ML20135E310

Forwards 850727 Board Notification 85-081 Concerning Allegations by Former Westinghouse Employee Re Certain Westinghouse Analyses & Qa.Related Correspondence

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

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WELATED COHHENFUM t) Illf

• j#  % UNITED STATES y 'h NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 8

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September 12, 1985 *NS Sgp g A?O$2

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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 G ADOCK 05000250 PDR 1

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1. ,e'-W. N UNITED STATES j .y( . h NUCLEAR REGULATORY COMMISSION i W ASHING TON, D. C. 20555

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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 f

This Notification is being provided to the Commission in accordance with the 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 concern: (1) lost calculation notes in support of FSARs; (2) non-disclosure 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. ,

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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. -

Hu JDI 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)

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DISTRIBUTION LIST FOR BOARD NOTIFICATION .

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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.

Phillip Ahrens, Esq. Elizabeth B. Jqhnson i 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

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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

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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  !

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3rd Notification No. 85- 081 Page 2 {

Allegati,ons Concerning Westinghouse Analyses and QA t.

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Branch service lists of addressees receiving material on the following dockets: F i

1 SOUTH TEXAS DOCKET I

'Mr. J. H. Goldberg  !

1 Mr. J. T. Westermeir -!

Mr. E. R. Brooks  !

1 Mr. H. L. Peterson Mr. J. B. Poston  !

Resident Inspector 1

Mr. Jonathan Davis i Mr. S. Head J Mr. Mark R. Wisenburg  :

Mr. Charles Halligan

• Regional Administrator, Region IV  ;

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Enclosure 1 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.

joining Westinghouse in 1980, I have been located at Since 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

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1. LOST DIABLO CANYON SAFETY ANALYSES

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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 and ,approximately .

, 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.

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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. -

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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 hand, I did not disclose this fault in the customer report

• i (NS-RAT-PTA-84-171) since disclosing it would result in either the Indian Point 2 and Turkey Point units having to t j

undergo substantial modifications (to make rod-on-bottom signal device single failure proof) or the the r

I 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 City.

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I discussed this dilemma with two of my colleagues,  !

and, to a lesser extent, later checked my cale note.  !

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4 REVIEW:CTCOMMITTEE REPORTING APPARENT SAFETY VIOLATIONS TO THE SAFETY A.  :

Analyses That Raise the Reactor Trip on Turbfhe Se: point Trip me In January 1985 a colleague, pointed.out l

that a Comanche Peak plant to previously checked specific study he had (CN-TA-84-971 to justify raising the setpoint for deletion of reactor its then existing value was in error. The error was trip on turbine trip above result the THINC3 of not transferring transient inlet temperatures the to computtr code where they can be calculate the departure from nucleate boiling ratio used As a result, the initial (DNBR).

to used to compute DNBR (constant) inlet temperature is throughout the transient. This is

'- unconservative since in inlet temperature rises cpproximatelysome cases analyzed the transient 20 to 30 degrees Fahrenheit above.the initial temperature .by the time minimum DNBR is reached. the

. . .s a dozen I reviewed studies our files of this andhad type determined been done that approximately 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 computational out that this error method currently being used, nonconservative while

. probably exists in severalpointing studies and that the problem should be reported other Westinghouse Water Reactor Divisions to the Cocmittee (SRC). (WRD) Safety Review the note, When I later spoke to attention and said criticized me for calling the problemregarding to would take care of it.

No plan for resolution of this problem was set-up as required quickly in Risk Assessment Technology procedure NS-RAT-IG-9 nor was the WRD SRC (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 my this problem has never been reported to the SRC and itknowledge, has only

< been corrected in two cases. .

B.

Dropped Rod Analyses for Turbine-Runback Plants In early 1985, ,, while working on a study to justify an increase in the turbine runback setpoint Turkey Point Units 3 and 4 (see CN-TA-85-6), discovered for an error to exist in the dropped rod methodology as outlined

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e in NS-TA-83-365 which yielded nonconservative results'.

Specifically the dropped rod performing the analysis at a turbine methodology catis for analysis limit 4% less than the turbine runback runback safety 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 error to was quickly but, no plan of resolution of this this problem set-up in accordance with RAT procedure

• "* NS-RAT-IG-9 nor was the WRD SRC alerted of this potential issue within NS-RAT-IG-9 the first two weeks as rgquired by Item 10 of To the best of my knowledge, the never reported to the SRC nor have any of theproblem was analyses been corrected. erronious I

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5. MONUN!?ORM PROCEDURES WITHIN WESTINGHOUSE FOR

~:TT.NT!A*. SAFETY VIOLATIONS REPORTING Information provided by Westinghouse management shows three'.different sets of procedures that should be Es110wed in reporting potential safety violations to' Westinghouse Water Reactor Divisions (WRD) Saf.etyI' Review the Cc=mittee TSRC).

In my opinion, the procedures that are first and second level managers (see B and C specified below) by can, and do, lead to intimidation as discussed in Item

' burying

• potential safety problems as discussed in Item 4and 2

Also, I think it is the intent of the NRC that one, only one, set of procedures be used within Westinghouse and 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

. the WRD SRC, or- on (3.) Report violation to R.A. Wesemann, the WRD SRC. Secretary of B. Stated in the Radiological Assessment Technology Instruction Guidance Material .

(1.) Report violation to supervisor, then (2.) Get supervisors approval, then SRC.

(3.) Provide plan for resolution of the problem to the 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 Plant Transient Analysis and Operating Plant Analysis of during a meeting in late 1984 and also provided in a Nuclear Safety Department handout to all members of the Department in early 1985 Nuclear Safety (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 1 intended to be a guideline.

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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 the Risk Assesment Technology (RAT) section with within regards to preliminary draft reports outside the RAT group.

transmitting requirements are the following: The (1) The transmittal letter should state the is preliminary. information (2) The report should be stamped ' PRELIMINARY *.

s.

(3) First level manager's approval is required.

On December 16, 1983, a Italian Reference, Plant functional preliminary copy of requirements were sent the out (see Letter NS-TA-83-520) without any of

. requirements implemented. Note that the above requirements did not go through the normal these functional but rather were be in-house review to reviewed by the customer (NIRA/SOPREN).

• B. Assigning a Competant Independent

, Risk Assessment Technology (RAT) SectionVerifier Within the 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.

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In fact, I requested that assign an independent checker to i

' check one of my calculations difficulty in finding an independent (CN-TA-85-29) when I had reviewer, returned the cale note that I should find my own later with an attached note stating independent reviewer.

and recalled didseeing check CN-TA-85-29 when I asked him to do so the note that wrote t

when I 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

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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.

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B. POOR CALCULATION NOTE CHECKING WHICH RESULTED QUALITY ASSURANCE VIOLATIONS AND IN NONCONSERVATIVE COMPUTER INFU" DATA

'A review was made of CN-TA-84-63, "CGE Deletion ~

Reactor Trio on Turbine Trip Below 50% Power (P-9)' by of and checked by Numerous errors were found to exist in the analysis. Most, if not ~a ll, of these errors should have been detected by reviewer. the independent 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 was in (2 CORE =ZRVO=ZSGT=2SGP=0) per page 9, but 2 CORE fact set to 120.0. (This error is in the nonconservative direction.)

c. The transient vessel inlet temperature, as 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 completely out. (Violates NS-RAT-1C-3 procedure.) 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. '

g.

. The Table of Contents on Page 2 is not completed.

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.

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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 identify the cale note it came from.) would be no Way to I

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k. The in'put listing for the third case is not- shown.

(violates NS-RAT-IG-3 procedure) 1.

coverThe microfiche identification numbers are sheet. (violates NS-RAT-IG-3 procedure) not on the

m. The cover sheet requires a managers signature, bdt there is none.

n. Microfiche identification numbers are anywhere in the cale note. (violates not NS-RAT-3 procedure) shown

o. The P-9 uncertainty already includes a nuclear uncertainty. It is not necessary flux to account for this uncertainty twice as is done in this analysis.

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The 24 uncertanty noted on page 47 is a nuclear flux t uncertainty, not a LOFTRAN uncertainty,.

q. On page 11, 5 lines

'should from the bottom, the be 4 degrees Fahrenheit last term uncertainties. uncertainty, not 4%

r. Use of CEND3 indicates a Model D3 steam generator should be used. The LOFTRAN input assumed the steam generator. Model 51 (one-of the two calculations is in error.)

s. On page 16, DKSCRA=

a trip reactivity, .04 is not shutdown margin, it is

t. On pages 28 and 29, the statement is made that modifications were made for 524 power, but were fact made for 60% power. they in u.

On page 28, no numerical value is given for NORDER.

v. QFINTL requires an input for .

each loop.

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The proper input should be QFINTL=3'l.0, not QFINTL=1.0

w. On page 56, third paragraph '--

a rapid increase coolant temperature' probably was intended in rapid increase in coolant pressure" to be *-- a

x. On page 62, middle of second

paragraphs operated relief valves are actuated, not the safety valves.the[ power i

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y. On page 63, last paragraph: *-- pressure PORVS -*

should be '-- pressurizer PORVS - '.

2.

There is no indication where the two typos referred to in Revision 1 are located. They should be clearly by a bar in the right margin along with the marked 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 reviewer, typical has never previously performed analysis. Therefore this type of

' , or disqualified from being the ind,ependent , should have ,

this cale note. reviewer of e

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Enclosure 2 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 s.

Dear Mr. Taylor:

This is to confirm our telephone conversation of July 11 in which we informed you that on that date we first becam,e 1985 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 investigation and quality assurance appropriate requirements", and requests your action.

Please be assured that we shall cooperate fully in this regard, and contained that we in have begun an internal review of the factual matters

~ allegations.

Our preliminary review has revealed no actual safety deficiencies as a result of the alleged incidents and practices. Moreover, we have found no reason to believe that or any other e=ployee has been inhibited from raising safety concerns through policies and the established procedures.channels as defined in the company's Our continuing review will place aighest priority on verification of the safety of licensed facilities, to affected and our findings licensees and will be communicated to your office. as appropriate Please call me f.412-374-4868) if I can be of further assistance a t any time ,

Very truly yours, i

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f P. Rahe, Jr., Manage'r Nuclear Safety Department 1

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