ML20217L877
| ML20217L877 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 04/03/1998 |
| From: | Black S NRC (Affiliation Not Assigned) |
| To: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| REF-QA-99900404 99900404-97-02, 99900404-97-2, NUDOCS 9804070411 | |
| Download: ML20217L877 (8) | |
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Apr'il 3,1998 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Company P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355
SUBJECT:
REPLY TO NOTICE OF NONCONFORMANCE AND UNRESOLVED ITEM l
Dear Mr. Liparulo:
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Thank you for your letter dated February 27,1998, in response to the Notice of Noncon-forinance and Unresolved item that was issued by the Nuclear Regulatory Commission (NRC) on January 28,1998, as a result of an NRC inspection of Westinghouse Electric Company (Inspection Report 99900404/97-02).
We have reviewed your reply and found it responsive to some of the concerns raised in the Notice of Nonconformance and Unresolved item. However, the staff still has concerns with several of your responses in that they do not adequately address either the specific issue (s) or the generic implications of the issues identified during the inspection. Furthermore, and subsequent to the inspection, the staff continues to identify proposed changes to Chapter 3 of the SSAR which are not related to changes effected to resolve issues raised by the NRC.
These new changes combined with the issues identified during the inspection have caused the staff to question the effectiveness of Westinghouse's AP600 configuration control and design review processes. The enclosure to this letter presents several specific examples of these new concems.
i With respect to your proposed resolution to further confirm the integrity of the design review
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process, we must withhold our conclusion until after the staff completes its review of the results
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of the Design Assurance Review (DAR), scheduled to be presented to the staff on April 13,
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1998. As discussed previously with Westinghouse management, we anticipate that a copy of the DAR report will be provided to the staff at the meeting for inclusion in the AP600 docket.
During this April 13,1998, meeting, we recommend that Westinghouse also be prepared to
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provide a brief synopsis of the AP600 design configuration control process (as described in AP-3.2, " Design Configuration Change Control for the AP600 Program") clearly articulating Westinghouse's bases for continuing to implement chances in the AP600 design documentation while recognizing the adverse impact of such changes on the SSAR information previously submitted to the NRC.
We will review the implementation of your corrective actions, including the DAR process and results, as well as the AP600 design configuration control processes during a future inspection to establish your compliance with the provisions of Appendix B to 10 CFR Part 50 and 10 CFR Part 62. Accordingly, the NRC requests that Westinghouse provide the information requested in the enclosure within 30 days of receipt of this letter.
9804070411 980403 PDR GA999 ENVWEST 99900404 PDR
N. Liparulo 2
April 3,1998 in accordance with 10 CFR 2.790 of the NRC's
- Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room.
Sincerely, 9 <
C.?6al Suzanne. Black, Chief Quality Assurance, Vendor inspection, and Maintenance Branch Division of Reactor Controls and Human Factors
- Office of Nuclear Reactor Regulation i
Docket No.: 52-003
Enclosure:
As stated i
Enclosure:
As stated cc w/encls: See Next Page DISTRIBUTION:
- HOMB R/F Central Files / Docket Files /PDR/Whitebook JRoe RLSpessard BSheron TCollins GHolahan CBerlinger -
DOCUMENT NAME:P:\\WRSPONSE.NON To receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
- SEE NEXT PAGE FOR REMAINING CONCURRENCES OFFICE HOMB/DRChi E
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Docket No.52-003 I
cc:
Nicholas J. Liparulo, Mapger Mr. Frank A. Ross Nu ar Safety and atory Analysis U.S. Department of Energy, NE-42 Nucle and need Technology Division - Office of LWR Safety and Technology Westin se Electric Corporation 19901 Germantown Road
. P.Oc ox 3 Germantown, MD 20874
- Ittsburgh, PA 230 Mr. Russ Bell Mr. B. A. McIntyre Senior Project Manager, Programs Advanced Plant Safety & Licensing Nuclear Energy Institute Westinghouse Electric Corporation 1776 i Street, NW
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Energy Systems Business Unit Suite 300 Box 355 Washington, DC 20006-3706 Pittsburgh, PA 15230 Ms. Lynn Connor Ms. Cindy L. Haag Doc-Search Associates Advanced Plant Safety & Licensing Post Office Box 34 Westinghouse Electric Corporation Cabin John, MD 20812 Energy Systems Business Unit Box 355 Dr. Craig D. Sawyer, Manager Pittsburgh, PA 15230 Advanced Reactor Programs GE Nuclear Energy Mr. Jack Bastin 175 Curtner Avenue, MC-754 Westinghouse Electric Company San Jose, CA 95125 11921 Rockville Pike Suite 107 Mr. Robert H. Buchholz i
Rockville, MD 20852 GE Nuclear Energy 175 Curtner Avenue, MC-781 Mr. Sterling Franks San Jose, CA 95125 U.S. Department of Energy
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NE-50 Barton Z. Cowan, Esq.
i 19901 Germantown Road Eckert Seamans Cherin & McIlott Germantown, MD 20874 600 Grant Street 42nd Floor i
Pittsburgh, PA 15219 i
Mr. Charles Thompson, Nuclear Engineer AP600 Certification Mr. Ed Rodwell, Manager NE-50 PWR Design Certification i
19901 Germantown Road Electric Power Research Institute i
Germantown, MD 20874 3412 Hillview Avenue l
Palo Alto, CA 94303 i
Mr. Robert Maiers, P.E.
l Pennsylvania Department of Environmental Protection Bureau of Radiation Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469
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ENCLOSURE
SUMMARY
OF STAFF CONCERNS WITH WESTINGHOUSE RESPONSE TO NRC INSPECTION REPORT No: 99900404/97-02, DATED JANUARY 28,1998 Nonconformance 99900404/97-02-01, item 1 Paragraph (a)(1)(l) of 652.47," Contents of applications," states that an application for design certification must contain "The technicalinformation which is required of applicants for construction permits and operating lice,nses by 10 CFR part 20, part 50 and its appendices, and parts 73 and 100, and which is technically relevant to the design [ emphasis added] and not site-specific."
Paragraph (b)(2)," Final Safety Analysis Report," of $50.34, " Contents of applications; technical information," states that final safety analysis report shall include "A description and analysis of the structures, systems, and components of the facility, with emphasis upon performance requirements, the bases, with technical justification therefore, upon which such requirements have been established, and the evaluations required to show that safety functions will be accomplished. The description shall be sufficient to permit understanding of the system designs and their relationship to safety evaluations."
10 CFR 50.36 " Technical specifications," 50.36(c)(2)(ii)(C), states that a technical specification limiting condition for operation must be established for "A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or translent[ emphasis added] that either assumes the failure of or presents a challenge to the integrity of a fission product barrier" Nonconformance 99900404/97-02. Item 1, was based on Westinghouse's failure to demonstrate compliance of the AP600 reactor vessel (RV) head vent valves with the requirements of i
650.36(c)(2)(ii)(C) in light of their role during a design basis accident or transient as described in AP600 Calculation CSAR-GSC-189,"AP600 SSAR inadvertent ECCS Analysis," Revision 2. As i
result of this omission, Westinghouse also failed to address:
The availability of unambiguous alarms or indications for increased RCS inventory events, and clear procedural instructions to operators to take appropriate actions within the time-frame assumed in the analyses.
The existence of 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, and The existence of SSAR text providing detail of the analyses that credited the requisite operator actions, in your response to this item, you indicated that this nonconformance represented a difference in approach for Westinghouse and the NRC regarding what should be included in the SSAR. The staff fi' ids this assertion a source of additional concern as it may be inferred that Westinghouse cannot objectively confirm that all structures, systems, or components relied upon in SSAR
I Chapters 6 and 15 analyses have been included in the AP600 Technical Specifications in accordance with 50.36 requirements.
Additionally, the staff disagrees with Westinghouse's conclusion that no steps are required to prevent recurrence of this issue. Subsequent to the inspection, the staff has learned that Westinghouse continues to find design F crepancies between the information contained in Chapter 3 of the SSAR and the AP600 design documentation (as defined in AP-3.2," Design Configuration Change Control for the AP600 Program"). The staff has identified the following examples of Westinghouse proposed changes to Chapter 3 of the SSAR which are not related to changes effected to resolve issues raised by the NRC:
The staff reviewed Revision 7 of SSAR Section 3.8.4.5.1 regarding the application of Appendix B of American Concrete Institute (ACl) ACl-349 for the design of embedded steel anchors and accepted the SSAR commitment. However,in Revision 11 of the SSAR, Westinghouse revised one of the design criteria without discussion with the staff.
In Revisions 3 through 17 of SSAR Section 3.8.4.4.1, Westinghouse committed that the ductility criteria of ACl-318, Chapter 21, are considered in detailing, placing, anchoring, and splicing of the reinforcing steel. This SSAR commitment was reviewed and accepted by the staff. However, in Revision 20 of the SSAR Section 3.8.4.4.1, Westinghouse revised its commitment by adding a new paragraph and indicated that the ductility criteria of ACl-318, Chapter 21, are only to be used for certain so-called " primary structural elements" without discussing the change with the staff in advance. The staff was informed that this SSAR revision was necessary because the ACl-318, Chapter 21 criteria wcre not documented in the Design Criteria and have never been used in the design of these structures.
l Westinghouse documented the load combinations used for the design of seismic Category I structures (other than the containment vessel and containment internal structures) in SSAR Table 3.8.4-1. The staff reviewed this SSAR table (up to and including Revision 17) and found that load combinations documented in the table meet the guideline of SRP Section 3.8.4 and, therefore, are acceptable. However, in Revision 20 of the SSAR, Westinghouse deleted Load Combination No. 6 from this table without discussion with the staff before the i
SSAR revision. The staff was informed that the reason for this SSAR revision is also because this load combination was not documented in the Design Criteria and has never been used in the design.
Figure 3H.5-11 of Appendix 3H to the SSAR shows the basic configuration and details of
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reinforcement of the shield building roof structures. In Revision 20 of this figure (Sheets 1 and 2), Westinghouse provided two #9 reinforcement bars (the area is equal to 2.0 in ) at 2
every 0.45 degrees on the top of the conical roof in the air-inlet column region. The staff reviewe --" ---[--'-d ""-
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d, tail. However, on March d
20,1998, Westinghouse 2
propose vith one #11 bar (the area is equal to 1.56 in ). The l
reason I
, was not clear. With regards to this issue, p
7 Westinc orrection in Revision 22 of the SSAR.
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o For the -
1e PCCWS tank, Westinghouse provided 2.55 in og 2
reinforca 3'-0" and 296'-0" in Revision 20 of the SSAR (SSAR Table 31 r, in an advanced copy of Revision 22 for Chapter 3 of 2
the sam lent was reduced to 1.27 in without any basis.
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The existence of these design discrepancies could potentially render the information in SSAR Chapter 3, submitted to the NRC pursuant to 52.47, invalid or at best indeterminate. If these discrepancies are the result of design errors or incorrect design, the staff assumes and expects that any resultant design changes have been executed in accordance with Westinghouse's AP600 quality assurance processes as described in AP-3.2 and AP-16.2, as appropriate.
Therefore, based on the above, Westinghouse's response to this part of the nonconformance is unacceptable. Furthermore, the staff remains concerned with regards to the effectiveness of the Westinghouse's AP600 configuration control and design review processes in assuring the integrity between the AP600 design documentation and the SSAR information submitted to the NRC pursuant to 652.47. Westinghousc has not yet proposed an adequate resolution for these issues. Additionally, the staff intends to further examine the consistency of design information contained in the SSAR and associated design documentation during a future inspection.
Unresolveditem 99900404/97-02-03 The following issues are part of Unresolved item 99900404/97-02-03, Paragraph b,
" Observations and Findings," of Section 3.6, "QA Review of WGOTHIC Computer Code." In its response, Westinghouse does not acknowledge either that steps have been taken to prevent recurrence or whether corrective actions and/or preventive measures are planned or complete.
The response only addresses the specific items identified by the staff during the inspection and
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any generic implications are ignored. Accordingly, the staff requests that Westinghouse provide the following information:
i NRC Observation 2 (CN-CRA-95-089. " Validation and Verification of INOUT Small Internal-l Use Computer?ronram." Revision 0 and 1.1 (1) Basis behind the statement "there was no error in the original document," when the author stated in the calculation note that if other changes were found to be necessary, then this error (emphasis added) should be corrected?
(2) The response is incomplete. In light of the existence of other calculations and/or analyses that may have used results of this calculation as input, Westinghouse needs to provide its basis for concluding that there am no more open or unresolved issues associated with this calculation.
(3) In light of its willingness to defer correction of errors, how does Westinghouse reconcile the effect of such errors on all and any calculations / analyses affected?
NRC Observation 4 (CN-TA-96-153 AP600. "Steamline Break Mass and Eneray." Rev. 0).
(1) While the four specific errors are unlikely to be critical to the DBA licensing analyses, has j
Westinghouse reconciled these errors, and their effect, with the new analyses provided in i
SSAR Chapter 21?
j (2) Westinghouse letter, dated February 20,1998, on "SSAR 6.2 Markup and Evaluation Model Changes" DCP/NRC 1247 (Attachment 2), stated that the SSAR DBA pressure transients i
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o (DECLG LOCA and MSLB) have been recalculated (emphasis added), in Attachment 2 to this letter, Westinghouse also indicated that " Identified errors in the WGOTHIC clime subroutines, that were previously evaluated to have no significant impact on pressure results (emphasis added), have been corrected."
(a) Please provide the rationale and basis for concluding that there was a need to recalculate the SSAR DBA pressure transients (DECLG LOCA and MSLB).
(b) Please describe the reasons and bases for the change in acceptance criteria that previously allowed Westinghouse to erroneously conclude that identified errors in the WGOTHIC clime subroutines "had no significant impact on pressure results."
(c) Please provide a list of all calculations affected by" Changes in the Evaluation Model input," as described in Attachment 2. Also, describe how such effects have been reconciled -
and their current review status.
.(d) With respect to "NRC Observation 4," please provide an evaluation of the changes described in your February 20,1998 letter, including a discussion of the bases of your conclusions.
NRC Observation 6 (CN-CDBT-92-233. "AP600 WGOTHIC Input Deck Development."
Revisions 2 and 3.
Corrections to errors in WGOTHIC are included in SSAR Chapter 21 calculations as well as additional heat structures, modeling changes (in addition to the three identified) and a "more accurate" representation of the steam system (refer to (2) under NRC Observation 4 above).
Please clarify the meaning of your statement that "Known errors have been corrected" and describe process by which such errors became "known."
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