ML20198L413

Forwards Westinghouse AP600 Final Safety Evaluation Rept Chapter 21, Testing & Computer Code Validation, Section 21.7, Quality Assurance Insp

ML20198L413
Person / Time
Site:	05200003
Issue date:	01/09/1998
From:	Black S NRC (Affiliation Not Assigned)
To:	Quay T NRC (Affiliation Not Assigned)
References
NUDOCS 9801160023
Download: ML20198L413 (13)

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NUCLEAR REGULATORY COMMISSION 7565 o $ WASHINGTON, o.C. 200eH001

,,,,, January 9, 1998 MEMORANDUM TO: Theodore R. Quay, Director Standardization Project Directorate DMslon of Reactor Program Management, NRR FROM: Suzanne C. Black, Chief '

Ouality Assurance, Vend r inspection, and Maintenance Branch Division of Reactor Controls and Human Factors, NRR <

SUBJECT:

WESTINGHOUSE AP600 - FINAL SAFETY EVAI.UATION REPORT -

CHAPTER 21, " TESTING AND COMPUTEli CODE VALIDATION,"

SECTION 21.7, " QUALITY ASSURANCE INSPECTIONS" Plant Type: AP600 f Project No: 52-003 TAC No: M98053 Licensing Status: Design Certification Application Rosponsible PD: PDST Review Branch: HQMB Review Status: Complete The purpose of this memorandum is to forward the Quality Assurance, Vendor inspection, and Maintenance Branch (HQMB) final safety valuation report (FSER) input on Chapter 21 Testing and Computer Code Validation," Section 21.7, " Quality Assurance inspections" (attar.hment).

i If you nave any questions regarding the attached information, please contact Juan Peralta at 415-1052.

Attachment:

As stated cc: T. Kenyon W.' Huffman I

N RC I U CEN T &l CilP Y g g o3 9905160023 980109 PDR ADOCK 052OOGt3 E PDR

.c o m

FSER INPUT ON CHAPTER 21,7, " QUALITY ASSURANCE INSPECTIONS"  ;

21.7 Quality Assurance inanections 21.7.1 QA Requirements for AP600 Design Certification Testing Activities ,

in Chapter 17 of the AP600 Standard Safety Analysis Report (SSAR), Westinghouse describes its quality assurance (QA) program for the design phase of the AP600 Advanced Light Water Reactor (ALWR) Plant Program, in Revision 5 to SSAR Chapter 17, Westinghouse stated that effective March 31,1996, activities affecting the pality of items and services for the AP600 Project during design, procurement, fabrication, inspection, and/or testing would be performed in accordance with the quality plan described in Westinghouse's

• Energy Systems Business Unit - Quality Management System,"

(QMS) Revision 1. The staff's review and approval of Revision 1 to the Westinghouse QMS was documented in a letter from Suzanne Black (NRC) to N. J. Liparuto (Westinghouse), dated February 23,1996.

Activities perfonned prior to March 31,1996, were performed in accordance with the quality i 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, were performed in accordance with the quality assurance plan described in topical report WCAP 8370/7800," Energy Systems Business ,

Unit Nuclear Fuel Business Unit, Quality Assurance Plan," Revision 11A/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 Assurance Program Plan," currently dated January 1997, a project specific QA plan, was developed by Westinghouse to enhance the QMS in specific areas and to establish additional commitments needed to support the AP600 Design Certification 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 Certification and FOAKE programs and for control of the techr,;calir terface between Westinghouse and engineering groups and suppliers provMng engineering services under such programs. WCAP-12600 also addresses Westinghr..;se's commitments to the provisions of ANSI /ASME NOA 1-1989 Edition through NOA 1b-1991 Addenda for the AP600 project.

Westinghouse also developed WCAP 12601 ("AP600 Prcgram Operating Procedures") to establish requirements and responsibilities for developing, approving, implementing, revising, and maintaining operating procedures to meet the QA and administrative requirements of the AP600 program, Overall, the staff conducted in-depth inspections of the five principal Westinghouse AP600 design certification test programs. The programs were inspecied to determine if design and testing activities performed to support design certification of the AP600 advanced reactor were i conducted under the appropriate provisions of WCAP-12600.

Attachment L

9 21.7.1.1 Core Makeup Tank Test Program The staff conducted a QA implementation inspection at Westinghouse's facilities in Monroeville, Pennsylvania during the week of May 1,1995 (NRC Inspection Report 99900404/95-01). During the inspection, the team assessed the Westinghouse implementation of the applicable QA criterla essential to support the AP600 design certification application, including design cer-tification testing. Specifically, the team evaluated the effectiveness of the QA program and controls in goveming the implementation of the AP600 core makeup tank (CMT) design certification testing programs.

For testing activities performed by the Westinghouse Test Engineering Group at the Waltz Mill facility, including the CMT test program, Westinghouse developed a specific QA plan or project quality plan (PQP) to implement the applicable provisions of WCAP 12601. This PQP established QA controls for the conduct of testing activities and encompassed design, construction and configuration control criteria for the CMT test program.

The inspection team reviewed the POP and the CMT test program specification to determine if design certification testing activities performed at the Waltz Mill facility were conducted in accordance with the appropriate provisions of Westinghouse's 10 CFR Part 50, Appendix B, QA program (WCAP 8370). Specifically, the inspection team examined the areas of performance and activities within the scope of the PQP, such as organizational responsibilities of the testing group, to confirm that activities in the pertinent areas were performed under suitably controlled conditions by property trained personnel, and that the test data collected during such activities were appropnately recorded and maintained.

The inspection team found that Westinghouse, in general, was adequatwy implementing the AP600 QA program plan with one exception: Westinghouse had conducted one inadequate audit at Alden Research Laboratory, Inc. (Alden Research). On October 20,1994. the Energy System Business Unit (ESBU) Projects Quoity Assurance organization had established the acceptability of calibration services provided by Alden Research for AP600 design certification activities on the basis of an audit conducted on March 4,1992. The audit, however, had not given adequate objective evidence that Alden Researr.h was a supplier of calibration services as a basic component"(as defined in 10 CFR Part 21), nor had it demonstrated the acceptability of Alden Research's techn! cal and quality program capabilities vrith respect to the requirements in 10 CFR Part 21. This was identified as Nonconformance 99900404/95-0103.

In Letter NTD NRC-95-4549 (September 12,1995), Westinghouse responded to Ncnconformance 99900404/95-0103. Westinghouse stated that Alden Research had been audited on May 25,1995, and that although Alden Research's QA program needed improvement in sm.e*al areas of its implementation, nothing had been found that would affect the calibrations performed on instrumentation for the AP600 design certification testing program. The staff found Westinghousts reply responsive to the inspection finoing and, in a letter dated December 5, 1995, told Westinghouse of its conclusion and stated that it would confirm during a future inspection the implementation of the proposed corrective and preventive actions relatsd to the nonconformance to establish that full compilance had been achieved and maintained. This was identified as Confirmatory item 21.7.1.1 1.

During an inspection (NRC Inspection Report 99900404/97 02) on November 17 through 21, 1997, the NRC verified that these actions had been complated and documentea. Based on the limited scope of calibration services as a Basic Compor..nl perfomled by Alden Research, and 2-

8 based on Westinghouse's conclusions that no audit findings identified impacted the calibration activities performed to support AP600 testing, the inspection team agreed that corrective actior's taken by Westinghouse were appropriate. On these bases, Confirmatory item 21.7.1.1 1 is closed.

21.7.1.2 Automatic Depressurization System Test Program The staff conducted a QA implementation inspection at the Ente per le Nuove Tecnologie, L'Energia e L'Ambiente's (ENEA's) Valve and Pressurizer Operating Related Experimants (VAPORE) test facility in Cassacia, Italy, during the week of July 24,1995 (NRC Ins,,=ction Report 99900404/95-02). ENEA implemented the pertinent provisions of WCAP 8370 at the VAPORE facility through its use of ENEA document AP600 GQ9402 (" Quality Assurance Plan

Description:

Aa600 Test Program conducted at the VAPORE Plant in ENEA Cassocia (Phase B)").

Under a technical cooparation agreement, Westinghouse, ENEA, and Ansaldo S.p.A. conibined resources to conduct testing at the ENEA's VAPORE test facility with two major objectives: (1) advance knowledge and understanding of passive safety system operations and (2) conduct testing of the APG00 automatic depressurization system (ADS) to provide both design information and data for computer code validation efforts needed to support AP600 design certification.

The VAPORE test specification required that testing, designed to demonstrate overall ADS performance verification, be conducted under a QA program that conforms to the requirements of the American Society of Mechanical Engineers (ASME) standard NQA 1," Quality Assurance Program Requirements for Nuclear Facilities," 1989 Edition through NQA 1 1991 Addenda.

During the inspection, the team reviewed the pertinent documents to determine if design certification testing activities performed at the ENEA VAPORE test facility during the ADS test program were conducted in accordance with the appropriate provisions of Westinghouse's 10 CFR Part 50, Appendix B, QA program (WCAP-8370). The team examined the performance of activities in specific areas within the scope of ENEA document AP600-GQ9402 (i.e., test control, test instrument calibration, facility and records configuration control) to confirm that activities in these areas were performed u'ider suitably controlled conditions by property trained personnel and that the test data collected during such activities were appropriately recorded and maintained.

On the basis of its review of inese areas, the team concluded that the QA program described in AP600-GQ9402, in conjunction with Westinghouse's implementation of the pertinent criteria of WCAP 12601, gave sufficient evidence of overall QA program implementation appropriate to design certification testing, except for one finding and one unresolved item. These were iden-tified as Nonconformsnce 99900404/95-02-01 and Unresolved Iteen 99900404/95 02 02, j respectively.

80Dgonformance 99900404/95-02 01 The team found that test facility as-built drawings, as required by the test specification and by ENEA doeurnent AP600-GQ9402, had not been prepared for the AP600 ADS Phase B testing at VAPORE.

I 1

a In Letter NTD-NRC 95-4591 (November 9,1995) Westinghouse responded to Nonconformance 99900404/95-02-01, Westinghouse stated that an audit of ENEA conducted in June 1995 had also uncovered an issue concoming the as built configuration documentation of the VAPORE test facility. Ansaldo had been hired to modify the facility for AP600 testing and was responsible for preparing the appropriate documentation.

A Westinghouse review of all documentation at Ansaldo offices in Genoa, Italy in July 1995 revealed that Ansaldo had used a combination of shop drawings and field measurerrents to create the as-built documentation. After assessing the elements used to define the as built configuration of the ADS test facility as well as the supporting documentation on the procurt-ment and fabrication of the piping sections, Westinghouse concluded that the as built documentation was in compliance with AP600 project and QA requirements. The staff reviewed Westinghouse's response and found it responsive to the concem raised in the nonconformance. In a letter dated December 5,1995, the staff notified Westinghouse of its finding and stated that the implementation of proposed corrective and preventive actions related to the nonconformance would be reviewed during a future inspection to establish that full compliance had been achieved and maintained. This was identified as Confirmatory item 21.7.1.21.

During an inspection (NRC Inspection Report 99900404/97 02) on November 17 through 21, 1997, the NRC reviewed a summary of Westinghouse's assessment activities at Ansaldo and concluded that appropriate actions had been taken to resolve this nonconformance. Accordingly, Confirmatory item 21.7.1.21 is cioded.

Unresolved Item 99900404/95-02 02 The team found that the ENEA QA program did not have adequate measures to effectively control the calibration status of reference instruments or standards. No provisions were in place to require their recalibration at the requisite intervals. The test specification required that the following measures be included in the detailed test procedure (s): (1) provisions for ensuring that calibration of test equipment is traceable to recognized national standards and (2) verification and documentation, to be submitted to Westinghouse, by the testing organization that the facility instruments were calibrated before :esting. The ENEA QAPD document, AP600-GQ9402, implemented these requirements.

During the inspection, the team confirmed that all test instruments used in the ENEA VAPORE test facility had been calibrated, both before and after testing, using standards or reference instruments traceable to the Servizio Italiano di Taratura (SIT) (Italian calibration system). Also, the team r6 viewed the calibration records of the VAPORE test facility which provided evidence of traceability to the appropriate ENEA controlled SIT certified standards. This review also gave evidence of the adequacy of the calibration status of facility Instrumentatiun during each testing phase. The team found, however, that the ENEA QA program did not contain adequate measures to effectivefy control the calibration status of reference instruments or standards used for instrument calibration, as no provisions were in place to require recalibration by SlT at the requisite intervals. Pending confirmation by Westinghouse that this lapse in the SIT-certified calibration interval for the ENEA reference instruments and standards did not undermine or adversely impact the VAPORE ADS test results, this issue would remain unresolved, in Letter NTD NRC 95-4591 (November 9,1995) Westinghouse responded to Unresolved item 99900404/95-02 02, Westinghouse stated that ENEA had submitted reven instruments involved in AP600 test instrument calibrations to a nationally certified laboratory. Westinghouse added that as of October 1995, fivs of the instruments had been found to be within expected

9 tolerances. The remaining two instruments would be tested by the end of November 1995. The staff found Westinghouse's reply responsive to the concem raised in the unresolved item. In a letter dateJ Dec. ember 5,1995, the staff notified Westinghouse that the implementation of propo ed corrective actions related to the unresolved item wofd be reviewed during a future inspection to establish their acceptability. This was identified as Confirmatory item 21.7.1.2 2.

During an inspection (NRC Inspection Report 99900404/97 02) on November 17 through 21, 1997, the NRC verified t~ n at ENEA submitted the seven instruments involved 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. Accordingly, Confimiatory ttem 21.7.1.2 21s closed.

21,7.1.3 Passive Residual Heat Removal System Test Program When Westinghouse conducted this test program, a configuration of straight vertical tubes represented the in plant configuration of the passive residual heat removal (PRHR) heat exchanger (PRHRHX). Subsequently, however, Westinghouse modified the PRHRHX design to a vertical C shaped tube bundle. The staff asked Westinghouse to justify in detail the applicability of the straight tube PRHRHX test data to the new C tube configuration. This was identified as Open item 21.3.31 in the DSER.

While conducting a OA implementation inspection of the CMT and PCCS LST test programs at Westinghouse's facilities in Monroeville, Pennsylvania during the week of May 1,1995 (NRC Inspection Report 99900404/95 01), the staff reviewed the PRHR test program design files.

Although Westinghouss did not seem to have conducted formal design reviews, all meetings, discassions, and other communications relevant to the test program had been documented in memoranda at the initiative of the responsible test engineer. As a result, a record of decisions concerning facility design and operation for this test program exists.

The team questioned the apparent lack of as-built drawings or identification of critical dimensional attributes for the PRHR test program. In discussions with the test engineer who was responsible for the program and the manager of test engineering, the team learned that there were only three critical attributes for this relatively small scale, separate-effects test: the length, diameter, and thickness of each of the three tubes used to simulate the operation of the PRHR heat exchanger. These " critical dimensions" were measured and documented in the final test report for the program. Although these critical dimensions were not formally identified as such, the team concluded that the PRHR test report would contain sufficient information for the staff to issue its finding on the technical acceptability of the program.

The staff has completed its review of the PRHRHX test program, and has concluded that heat exchanger heat transfer riodels based on the 3-tube test data are applicable to the C-tube design in the APG00. Discussion of data applicability and the details of the staff's review of this program can be found in lections 21.3.3 and 21.5.3, respectively.

21.7.1.4 OSU/ APEX Test Program The s;aff conducted an inspection at the Oregon State University (OSU) Advanced Plant Experiment (APEX) test facility in Corvallis, Oregon, during the week of August 29,1994 (NRC Inspection Report 99900404/94 01). Specific quality provisions applicable to the OSU facility were identified in AP600 Document Number LTCT-GAH-001 ("AP600 Long Term Cooling Test Project Quality Plan")(PQP). This plan established controls for the design and construction of the test facility as well as for the conduct of testing activities. -

The inspection indicated that Westinghouse, in general, was adequately implementing the AP600 project QA program at OSU, except for a few findings in certain areas. Specifically, the team identified findings with program implementation with respect to (1) the calibration of instrumentation, and (2) the accuracy of the facility as-built drawings. These issues were identified in Nonconformances 99900404/94-0101 and 99900404/94-0102. Also, a concem about OSU's acceptance of test results that failed to meet established test acceptance criteria, without an evaluation and disposition being included in the test design record file, was identified as part of Unresolved item 99900404/94-0103, Hanconformance 9ED0404/94-0101 The team found that contrary to the provisions of the PQP, The Industrial Company (TIC) which calibrated thermocouples at the OSU/ APEX test fael!ity, had hired Industrial Instruments, Inc. to calibrate the primary standards and had accepted the calibration certificates without having performed audits or a surveillance of that company. Also, OSU had failed to verify the validity of the flowmeter calibration ce:tificates received from Foxboro Company, an unaudited commercial supplier, in Letter NTD-NRC 95-4408 (February 15,1995), Westinghouse responded to Nonconformance 99900404/94 01-01. Westinghouse stated that a review, performed to identify suppliers of calibration services to the OSU test facility, revealed six suppliers for which QA oversight was needed to support test instrument calibration certifications. Because four of ; hose suppliers were not on the Westinghouse qualified suppDers list, they were audited. Westinghouse added that these audits revea'ed no conditions that would invalidate the calibrations performed on any OSU test facility instruments. After the audit, Westinghouse sent all devices used to perform the post-calibration checks to a qualified supplier of calibration services for calibration. To prevent future problems, Westinghouse would revise the OSU PQP to describe the requirements for procurement of calibration services and calibration of commercially procured test instrumentation and calibration equipment, During a subsequent QA implementation inspection at Westinghouse's facilities in Monroeville, Pennsylvania during the week of May 1,1995 (NRC Inspection Repor199900404/95 01), the team reviewed the Westinghouse audit reports of the four suppliers of calibration services not on Westinghouse's qualified suppliers list (QSL) to confirm that the supplier's QA programs were suitable to ensure reliable instrument calibration. In general, the reports demonstrated that calibration services supplied by these companies were adequate. Some questions were raised with regard to the audit of Morris Scale, but it was determined that the instruments in question (load cells) were not used for any critical measurements or to determine key facility parameters, such as energy and mass balances. Calibration results were to be included as part of the final data report for the APEX test program. Westinghouse submitted this report on June 13,1995.

The team confirmed that Westinghouse had revised the OSU APEX PQP to describe re-quirements for procurement of calibrati>n serv!ces and calibration of commercially procured test instrumentation and calibration equipment as stated by Westinghouse in its letter of February 15, 1995. The team verified that all other corrective and preventive actions identified in the subject letter had been completed and documented. On this basis, Nonconformance 99900404/94-01-01 is closed.

Nonconformance 9990Q404/94-01.Q2 The team found that contrary to the provisions of the PQP, (1) no procedures or instructions had been available identifying methods, accuracy, and/or the acceptance criteria to be used for determining the as built elevations and dimensions of the OSU/ APEX test facility and (2) the TlO Calibration Procedure 19, which had been used to calibrate thermocouples for the long term cooling tests at the OSU facility, had not noted who originated, reviewed, or approved the document.

In Letter NTD-NRC 95-4408 (February 15,1995), Westinghouse responded to Nonccnformance 99900404/05-01 02. Westinghouse stated that a specific set of requirements were being incorporated into the OSU POP for documenting critical dimensions, and that the two Tic procedures cited in the nonconformance had been superseded by two OSU procedures which corrected the inadequacies identified by the team. As preventive actions, Westinghouse stated that Procedure AP 3.11 in WCAP 12001 was being revised to address documentation of critical attributes of test facilities, and that the OSU APEX PQP was being revised to include requirements for preparing instrument calibration procedures.

During a subsequent QA implementation inspection at Westinghouse's facilities in Monroeville, Pennsylvania during the week of May 1,1995 (NRC Inspection Report 99900404/05-01), the team verified that Westinghouse had incorporated a set of requirements into the OSU/APCX POP for documentinD cntical attributes of the facility design. The reverification of critical dimensions had been completed, and a report was being prepared.

The team also veri'ied that two thermocouple calibration procedures used by TIC for APEX had been replaced by two OSU procedures which were incorporated into the APEX facility maintenance plan. The team verified that the two procedures properly indicated originator and management approvals and that other corrective and preventive actions identified in the February 15,1995, letter had been completed and documented by Westinghouse. On this basis, this part of Nonconformance 99900404/94 0102 is closed.

Unresolved itemj9900404/94-0103 The team found that OSU had accepted test results which had failed to meet established test acceptance criteria, without placing an evaluation and disposition in the test design record file. It appeared that at least two facility characterization tests did not meet the acceptance criteria.

Nevertheless, these two tests were not terun, and no documentation was available at OSU to indicate the disposition of the apparent deviations.

Westinghouse's QA procedures require that test acceptance documentation contain evidence that any deviations occurring during a test have been evaluated and, if necessary, dispositioned.

Westinghouse stated that acceptability of a test is documented in the quick look report (QLR) for that test. A'so, the final data report (FDR) for each test program would contain a fulllisting of all tests performed in the program, would identify those tests considered to be invalid, and would explain why tests considered to be invalid had been disqualified. Westinghouse's Test Engineering Group performs the evaluations and prepares the OLRs and the FDRs.

Westinghouse added that it, not the testing organization (OSU); makes the final determination about the acceptability of test results and that documentation of this evaluation and its disposition would be placed in the official design record file at Westinghouse offices in Monroeville.

~1-l l

During a subsequent QA implementation inspection at Westinghouse's facilities in Monroeville, Pennsylvania during the week of May 1,1995 (NRC inspection Report 99900404/95 01), the team discussed the results of the OSU inspection with Westinghouse's Test Engineering Group.

The team leamed that for one of the tests related to the unresolved item at OSU, the data had been determined, after the fact, as not essential for facility characterization. For the second test, the flows that had been attained in the test had not met the acceptance criteria but were determined to be useful to characterize the system and were accepted on that basis.

Discussion of the reasoning used in making these decisions was to be included in the final data report (FDR) and the test analysis report (TAR). Although the reports had not been issued at the time of the inspection and, therefore, could not be reviewed to ascertain that the dispos! tion of these deviations had been appropriately documented, after speaking with Westinghouse's Test Engineering Group, the team concluded that the evaluations had been performed, that the reasoning behind the decisions on data acceptability and usefulness was sound, and that the QA program requirements had been met. Subsequeat review of the OSU FDR confirmed that discussion on the acceptance basis had been included. Therefore, this part of Unresolved item 99900404/94-0103 is closed.

21.7.1,5 SPES 2 High Pressure, Full 41elght Integral Systems Test Program The staff conducted a QA Implementation inspection at the Societa' Informazioni Esperienze Termoldrauliche (SIET) SPES-2 test facility in Piacenza, Ite'y, during the week of October 10, 1994 (NRC Inspection Report 99900404/94 01).

The quality related activities associated with the AP600 full-height, full pressure integral system tests performed at SPES-2 were conducted under the auspices of a cooperative agreement between Westinghouse, ENEA, Ente Nazionale Per L'Energia Elettrica (ENEL), and SOPREN-Ansaldo. The test program provided thermal-hydraulic data for computer code validation and simulated the operation of the AP600 passive safety systems. SIET described the general features of its QA system in its quality manual,0000100. Additional quality plan provisions specific to AP600 testing were also detailed in Procedure 00006-Q0 92, " Quality Plan Relative to Nuclear Area Orders," which cross referenced European quality standards to the criteria of NOA 1, in order to conduct these confirmatory tests, SIET had implemented an intemal quality system which incorporates the requirements of both the Intemational Organization for Standardization (ISO) Code Series 9000 (UNI EN 29000) and the Italian Code UNI 8450 (1983).

During the inspection, the team found that Westireghouse had established appropriate procedural controls at the SPES 2 test facility which property incorporated the applicable provisions of WCAP 8370 except for a few findings in certain areas. Specifically, the team identified a nonconformance with program implementation with respect to the accuracy and preparation of facility a.s-built drawings. These issues were identified as part of Nonconformance 99900404/94 01 02. Also, the team identified an unresolved item conceming SIET's acceptance of test results that had failed to meet established test acceptance criteria, without an evaluation and disposition being placed in the test design record file. This was identified as Unresolved item 99900404/94-0103.

Nonconformance 99900404/94-01-02 The team found that contrary to the provisions of WCAP-8370 and WCAP 9565, (1) no

!nstructions or procedures were available at the SIET SPES 2 test facility to verify critical dimensions or configuration of commercial manufacturing drawings before accepting these drawings as representing the as built design condition and placing them under the SIET QA system, and (2) the procedures for determining system and component elevations and arran-gements at the SPES 2 test facility did not prescribe the requireu accuracy or include any acceptance criteria for such measurements.

In Letter NTD NRC 95-4408 (February 15,1995), Westinghouse responded to Nonconformance 99900404/95-01 02. Westinghouse stated that SIET had prepared a procedure for AP600 test configuration control, which would list the applicable portions of SIET Document 00006-QQ 92 related to the requirements for component inspections. Also, SIET confirmed that inspections had been performed for all vessels constructed to simulate parts of the AP600 design. SIET had compiled all inspection records and would venfy that the component acceptance inspections were performed in accordance with SIET Document 00000-00 92. With respect to the other issue identified in the nonconformance, Westinghouse stated that SIET had prepared an AP600 test configuration control document (00011-Q0 94), which contained specific requirements related to the identification of critical facility dimensions, including applicable tolerances. Also, SIET would revise the SPES 2 test specification to identify the critical dimenslens of the facility and the required tolerances. As preventive actions, Westinghouse stated that it would revise relevant procedure (s)in WCAP 12601 to address documentation of critical attributes of test facilities, in the course of a subsequent QA implementation inspection at Westinghouse's facilities in Monroeville, Pennsylvania during the week of May 1,1995 (NRC Inspection Report 99900404/95 01), the team verified that SIET had developed a procedure for inspecting components acquired from commercial contractors. In addition, SIET had reviewed records of equipment inspections for the SPES 2 test facility, and had confirmed that vendor drawings and specifications properly reflected as built attributes of relevant components. The team verified that the SPES 2 test specification had been modified to identify facility critical dimensions and associated required accuracy, and that as built critical attributes were confirmed by SIET. On this basis, this part of Nonconformance 99900404/94 0102 is closed.

1)ntt1Dlted_lltm3.9900404/94 0103 The team identified an unresolved item concerning SIET's acceptance of test results that failed to meet established test acceptance criteria, without an evaluation and disposition being placed in the test design record file. Westinghouse's QA procedures require that test acceptance documentation contain evidence that any deviations occurring during a test have been evaluated and, if necessary, dispositioned. Westinghouse stated that acceptability of a test is documented in the quick look report (QLR) for that test. Also, the final data report (FDR) for each test program would contain a fulllisting of all tests performed in the program, would identify those tests consid9ted to be invalid, and would explain why a test considered to be invalid had been disqualified. Westinghouse's Test Engineering Group performs the evaluations and prepares the OLRs and the FDRs. Westinghouse stated during the inspections that it, not the testing organization, makes the final determination about the acceptability of test results and that documentation of this evaluation and its disposition would be placed in the official design record file at Westinghouse offices in Monroeville, Pennsylvania.

During a subsequent QA implementation inspection at Westinghouse's facilities in Monroeville, Pennsylvania during the week of May 1,1995 (NRC Inspection Report 99900404/95-01), the team discussed Westinghouse's process for the evaluation and disposition of test results that do not meet the acceptance criteria, as described above. After discussing this process with 9

Westinghouse's Test Engineering Group, the team concluded that the review procedure fulfills Westinghouse's documented AP600 QA requirements. On this basis, this part of Unretolved item 99900404/94-0103 is closed.

21,7.1.6 Large-Scale Pasi,1ve Containment Cooling System Test Program The staff conducted a QA implementation inspection at Westinghouse's facilities in Monroeville, Pennsylvania during the week of May 1,1995 (NRC Inspection Report 99000404/95-01). During the inspection, the team reviewed the Westinghouse Irnplementation of the applicable QA cnteria essential to support the AP600 design certification application, including design certification testing. Specifically, the team evaluated the effectiveness of the QA program and controls in goveming the implementation C the AP600 passive containment cooling system (PCCS) Large-Scale Test (LST) design certification testing program.

Testing activities performed at Westinghouse's Science and Technology Center (GTC), including the PCCS LST test program, were conducted under direct oversight by the Energy System Dusiness Unit (ESBU) QA organization. A separate STC based QA plan was not identified as a requirement for STC project tasks. The quality related activities associated with the PCCS LST tests were controiled in accordance with the test specifications and the test procedures. No specific LST quality plan was developed, however, a one page quality plan that was prepared for the integral extension test was app!!ed to the LST.

The results of the inspection indicate that W, in general, was adequately implementing the AP600 Quality Assurance Program Plan with the exception of a few findings in certain areas.

Specifically, the team identified Nonconformances with program implementation with respect te (1) test facility configuration control, and (2) the accuracy of the facility as built drawings These findings were identified as part of Nonconformances 99900404/95-0101 and 999b0404/95 02, respectively. Also, the team identified a concem with respect to the disposition of test deviations between the Test Engineering group and the Containment ar,d Radiological Analysis group (SDSER Confirmatory item 21.7.1.6-1).

Ngacnnformance 99900404/95-0101 The team fourid (NRC Inspection Report 99900404/95-01) that the PCCS LST specification did not accurately reflect the instrumentation that was procured and Installed in the PCCS Large Scale Test Facility as required by the provisions of WCAP 12601, in a letter dated September 12,1995, Westinghouse responded to Nonconformance 99900404/95-0101.

Westinghouse stated that it would revise the PCCS LST specification to reflect the final configuration of thi PCCS LST. The staff found Westinghouse's reply responsive to the concem raised in the nonconformance. in a letter dated December 5,1995, the staff notified Westinghouse of its finding and stated that the implementation of proposed corrective and preventive actions related to the nonconformance would be reviewed dunng a future inspection to establish that full compliance had been achieved and maintained. This was identified as Confirmatory item 21.7.1.6 2.

During an inspection (NRC inspection Report 99900404/97 02) on November 17 through 21, 1997, the NRC vorified that PCS T1P-002 had been revised to reflect the final configuration of the Large Scale Test Facility. As preventive actions, Westinghouse revised test specifications 6

for subsequent tests (including the Core Make Up, Long Term Cooling, and Full-Height / Full Power tests) to reflect the final conf;guration of the respective facilities. The inspection team verified that these actions had been completed and documented. Accordingly, Confirmatory item 21.7.1.6-2 is closed.

Noncon{ormance 99900404/95-0102 The team found (NRC Inspection Report 99900404/95-01) that procedures or instructions for determining the as-built elovations and critical dimensions of the PCCS LST had not been available to or utilized by the Containment and Radiological Analysis Group as required by WCAP 9565. In Letter NTD.NRC-95 4549 (September 12,1995), Westinghouse responded to Nonconformance 99900404/95 0102, stating that it would remeasure appropriate critical dimensions in accordance with a written procedure. Measurements so obtained would be compared to those previously recorded and additional remeasurements would be taken if necessary. Westinghouse added that after the PCCS LST program had been completed h had revised AP600 Procedure 3.11 to require that a written procedure be used to obtain the specified critical dimensions of any safety related AP600 test facility. The staff reviewed Westinghouse's response and found it responsive to the concem raised in the nonconformance, in a letter dated December 5,1995, the staff notified Westinghouse ofits finding and stated that the implementation of proposed corrective and preventive actions related to the nonconformance would be reviewed during a future inspection to establish that full compliance had been achieved and maintained. This was identified as Confirmatory item 21.7.1.6-3.

During an inspection (NRC Inspection Report 99900404/97-02) on November 17 through 21, 1997, the NRC verified that proposed corrective and preventive actions had been completed and documented by Westinghouse. Confirmatory item 21.7.1.6-3 is closed.

Confirmatory item 21.7.1.0-1 During the inspection (NRC Inspection Report 99900404/95-01), the team reviewed Test Procedure 219.1, Revision 0, which was used during Runs 54 and 57, to verify acceptable implementation of the AP600 quality plan. The purpose of Test 219.1 was to investigate the distribution of noncondensibles as a result of changes in vessel cooling. While reviewing the test data for this test, the team noticed that the rate of water flow to the top of the vessel had not been constant, as is required by the test procedure. Another target test parameter was an inlet steam flow of 0.0910.02 kg/s (0.210.05 lb/s). This steam flow was lowered to approximately 0.054 kg/s (0.12 lb/s) to limit the vessel pressure and baffle temperatures to an acceptable range. The team considered the failure of the test conditions to meet the target test parameters to be a deviation from the test procedure, in accordance with AP-3.11, "AP600 Testing," these deviations were recorded in the test logbook and the Test Engineering Group was notified of the deviations. The Test Engineering Group was responsible for evaluating the reported test deviations and documenting the disposition of deviations by sending an official test engineering transmittal to the test group.

Representatives of the Test Engineering Group stated that it was normal practice to document deviations in the FDR. The team verified that the deviations had been documented in the FDR for Test 219.1. The engineering procedure also required the concurrence of the cognizant design group, in this case the Containment and Radiological Analysis Group, for disposition of a deviation affecting compliance with the test specification.

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0 Representatives of the Test Engineering Group stated that the Containment and Radiological AnaVsis Group *cdi;;+1 the disposition of these and other deviations by their acceptance signatures on the QLR and FDR. The staff would confirm the disposition of test deviations  ;

between the Test Engineering Group and the Containment and Radiological Anaysis _ Group i during a future inspection. This was identified as Confirmatory llam 21.7.1.61.

During an inspection (NRC Inspection Report 99900404/g7-02) on November 17 through 21, 1997, the NRC discussed the PCCS LST acceptance criteria with appropriate Westinghouse _

sistf. The fot:owing test acceptance criteria had been established for the LST:

1. Data on forcing functions were available, i.e. steam flow rate, fan speed, water flow rates, inlet ternparature of steam, water and air. Strict adherence to the specific absolute pressures i

and flow rates was not necessary but values should be nearly constant as defined in the test matrix.

2. Data on response variables available, i.e., condensate flow rates, excess water flow rates, i air, water and steam outlet temperatures, vessel pressure,80 % of the vessel and fluid temperature, and vessel water coverage measurements were taken.

3. Unplanned excursions were to be evaluated on a car.e by case basis. Failures that could result in faulty data outputs were not acceptable.

4. The vessel pressure was maintained within specified pressure limits during the constant pressure portions.

Variations in the PCS water coverage flow rate were not considered in the development of the test acceptance criteria. The important criterion was the target coverage area, as specified in  ;

the test matrix. Even then, the acceptance criteria did not require strict adherence to the target value, only that a nearly constant value could be determined for a test. With respect to the specific steam flow rate for test 21g.1, the test acceptance criteria were followed. On these ,

bases, Confirmatory item 21.7.1.61 is closed.

21,7.2 Summary After considering the QA implementation inspections of Westinghouse's design certification test facilities or programs or both, the staff concludes that the QA programs goveming Westinghouse's AP600 design certification test prcgrams have satisfied the requirements of 10 CFR Part 52 and the pertinent provisions of Appendix B to 10 CFR Part 50.

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