ML20135E310
| ML20135E310 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point |
| Issue date: | 09/12/1985 |
| From: | Matt Young NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Cole R, Lazo R, Luebke E Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-496 OLA, NUDOCS 8509160357 | |
| Download: ML20135E310 (20) | |
Text
-
WELATED COHHENFUM t) Illf
- j#
UNITED STATES y
'h NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 8
\\
/
September 12, 1985
- NS Sgp g A?O$2
[: _
. ]= :-
Dr. Robert M. Lazo, Chairman Dr.RichardF."Co[e.
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Enuneth A. Luebke Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 In the Matter of FLORIDA POWER AND LIGHT COMPANY (Turkey Point Plant, Units 3 and 4)
(Vessel Flux Reduction)
Docket Nos. 50-250, 50-251 OLA
Dear Administrative Judges:
Enclosed for your infonnation is a copy of a Board Notification (BN-85-081),
dated August 27, 1985, concerning allegations by a former Westinghouse employee regarding certain Westinghouse analyses and quality assurance.
Turkey Point is among the plants specifically identified by the alleger as a facility to which at least some of the allegations app?y. Copies are also being transmitted to the parties to this proceeding by means of this letter.
Sincerely, Mitz
. Young Counsel for NRC Staff
Enclosure:
As stated cc w/ enclosure: Service list 8509160357 850912 PDR ADOCK 05000250 G
PDR 3so7 1
N005
- ,e'-W.
N UNITED STATES j
.y(. h NUCLEAR REGULATORY COMMISSION
, Is i, ",.NY/.:
i W ASHING TON, D. C. 20555 AUG 2 7 1989 Decket Nos.: 50-400/401, 445/446 and STN 50-498/499 MEMORANDUM FOR: Chairman Palladino Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Zech FROM:
Hugh L. Thompson, Jr., Director Division of Licensing
SUBJECT:
BOARD NOTIFICATION NO.85-081 ALLEGATIONS CONCERNING WESTINGHOUSE ANALYSES AND QA This Notification is being provided to the Commission in accordance with the f
revised Commission's notification policy of July,6,1984, to inform the Commission on all issues on the cases before the Commission. By copy of this memorandum, the appropriate ASLBs and ASLABs and parties to the proceedings are also being informed of this new information.
The enclosed document (Enclosure 1) contains allegations by a former Westinghouse employee that certain incidents at Westinghouse constitute violations of either NRC regulations or Westinghause quality assurance requirements. The allegations (1) lost calculation notes in support of FSARs; (2) non-disclosure concern:
of an unsafe plant condition-violation of single failure criteria; (3) threats of retaliation against employee for disclosure of item (2); (4) failure to report apparent safety violations to Westinghouse Safety Review committee; (5) discrepancies within Westinghouse OA procedures for reportin safety problems; (6) violation of Westinghouse QA Procedure; (7)g potential threatened retaliation against employee for presenting his concerns in writing; and (8)
Westinghouse QA violations regarding independent calculation checks and i
nonconservative computer input data.
Item (1) applies only to Diablo Canyon, while items 2 through 8 could potentially apply to all Westinghouse plants.
The following plants were specifically identified:
Indian Point 2 & 3 Turkey Point 3 & 4 Point Beach I & 2 Comanche Peak Ginna Beznau Italian Reference Plant Also enclosed is a letter from the Manager of Westinghouse's Nuclear Safety l
Department (Enclosure 2). The letter states that Westinghouse has begun an i
internal review of these allegations.
j
, ::.ocuu 5
~..
2-Agg 2 7 1995 The staf-has scheduled an inspecticn at Westinghouse n late Augpst. We will inform the Commission and the Boards of the resolution of the_se allegations.
JDI
[
Hu L. Thompso(, Jr.,
frector Division of Licensin
Enclosures:
As stated cc w/ enclosures:
SECY (2)
OPE OGC EDO Parties to the Proceeding ARS (10)
-e sext page Atomic Safety and Licensino Board For:
Comanche Peak (Bloch, Jordan, McCollom)
Seabrook (Hoyt, Harbour, Luebke)
Shearon Harris (Kelly, Bright, Carpenter)
South Texas (Bechhoefer, Lamb, Shon)
Atomic Safety and Licensing Appeal Board For:
Shearon Harris (Moore, Gotchy, Wilber)
O a
j L
-+
e-e y
g 9
,_e-m o-.
6
.-+----.--m
-,._._w 4
m
DISTRIBUTION LIST FOR BOARD NOTIFICATION d.
4 L
Cemanche Peak Units 1&2, Docket Nos. 50-445/446 Seabrook Units 182, Docket Nos. 50-443/444 Shearon Harris Units 1&2, Docket :los. 50-400/401 i
South Texas Units 1&2, Docket Nos. 50-498/499 i
Atomic Safety and Licensing Herbert Grossman Jo Ann Shotwell, Esq.
Board Panel Robert P. Gruber Lanny Alan Sinkin Atomic Safety and Licensing Dr. Jerry Harbour Carole S. Sneider, Esq.
Appeal Panel Mr. Robert J. Harrison George F. Trowbridge, Esq.
Brentwood Board of Selectmen Donald L. Herzberger, MD Dr. Mauray Tye livision of Consumer Counsel Renea Hicks, Esq.
Ms. Ann Verge PeFng and Service Section Ms. Beverly Hollingworth Richard D. Wilson, M.D.
'-c Management Branch Gary W. Holmes, Esq.
Robert A. Wooldridge, Esq.
- car *anager's Office Helen Hoyt, Esq.
Town of North Hampton Senator Gordon J. Humphrey Robert A. Jablon, Esq.
i Phillip Ahrens, Esq.
Elizabeth B. Jqhnson Robert A. Backus, Esq.
Bradley W. Jones, Esq.
Charles Bechhoefer, Esq.
Richard E. Jones, Esq.
Brian Berwick, Esq.
Dr. Walter H. Jordan Peter B. Bloch, Esq.
William S. Jordan, III, Esq.
Mr. Glenn 0. Bright James L. Kelley Mrs. Peggy Buchorn Dr. James C. Lamb, III William H. Burchette Dr. Linda W. Little Mr. Calvin A. Canney Dr. Emmeth A. Luebke Dr. James H. Carpenter Mr. Angie Machiros Brian P. Cassidy, Esq.
Robert D. Martin Mr. Donald E. Chick Dr. Kenneth A. McCollom Mr. Mendall Clark John H. McEachern, Esq.
Mr. Nicholas J. Costello James T. McGaugby Mr. W. G. Counsil Patrick J. McKeon Edward L. Cross, Jr., Esq.
Mr. Edward F. Meany Mr. James E. Cummins Jack R. Newman, Esq.
+
Thomas G. Dignan, Jr., Esq.
Mr. Travis Payne, Esq.
Mr. John F. Doherty Spence W. Perry, Esq.
Ms. Jane Doughty Ms. Roberta C. Pevear Mr. Owen B. Durgin Mr. David Prestemon Kim Eastman Senator Robert L. Preston Wells Eddleman Ms. Diana P. Randall Mrs. Jaunita Ellis Daniel F. Read Dr. Harry Foreman Nicholas S. Reynolds, Esq.
R. X. Gad III, Esq.
Steven Rochlis Joseph Gallo, Esq.
Anthony Z. Roisman, Esq.
r Billie Pirner Garde John Runkle Ms. Sandra Gavutis Mr. Alfred Sargent t
Ellen Ginsberg, Esq.
Melbert Schwarz, Jr., Esq.
Ray Goldstein, Esq.
Frederick J. Shon I
~
u.
~
Branch service lists of addressees receiving material on the fc lowing dockets for BN 85-081:
COMANCHE PEAK DOCKET Mr. Robs-t E. Ballard, Jr.
Mr. A. 7. Darker Mr. David R. Pigott, Esq.
Mrs. Nancy H. Williams Regicnal Administrator, RIV W. G. Counsil Mr. Dennis Kelley Mr. John W. Beck Mr. Jack Redding William A. Burchette, Esq.
Mr. James McGaughy Nancy E. Wiegers Mr. Homer C. Schmidt SEABROOK DOCKET Bruce Beckley D. Pierre G. Cameron, Jr., Esq.
Regional Administrator, Region I E. Tupper Kinder, Esq.
Resident Inspector Mr. John DeVincentis Mr. A. M. Ebner Mr. Warren Hall Honorable Richard E. Sullivan Mr. William B. Derrickson Ms. Jane Spector Mr. Rob Sweeney SHEARON HARRIS DOCKET Mr. E. E. Utley Mr. David Gordon, Esq.
Mr. Thomas S. Erwin, Esq.
Resident Inspector Charles 0. Barham, Jr., Esq.
Mr. George Jackson Regional Administrator, Region II SOUTH TEXAS DOCKET Mr. J. H. Goldberg Mr. J. T. Westermeir Mr. E. R. Brooks Mr. H. L. Peterson Mr. J. B. Poston Resident Inspector Mr. Jonathan Davis Mr. S. Head Mr. Mark R. Wisenburg Mr. Charles Halligan Regional Administrator, Region IV i
.n
+..
- - ~~ -
9
-.,m
, y wm9
i Board Notification N: 35- 081 i
Allegations Concernin-..estinghouse Analyses and QA 4
Branch yervice lists of addressees receiving material on the following dockets:
COMANCHE PEAK DOCKET f
1 I
Mr. Robert E. Ballard, Jr.
Mr. A. T. Parker Mr. David R. Pigott, Esq.
Mrs. Nancy H. Williams 4
Regional Administrator,' RIV i
W. G. Counsil Mr. Dennis Kelley Mr. John W. Beck Mr. Jack Redding l
William A. Burchette, Esq.
Mr. James McGaughy Nancy E. Wiegers Mr. Homer C. Schmidt i
l SEABROOK DOCKET Bruce Beckley D. Pierre G. Cameron, Jr., Esq.
Regional Administrator, Region I E. Tupper Kinder, Esq.
Resident Inspector Mr. John DeVincentis Mr. A. M. Ebner Mr. Warren Hall l
Honorable Richard E. Sullivan l
Mr. William B. Derrickson i
Ms. Jane Spector Mr. Rob Sweeney l
SHEARON HARRIS DOCKET i
Mr. E. E. 'Jtley
(
Mr. David Gordon, Esq.
Mr. Thomas S. Erwin, Esq.
Resident Inspector Charles D. Barham, Jr., Esq.
Mr. George Jackson Regional Administrator, Region II
?
I 2
t t
- ~
=
4 L
g k
?
- 3rd Notification No. 85- 081 Page 2
{
Allegati,ons Concerning Westinghouse Analyses and QA t.
{
Branch service lists of addressees receiving material on the following dockets:
F i
SOUTH TEXAS DOCKET 1
I
'Mr. J. H. Goldberg Mr. J. T. Westermeir 1
Mr. E. R. Brooks 1
Mr. H. L. Peterson Mr. J. B. Poston Resident Inspector Mr. Jonathan Davis i
1 Mr. S. Head J
Mr. Mark R. Wisenburg Mr. Charles Halligan Regional Administrator, Region IV t
i 1
e 1
r i
f i
[
J
)
r I
I i
s t
I b
I J
i i
i I
3 k
I i
l
. r
.- r - -
c :-.
u-
Pi t t sbu r gh, Pennsylvania 15239
_r June 17, 1985
+'
To:
- Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dear Sirs s.
Until July 31st of this year, I will hold the position of Senior Engineer in the Westinghouse Water Reactor Divisions / Nuclear Technology Division / Nuclear Safety Department / Risk Assessment Technology section.
Since joining Westinghouse in 1980, I have been located at the Monroeville Nuclear
- Center, Monroeville, Pennsylvania, where I primarily perform accident analyses.
Over the past year, I have either been involved in or have knowledge of incidents that I believe are violations of either nuclear regulatory law or Westinghouse quality assurance requirements.
These incidents have been categorized and are shown as Items 1
through 8
on the attached sheets.
It is requested that you investigate these incidences and take appropriate action where necessary.
If I can be of further assistance, please call me.
Sincerely, 9
Phone
,a y
.-.y r_
v
--w.
m7
1.
LOST DIABLO CANYON SAFETY ANALYSES
=
During a group meeting held in late 1984 for,the' Plant Transient Analysis and Operating Plant Analysis
- groups, it was stated by that almost all of the calculation notes that support the Diablo Canyon Final Safety Analysis Report are missing.
Apparently these supporting analyses were lost when they were to be put on tape in 1974.
To the best of my kncwledge, these lost analyses have never been retrieved and no attempt has been made to inform the Westinghouse Water Reactor Divisions safety Review Committee, the NRC, or the customer of this situation.
Also present at the meeting were
,approximately and twelve engineers and techniciana from both groups.
I believe this is a safety violation since not keeping records that are required by a
licensed condition is a
violation of 10CFR50.71, Part C.
e e
[
I e
9
I 2.
NONDISCLOSURE OF AN UNSAFE PLANT CONDITION Asp RETAL!ATION BY MANAGER I
During November of 1934, I was assigned the tank of performing an analysis to evaluate the impact of removing the flux rate signal device from the Indian Point 2 n6 clear power plant.
This device is used to initiate turbine runback to protect against departure from nucleate boiling in case a dropped rod or dropped bank accident occurs.
Redundant protection is provided by a rod-on-bottom signal device which also causes a
turbine runback.
The rod-on-bottom device operates concurrently with the flux l
rate signal device to provide the redundant protection.
Before I started the Indian Point 2 task, I reviewed a
similar study that was done for the Turkey Point units (see CN-TA-82-104).
It immediately became apparent to me that deleting the flux rate signal device at Turkey Point violated the single failure criteria as specified in IEEE 279-1971
- Criteria for Protection Systems for Nuclear Power Generating Stations".
This is because the rod-on-bottom
- device, by
- itself, is not. totally ~ redundant.
When I
informed
~ - - - - - '
of this fiolation, said do not disclose this information or we will be i
sued."
(I presume meant Westinghouse would be sued by Florida Power and Light (FP&L)).
After some further discussion on this matter, I dropped the issue because I
believed would retaliate against me if I pursued it further.
Independent of my finding, FP&L later recognized the same unsafe condition existed that I
called to attention in November 1984.
In early 1985 FP&L issued an LER to report this problem.
This time did not attempt to conceal the problem nor did inform FP&L that I had previously determined this problem to exist.
The Westinghouse response to the FP&L finding was documented in Letter NS-RAT-PTA-85-091 which provides recommendations on how FP&L should sodify the existing hardware to make the system redundant.
On the 29th of January
- 1985, I
had my performance appraisal for the year 1984 and was informed by that I was being terminated from Westinghouse on July 31, 1985.
I believe a factor in my termination was retaliation against me for uncovering this faulty Westinghouse recommendation of which wa s-the originator.
4
. -. - - -.. = -. -
- ~....
- :: - =: - - -- :w
f 3.
FEAR OF RETALIATION 1
As noted in Item 2 shown on the previous page, ~ I was required to perform a safety evaluation for Indian Point 2,
i similar to the one that had performed for the Turkey Point Units.
In the Indian Point 2 analysis, I stated that the rod-on-bottom unit by itself was not completely single failure proof. (see Page 10 of CN-TA-84-202).
On the other i
hand, I did not disclose this fault in the customer report (NS-RAT-PTA-84-171) since disclosing it would result in either the Indian Point 2 and Turkey Point units having to j
t undergo substantial modifications (to make the rod-on-bottom signal device single failure proof) or the I
r flux rate signal device could not be removed from
- service, i
which would negate the need for the analysis.
Furthermore, based on response to my finding in the case of the Tarkey Point Units, I feared retaliation by if I
disclosed this fault to Consolidation Edison of New York i
City.
L I discussed this dilemma with two of my colleagues,
- and, to a
lesser
- extent, later checked my cale note.
(
i f
I i
L l
i i
i i
- CT REPORTING APPARENT SAFETY VIOLATIONS TO s.
4 THE SAFETY REVIEW COMMITTEE A.
Analyses That Raise the Reactor Trip on Turbfhe Trip Se: point In January 1985 a colleague, pointed.out to me that a
Comanche Peak plant specific study he had previously checked (CN-TA-84-971 to justify raising the setpoint for deletion of reactor trip on turbine trip its then existing value was in error.
above The error was the result of not transferring transient inlet temperatures to the THINC3 computtr code where they can be used to calculate the departure from nucleate boiling ratio (DNBR).
As a result, the initial (constant) inlet temperature is used to compute DNBR throughout the transient.
This is unconservative since in some cases analyzed the transient inlet temperature rises cpproximately 20 to 30 degrees Fahrenheit above.the initial temperature
.by the time the minimum DNBR is reached.
I reviewed our files and determined that a dozen studies of this type had been approximately
...s done in only one of these studies (CN-RPA-78-66) didpreviously and the correct inlet temperature history.'
THINC3 use I wrote a memo on January 25, 1985 to informing of the nonconservative computational method currently being
- used, while pointing out that this error probably exists in several other studies and that the problem should be reported to the Westinghouse Water Reactor Divisions (WRD)
Safety Review Cocmittee (SRC).
When I later spoke to the note, criticized me for calling the problemregarding attention and said to would take care of it.
No plan for resolution of this problem was quickly set-up as required in Risk Assessment procedure NS-RAT-IG-9 nor was the WRD SRC Technology (RAT) alerted of this potential issue within the first two week's as required by Item 10 of NS-RAT-IG-9. To the best of problem has never been reported to the SRC and itknowledge, this my been corrected in two cases.
has only B.
Dropped Rod Analyses for Turbine-Runback Plants In early 1985,
,, while working on a
study to justify an increase in the turbine runback Turkey Point Units 3 and 4 (see CN-TA-85-6),
setpoint for discovered an error to exist in the dropped rod methodology as outlined
._,,.____m#_,-
,-,,,.f-
.-y,_-,,ysw--
y,~_,w,
,y.--yw m--
,%,,.--m.--
i 4.(cg'ntinue )
e in NS-TA-83-365 which yielded nonconservative results'.
Specifically the dropped rod methodology catis for performing the analysis at a
turbine runback safety analysis limit 4% less than the turbine runback setpoint.
However, the safety analysis limit should be 4%
more than the setpoint value.
This 8%
error was incorporated into the following plant specific safety analyses.
Point Beach 1 and 2 Turkey Point 3 and 4 Indian Point 2 and 3 s.
Ginna Beznau informed me he reported this error to but, no plan of resolution of this problem was quickly set-up in accordance with RAT procedure NS-RAT-IG-9 nor was the WRD SRC alerted of this potential issue within the first two weeks as rgquired by Item 10 of NS-RAT-IG-9 To the best of my knowledge, the problem was never reported to the SRC nor have any of the erronious analyses been corrected.
I e
'I 9
f e
5.
MONUN!?ORM PROCEDURES WITHIN WESTINGHOUSE FOR REPORTING
~:TT.NT!A*. SAFETY VIOLATIONS Information provided by Westinghouse management shows three'.different sets of procedures that should be Es110wed in reporting potential safety violations to' the Westinghouse Water Reactor Divisions (WRD)
Saf.etyI' Review Cc=mittee TSRC).
In my opinion, the procedures that are specified by first and second level managers (see B and C
below)
- can, and do, lead to intimidation as discussed in Item 2
and
' burying
- potential safety problems as discussed in Item 4 Also, I think it is the intent of the NRC that
- one, and only one, set of procedures be used within Westinghouse to report potential safety violations.
A.
Posted in the main lobby of the Monroeville Nuclear Center, Monroeville, Penna.
l (1.)
Report violation to supervisor, or-(2.)
Report violation to Manager's Representative on the WRD SRC, or-(3.)
Report violation to R.A.
- Wesemann, Secretary of the WRD SRC.
B.
Stated in the Radiological Assessment Technology Instruction Guidance Material (1.)
Report violation to supervisor, then (2.)
Get supervisors approval, then (3.)
Provide plan for resolution of the problem to the SRC.
If the supervisor disapproves your request to report the potential safety item, you may (4.)
Report directly to the WRD SRC.
C.
Stated in undated memo provided to members of Plant Transient Analysis and Operating Plant Analysis during a
meeting in late 1984 and also provided in a Nuclear Safety Department handout to all members of the Nuclear Safety Department in early 1985 (1.)
Get supervisors approval.
Note:
I have asked for clarification regarding this issue in letter NS-RAT-PTA-85-047 The response to my request (see Letter NS-RAT-PTA-85-051) states the memo referr.ed to in Item C above was only intended to be a
" guideline',
but there is nothing on the memo to indicate it was only intended to be a guideline.
1 l
l
e 4
6.
VIOLATION OF QUALITY ASSURANCE PROCEDURES
_r A.
Transm,ittal of Preliminary Draft Reports Letter NS RAT-83-036 dated Noveber 29, 1983 states the requirements to be followed within the Risk Assesment Technology (RAT) section with regards to transmitting preliminary draft reports outside the RAT group.
The requirements are the following:
(1)
The transmittal letter should state the information is preliminary.
(2)
The report should be stamped ' PRELIMINARY *.
(3)
First level manager's approval is required.
s.
On December 16,
- 1983, a
preliminary copy of the Italian Reference, Plant functional requirements were sent out (see Letter NS-TA-83-520) without any of the above requirements implemented.
Note that these functional requirements did not go through the normal in-house review but rather were to be reviewed by the customer (NIRA/SOPREN).
B.
Assigning a Competant Independent Verifier Within the Risk Assessment Technology (RAT) Section Westinghouse Nuclear Technology Division procedure NTD-DPP-38, Rev. 2 dated 7/24/81 and RAT section procedure NS-RAT-IG-2 state that the cognizant (or Appropriate RAT) manager shall assign an engineer to act as the independent (or RAT independent) reviewer.
This procedure is rarely if ever followed in the Plant Transient Analysis or Operating Plant Analysis groups.
In
- fact, I
requested that
~
assign an independent checker to i
check one of my calculations (CN-TA-85-29) when I
had difficulty in finding an independent
- reviewer, returned the cale note later with an attached note stating that I
should find my own independent reviewer.
did check CN-TA-85-29 when I asked him to do so and recalled seeing the note that wrote when I
t called the incident to his attention on March 25, 1985 9
7 TF.REATENED RETALIATION FOR SENDING WRITTEN MESSAGES d
On Thursday morning, February 14,
- 1985,
, _r called me into office and told me would terminate my employment with Westinghouse.with two months notice if I
continued to harass What considered harassment included only the following items, 1.
Writing Letter NS-RAT-PTA-85-047 which requested clarification on the correct procedure to use to report potential safety problems to the Westinghouse Water Reactor Divisions Safety Review Committee.
2.
An informal memo dated 2/7/85 from me to asking why the normal in-house review and comment procedure
,' was not followed for the Italian Reference plant's j
Functional Requirements (Letter NS-TA-83-520).
~
3.
An informal memo from me to i stating that I
Tianned to give the Italian Reference plant's Back-up P:otection system Functional Requirements a
PRELIMINARY status until they were checked by the customer since this would conform with NS-RAT-83-036.
4.
An informal memo from me to regarding a complaint by Consolidated Edison of New York City that Westinghouse had never called back when they (Consolidated Edison) requested a
meeting between Consolidated Edison and Westinghouse a
month earlier.
I also expressed my concern that our good business relationship with Consolidated Edison was being strained because of this incident.
i demanded that any future communication I
have with be limited to verbal communications.
l l
r l
l l
-_, _ _ _ _. _ _ _ _ _ _ _ _ _. _ _ _ __.. :__ SJ ". __ Z:. _ _ _ _ -
B.
POOR CALCULATION NOTE CHECKING WHICH RESULTED IN QUALITY ASSURANCE VIOLATIONS AND NONCONSERVATIVE COMPUTER INFU" DATA
'A review was made of CN-TA-84-63, "CGE Deletion of
~
Reactor Trio on Turbine Trip Below 50% Power (P-9)'
by and checked by Numerous errors were found to exist in the analysis. Most, if not
~ ll, of a
these errors should have been detected by the independent reviewer.
1 The following errors were noted:
a.
The Model 51 steam generator is simulated in this study.
It does not have a preheater, but the input data (MODEPH=1) indicates a preheater exists.(One or the other of these inputs is in error.)
b.
The buoyancy calculations were to be turned off for conservatism (2 CORE =ZRVO=ZSGT=2SGP=0) per page 9, but 2 CORE was in fact set to 120.0.
(This error is in the nonconservative direction.)
The transient vessel inlet temperature, as c.
computed by the LOFTRAN code, increases with time but this data never got into the THINC3 calculation of departure from nucleate boiling ratio.
(This error is in the nonconservative direction.)
d.
The front page of CN-TA-84-63 is not out.
(Violates NS-RAT-1C-3 procedure.)
completely filled e.
The checklist shows CN-TA-84-63 to contain a
purpose and results near the front.
In fact, a purpose and results are not shown near the front of the calc note.
f.
The Introduction section (page 3) states four cases were analyzed, but only three cases are shown.
The Table of Contents on Page 2 is not completed.
g.
h.
Information that should appear in the
" Analysis Method and Calculations
- or ' Input Listing
- sections (pages 2
to
- 40) are actually put into the Introduction section.
i.
No sample calculation is shown, but the checklist shows the cale note to contain one.
I The checklist page is not numbered nor is the cale note number shown on the checklist page.
(If this page were separated from the cale note, there would be no Way to identify the cale note it came from.)
I
__ _, z _
t 8.(Continued) s k.
The in'put listing for the third case is not-shown.
(violates NS-RAT-IG-3 procedure) 1.
The microfiche identification numbers are not on the cover sheet.
(violates NS-RAT-IG-3 procedure) m.
The cover sheet requires a
managers signature, bdt there is none.
n.
Microfiche identification numbers are not shown anywhere in the cale note.
(violates NS-RAT-3 procedure) o.
The P-9 uncertainty already includes a
nuclear flux uncertainty.
It is not necessary to account for this uncertainty twice as is done in this analysis.
...[
p.
The 24 uncertanty noted on page 47 is a
nuclear flux uncertainty, not a LOFTRAN uncertainty,.
t q.
On page 11, 5 lines from the
- bottom, the last term
'should be 4
degrees Fahrenheit uncertainty, not 4%
uncertainties.
r.
Use of CEND3 indicates a
Model D3 steam generator should be used.
The LOFTRAN input assumed the Model 51 steam generator. (one-of the two calculations is in error.)
On page 16, DKSCRA=
.04 is not shutdown margin, s.
a trip reactivity, it is t.
On pages 28 and 29, the statement is made that modifications were made for 524 fact made for 60% power.
- power, but they were in On page 28, no numerical value is given for NORDER.
u.
~
v.
QFINTL requires an input for each loop.
The proper input should be QFINTL=3'l.0, not QFINTL=1.0 w.
On page 56, third paragraph a
rapid increase in coolant temperature' probably was intended to be a
rapid increase in coolant pressure" x.
On page 62, middle of second paragraphs operated relief valves are actuated, not the safety valves.the[ power i
t
-?
8.(Continued) y.
On page 63, last paragraph:
pressure PORVS should be '-- pressurizer PORVS - '.
There is no indication where the two typos referred to 2.
in Revision 1 are located.
They should be clearly marked by a bar in the right margin along with the appropriate revision
- number, but I
don't see any such marking.
(violates NS-RAT-IG-3 procedure. )
s.
A review made of analyses which justify setpoint for reactor trip on turbine trip above theraising the 104 power level has shown the independent typical
- reviewer, has never previously performed this type of analysis.
Therefore
, or should have,
disqualified from being the ind,ependent reviewer of this cale note.
e 9
-~
westing:c::se Water Reactor Ele:tric Corporation DMsions
- 'r Pm O ':sv seim P ms u s Nnnsri m t u r July 12,1985 Mr. James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Taylor:
s.
This is to confirm our telephone conversation of July 11 in which we informed you that on that date we first becam,e1985 aware of a letter dated June 17, 1985 and sent to your office by Water Reactor Divisions at the Monroeville Nuclear Center.a former emp alleges in this letter certain practices and events in which he was involved while an employee which he believes were violations of either " nuclear regulatory law or Westinghouse quality assurance requirements", and requests your investigation and appropriate action.
Please be assured that we shall cooperate fully in this regard, and that we have begun an internal review of the factual matters contained in
~ allegations.
Our preliminary review has revealed no actual safety deficiencies as a result of the alleged incidents and practices.
we have found no reason to believe that
- Moreover, other e=ployee has been inhibited from raising safety concerns or any through the established channels as defined in the company's
'policies and procedures.
Our continuing review will place aighest priority on verification of the safety of licensed facilities, and our findings will be communicated as appropriate to affected licensees and to your office.
Please call me f.412-374-4868) if I can be of further assistance a t any time,
i Very truly yours,
'w ?_ ?
=
f P. Rahe, Jr., Manage'r Nuclear Safety Department 1
~ ~8508300310 g 827 f~
~ =cr 4,
P
~
__.