ML19308B867

Rept of Investigation on 790514-31 of Alleged Susceptibility to Small Break LOCAs of B&W 205 Fuel Assembly PWR

ML19308B867
Person / Time
Site:	Crane
Issue date:	06/26/1979
From:	Oxfurth A, Thompson D, William Ward NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
References
REF-QA-99900400, TASK-TF, TASK-TMR 79-HQ-001, 79-HQ-1, NUDOCS 8001170474
Download: ML19308B867 (15)

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REPORT OF INVESTIGATION TITLE:

BABCOCK & WILCOX 205 FUEL ASSEMBLY PWR/ Alleged Susceptibility to Small Break LOCAS CASE NUMBER:

79-HQ-001 SUPPLEMENTAL:

VENDOR NUMBER 99900400 PERIOD OF INVESTIGATION:

May 14-May 31, 1979 REPORTING INVESTIGATOR:

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(Ailliam p. Ward, Sdnior Investigator, Executive Office for Opdrations Support, IE:HQ

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PARTICIPATING PERSONNEL:

Arthur Oxfurth Career Management Branch, IE:HQ Executive Office For Management and Analysis STATUS OF INVESTIGATION:

Pending REPORT APPROVED BY:

udley Tym'pson, Exec 6tive Officer for Operations Support Office of Inspection and Enforcement

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d 8001170 t

b DISTRIBUTION Victor Stello, IE John G. Davis, IE H.D. Thornburg, IE N.M. Mosley, IE D. Thompson, IE Regional Directors C. Kammerer, OCA J. J. Cummings, OIA H. Denton, NRR M. Carbon, ACRS

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D. Gamble, TMI Task Force

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SUMMARY

In April, 1979, the Office of Inspection and Enforcement received a copy of a January, 1978. Report prepared by a consultant to the Advisory Committee on Reactor Safeguards (ACRS) concerning the s'usceptability of certain pressurized water reactors desigsed by Babcock & Wilcox to small pipe break LOCAS.

.Because_of.his concern that the information contained in theiReport may fall!

pinto.that category'of safety'infdraation-thst"must be reported in 'dcordance.

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a twith.10 CFR 21, the Director,'Divis'i~on'of'Rea'ctor' Construction Inspection

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requested that an investigation be initiated concerning the Part 21 signifi-cance of the Report.

When interviewed, the author of the report, who is.

, employed by,TVA as an engineer, indicated that he had' written the. Report inj

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(the Fall.of 1977; at which time he[provided a copy,to 'al member ~of.the.ACRS; he

,alsojprovided a copy;to B&Wf and asked lfor'their. analysis of this issue.

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[did~not' hear anything from B&W,VJanuary 1979, response from B&W was unsa until January,;1979, and.had.no,further contact with~NRC until April, 1979.c'A tory to him so he sent them{another request inl February,1979, but has not received a response to it.

Interviews of_seven,(7)_B&W employees. involved _

with this Report revealed thatjanalysis of;the' Report received _ allow priority, and that it languished without detailed analysis until Winter, 1978.,

Inter-viewees_ claimed that their. preliminary evaluation,of. the Report was that it pasftechnicallyvalid?for.themostipartibutit'didnot'identifyany~itemnot:

!alreadyknownitoor;consideredbyB&W.'None,ofthe.fistervieweesjfelt'itfwas[a matter of_ substantial safety. significance, and none.feltEthat itLshould.havel

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besa: considered a's;,X Part 21; item.d Appendix. K to a May', J1979,5reportiby, B&Wi 1

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represents, accordi.lg to. interviewees,,is the formal B&W analysis of,the;

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[ Report'sconcerns;thisB&WReportrefutes'thecontentionsoftheConsultant's Report.' Investigation to date has included the obtaining of copies of both the typed and handwritten drafts of the Consultant's Reports, copies of..B&W mail

,and telephone logs,,and. copies of B&W Part 21 procedures. lInves.tigation' pcontinuesjpendingajNRRdetermination'of"the~ safety"significancesof~theinform2 i;ationlin the Consultant's Report"as well'as the' desirability"of' investigation

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at TVA.

DETAILS PREDICATION AND BACKGROUhT On April 17, 1979, Mr. Darrell Eisenhut, Deputy Director, Division of Oper-ating Reactors, Office of Nuclear Reactor Regulation (NRR) forwarded a copy of a 1978 Draf t Report (Atch (1)) entitled, " Decay Heat Removal During a Very Small Break LOCA for a B&W 205 Fuel Assembly PWR" to the Office.of. Inspection and Enforcement.

This report, hereinafter., referred to as thelMiche,1 son Repyj

( ort,' was prepa red by.Mr.2Carlyle;Michelson,)an engineer with the Tennessee Valley Authority (TVA) who is also a consultant to the NRC Advisory Committee

,on, Reactor, Safeguards (ACRS)._. Upon reviewing this report, both the Acting.,

iDirector,10IE, and the Director,. Division of Reactor Construction Inspection?

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,eppressedconcernthat'the'information,c'o'ntained"inthe]repor,t}notonlyiwas[

significant' ibut that itlmayf fa'll1into ithe category of information that must bE repoEt'ed expeditiously "to 'the NRCLin accordance with!101CFR 214__.

Accordingly,thequestionofthe}(applicabilityof_Part21wasirsferred:tothe

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Office of the Executive Legal Directori(OELD).

On May 4,~1979 ', ~an 'att'oine~y with OELD advised 0IE that information such as that contained in,the_Michelson

, Report;could~ be encompasse'd jwithin the ambit of Part 21, but that; additiona_lj information would be.needed;in order to make.a specific determination. Based on the' forejoing',"on"May ~14, 1979, Mr. Harold Thornburg, Director, Division of Reactor Construction Inspection requested that an investigation be initiated regarding the Part 21 implications of the Michelson Report.

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e INVESTIGATION AT NUCLEAR REGULATORY COMMISSION HEADQUARTERS

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L INTERVIEW WITH CARLYLE (NMN) MICHELSON Michelson when interviewd in the ACRS Offices, Washington, D.C. by Investigator W.J. Ward on May 21,.1979,..,indicatedthathelf1rs~tTbecamelcoicernedabouth

,f small pipe break'.LOCAs ;in;1974l and_that this[interdsl, which'was[ independent;

( of-his consulta.nt_ relationship-with,the ACRS,. grew over.the years.

Stimulated by a y1975, report-regarding the ; susceptibility of rcertain Combustion Engineering;

_(CE)[ react'orsito.this. phenomenon, he said heffirstiwrote a. report regarding; (those reactor.s; Later, after. deciding thatIB&W< reactors were even more vulner-able than~ CE's, he wrote afreport:inySeptember,l 1977jdocumenting his concerns.

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.He. related that he proviced a thandwritten copyjof that report to Mr. LJessej

[Ebersole,; his former supervisor at TVA, then and now a member of the ACRS.

According to Michelson, Ebersole advised him to "ha_rden up'.'

the report _in_that-,

it was too speculative.

He did so, and prepared a { typed dyaft in January,1978.'

Michelson said he did not know if Ebersole had shown his draft report to anyoneelseinNRC,butcommented.that{certainl questions $ asked.by_theACRS.

during the Fall,1977 ! Pebble Springs. hearings weref apparently; bas,ed Jon hisL 7kreport. Michelson denied having any other contact with NRC regarding the report during that period.

Michelson stated that he had several discussions concerning his report _.within TVA during the Winter of 1978 that eventually resulted in afletter toLB&W!

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{ dated' April 27,1978,1 (Attachment 1) forwarding a copy of his report and asking for"a'B&W Tesponse to it.

Michelson during this time indicated that the highest level of TVA management with whom he discussed his concerns was his immediate supervisor, Mr. E. G. Beasley, Head Nuclear Engineering Group.

Michelson advised that he did discuss whether his concerns may fall within the ambit of 10 CFR.21..with Mr. E. J. Walker, TVA Licensing. _According to Michelson, it was [ decided l that neither Part 21' nor?10 CFR 5.0:55(e) appliedjto his concerns, the former because of TVA's perception that it applied only to vendors, and the latter because it did not fit the rigid criteria developed by TVA to determine whether an issue was encompassed by that regulation.

Michelson related that between April, 1978 and December, 1978, he asked TVA Contracts to contact B&W on at least six different occasions to stimulate a response to his questions, and that he participated in a telephone conference in December after which he transmitted a one page summary of his concerns to B&W via facsimile.

Michelson went on to say that, nonetheless, he,did not receive a written reply until January 23, 1979.

Feelingthatthis(reply 1(Attach-ment 2)wasnot. entirely,responsivetohis, concerns,heauthoredatsecond~letterj

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which was mailedito B&Wlon February 8,1.1979)(Attachment 3).

He claimed that B&W has yet to respond to that letter.

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..In.ronclusion,_Michelson emphasized that the thrust of his[ concern was :not' (thathewas;certainithatthe.small_pipebreakLOCA'.s.that,hepostuldad~pr$-

i seateda!significantsafetyhazard,.butratherhe'feltthatthe[ha'?idtbidnj d

i suffiEiently analyzed. Michelson conceded that it"was"possible that T.'more' ~

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(NiioFotis7saiysis of his concerns might well demonstrate that there is not a

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problem. A detailed results of interview with Mr. Michelson is (Attachment 4).

. RE-CONTACT WITH CARLYLE MICHELSON h ned the reporting investigator and Michelson te ep o Michelson..had recently had,a l

30, 1979, ld_him that_he hadifound.a copy-.of.an,3 b tance:

At 1635 hrs., May provided the following.information in su s RLSt.aff_membe_r whichihad_, re conversation,with! Jesse Ebersole lwho _to sOctob,er 21,.19791no e;from an NR i

of the t

61 written draftireportsiprepared by Michelson l

iven at an earlier date.

Februa ry, 1978..

Ebersole a copy of the typed draf t report, but couHe signer of the Note.

Michelson indicated.that he had? legible. copies oihe"would~ forw it was.

d d rs concerningSboth.CEiand B&W! reactors thare subsequently received and a

< investigator. 1These copies weSiand_.6),respectively.

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Attachment:

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EXTRACT OF NRC REGULATIONS A copy of 10 CFR Part 21, the question of' compliance with which forms the j

basis of this investigation, is appended as (Attachment 7).

Additionally, a copy of 10 CFR Part 50:55(e) which was alluded to during Michelson's interview as a-i i

setting forth criteria against which the safety significance of his report was measured is (Attachment 8).

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O INVESTIGATION AT LYNCHBURG, VIRGINIA l

rb INTERVIEW OF ROBERT E. LIGHTLE w.. -,~.

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ILfghtle Associate _ Project Manager _at the B&L Nuclear Power Generation Division, y

when int.rviewed by Mr. Arthur Oxfurth, NRC and the reporting investigator on May 29, 1979, provided the following information in substance:

According to his mail logs, the Michelson Report was received

. He, q madecopiesofitandprovidedthemroutinelyto[by_B&WonMay3,,1979.his supervisor,7 a J

and another employee in his group, Scott Delicate.

He does not recall spB cifically discussing the report at that time with either person.

Upon reading the report,_he felt that any action,to,be taken regarding it should be taken

,by,the)ECCSAnalysisGroupwhoheunderstoodLassignedit.tooneofhileng'ineers) tRobert Jones:

He recalled"dischssing the matter shorily'afterwards'with'Jodes"^

who indicated to him that the report contained a lot of good points but that he was busy conducting a small break analysis which encompassed breaks of the size described within the Michelson Report.

Nothing further was done regarding the Report until he recieved a call from TVA on June 9, 1978, inquiring about the status of the B&W reply.

Several other calls were received from TVA on this same subject.

These calls were all entered into Lightle's telephone log.

A one and one half hour conference call was held between several TVA personnel including Michelson, and several B&W employees including, Jones _ on December 4,1978. _In response 1.o.yet,another-,

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., telephone call, Michelson provided'a.one page summary of his,concernsfto B&Wj Lvi_al facsimile;(Attachment 9)l. ThTresisonse was finally written on January 19, 1979, and mailed to TVA on January 23, 1979.

On February 9, 1979, TVA advised that a letter

."is enroute to B&W asking for additional information.

On March 5, 1979, j

B&W promised a respoase by mid-May, and on April 2, 1979, TVA called to state that they had to have an answer as soon as possible.

In summary, the Michelson Report was the subject of at least thirteen (13) telephone conver-sations between B&W and TVA during the period between May 3, 1978, and April 2, 1979.

Lightle indicated that he had fraquently asked Jones the status of the Report, but that he did not see the issue as requiring referral to any higher level within B&W.

He felt that the Report basically was a valid technical comment, but that he did not perceive it as having safety significance.

He also in-dicated that he had not discussed the issue with any other B&W officials prior to the Three Mile Island Accident at a higher management level than Dunn or

,McFariand. _Lightle_provided, copies sof the,B&W Mail Logz(Attachment 9), the (telaxed copy,of_Hichelsantsione.pagemsummaryl(Attachment,10); and coyies of his a

telephone logs covering this period (Attachment 11).

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ INTERVIEW WITH JAMES (NMN) MCFARlAND 7,.,.

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iMcFarland,iSenior. ProjectiManager's B&W Nuclear Power Generation Division, interviewed May 29, 1979, by Arthur Oxfurth, NRC, and the reporting inves-tigator provided the following information in substance:

He recalled seeing the Michelson Report when it first came into the B&W system.

He understood that his assislint, Robert Lightle, was handling it and was._ confident _that,Lightle,

,yas competent to do so. 5Nothing then or since led him'to'believe that the Reporte

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idealt"withYa!. signifil:aElsafetyl hazard.[Fsr tliat7eason, he saw no particular~~

reaso'n to'put'Any"extraordinaVy iressure upon the ECCS Group to expedite their analysis of it.

He noted that the Group was especially busy during this period.

He did not discuss this report,or_.its substance with.B&W management,..nor,did

,he discuss-it with,the B&W Licensing.. Manager, James Tay" lor, who has._overalli iresponsibility;for the B&W Parti 21 Program. 'Hi did'not discuss either the "

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' Report or its substance with't"h'e"NRC"duiing this period. He noted that TVA Engineering aperiodically, generates, a list of TVA projects. awaiting, action calledtheTOIL,(TVAOutstanding"ItemList)h..As.theiMichelson,Reportand(

7ttransmittal. letter:did notlever appearion;the TOIL, he, assumed that TVA itself

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s E did -not consider. theeletterito_bec especially important.

McFarland was unable to provide any additional information.

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INTERVIEW OF ROBERT JONES y ~_

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.- 9 iJones,ia Senior:Engineerfwith;B&Wf when interviewed May 29, 1979, at Lynchburg, Virginia by the reporting investigator, stated that he had received the Michelson Report in early May, 1978, and been assigned responsibility for responding to the questions raised by it.

He related that a cursory review of the Report led him to conclude that it appeared to be technically valid, but did not bring to light any information.

On the other hand, according to Jones, he felt that Michelson used the wrong calcula_tional. approach _ ___ _ _

_('_' energy._. balance"),in a rriving at._ his. answers _,,and hej did : not agree withl all-'of j

{Michelson'sReportas_ra.ising;a, substantial: safety. issue]andthatiti[most'cer-j

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ttainly did not meet th'jreporting criteriaiof110,CFRL21;~ For that reason he i e denied having informed higher management or discussing the issue with NRC.

He indicated that during the period until the Fall of 1978, he was too busy on other projects to reply to TVA notwithstanding many reminders from Robert Lightle, Project Management Group.

He claimed that he finally prepared a response in December, 1978, that formed the._ basis of B&W's January 23,_1979,,

, letter..to.TVA.

Jonesrecounted_that_he_was;alsoasjighed;thefaction;torespondl s

, ito the resulting. February 8,1979,- TVA letter,,that he assigned.it a low!

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j i p~riority,1butTnever answered:itidue'to'the:Three Mile' Island Accidcnt.

Jones as'serted," howeves, lh'at' Appendix K"tfa' May Y, '1979, B&W report to ilii NRC

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entitled, " Evaluation of Transient Behavior and Small Reactor Coolant System i

Breaks" in the 177 Fuel Assembly Plant _ adequately addressed,and_ resolved,

Miche? son's concerns. The Conclusionsfsection ofcthatiAppendix;is: (Attachment 12)!

to this report.

The interview was concluded with Jones averring his~ belief that

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the Michelson report did not meet the reporting criteria of Part 21 and did not represent data new to B&W or not already encompassed by previous studies.

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dut2iled Results of Interview with Jones is (Attachment 13).

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. INTERVIEW OF BERT DUNN

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T(D'#*~unn,jHana'ger,",E'CCS Analysis Group) B&W Nuclear Power Generation Division, when interviewed May 29, 1979, by the reporting investigator provided the following information in substance: He recalled that the Michelson Report had been received by his group in early May 1978, and that he had assigned it to Robert Jones who was at that time engaged _in an, extensive _small_ pipe _.,

7 break _. analysis.c.xJones told him that._ int Jon.es 's: opinion detailed analys_i_s,pfj 3

the,ReportJcould. wait.x Dunn: concurred with,this; and the intervening period of May-September was spent with Jdii s"ddGotiing h'is effort to higher priority

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projects.

Dunn subsequently became aware of the increasing pressure from TVA for an answer at the time Jones became involved in drafting a formal reply to TVA.

Dunn stated that he did not discuss the Michelson Report with any person in the B&W management of a higher level than himself.

Dunn indicated that he had not noted anything about the Michelson Report that would have led him to overrule Jones's decision to work on projects that Jones felt deserving of higher priority.

In conclusion, Dunn stated that he disagreed with Michelson's concerns and pointed out that he had been personally involved in the preparation of the May 7, 1979, Report mentioned by Jones during his interview that refuted Michelson's tentative conclusions.

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Q INTERVIEWS OF B&W SENIOR MANAGEMENT OFFICIALS The following senior level management officials of the B&W Nuclear Power Generation Group were interviewed May 29, 1979, by the reporting investigator:

E. Allen Womack, Manager, Plant Design Department James C. Dedden, Manager, Project Management Department James H. Taylor, Manager, Licensing Womack is the immediate supervisor of Bert Dunn.

Dedden is the immediate supervisor of James McFarland.

Both persons when interviewed stated that they did not learn of the existence of the Michelson Report until after the Three Mile Island Incident.

Neither could recall any conversations with their staff regarding it prior to that time.

Taylor, who is responsible for administration of the Part 21 program at B&W, asserted that he did not hear of the existence of the Michelson Report until Congressional hearings subsequent to the Three Mile Island Incident.

He stated that he was certain that no Part 21 action was initiated regarding this Report as he would have been involved in any Part 21 reports made by.the B&W Nuclear Power Generation Division.

He indicated that he knew of no management official at a level higher than he who was aware of the Report during the period in question.

Taylor said that B&W has written procedures regarding the review of potential

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Part 21 matters and provided copies of both the B&W Corporate and Nuclear Power Generation Division procedures.

(Attachment 14 and 15 respectively).

Investigators Note:

Examination of Official Bulletin Boards revealed that the written notice required by 10 CFR 21-6 was posted.

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Q STATUS OF INVESTIGATION 4

This investigation continues in a PENDING status awaiting an official evaluation from NRR as to whether the information in the Michelson Report j

meets the reporting criteria of 10 CFR Part 21,-and wi.-ther fdrther investiga-tive effort is warranted in view of the information gatuered to date.

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ATTACHMENTS

!O Item Dissemination

1) April 27, 1978, TVA letter to B&W w/Michelson Report

2) Jan. 23, 1979, B&W to TVA Copy All

3) Februc 8, 1979, TVA ltr to B&W Copy All

4) Results of Interview of Michelson Orig. (XOOS), Copy All

5) Draf t C-E Rpt by Michelson Copy All

6) Draft B&W Rpt by Michelson Copy All

7) 10 CFR 21 Copy All

8) 10 CFR 50:55(e)

Copy All

9) B&W Mail Log Copy All

10) Telafax to B&W Copy All

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11) Lightle telephone Copy All 12.' Appendix K Conclusion Copy All

13) Results of Interview of Jones Orig.

(X00S), Copy All

14) B&W Corp Procedures Copy All

15) B&W NPGD Procedures Copy All i

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