ML20132D236
| ML20132D236 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 07/31/1985 |
| From: | Reytblatt Z WARREN WILSON COLLEGE, SWANNANOA, NC |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20132D206 | List: |
| References | |
| 2.206, DD-85-10, NUDOCS 8509300115 | |
| Download: ML20132D236 (7) | |
Text
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b W ARREN WILSON COLLEGE Swann!nn, N::rth Czrolina 28778 4
pot) 298 3325 July 31, 1985 00CMETED U%RC Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission D g -f p4;j4 Washington, DC 20555 GF m f U SECHr.TM,400CMiin APPEAL In the matter of SRAncg COMMONWEALTH EDISON COMPANY ON THE EMERGENCY RELIEF DECISION I
(Zion Station, LaSalle Station)
DD-85-10 of JULY 3, 1985 i
AND ALL LIGHT-WATER REACTORS Docket No 50-295 I
INTRODUCTION on January 9, 1985,'the Petltioner filed an emergency relief petition with the Office of the Executive Director for Operations seeking an immediate postponement of all integral containment leak rate tests (ILRT) until the NRC i
approves a procedure for determining the weight coefficients, and a substantially improved procedure for verification thereof is implemented.
Calculations supporting the petition prove that the present no-rule situation for cetermining the weight coefficients and the present faulty verification I
procc dures may lead to underestimating abnormally high leak rates to the degree that nuch Jeak raten would appear to be within normal limits. The Petition cit *n tho Zion, Unit 1 containment where the weight coefficients used in j
several tests were obviously incorrect which was confirmed by multiple verification test failures, as a containment where a conservative estimate of the true leah rate was in excess of legal limits.
i On the same January 9, 1985, the Petitioner filed another emergency relief Petition with the name Office seeking an immediate withh owal, debugging and revalidation of nortware uced for LaSalle and Zion tests. The Petition wac nupported by calculations showing t. hat the computer program either does not i
perform addition or it has a fraudulent option for doubling of weight j
coefficients.
My Petitions an stated in the NRC letter to me of February 20, 1985 have been considered by the NRC Staff. They were found to provide insufficient bases for emergency relief actions on the part. of NBC. The NRC Decision has not been -
nnpported by any esLential calcu]ntions, discuusion or references. The FOIA search revealed that no calculations exist that would support the NRC allegations.
On Match'6 and March 8,
- 1985, the Petitioner uppealed the afore mentionod NRC
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Deciolons on the ground that they contained no substance. In addition, tho y
nullification of'the NRR Director's. Decision of March 15, 1984 on LaSalle tosts w n requented on the ground that thin Decinion was baned on false statements.
Cn April 22, 1985 the NDR Director acknowledged the receipt of Petitioner'n lettern. The Direct or's letter combined both Appeals in one (original)
Pt ti t j or;. The recel pt of. Petit ioner 's requent to mako nul1 and void the Di rect or 'r, Decinion of March 15, 1984 an baned on falso statemento, han not 8509300115 850731
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PDR ADOCM 05000295 C
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ba n acknowledged. No immediate actions were taken.
In hib 1etterb of April 29 and 30, J985, t.he Petitloner objected to (1) the Director's no-action policy, (2) combining two petitions in ene, and (3) the refusal to acknowledge the receipt of Petitioner's request. No answer has been received by the Petitioner.
In the period from February through May 1985 several.FOIA actions were taken by the Petitioner to obtain names, listings, validation acts of software used for leak rate test data processing that are subject to FOIA, and all the records related to the NRC Decision of February 20 denying the Petitioner's request. No
-such items exist, according to the NRC.
On May 21, 1985 the Petitioner referring to a letter from Mr. Carp, requested information on the authorship of the fraudulent LaSalle-Zion computer programs.
No such information has been provided.
On July 3, 1985 the Director's Decision was made. This Decision is not based on any calculations or technical discussions. It ignores the Petitioner's arguments. It employs false arguments. It does not consider important matters.
Finally, several statements known by the Director to be false are misrepresented as being correct.
We proceed now with the contents of the Director's Decision, the discussion thereof, and with the conclusions.
CONTENTS OF DIRECTOR'S DECISION.
J.
In the " Introduction", a summary of the Petitioner's requests and a list of corretpundence to be responded, ir presu. Led.
1.1 The Petitioner's request to void the Director'c Decision of March 15, 1984 as based on false statements is not considered.
1.2. Letters of April 29-30 and of May 21 are not considered.
a
- 2. In the " Discussion" the Decision presents the NRR view on the history of the problem. Three issues of the Petition are outlined:
a) the wrong mass equation used by the industry; b) the weight coefficients which may not be correct and which can be manipulated;.and c) " inadequacy in certain coftware".
A. The Decision presents no technical discussion (derivations, equations, calculations etc). It does not respond to the Petition. It repeats in abbreviated form the ridiculous statements of the contested previous Director's Decision of March 15, 1984 which was based on false statements. The only
" improvement" is that the fraudulent LaSa13e example (used as a " proof") han been abandoned in the present Decision.
D.
No technical discussion in precented.
C. The HPC checked up the Volumetrics program output for Fermi, Unit 2 tent and. -
"has not found it necessary to review the Volumetric software." The Decision admit t hat 3.omo data wat t hrown out (two out of nine readings) during the Zion test but aljeges that the computet program in use (of a secret origin) was averaging correctly the good readings. Again, neither a software review nor calculations are exhibited.
The Decision discusses the verification tests on Zion. Basically, it tries to discredit the first verification test (which confirmed that the weight coefficients for Zion were wrong) in favor of the second verification test. No discussion of validity of Zion weight coefficients (which are obviously incorrect) has been presented, nor any conservative estimates of leak rate derived. No discussion of the significance of the verification test as performed by industry, is presented.
In the " Conclusion" the Director denies the Petitioner's request for relief.
DISCUSSION O. General comments.
O.1 The Decision has not discussed many very important issues raised by Petitioner: i) nullification of the Director's illegal Decision of March 15, 1985 which was based on false statements; ii) authorship of fraudulent Zion-LaSalle software; iii) verisimilitude of the wrong Zion weight coefficients; iv) conservative estimates of the true leak rate; v) significance of meaningless verifi. cation tests.
0.2 with_the exception of a brief discusiion on Zion verification test which has a resemblance of a technical discussion, the discussion is non-technical oral it not supported by derivations, calculations etc.
0.3 The Decision does not address many pieces of evidence presented by the Petitioner:~1) the correct gas equation used in conventional science and the wrong equation used by the industry; ii) the undeniable proof that any leak rate can be obtained from any data set using certain weight coefficients; iii) numerical examples proving that using the wrong equation or coefficients may lead to errors hundred times greater then allowable; iv) actual exceedance of the legal limit of 0.1 by some of the weight coefficients in LaSalle and Zion tests; v) the use of fraudulent examples; etc., etc.
0.4 The Decision knowingly uses false causal relationships for deception.
i) It is a general knowledge that a particular option in a computer program may or may not. be executed in a particular run and, therefore, review of a listing is an integral part of validation process; the Decision falsely claims that because a computer program produced a correct result in a particular run, no review.of the program is necessary to establish the presence or absence of fraudulent options (Volumetrix).
- 11) Obviously, any equation (wrong or correct) always can be made correct by introducing appropriate changen. Thus, the wrong ANS equation can be converted into the correct conventional physics equation. The Decision falsely states that the original wrong AUS equation used in the industry is correct becauce "improvementr, may be made."
[1]ogical pr m ntation is peculiar to the Decioion.
n.5 I n format ion relevant to the subject natt er and in the ponconsion of Nke __
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ir.ust be used in preparation of the Decision even if this would support the Petitioner's view. This constitutional principle is grossly violated by the MRC.
- 1) I have a positive proof that the NRC is in the possession of a listing of fraudulent Commonwealth Edison computer programs used in LaSalle-Zion tests. It rshould not take more than a few minutes to locate the fr'audulent option subject of my Petition; ii) The NRC is in the possession of many other computer programs which, according to the FOIA Office Director, are not available on FOIA requests.
- 1. Comr:icnts on " Introduction" The Decision does not acknowledge the receipt of the Petitioner's request for nullification of the Director's Decision of March 15, 1984 as based on false statement.
The Decision does not acknowledge the receipt of Petitioner's letter of April 29, 1985.
The Decision does not acknowledge the receipt of Petitioner's letter of May 21,
- 1985, s
This is done deliberately to; avoid discussion of these pieces of evidence.
- 2. Comments on " Discussion."
2.0 The Decision presents tha history of the problem as a smooth process of blending of various opinions to achieve " improvements to the regulations."
The reality is different. The NRC has been presented with the undeniable evidence that the present leak rate testing methodology is deficient to the degree that any leak rate value can be " legally" obtained from any set of the raw data. Accordingly, immediate actions have been reuqested to substantially improve the situation.
To.the detriment of the American people, the NRR elected a policy of sabo.tage in thin most important issue.
The weaponn used by the NRC included:
i) refusal to provide technical answers (my 2-3 years old technical submittals are not yet answered) ;
- 11) refusal to engage in a technical discussion (there was not a single meeting whore I would be allowed to ask questions and receive answers);
iii) deception (forged meeting summaries, false statements, knowingly alogical atatementa);
iv) cover-up cf bad tests (Slurry, LaSalle, Zion);
v) wit.hholding of information (LasalJc, Zion);
vi) resistance to introduction of any improvement to the testing methodology, postponements and delays in preparation of. regulatory documents; deadlines for the Peg. Guide were broken in 1982, 1983, 1984; what was presented in 1985 does no t. ev. o remotely renemble a guide.
It appears that there is a conspiracy to prevent a meaningful review of all the past tests of which many are similar to the fraudulent Zion tests officially recognized an deficient.
It appears that there is a conspiracy to raintain the present highly deficient _
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testirig practices to the detriment of the public safety.
2.A. On the issue of the wrong gas mass equat. ion, the NRC, in its fraudulent nsretical example exhibited in the illegal Decision of March 15, 1984, recognizes that there are two methods for mass calculation - the AMS methodLand the conventional physics method (the latter incorrectly called "Reytblatt's rt:ethod").
2.A.1 The conventional physics equation (ideal gas law) has been known for more than two hundreds years and is generally recognized as one of the cornerstones of physics. The ANS equation was derived about 25 years ago. However, the derivation was erroneous (an elementary mistake was made that f[//[p))- dA
=}!Jf66
). This error was exposed 16 years ago, and, independently, by the Petitioner, 12 years ago. Three years ago the NRC was presented with the truth. A year ago
.this was officially confirmed by NUREG-3549 (which mistakingly calls the ideal gas equation as "EXTRAN formulation"). I quote from Page 49, line 15 from the bottom:
"...the EXTRAN formulation... is correct while the ANSI /ANS equation is not...". A pseudo-scientifip nonsense that is presented in the Decision on the subject is indicative of tha scientific level and integrity of those who prepared the nonsensical discussion.
2.A.2 Regrettobly, the Decision repeats another pseudo-scientific nonsense of the March 15, 1984 Decision (of course, without presenting any technical proof) that " stabilizing" as done by the industry reduces the error due to the wrong equation to acceptable levels. The NRC has been supplied with the examples when
" stabilizing" was perfect but errors still were two orders of magnitude larger than al] owed. The preparers of the Decision are known to have been familiar with these examples. "Equilizing-stabilizing" has long been known as worthless scienti fically but as a very effective cheating tool. It was used during the f r audulent Zion, Spring 19H2, test "to help" the verificat. ion.
2.A.3. The statement that "puch an improvement (return to the correct equation
- Z.R.) would be more correct but would produce no meaningful change" is I.otally baselers (you provide no numerical estimates). This statement is wrong on proven by theoretical estimates, worked examples and real life exampics of which the preparers of the Decision are known to be aware of. In fact, some of past tests reviewed by the NRC Consultant in 1982 and covered-up, showed errors in excess of legal limitu. If the correct methodology were used, these cont oinment systems would have to be repaired to provide the citizens with the degree of safety they are entitled to by law.
2.D.
In a trivial remark it is stated that "a properly conducted test would not upon t a i n... use of unjustified weighting coefficients... and would subject licensees to NRC enforcement actions..." The Decision continues:
to ensure compliance...., NRC inspectors regularly observe the tests..." That is all!
Let ce elaborate on the situation. No guidance on determining the weight coefficients is presented in the current methodology except that the tnefficients should not exceed 0.1. As recognized by scholars in the field and has been shown in my Petition, thr>y are extremely important for the leak rate measurement. The current-practices are unsatisfactory; a good example is provided by Zion where these. coefficients are obviously wrong, and by LaSalle where they exceed 0.1. The NRC inspectors are not supplied with the criteria thot would help t hem t.o detect the wrong weight coefficientu.
No wonder that even cuch experienced NBC inspectors as Mests. Reyes and' Maura did not rocqqnize an deficient weighting coefficients at LaSalle and Zion.,
s.w -
It is a great deception to state that in the absence of a guiding document, an NRC inspector would be able to detect the wrong weighting coefficients. After such guidance is provided, as requested in my Petition, the testing can be adequately performed. It is noteworthy that the so-called " verification test" ban very little to do with verification of weight coefficients. Therefore, the only r.eans to stop fraudulent and/or inadequate testing would be a development of guidance on determining the weight coefficients.
7.C. As stated before, the Petitioner obtained the proof that the listing of the fraudulent cornputer program used in LaSalle-Zion tests is in the possession of the NRC. It appears, as stated.in the Petitioner's letter to the NRR Director of May 21, 1985, that the developer of these programs was not Volurret rics as the NRC previously alleged and as it was assumed by the retitioner. Since Commonwealth Edison, a company of Illinois, used these and Limilar programs, we will use an abbreviation "CE type program" for these programs.
2.C.]. As noted before, the " proof" that the Volumetrics program is not of the CE type, is fallacious. The Petitioner, however, does not claim at the present momr+t that the Volumetrics program is of the CE type, that is, fraudulent. The Petitioner insists that the listing of Volumetrics program be made public in fran.e of t he general check-up of all the sof tware used in the U.S. A. for the leak rat e testing.
2.C.2 The Decision confirms the manipulation of the Zion test data which included " declaring 'out-of-service' of two out of nine sensors" and
" averaging,' correctly', the readings of the seven 'in-service' channels." This
.in a blatant lie. It is no wonder that neither calculations nor cornputer lirling are exhibited to support the Decision claim.
What the program actuallly did, was throwing out two readings that would have affected the value of leak rate in a " bad" way, and doubling of two weighting coefficients. It ubculd be noted that no legal baulu for such actions exists.
It is fraud in its purest form. The word " averaging" used in the Decision 18 deceptive. Immediate ban on all the CE type programs must be imposed regardless
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whet her a doubling (or a similar) option has ever been executed.
2.C.3. The Occision does not dispute my Petition statement that Zion weighting coefficients are obviously incorrect. No attempt is made to estimate the error
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in weighting coefficients.
7.C.4 The Decinion does not dibpute my Petition discussion that the m ification tests such as those perforrned at Zion are meaningless.
?.C.S.
I nnt ead, t he Decision t rion to discredit. the first (failing) ver i fication test in favor of t.be second ("pasning") verification test.
The declared goal of a verification test is to confirm the test assumptions, henica))y, the weight coefficients. This wac not done. Instead, "the licencee did speculate on the coune.... It was thought that the verification test equipent ooy have been leaking.... A second verification test was then tor. ducted using a larger imposed Icak rate (1.1 L versus 0.82 L ).. " If the e
t secor.d verification test were performed at the same L an the first then the "12 r < nnee 'r npeculat ion" at Jeant would have some ground. With the second wri fication performed at 401 larger L;the only conclusion that can be drawn L;=0.82 L and pass at Lg out t_
tbene " verification" tents is that they fall at t
i 1
i
=1.1 L.. Therefore, conservatively, the test assumptions should have been j
niec l a red i nadertua t e (which, certainly, could have been detected by ohne n v it. i on ).
Interestingly, several " verification" tests on Zion failed in the past and the tent assumptions have never been questioned!
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Impcrtantly, the conservative estimates of the Zion leak rate have been obtained using conservative estimates of the weighting coefficients. These estimater are in excess of t he legal limits.
t The Zion weighting coefficients are obviously incorrect. Even the phony
" verification" tests do not save the situation. Therefore, we must rely on the concervative estimates of Joak rate. These clearly indicate that the necessary
. j repais: must be done on the containment system with a subsequent adequate testing thernof.
CONCLUSIONS l
- 1. The Decision did not address all the requests of the Petition.
- 2. The Decision did not consider and respond to the substantial evidence presented in the Petition.
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- 3. The Decision did no't demonstrate any flaws in the Petition with the exception that the fraudulent LaSalle-Zion software turned out to have been-develcq(>d not by Volumetrics but by an unidentified organization.
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- a. The imeibion did not support its reasoning by such technical means as derivations, calculations, proofs etc.
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- 5. In ruany Jnstancen the reasoning was intentionally deceptive.
- 6. Some essential. evidence has been withheld by the NRC.
j PEQUESTS
- 1. For the reasons stated above I insist that your Decision be nullified in full.
2.
I insist that my Petition be satisfied with the following changes instead of "Volumetrics noftware" use "CE type software."
- 3. 1 propose that a meeting be called (in Washington, D.C. or in Chicago, II) where the preparcrs of the Decision would havn an opportunity to present the
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pro:,f n of t heir statements or any other materials supporting their views.
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.t Sincerel.
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