ML20136B555
| ML20136B555 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1985 |
| From: | Jocelyn Craig, Milano P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20136B487 | List: |
| References | |
| REF-QA-99900404 NUDOCS 8511200235 | |
| Download: ML20136B555 (19) | |
Text
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION
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PITTSBURGH, PENNSYLVANIA REPORT INSPECTION INSPECTION NO.: 99900404/85-02 DATE(S): 8/26-30/85 ON-SITE HOURS:
59 CORRESPONDENCE ADDRESS: Westinghouse Electric Corporation Nuclear Technology Division ATTN: Mr. J. L. Gallagher, General Manager Post Office Box 355 Pittsburgh, Pennsylvania 51230 ORGANIZATIONAL CONTACT: Mr. P. T. McManus, Quality Assurance TELEPHONE NUMBER:
(412)825-7988 PRINCIPAL PRODUCT: Nuclear Steam Supply Systems NUCLEAR INDUSTRY ACTIVITY: Westinghouse provides NSSS components, other safety and non-safety related components, and services.
ASSIGNED INSPECTOR:
3Rb u/t/T5 P. D. Milano, Special Projects Inspection Date Section (SPIS)
OTHER INSPECTOR (S):
R. P. McIntyre, SPIS G. A. Schwenk, Core Performance Branch sl//'/h APPROVED BY:
w Uats AphnW.Craig, Chief,QIS,VendorProgrambranch INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and 10 CFR Part 50.
B.
SCOPE:
The purpose of this inspection was to followup on allegations presented by a former Westinghouse Nuclear Technology Division employee.
PLANT SITE APPLICABILITY: Docket Nos. 50-244, 247, 250, 251, 266, 275, 286, 301, 323, 334, 361, 362, 390, 391, 395, 412, 413, 443, 444, 445, and 446.
8511200235 851118 PDR GA999 EPtVWEST 99900404 PDR e
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ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION N0.: 99900404/85-01 RESULTS:
PAGE 2 of 12 i
A.
VIOLATIONS:
None.
B.
NONCONFORMANCES:
1.
Contrary to 10 CFR 50, Appendix B, Criterion V, and Westinghouse Risk Assessment Technology Instruction / Guidance NS-RAT-IG-9, the decision that a potential issue did not warrant referral to the Westinghouse Safety Review Comittee was not documented and filed.
C.
UNRESOLVED ISSUES:
None.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
The status remains as presented in NRC Inspection Report #99900404/85-01.
An evaluation of open inspection findings was not conducted.
E.
OTHER FINDINGS AND OBSERVATIONS:
In June 1985, allegations were presented to the Nuclear Regulatory Comission, Office of Inspection and Enforcement by a letter from, at that time, an employee of Westinghouse Nuclear Technology Division.
The alleger was employed as a Senior Engineer until the date of his termination in July 1985 in the Plant Transient Analysis Group, Risk Assessment Technology Section of the Nuclear Safety Department. His letter dated June 17, 1985, detailed eight categories of alleged violations of Nuclear Regulatory Comission and/or Westinghouse requirements. This inspection was conducted to determine the validity of those allegations that were of a technical nature. The remaining allegations which addressed alleged harrassment and retaliation by his immediate manager were not reviewed during this inspection.
At the start of the NRC inspection, Westinghouse presented the inspection team with a memorandum, NS-85-1366, dated August 9, 1985, from the Nuclear Safety Department to the Safety Review Comittee. This memorandum provided a draft response to each allegation for coment by the members of the Safety Review Comittee. While a Safety Review Comittee meeting was held on August 27, 1985, the formal results were not presented to the inspectors during the duration of the inspection. The results of the meeting and Westinghouse's formal response to the allegations was
e e
- e ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 3 of 12 received by the NRC, Office of Inspection and Enforcement, on September 20, 1985 in a letter dated September 13, 1985. While the September 13, 1985 response did not contain the details delineated in the draft response presented during the inspection, the response did not differ to any extent in the statements of safety significance or corrective actions.
The allegations are summarized below, along with the results of the inspection of each item, in the order that they were presented in the June 17, 1985 letter. See Enclosure 1 for complete allegations. The inspection was comprised of personnel interviews and a review of the applicable files, calculation notes, and procedures.
1.
Allegation - Diablo Canyon Analysis - It was alleged that in a group meeting in late 1984, statements were made by the Manager, Operating Plant Analysis, that almost all of the calculation notes for the subject station were missing.
Inspection Finding - The NRC inspectors requested and received an index of documents applicable to the Diablo Canyon Station. All calculation notes listed were obtained from Westinghouse. The documents provided were the originals or a copy from microfilm of the original.
This allegation was not substantiated as evidenced by the availa-bility of the calculation notes for Diablo Canyon. There were no minutes of the meeting referenced in the allegation and individuals interviewed during the inspection could not recall the alleged statement having been made.
2.
Allegation - Nondisclosure of an Unsafe Plant Condition and RetaTration by Manager - The allegcr asserted that he recognized the deletion of the flux rate signal for turbine runback at Turkey Point violated the single failure criteria specified in IEEE-279-1971 and when he brought this fact to his supervisor's attention, he was told by her to remain silent.
Subsequent to his recognition, the alleger stated that Florida Power and Light (FPL) independently the modification at Turkey recognized the condition, after performing (LER).
Point, and issued a Licensee Event Report Inspection Finding - During the inspection, the Turkey Point analysis (CN-TA-82-104) performed by Westinghouse to support the deletion of the negative flux rate signal (NIS) and the logic diagrams for the i
1 3
m.
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION
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PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 4 of 12 turbine runback circuit were reviewed by the NRC inspectors.
Westinghouse based the removal of the NIS signal on the fact that a single failure of a rod-on-bottom sensor / transmitter to initiate a turbine runback for a single dropped rod was bounded by the previously analyzed transient of a static misaligned control rod. The Westinghouse analysis did not discuss the means by which the actual modification would be performed. However, it is evident from a cursory review of the logic diagrams (Enclosures 2 and 3),
that removal of the NIS signal would eliminate the governor load reference circuit as a means of initiating a runback. Unlike the turbine load limit circuit, the governor load reference circuit did not have an input from the rod-on-bottom signal. The FSAR for Turkey Point 3 & 4 states that turbine runback is redundantly obtained by acting upon the turbine load limit and the turbine governor control system.
The Westinghouse letter to FPL, W-PTP-64, dated June 22, 1982, provided the report concluding that the NIS signal could be deleted.
While the analysis discussed the single failure of one rod-on-bottom signal, it did not discuss other possible single failures that could prevent turbine runbacks for multiple dropped rods because the rod-on-bottom circuit was not redundant.
FPL addressed questions to Westinghouse concerning the negation of the governor load reference circuit's ability to cause a runback (reduction of load reference setpoint of the governor valve by a preselected amount) when the NIS signal was removed. However, the allegation concerning the belief that the rod-on-bottom circuit must in itself be redundant, was not addressed by FPL.
Interviews with Westinghouse personnel verified that the alleger had raised a concern over the need for the rod-on-bottom circuit to be redundant. Westinghouse personnel, however, concluded that this circuit was not required to be redundant. The rationale for this conclusion, as presented by Westinghouse during the inspection, was:
since the original design of the turbine runback system did not meet all the criteria of IEEE-279 for redundancy or environmental and seismic qualification, the modified system did not have to meet all of these requirements. Neither the concern raised by the alleger, nor the Westinghouse rationale were discussed with FPL. Also, Westinghouse stated that their contract with FPL was solely for an analysis to suppert the removal of the NIS device and not for the development of yie hardware modification design.
The modification request and sup;orting analyses were presented by FPL to the NRC, FPL letter L-82-343 dated August 10, 1982.
This modification was approved by the NRC on January 6, 1983.
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION
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PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 5 of 12 Subsequent to the modification deleting the negative flux rate input on Unit 3 in February 1985, FPL asked Westinghouse to review the hardware modification.
FPL reinstated the NIS signal after a telecon recommendation from Westinghouse was received on February 20, 1985.
The Westinghouse letter to FPL, FPL-85-586, dated March 18, 1985, stated that the mechanism by which FPL deleted the NIS signal had removed diversity from the turbine runback system (i.e., NIS was the only input to governor load reference for dropped rod). Additionally, the Westinghouse letter noted (page 3) that discussions with plant personnel indicated that the cabling between the point where the rod bottom signals connect and the point where the turbine runback trains diverge was not redundant. Thus, with the NIS signal deleted, a single failure in this cabling could prevent a runback from oc-curring.
Finally, the Westinghouse letter recommended that future modifications be made such that no single failure will prevent a runback, and stated that this cabling could be made redundant.
This would ensure that the single failure condition meets the 1982 safety evaluation used to justify removal of the NIS signal and, therefore, the subsequent NRC approval for the modification would remain valid.
The 1982 Westinghouse analysis did recognize that the rod-on-bottom signal was not fully redundant and, therefore, concerned itself only with failures in the sensor / transmitters. While the Westinghouse view presented during the inspection was that the rod-on-bottom circuit need not meet redundancy requirements, it appears to conflict with the information Westinghouse provided to FPL in the March 18, 1985 letter. The allegation is substantiated in that Westinghouse had information that the potential existed for the hardware modification to be done in a manner that would negate the validity of the NRC approved analysis. This is in addition to the potential for loss of diversity when the NIS signal was removed from the governor load reference circuit. This second item was identified during the inspection and was not part of the allegation.
3.
Allegation - Fear of Retaliation - Although this allegation is entitled " Fear of Retaliation," it did contain technical issues that were tied with a previously discussed allegation, Number 2.
The alleger stated that the redundancy issue concerning the rod-on-bottom circuit for Consolidated Edison (Con Ed) Indian Point Unit 2 was not disclosed in the customer report (NS-RAT-PTA-84-171),
although it was in the analysis performed by the alleger (CN-TA 202) to support removal of this NIS signal.
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION
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PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 6 of 12 Inspection Finding - Westinghouse personnel stated that, as in the case of the Turkey Point modification, Westinghouse was aware that the system was not required by the FSAR to meet IEEE-279 and that the work performed by Westinghouse was not hardware design, but an analysis to support removal of the NIS signal from the turbine runback logic. The results of the analysis were presented to Con Ed in Westinghouse letter IPP-85-507, dated January 16, 1985. The letter addressed a single failure that would prevent a runback for a single dropped rod.
However, it did not indicate that because the rod-on-bottom circuit was not redundant, a single failure in portions of this circuit could result in the failure to initiate a runback for multiple dropped rods.
In a letter to Con Ed, IPP-85-774, dated August 23, 1985, Westinghouse provided information similar to that presented to FPL in the March 18, 1985 letter. The letter to Con Ed stated that a single failure for a multiple dropped rod event is acceptable if the failure occurs in the rod-on-bottom sensor / transmitter and not in the non-redundant portion of the system. T Ns, Westinghouse, in apparent contradiction to previous statements, concerning redundancy made in the letter to Con Ed dated January 16, 1985, recommended modifying the turbine runback circuit such that no single failure could prevent a runback. As stated in the August 23, 1985 letter, the raodification could be done by modifying the system so that the rod-on-bottom protection is redundant.
The August 23, 1985 Westinghouse letter to. Con Ed also discussed the diverse action of turbine runback by the reduction of the load reference setpoint of the turbine governor speed changer and by reduction of the turbine load limit (relief valve which limits control oil pressure). The NRC inspectors reviewed the FSAR logic diagrams for Indian Point and determined that Indian Point 2 uses diverse load limit circuits and does not have the automatic load reference reduction circuit. This was subsequently verified when Westinghouse personnel contacted Con Ed during the inspection.
Unlike Turkey Point, at the time of the inspection the Indian Point 2 modification had not been presented to the NRC for approval and no modification to the diverse load limit circuits involving the Westinghouse analysis had been performed.
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C ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 7 of 12 As with the previous allegations, this allegation is substantiated in that the potential for reduction in system protection was present if the modification did not involve changes in addition to the elimination of the NIS signal. Westinghouse's January 16, 1985 letter to con Ed did not discuss the possibilities for single failure in the nonredundant portions of the system. This was not presented to Con Ed until the August 23, 1985 letter.
4.
Allegation - Not Reporting Apparent Safety Violations to the Safety Review Committee - This allegation is comprised of two separate sets of circumstances in which it was alleged that apparent potential safety significant items were not presented to the Westinghouse Safety Review Committee (SRC) as required by Westinghouse Policy /
Procedure WRD-0PR-19.0 and Risk Assessment Technology Section Instruction / Guidance NS-RAT-IG-9.
a.
Analyses that Raise the Reactor Trip on Turbine Trip Setpoint -
This first item involves the alleged failure to properly evaluate and present analytical errors to the SRC. This error involved the methodology in which vessel inlet temperatures were used in a specific Comanche Peak analysis. This analysis was used to calculate the departure from nucleate boiling ratio (DNBR) as part of a study to justify raising the setpoint for a reactor trip on turbine trip. Additionally, this allegation included approximately eleven other studies of this type.
In a memorandum dated January 25, 1985 to his manager, the alleger stated that he highlighted the error.
However, no action was alleged to have been taken per procedure NS-RAT-IG-9.
Inspection Findings - The problem identified in the allegation related to.the methodology used in modeling and inputing vessel inlet temperature into a computer program which calculates departure from nucleate boiling ratios (DNBR). This potential problem was first addressed in a specific analysis performed for Comanche Peak which, while similar, was not a P-9 analysis as in the allegation. Documentation of a completed calculation note revision dated July 26, 1985, was provided to the inspectors which concluded that the Comanche Peak analysis remained bounded by the analyses addressed in the FSAR. This analysis was reviewed during the inspection and found to be appropriate.
LT ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 8 of 12 The allegation stated that the potential error also existed with 11 P-9 loss of load / loss of flow analyses which were performed in a manner similar to the Comanche Peak analysis.
Following receipt of the allegations, the Westinghouse Plant Transient Analysis Group determined that the vessel inlet temperature modeling utilized in each P-9 analysis did not impact the validity of these analyses. This was reviewed by the inspectors and found to be satisfactory.
It was noted that although the constant inlet temperature assumption was nonconservative, the coolant pressure was also assumed to remain constant. The conservative pressure assumption reduces the affect of the temperature assumption upon the results of this analysis. Also, the P-9 analysis is performed using reactor power at 50% which also reduces the significance of the temperature assumptions upon the results of the analysis. Based upon these findings, the allegation that this item should have been presented as a Potential Safety Item (Concern) to the Safety Review Committee was not substantiated.
b.
Dropped Rod Analysis for Turbine Runback Plants - This second item involves the alleged failure to properly evaluate and present analytical errors to the SRC. The problem involved the direction in which the turbine runback setpoint error was applied when utilized in the dropped rod analysis.
The setpoint error was in the nonconservative direction. However, no plan for resolution or for informing the Safety Review Committee was conducted.
Inspection Finding - The inspectors determined that the error had existed since June 1983 in the Westinghouse analytical procedure for the dropped rod analysis. During discussions with the NRC inspectors, Westinghouse personnel stated that an informal review had been conducted at the time the error was found in February 1985 to determine if sufficient margin existed for the affected plants.
Westinghouse Policy / Procedure WRD-0PR-19.0, Figure 1, states that if the decision is made not to refer a potential issue to the Safety Review Committee, the basis for the position must be documented and filed.
In further clarification of this require-ment, Risk Assessment Technology Instruction / Guidance NS-RAT-IG-9, Rev. O, " Procedure to Address Safety Issues," Section 5, states that the goal of a plan for resolution is to either refer the issue to the WRD Safety Review Committee or to write and file a Safety Evaluation (SE) letter documenting the basis for a 1
1 ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION l
PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 9 of 12 decision not to refer the issue to the WRD Safety Review Connittee. The Manager of SE is required by this procedure to maintain a Safe.ty File containing appropriate documentation of these decisions.
Other than the reanalysis for Turkey Point 3 & 4, the decision not to refer the issue to the SRC and the conclusion that sufficient DNB margin existed for other plants were based on undocumented engineering judgement. No documentation, including notes or telecon reports, were available to support the decision.
This allegation was substantiated. Undocumented engineering judgement concerning the availability of DNB margin for the plants and the lack of documentation to support the decision not to refer the issue to the Safety Review Committee was not in accordance with Westinghouse procedures.
(RefertoItemof Nonconformance B.1.)
5.
Allegation - Nonuniform Procedures Within Westinghouse for Reporting Potential Safety Violations - The two aspects of the allegation are discussed below, a.
This first involved the requirements in Risk Assessment Technology Instruction / Guidance NS-RAT-IG-9 as it differs from the procedure posted in the Monroeville Nuclear Center Lobby. The alleger believed that the differences lead to intimidation and " burying" of potential safety issues.
Inspection Finding - The posted notice does not require that an employee report the violation to his supervisor and obtain his/
her approval prior td reporting the issue to the Safety Review Committee (SRC) whereas NS-RAT-IG-9 does require approval of a supervisor prior to reporting an issue to the SRC.
However, NS-RAT-IG-9 allows an employee to report potential safety items directly to the SRC if the employee disagrees with the supervisor's disapproval of the request.
Based upon inter-views with personnel in the I! ant Transient Analysis Section, governed by this instruction, the inspectors could not identify an instance in which intimidation and/or burying of potential safety problems had occurred.
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ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 10 of 12 Westinghouse Policy / Procedure WRD-0PR-19.0, Section titled
" Responsibility," states that "each employee is responsible for promptly notifying his or her supervisor, or manager, or the cognizant managers, or Safety Review Comittee as designated by division and departmental procedures, of any condition adverse or potentially adverse to safety of WRD products and services or NRC licensed activities, when he or she becomes aware of such a condition."
This allegation was not substantiated. While the Risk Assessment Technology Instruction / Guidance is not worded identically to the posted procedure these instructions are consistent with each other and are consistent with Westinghouse Policy WRD-0PR-19.0.
b.
The second involved an undated memo provided to members of the Plant Transient Analysis and Operating Plant Analysis sections by the supervisors of each section. This memo was entitled
" Items Requiring Manager Review and Approval Signature." The allegation was that this memorandum was contradictory to Westinghouse Policy in that it lists " requests for potential items" (i.e., mechanism for establishing file for evaluation of potential safety item) and did not include a statement or provision concerning the employee's ability to go directly to the SRC if there is a disagreement with the supervisor's disapproval.
Inspection Finding - Based upon a review of the subject memo-randum and discussions with the supervisors, the inspectors determined that this memorandum was a general list of areas that require managerial approval.
This allegation was not substantiated. The formal Westinghouse policy instructions are the governing documents for reporting conditions adverse or potentially adverse to safety to the SRC.
6.
Allegation - Violation of Quality Assurance Procedures a.
Transmittal of Preliminary Draft Reports It was alleged that a preliminary copy of the Italian Reference Plant functional requirements was transmitted without the following requirements per Westinghouse letter NS-RAT-83-036, dated November 29, 1983, being implemented.
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 11 of 12 (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 Inspection Finding - Although the documentation in question is for a foreign national utility, the allegation was reviewed.
The Westinghouse cover memorandum from the Nuclear Technology Division to International Licensing clearly indicated that the attached report was preliminary. Along with the limited scope of the work that the document encompassed, this item does not indicate a failure to follow Westinghouse quality assurance requirements, b.
Assigning a Competent Independent Verifier Within the Risk Assessment Technology (RAT) Section The basis of this allegation is that within the Risk Assessment Technology Section, the procedural requirements governing assignment of independent design verifiers are not followed.
8 Rather than the Manager, Plant dansient Analysis or Operating Plant Analysis, assigning the independent verifier as required by RAT Instruction / Guidance NS-RAT-JG-2, a verifier was selected by the individual who had prepared the calculation which was to be subsequently reviewed.
Inspection Finding - This allegation was substantiated.
In the Westinghouse response to this allegation, Westinghouse determined that the allegation was correct. Westinghouse conducted a review of all calculation notes since September 1, 1984 to verify that no unqualified reviewers were utilized.
It was also noted by Westinghouse that an internal Nuclear Safety Department audit had noted in the report dated May 22, 1985 that the files utilized for verification of reviewer quali-fication were not formally reviewed by management.
Based on the internal audit and the review of this allegation, Westinghouse has committed to revise the instruction / guidance to clarify independent reviewer selection procedures and ensure management assignment or approval of the reviewer.
L
ORGANIZATION: WESTINGHOUSE ELECTRIC CORPORATION PITTSBURGH, PENNSYLVANIA REPORT INSPECTION NO.: 99900404/85-01 RESULTS:
PAGE 12 of 12 7.
Allegation - Threatened Retaliation for Sending Written Messages This allegation did not include technical issues not previously addressed. The basis of the allegation, i.e., retaliation, was outside the scope of this inspection.
8.
Allegation - Poor Calculation Note Checking Which Resulted in Quality Assurance Violations and Nonconservative Computer Input Data M
a.
Poor Calculation Note Checking - Thu allegation involves a review performed by the alleger of calculation note CN-TA-84-63, "CGE Deletion of Reactor Trip on Turbine Trip Below 50% Power (P-9)" that had been previously independently checked by anocher reviewer. During his review, the alleger found twenty-six arrors thct should have been detected during the previous review.
Inspection Finding - This allegation was substantiated. The NRC inspection team reviewed the calculation note and the Westinghouse evaluation of the allegation. The Westinghouse evaluation included a review of each item and its impact on the calculation. The deficiencies for the most part existed in the calculation as alleged.
However, none of the deficiencies was significant such that it would have resulted in the calculation note not being approved.
During discussions with the Manager, Operating Plant Licensing Support, the procedure for preparation and review of calcu-lations, NS-RAT-IG-3, was shown to be under review. This procedural review was begun prior to the date of the allegation letter.
b.
Qualification of the Independent Reviewer - This section alleges that the independent reviewer for the above noted calculation was not qualified.
Inspection Finding - Based on the types of calculations that the reviewer had previously performed and interviews with responsi-ble management concerning the reviewer's qualification, this portion of the allegation could not be substantiated.
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1 ENCLOSURE 1 9201 Wedgewood Drive Pittsburgh, Pennsylvania 15239 June 17, 1985 To
- Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission
{
Washington, D.C.
20555 Dear Sir Until July 31st of this year, I will hold the position of Senior Engineer in the Westinghouse Water Reactor i
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, j
where I primarily perform accident analyses.
4 i
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 i
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.
4 If I can be of further assistance, please' call me.
4 k
sincerely, do& R.
-- h hn
..eg1et..
gen,ei W m_ sr g Phone:
.(412)795-2795
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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 the manager of Operating Plant
- Analysis, Pat Loftus, 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 knowledge, 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 the Manager of Plant Transient
- Analysis, Melita
- Osborne, and approximately twelve engineers and technicians 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.
2.
NONDISCLOSURE OF AN UNSAFE PLANT CONDITION AND RETALIATION BY MANAGER During November of 1984, I was assigned the task of performing an analysis to evaluate the impact of the flux rate signal device from the Indian Point 2 removing nuclear 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 la provided by a rod-on-bottom signal device which also causes a
turbine runback.
The rod-on-bottom device operates concurrently with the flux rate signal device to provide the redundant protection.
Before I started the Indian Point 2 task, I reviewed similar study that was done for the Turkey Point units a
(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 Generating Stations".
Power This is because the rod-on-bottom
- device, by
- itself, is not totally redundant.
When I
informed my manager (and author of the Turkey Point analysis), Melita
- Osborne, of this violation, she said
" John, do not disclose this information or we will be sued."
(I presume Melita 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 Melita would retaliate against me if I further,,
pursued it Independent of my finding, FP&L later recognized the same unsafe condition existed that I
called to Melita's attention in November 1984 In early 1985 FP&L issued an LER to report this problem.
This time Melita did not attempt to conceal the problem nor did she inform FPEL that I had previously determined this problem to exist.
The Westinghouse response to the FP&L finding was documented Letter NS-RAT-PTA-85-091 which provides in recommendations on how FPEL should modify 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 Melita Osborne 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 Melita was the originator.
1
__y_
U 3.
FEAR OF RETALIATION As noted in Item 2 shown on the previous
- page, I
was required to perform a safety evaluation for Indian Point 2,
similar to the one that Melita 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 (NS-RAT-PTA-84-171) since disclosing it would result in either the Indian Point 2 and Turkey Point units having to undergo substantial modifications (to make the rod-on-bottom signal device single failure proof) or the flux rate signal device could not be removed from
- service, which would negate the need for the analysis.
Furthermore, based on Melita's response to my finding in the case of the Turkey Point Units, I feared retaliation by Melita if I
disclosed this fault to Consolidation Edison of New York City.
I discussed this dilemma with two of lay colleagues, Thomas Blackburn
- and, to a
lesser
- extent, Mark Adler.
Thomas Blackburn later checked my calc note.
i
4.
NOT REPORTING APPARENT SAFETY VIOLATIONS TO THE SIFETY REVIEW COMM TTEE A.
Analysts That Raise the Reactor Trip on Turbine Trip setpoint In January 1985 a colleague, Mark Grace, pointed out to me that a
Comanche Peak plant specific study he had previously checked (CN-TA-84-97) to justify raising the setpoint for deletion of reactor trip on turbine trip above its then existing value was in error.
The error was the reJult of not transferring transient inlet temperatures to the THINc3 computer 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 approximately 20 to 30 degrees Fahrenheit above the initial temperature by the time the minimum DNBR is reached.
I reviewed our files and determined that approximately a dozen studies of this type had been done previously and in only one of these studies (CN-RPA-78-66) did THINC3 use the correct inlet temperature history.
I wrote a memo on January 25, 1985 to my
- manager, Melita
- Osborne, informing her 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 Committee (SRC).
When I later spoke to Melita regarding the note, she criticized me for calling the, problem to her attention and said she would take care of it.
No plan for resolution of this problem was quickly set-up as required in Risk Assessment Technology (RAT) procedure NS-RAT-IG-9 nor was the WRD SRC alerted of this potential issue within the first two weeks as required by Item 10 of NS-RAT-IG-9. To the best of my knowledge, this problem has never been reported to the SRC and it has only been corrected in two cases.
B.
Dropped Rod Analyses for Turbine-Runback Plants In early 1985, Glen Hebele, while working on a
study to justify an increase in the turbine runback setpoint for Turkey Point Units 3 and 4 (see CN-TA-85-6),
discovered an error to exi.st in the dropped rod methodology as outlined M
4.(Continued) in NS-TA-83-365 which yielded nonconservative results.
Specifically the dropped rod methodology calls 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 44 more than the setpoint value.
This 84 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 Ginna Beznau Glen Heberle informed me he reported this error to Melita Osborne, 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 required 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.
5 NONUNIFORM PROCEDURES WITHIN WESTINGHOUSE FOR REPORTING POTENTIAL SAFETY VIOLATIONS Information provided by Westinghouse management shows three different sets of procedures that should be followed in reporting potential safety violations to the Westinghouse Water Reactor Divisions (WRD)
Safety Review Committee (SRC).
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.
(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
(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 referred 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.
l e
-n-
,n.
.g i
i 6.
VIOLATION OF QUALITY ASSURANCE PROCEDURES A.
Transmittal 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.
On December 16,
- 1983, a
preliminary copy of the 4
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 Westi.nghouse Nuclear Technology Division procedure NTD-DPP-3B, 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 my manager, Melita Osborne, assign an independent checker to check one of my calculations (CN-TA-85-29) when I
had difficulty in finding an independent reviewer.
Melita returned the calc note later with an attached note stating that I
should find my own independent reviewer.
Tom Blackburn did check CN-TA-85-29 when I asked him to do so and recalled seeing the note that Melita wrote when I
called the incident to his attention on March 25, 1985.
t I
.,.-..,___..-_,_r
7 THREATENED RETALIATION FOR SENDING WRITTEN MESSAGES On Thursday morning, February 14,
- 1985, my
- manager, Melita Osborne, called me into her office and told me she would terminate my employment with Westinghouse with two months notice if I
continued to harass her.
What she 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 l
Divisions Safety Review Committee.
2.
An informal meno dated 2/7/85 from me to Melita 1
asking why the normal in-house review and comment procedure was not followed for the Italian Reference Plant's Functional Requirements (Letter NS-TA-83-520).
3.
An informal memo from me to Melita stating that I
planned to give the Italian Reference plant's Back-up Protection 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 E.P.
Rahe and D.C.
Richardson 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.
Melita demanded that any future communication I
have with her be limited to verbal communications.
t d -
m 8.
POOR CALCULATION NOTE CHECKING WHICH RESUL ED IN QUALITY ASSURANCE VIOLATIONS AND NONCONSERVATIVE COMPUTER INPUT DATA A review was made of CN-TA-84-63, "CGE Deletion of Reactor Trip on Turbine Trip Below 50% Power (P-9)"
by E.
Kurt Hackman and checked by M.P. Osborne.
Numerous errors were found to exist in the analysis. Most, if not
- all, of these errors should have been detected by the independent reviewer.
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 (ZCORE=ZRVO=ZSGT=ZSGP=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 completely-filled out.
(Violates NS-RAT-IG-3 procedure.)
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 cale 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 calc note to contain one, j.
The checklist page is not numbered not is the cale note number shown on the checklist page.
(If this page were separated from the calc note, there would be no way to identify the cale note it came from.)
8.(Continued) k.
The input 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 calc 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 2% uncertanty noted on page 47 is a
nuclear flux uncertainty, not a LOFTRAN uncertainty.
q.-
On page 11, 5 lines from the Esottom, the last term should be 4
degrees Fahrenheit uncertainties.
uncertainty, not 4%
r.
Use of GEND3 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, DESCRA=
.04 is not shutdown margin, it is s.
a trip reactivity.
t.
On pages 28 and 29, the statement is made that modifications were made for 524
- power, but they were in fact made for 60% power.
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*1.0, 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" l
x.
On page 62, middle of second paragraph the power operated relief valves are actuated, not the safety valves.
i
g a
'o 8.(Continued) y.
On page 63, last paragraph:
pressure PORVS should be "-- pressurizer PORVS - ".
There is no indication where the two typos referred to z.
in Revision 1 are located.
They should be clearly marked by a bar in the right margin along with the appropriate i
revision
- number, but I
don't see any such marking.
(violates NS-RAT-IG-3 procedure.)
1 4
A review made of analyses which justify raising the setpoint for reactor trip on turbine trip above the typical 104 power level has shown the independent
- reviewer, Melita
- Osborne, has never previously performed this type of analysis.
Therefore Melita, or her
- manager, should have disqualified her from being the independent reviewer of this cale note.
e 1
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