report /Nonconformance Report With Part j

21 Evaluations l

Conservative and Self-Critical Approach I

l Analysis of Record Peak Clad Temperature (PCT) l Tracking & Reporting Safety Evaluation Report Restriction Clarification L

Process Developing issue Briefings i

e 50 4

1 c

siemess i

Core Performance Action Plan inspection Response i

f a

I Demand for Information Issues (continued) 2D Notification of Significant Issues With LOCA EM l

Changes & New Fuel Designs (continued?

(

i Regulatory Submittal Guideline j

Quality Forum Oversight j

Nuclear Safety Oversight Board j

i 4

i i

e i

e.

SIEMENS 4

Core Performance Action Plan inspect. ion Response Demand for Information issues (continued) 3?

Adequacy of Safety Analysis Codes Documentation SPC's Assessment of Causal Factors EMF-608, Rev.16, Engineering Software Code j

t Control Requirements i

i l

Retrofit V&V Program j

Code Documentation Upgrade Code Manual Update l

I

-,. an r

f

siumsms Core Performance Action Plan 1

Inspection Response l

i Demand for Information issues (continuedD 4)

Assurance That Model Revisions Have Sufficient, l

Accurate. Data Bases SPC's Assessment of Causal Factors t

Correlation Development Guideline i

Design of Experiments Approach e

Statistical Treatment of Uncertainties I

Additional Testing Requirements i

Peer Review Process Design Criteria Disposition Process Nuclear Safety OversigM Board emm

t 7

l SIEMENS l

Core Performance Action Plan i

Inspection Response

<7 7 w.

' ' ;.s:

[

w m.,f j

.p sits %

i NRC Briefing 7

,I i

January 21,1998

• \\i# n i(.

1

~.

m, 3

9:00 a.m.

i $'-4 l

1 t

n H. D. Curet, Manager Product Licensing l

}

CtsP 90 N f

1 l

sismus t

~

I Core Performance Action Plan i

Inspection Response Nonconformance 99900081/97-01-01:

j 1.

SPC failed to verify its application of the ANFB correlation to the ATRIUM-10 fuel design that l

resulted in the local peaking factor and a j

i non-conservative flow-bias that were outside

]

NRC-approved methodology. (Section 3.3.5.13 i

2.

SPC failed to verify its application of the ANFB correlation to the ATRIUM-9 fuel design that l

resulted in an inadequate number of test points and range of conditions to support the design.

(Section 3.3.5.2) i i

i l

l i

siewsms i

Core Performance Action Plan Inspection Response 4

l Causal Factor Summary and Response:

l 1.

Interim modification to ANFB implemented to address t

team concerns. Additional ATRIUM-10 critical power tests were performed and the critical power correlation "ANFB-10" was developed and a topical report j

was submitted for review.

j l

2.

Interim additive constant uncertainties associated l

i with the limited data set for ATRIUM-9B were increased statistically and described in a topical report 4

submitted for review.

l I

i Additional ATRIUM-9B critical power tests are in progress to extend the range of experimental conditions and to confirm additive constant j

uncertainties. A topical report will be submitted to the NRC for approval in May 1998.

t DON WSN

i siemens l

Core Performance Action Plan l

Inspection Response i

f i

. Nonconformance 99900081/97-01-02:

1.

SPC failed to perform adequate V&V on codes bought l

from sources outside SPC. (Section 3.3.2.b.1;l 2.

SPC failed to document input errors or their effect on the analysis. (Section 3.3.2.b.4) 3.

SPC failed to document and confirm assumed causal

. factors and consider variables. (Section 3.3.2.b.5) i 4.

SPC failed to perform adequate V&V on major l

modifications of the RELAX and FLEX codes.

(Section 3.3.2.b.6) i i

I c,

l seemens i

Core Performance Action Plan j

i inspection Response 4

l

. Causal Factor Summary and Response:

1.

V&V and code documentation of some licensing codes is in progress and plans for other procured licensing codes will be provided. EMF-608, Rev.16,

" Computer Code Control Requirements" and SPC l

Policy Guide 10.2 are being updated to address v'&V i

of procured computer codes 2.

EMF-608, Rev.16 will provide more rigor to the j

procedures for SDR reviewers.

j 3.

Same as (2) above.

l 4.

EMF-S08, Rev.16, " Computer Code Control I

Requirements" has been updated to address V&V concerns. Additional V&V has been performed and more is in progress for the FLEX and RELAX codes.

j o m wee j

m o.o, f

1

smucm j

Core Performance Action Plan i

Inspection Response 1

l Nonconformance 99900081/97-01-03:

1.

SPC failed to comply with 10 CFR 50.46.

(Section 3.3.2.b.3) j

Response

1.

SPC will take exception to this nonconformance.

The observed significant temperature change (> 50 F) in a peak cladding temperature (PCT) will be explained 4

to be a temperature from an intermediate. verification step; not the final licensing methodology calculation.

l The subject SBLOCA PCT was not the peak cladding l

temperature for the limiting transient.

c l

Work Practice P104,107, Rev.1, "10 CFR 50 Interactions with the U.S. Nuclear Regulatory Commission and Licensees" enhances procedures for 50.46 reporting.

=~

J i

SIEMENS Core Performance Action Plan Inspection Response i

Nonconformance 99900081/97-01-04:

1.

SPC failed to establish adequate procedures for V&V

)

of code development and modifications.

l (Section 3.3.2.b.2) 2.

SPC failed to establish adequate measures to control l

l code errors.

(Section 3.3.1;l i

l 3.

SPC failed to establish adequate measures for the l

selection of the appropriate entrainment fraction.

i (Section 3.3.3.2:!

l l

l l

i

._.O CMP 99909

sewes L

Core Performance Action Plan Inspection Response l

. Causal Factor Summary and Response:

r 1.

EMF-608, Rev.16, " Computer Code Control

[

i Requirements" has been updated to address V&V procedures for code development and modifications.

l l

2.

The update to EMF-608, Rev.16 and the full implementation of QAP-13 " Control of l

1 Adverse Conditions and Nonconformances" and

{

QAP-14 " Corrective Action and 10 CFR Part 21 l

Evaluations" address measures to control code errors.

3.

Specific entrainment criteria have been finalized and j

documented in a licensing analysis guideline for

{

analysts.

i omew M99901 i

?

l L

Core Performance Action Plan Inspection Response i

i

. Nonconformance 99900081/97-01-05:

I

)

l 1.

SPC failed to establish an adequate training program.

(Section 3.2.1.b.3;l l

. Causal Factor Summary and Response:

j 1.

Development and implementation of Work Practice P104,105, " Personnel Training and Qualification."

L The work practice addresses and corrects the training deficiencies identified in the NRC document by pre /iding:

a) a method and a requirement to d ane the knowledge and skill level abilities required l

l to perform engineering related tasks, b? assignments l

to become qualified, and c3 a procedure for l

evaluating and recording the effectiveness of the training.

1 l

'_C

SIEMENS Core Performance Action Plan Inspection Response c.

k i, f.

l

-#7 y

i

, n _.;,h Y'.lhf[

Q NRC Briefing j

p p

January 21,1998 fA 1

.. e 9:00 a.m.

}q t

a s

i u

J. S. Holm, Manager Product Licensing l

l

~

01/19199 08P 98 tiet il.

SIEMENS Ccce Performance Action Plan Inspection Response

. Unresolved item 99900081/97-01-06:

. Additional information is needed to resolve questions about the use of Semiscale pump data versus relevant pump data as required by Appendix K to 10 CFR Part 50.

(Section 3.3.4.1.b.1)

. Response:

. Submitted December 3,1997.

. Compliance of SPC's EXEM/PWR LOCA Evaluation Model

[

with 10 CFR 50 Appendix K requirements demonstrated by validation with additional applicable two-phase pump performance data.

ESC

. siemens Core Performance Action Plan Inspection Response

. Unresolved item 99900081/97-01-07:

. Additional information is needed to demonstrate that the FCTF reflood heat transfer correlation produces conservative results for other than 17x17 rod arrayed fuel designs. (Section 3.3.4.2.b.1)

. Response:

. Submitted September 23,1997.

. Comparisons made between predictions with the FCTF heat transfer correlation and measured peak cladding temperatures from CCTF facility.

Predictions conservative.

, 'SIEMENS Core. Performance Action Plan Inspection Response Unresolved item 99900081/97-01-08:

. Additional information is needed to demonstrate that the FCTF reflood heat transfer correlation produces conservative results by either providing documentation that the 17x17 rod array data was analyzed using a valid data analysis code or perform a complete reanalysis of the data. (Section 3.3.4.2.b.2)

.- Response:

. Submitted August 6,1997.

. SPC confirmed data was originally analyzed using a valid code.

SPC redocumented the code and reanalyzed the test data resulting in a confirmation that the original data reduction was correct.

l l

=

m

MIMILEME@EEEEMEW

' SIEMENS

[

1 Core Performance Action Plan Inspection Response

. Unresolved item 99900081/97-01-09:

. Additional information is needed to demonstrate the adequacy of SPC's underlying assumptions about the different coefficients for each fuel: design to which the l

ANFB correlation is applied. (Section 3.3.5.2) 1

Response

. Additional tests are being performed that will address the app licability of the coefficients to ATRIUM-9B (May 1998).

' SIEMENS Core Performance Action Plan Inspection Response

. Unresolved item 99900081/97-01-010:

. Additional information is needed to demonstrate that the

' analysis performed for the St. Lucie Unit 1 Cycle 14 reload was consistent with NRC-approved methodology.

l (Section 3.5.2.b.2)

. Response:

. Use of physics data generated by ANC rather than XTG not explicitly approved by NRC.

cw

' SIEMENS Core Performance Action Plan Inspection Response i

. Unresolved Item 99900081/97-01-010 (continued):

i Response (continued):

i

. Analyses technically adequate.

i

. Westinghouse methodology document approved by NRC.

. FPL benchmark document approved by NRC for Turkey Point plants also contained physics comparison data for St. Lucie r

Unit 1.

i

. Comparisons of FPL and SPC generated data for a previous cycle.

i

> Licensee utilized analyses under 10 CFR 50.59.

I d

l

(

3

~.,

' SIEMENS Core Performance Action Plan s

inspection Response

. Unresolved item 99900081/97-01-11:

i

. Additional information is needed to describe how SPC's topical report XN-NF-81-58(PXA) and the associated SER l

address the use of the average Apsnt, densification.value j

instead of the largest mean Apsntr densification value when applying the 95% UCL, and to address the confusing statements in that topical report and associated SER. (Section 3.5.3)

. Response:

. Submitted May 1997.

Analyses performed consistent with NRC-approved SPC methodology.

. SPC will submit a modification to its methodology i

1 consistent with Regulatory Guide 1.126 (August 1998).

_a 1

i m