ML20207F630
| ML20207F630 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/03/1992 |
| From: | Blanch P NORTHEAST UTILITIES |
| To: | Norton L NRC OFFICE OF THE INSPECTOR GENERAL (OIG) |
| Shared Package | |
| ML20207F629 | List: |
| References | |
| FOIA-98-32 50-245-92-13, 50-336-92-14, 50-423-92-13, NUDOCS 9906090163 | |
| Download: ML20207F630 (20) | |
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Cwpte:noer 3, 1992 Mr Leo Norton
- USNRC Office "
.ne Inspector General EWW'b42-Washington DC. 20555 FAX'301-492-4474.
Dear Mr. Norton:
Enclosed is a ' copy of; excerpts from a recent NRC inspection report directly related to my actions on the resolution of a minor problem with Millstone Unit-3.
The potential problem here was that there may have been a minor error of 0.2% or about a one half inch associated with a setpoint.. This was an issue identified by Millstone personnel and, as it. turned out, there was never any safety-problem orferror'outside of the. analyzed setpoint, however this was very responsible action by the Plant and NU corporate engineering..
I agree that all setpoints and instrument accuracies are importants however, the priority of the potential safety significance must be considered when addressing these issues.
Because this issue potentially affected a trip setpoint, it was given a high priority'even though the potential error was only 0.24.
To address this issue it was necessary to contact both the vendor (Tobar) and Westinghouse to determine the actual errors'and to develop new calibration' procedures if required.- Additionally, meetings with the plant staff, Westinghouse and the NRC were conducted to provide status updates and assurance that the plant was not operating outside of Technical Specifications-.
This.As1a typical action taken by-NU in addressing any potential
-safety. problem.
We have taken similar actions in addressing other
-major issues such as the Rosemount transmitters, pressurizer level errors on MP-2, NT-3, CY and the potential errors of greater than
. twenty feet reactor vessel level on Millstone Unit 1 even after the.NRC! chose to' ignore these major issues.* Although this
. potential NP-3 error was-minor and had insignificant consequences, it still; received the highest priority from the plant and'NU corporate engineering.
Needless to say, I was shocked to read the inspection report 1 which stated that *... corporate engineering support was remiss...and was delayed for about-13 days from the time of request."
This-NRC dissatisfaction with NU's. handling of the issue was never
. discussed with me or NU staff prior to the issuance of this inspection report.
I am very curious as to what is considered to be:timelyfaction.on an issue which has no safety significance.
INRC COMBINED thPECTION $0-245/92-13; 50-336/92-14: 50 423/92-13 dated July 22,1992 (Page 15) 163 990602 FOIA FERRARO98-32 PDR
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1 believe that these statements in the inspection report are a direct leflection on the capability of me personally and also the responsiveness of my engineers.
this. turned out to be a non-issue but provided a vehicle fer the NRC to attack my personal creditability.
I believe that this NRC criticism will be reficcted in the next Millstone SALP report and therefore my NU personal performance evaluation will be negatively affected as it will question my capability to respond to " safety issues".
This is a. prime example of the NRC making a major issue of a non problem while continuing to ignore major issues such as the 100%
errors on the most vital instrument on BWR's and ignoring 40%
error en pressurizer level for.over three years.
According to a Westinghouse letter dated February 1, 1,989, this issue has resulted in actual tailures of the primary pressure boundary, but the NRC has determined that this is not an issue.
Apparently the NRC sees more significance to a one-half inch level error on the steam generators than a twenty. foot errce on the reactor vessel j
level indicators or a fifteen foot error on the pressurizer level i
devices.
If this minor issue is as significant as the NRC criticism indicates then there are logical questions which need to be addressed for future timely actions.
How.does the NRC determine the appropriate time frame for j
handling an issue of this low safety significance?
If this is truly an issue, then has the NRC required all other plants using Tobar transmitters to address the problem in a manner similar to NU?
When NU identifies a major, generic safety issue and provides a timely resolution for not only NU but the entire industry, why aren't these positive facts reflected in the inspection reports or in the SALP ratings?
Why is it acceptable for the general public to a11cw the NRC to ignore major problems, affecting over one hundred nuclear
-plants for three years when 13 days is " remiss" action dealing with a minor issue on a single plant?
This type of action also acts as a deterrent on behalf of myself and otherlNU personnel to even consider addressing future potential safety issues.
If NU ignored this particular potential problem, as has been done by most other utilities, then we would i
not suffer,any criticism by the NRC.
Obviously, it appears that if we do nothing, then there will be no criticism of our actions.
I consider this type of action by the NRC personnel of Region I, a
form of direct retaliation and harassment of me as a result of my questioning the NRC's ability to properly regulated the nuclear industry.
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'o Paul M.
Blanch I&C Engineering Supervi=or Northeast Utilitics cc:
Atty. Ernest Hadley FAX 508-295-7002 Senator Joseph Lieberman FAX 202-224-9750 Tim Martin NRC Region 1 FAX 215-337-5324 R. M. Eacich
.NU Director of Licensing 1
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JUL 2 21932 Docket Nos. 50 245; 50-336; 50-423 Mr. John F. Opeka Executive Vice President - Nuclear s :,", 27gy Nonheast Nuclear Energy Company P.O. Box 270
' ; b ri Hartford, Connecticut 06141 0270
Dear Mr. Opeka:
i
SUBJECT:
MII.LSTONE COMBINED INSPECTION 50-245/9213; 50-336/92-14; 50-423/92-13 5
This refers to the safety inspection conducted by Mr. W. Raymond of this office on May 3, 1992, through June 13,1992, at Millstone Station in Waterford, Connecticut. The preliminary firdings were discussed with Mr. S. Scace, the Unit Directors, and others of your staff at the conclusion of the inspection. Areas exammed during the inspection are described in the enclosed repon. Within these areas, the inspection focused on issues important to public health and safety, and consisted of petformance observations of ongoing activities, independent verification of safety system status and design configuration, interviews with personnel, and review of quality records.
Good perfonnance was noted for several activities discussed in the enclosed repon, including the actions to address static pressure effects of Veritrak transmitters at Unit 3, and the activities by the PORC and NRB to address existing design issues at Unit 1. However,,
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notwithstanding the good action by Unit 3 site personnel to resolve the Veritrak issue, we did
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, note delays in corporate engineering suppon of the site evaluation. This indicates a need to
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strengthen the site-corporate interface to assure timely suppon of emerging site issues.
The inadequate planning and work controls for the removal of pipe insulation in suppon of the November 1991 erosion and corrosion inspection at Unit 3 resulted in the degradation of the supplementary leak collection and release system (SLCRS) and the failure to meet the
- technical specification requirements for enclosure building integrity. While the safety significance of this event was minor and your actions for the specific event were acceptable, we believe your corrective actions should be broadened to assure that maintenance does not exceed the defined job scope. An apparent violation of NRC requirements is identified in the i,
enclosed Notice.
Also, inadequate tagging and work controls resulted in the failure to drain ponions of the feedwater system at Unit 2 and the flooding of the '1B' feedwater heater while a worker was inside the heater shell. An apparent violation of NRC requirements is identified in the enclosed Notice.
W oi2f C Z W 1 //?
Northeast Nuclear Energy Company 2
You are required to respond to the enclosed Notice of Violation and should follow the instructions when preparing your response. In accordance with 10 CFR 2.790 of the NRC's
" Rules of Practice,* a copy of this letter and the enclosed Notice are not subject to the clearance' procedures of the Office of Management and Budget as reqmred by the Paperwork Reduction Act of 1980, Public Law No. 96.511.
We appmciate your cooperation.
Sincerely, A. Randolph Blough, Chief Projects Branch No. 4 Division of Reactor Projects
Enclosure:
- 2. NRC Combined Inspection Report 50-245/92-13; 50-336/92-14; 50-423/92-13 cc w/cac1:
W. D. Romberg, Vice President Nuclear, Operations Services S. E. Scace, Nuclear Station Director H. F. Haynes, Nuclear Unit Director, Unit 1 J. S. Keenan, Nuclear Unit Director, Unit 2 C. H. Clement, Nuclear Unit Director, Unit 3 R. M. Kacich, Director, Nuclear Licensing D. O. Nordquist, Director of Quality Services Gerald Gadield, Esquire Nicholas Reynolds, Esquire K. Abraham, PAO (2)
Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Connecticut S14 Designee
)
4 12 The inspector performed a field walkdown to review the assumptions contamed in OD 92-22 and veri 5ed that equipment configurations were correct, opera:ing and surveillance procedures were modified, and personnel had established appropriate tracking mechanisms by which the assumptions contained in OD 92-22 could be verined. Based upon a review of previous work orders performed on beat exchangers, the inspector was able to determme that the assumption of a clean service water system was reasonable given the low frequency of required heat exchanger cleamng. The inspector was informed that if heat exchanger fouling is identified during a routine inspection, an engineering evaluation of service water operability would be performed. De inspector noted that each service water system heat exchanger was tagged with an instruction to inform the cognizant engineer if fouling of a heat exchanger was identified. The inspector also verified that NNECo was tracking the plugging status of the service water heat exchangers and that the assumptions contained in OD 92-22 concernmg tube plugging were met. The inspector noted that additional modifications to the service water system were being tracked under project assignment 92-003.
I The inspector concluded that the assumptions made by the operability deternunation were reasonable and implemenal aphropriately. The inspector considered that the assumptions made in the operability daterrrdnation were conservative since the minimum flow requirements for each component included a ten percent margin and the service water pumps were assumed to have degraded to below ASME Section XI limit yet both are operanng currently at opnmum N' i-ance.
6.2 Differential Transmitter Static Pressure Effect - Unit 3 Event Descrintion
' On May 7,1992, NNECo determined that static pressure zero effect was not accounted for in the serpoints of Veritrak differential pmssure (dp) transmitters. The failure to acccunt for the zero effect reduced the margin of the transmitter settings to the technical specifiution (TS) serpoints. The phenomena occurs beca'use static pressure exerted on both sides of the dp transmitter cancel each other out but finite differences in the effective areas of the two diaphragms cause a slight shift in transmitter output.
B:.ektround An NNECo I&C engineering specialist identified a condition in which the potential existed for some of the reactor protection system (RPS) and engineered safety features actuation system (ESFiS) setpoints to be less conservative than those required by TS. This conclusion was based on the fact that static pressure effects (SPE) for Veritrak and Tobar dp transmitters were not calibrated out nor totally accounted for in the original setpoint calculations. Steam generator (SG) level and pressurizer level transminers were affected.
During troubleshooting of the drifting 'A' SG level transminer (3FWS*LT519) a NNECo 1&C engineering specsalist performed bench tests on sparc dp transmitters for SPE and
13 observed them to shift in excess of the amount assumed in the transnunct sutistical setpomt methodology (WCAP-10991). The speculist notified the supplier of the Tobar tmnsmitter, and was informed that the shift was within the equipment specifications for both Veritrak and Tobar transminers. Tobar informed the specialist that the specification for SPE for the instrument in question was i 0.5% of the upper range limit /1000 psi. De error attributed to SPE in the WCAP was 0.5E Since the performance speci5 cation was provided in terms of percent of upper range limit, a turndown ratio (ratio of the upper range limit for the transmitter used and the desired calibrated span) is used to determine the magnitude of error for the transmitter application. : Based on this information, I&C engineering identified the potential for transminer inaccuracies greater than that accounted for in the Westinghouse setpoint analysis caused by the failure to perform static pressure calibrations or accurately factor the transminer SPE into the protection system setpoint almidons.
Chronolory During the week of April 12 NNECo 1&C performed bench tests for replacement transminers to be used c ! 'A' OG level transminer and discovered shifts in the instruments which were not expectec, Durng the week of April 20, I&C engineering queried NUSCo and Westinghouse repre: entatives regarding SPE since documentation (i.e., updated instrumentation calculations) was not available on site. NUSCo did not respond to the initial phone query but requested that the TF -inerine mmmuniste their concerns by memo' un Apnl 28, I&C issued a memo to NUSCo and Westinghouse Fgarding the pw utial RPS/ESFAS setpoint inaccuracies and also nodfied site engineering of the potential problem.
Site engineering requested quantification of available margin in the present calculation to safety evaluation of resetting the bistable setpoints.
On May 1 site engineering conservatively concluded that RPS/ESFAS setpoint reset was
'i-y based on preliminary calculations using the WCAP and the inability to verify with the vendor that the instruments were compensated for SPE by type tesung. By May 4 site engineering and I&C developed conservative setpoints and prepared a procedure change and safety evaluation to reset the RPS bistables. Thineen days later the bistable adjustments were completed and a confirmation was received that the setpoint analysis did not accurately
' account for the Veritrak transmitter SPE. Subsequent to receiving the updated setpoint calculations from NUSCo, I&C recalculated and confirmed that sufficient margin was added to the bistable trip setungs. Durmg this inspection period, a maintenanm outage occurred in which as found calibration data was tsken for all of the Veritrak transminers. None of the transmitters were found.to have exceeded the 'IS allowable limits because of the SPE; two transmicers were inoperable for other reasons. All of the transminers were recalibrated prior to restan from the maintenance outage.
Ucensee Attatsment and Corrective Action 6
De licensee determined the root cause of this error to be inconcet assumptions by the plant staff and the individuals performing the serpoint calculations during initial development of I
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14 plant adibration procedures in 1985. The individuals performing the setpoint calculations believed the plant would calibrate the instruments to compensate for the SPE.~ ne plant suff did not realize that the correction was required and the vendor transminer calibration instructions did not require a static pressure correction.
He inspectors determined the site took prompt action to adjust the SG level and pressuruer level bistable setpomts to conservative values prior to confirmation of this problem. The vendor provided the licensee with a recommended method for Aminnting the SPE. All applicable survedlance procedures were revised to reflect the calibration method and the transmitters were calibrated. In addition, the vendor is evaluating the need for generic notification to other utilities regardmg cis issue.
Kafety sienifienne Reactor trip setpoints have been developed to ensure that the reactor core and reactor coolant system do not eaceed the safety limits during normal operation and design basis anticipated operational occurrences and to mitigating the consequences of accidents. De seapoints for the reactor trip system are con ' cred to be consistent with the nominal TS value when the as-measured setpoint is within the allowed for calibration accuracy and instrument drift.
Operation with setpoints less conservative than the TS specified trip setpoint but within the allowable value is acceptable since allowance has been made in the safety analysis to accommodate for instrument errors. Technical Specification 3.3.2 permits continued plant operation and requires that instrument setpoints less conservative than the trip setpoint be adjusted consistent with the TS value.
De steam generator level transmitters generate a reactor trip and initiate auxiliary feedwater on low level and isolate feed water supply on high level. Dere are three Veritrak level transminers and one Rosemount level transminer per SG. A minimum of two transmitters are requimi to generate a trip signal in any SG. Pressurizer level transminers generate a reactor trip signal on high level and provide equipment protection at low 1cvels. Here are two Rosemount transmincts and one Veritrak transmitter for pressurizer level indication. A minimum of two transminers are required to generate a trip signal on p essurizer level high.
The NRC determined the safety significance of this event was low. The Rosemount transmitters had a clear requirement to compensate for SPE and were wirstly compensated.
De as found condition of 11 of the 13 affected Veritrak transmitters was within the allowable timits at the last calibration and, therefore, would have performed their intended safety function. The two other transmitters had additional problems unrelated to the SPE phenomenon. The 'A' SG level transminer (3FWS*LT519) had been declami inoperable due to transmitter drift prior to the discovery of the SPE problem and the.yywyi. ate action had been taken in accordance with 'IS Table 3.3-1. The 'D' SG level transmitter (3FWS*LT547) as-found, data was suspect due to water remaining in the dp cell during calibration and, thereforaf the actual as-found condition was not verifiable because transminer adjustments were made.,
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15 Inmector Assessmem ud Conclusions ne inspectors reviewed the licensee assessment of the event and concurred with the conclusion that vendor requirements were neither clearly communicated nor fully understood by the plant staff. De 1&C specualist demonstrated a good questioning attitude and regard for safety when he noted the abnormal shift in the level instrument. Once the problem was identified, NNECo's analysis and evaluation efforts demonstrated strengths in areas of
- l
- engineering and technical support. However, the be=w noted that swyerate engineering support was remiss __in that the documentation requested by the site to accurately analyze the I
safety impact was delayed for about 13 days fmm the time of request.
g,/AC.A of f W WG d-6.3 Environmental Qualification of PORVs. Unit 3 y
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On June 1,1992, the licensee identified discrepant gasket material used in the pssmizer power operated relief valve (PORV) electrical enclosures. Grafoil type gaskets were found in the electrical enclosures for PORVs 3RCS*PCV455A and 456. De vendor test report stipulates that the solenoid housing and the limit switch housing attemhlies be environmentally scaled. The environmentally qualified (type tested) configuration for the PORVs utilizes an Ethylene Propylene Diene Momer (EPDM) type material as the gasket or scaling media. He licensee could not pmduce any documentation on file supporting the use of Grafoil gaskets to maintain an environmentally qualified boundary.
During full power operation, the PORVs perform no safety function. Their purpose is to relieve reactor coolant system pressure during transients to prevent actuation of the high pressure reactor trip and prevent challenging the primary system code safety valves. Further, the PORVs are a means of overpressure protection when the reactor coolant system is less than 350'F. PORV position indication is classified as a class D variable by Reg Guide 1.97.
On May 19,1992, NNECo engineering was resolving a part number discrepancy between the component replacement schedule (CRS) designated part numbers and the bill of material (BOM) part numbers for the PORV position switch assembly cover and ' solenoid valve cover gaskets.. The part numbers listed for the limit switch and solenoid housing gaskets were different. Both part numbers are specified as being an EPDM style gasket. During iaWn of the PORVs, electrical maintenance had observed that the installed limit switch housing gaskets were a Grafoil type gasket. A Grafoil type gasket had been installed as the solenoid housing gasket on 3RCS'PCV455A and on the limit switch housing gaskets in 3RCS*PCV455A and 456. During the May 1992 maintenance outage a new valve was installed as 3RCS*PCV455A due to valve seat leakage. The new valve was supplied with EPDM gaskets already installed. '!he Grafoil limit switch hen gasket on 3RCS'PCV456 was replaced with an EPDM type gasket during the outage.
On May 30 after the gasket replacement work was completed the licensee installed resistance temperature detectors on the limit switch assembly covers for the PORVs to determine actual 3
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l RETURN DATE:
Septomoer 1 1992 :
SUPERIOR COURT
.7.D. Cfr HARTFORO/NEW BRITAIN PAUL M. BLANCH AT NEW BRITAIN V.
i AUGUST 7. 1992 ROSEMOUN7 INC.
COMplAfNT The Plaintiff. Paul M. Blanch, an American citizen, a 1.
and has, at all times.
resident of the state of Connecticut, been a citizen of'this State and United states.
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He was aianen is an eneineer by profession.
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Graduated from the University of Nartford in 1972 with a bacheior's degree in Electrical Ensincerins. after serving for a
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seven (7) years in the U.S. Navy's Nucisar Power Program.
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3.
From May i972 until the present time. Blanch has been I
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- il empicyod by Northeast Utilities in various engineering 4
l 1
Since 1980. Blanch has held various menseement capacities.
ti Positions, primarily as supervisor of Instrumentation and l
1 Controls in supssort of Northeast Utilities nuclear power Piants.
In this i:apacity Blanch was responsible for assuring 4
the comp 1' lance'of safety Reiated Instrumentation and Reactor Protection Eeuipment with the Nuclear Regulatory Commission
'(NRC) requirements of Title 10 of the Code of Federal Regulations (10 CF.R ).
Inc., of Eden Prairie.
5.
The Defendant. Rosomount Hinnesota is a subsidiary of Emerson Electric and a primary g
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J supplier of nuclear components to commercial nuclear power plants.
6.
As a,suppliar of safety related components. Rosemount is required to comply with the requirements of 10 CFR 21 titled I
- Reporting of Defects and Noncompliance."
7.
Since the early 1980's, Rosemount has been supplying pressure transmitters to the nucisar industry under the reeuirements of 1' 0 CFR 21.
These pressure transmitters prsvide 1
the primary input to the Reactor protection Systems for the i
majority of the U.S. nuclear plants.
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In order to comply uith the environmental s
45g gi Pseuirements as stated in 10 CFR 50.49, Rosecount modified their f
standard design to comply uith the strict safety environmental' J
"y ree. Irements m'andated by USNAC statutes for nuclear planta.
l.
- 9. ' Ae a result of this modification. additional stresses were introduced, such that the pressure transmitters failed in a I
manner which is prohibited by NRC regulations.
10.
Failures in violation of 10 CFR 50.73 were reported to Rosemount by various utilities as early as 1985, 11.
Rosemount was fully aware of the application of.the transmitters and said reporting roouirements of 10 CFR pressure 21.
12.
During 1987 and 1988 multiple failures were reported to both Rosemount and the NRC by Northeast Utilities.
Rosemount 4
cm at *a es cry:aa; 612 942 6125 PfEE.006
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e denied or substantially minimized any generic defect associated uith the design of its components.
13.
Durins mid-1988 The Electric Power Research f
Institute (EPRI) recognized the potential safety sienificance of
]
the failure mechanism and asked Blanch for computerized data relatina to the failures experienced at Northeast Utilities Millstone Nuclear power planc.
14.
After analyzins the data of the failure eschanism, I.
I Blanch informed both EPRI and his immediate monasement of a i
potential,sionificant safety issue.
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15.
EPRI requested that Blanch, on behalf of Northeast hg I
Utilities, support EPRI research in the identification and
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resolution of the failures.
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e 16.
Northeast utilities manneement denied Blanch permission to support the EPRI reeuest on Northeast Utilities k
l time.
I In late 1988 Blanch requested, and obtained, 17.
permission from Northeast utilities
- management and legal.
Department to support as an independent consultant, an EPRI program to identify the root cause and risk of the Rosemount
)
failures.
In December. 1988, written approval was granted to 18.
i Blanch to support the EPRI request.
'Durins January 1999, Slanch entered into a centract.
19.
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~J I with Performance Associates Inc., which firm would supply l
j Blanch's services to EPRI.
proposal between EPRI. PAI and Blanch 20.
The contract amounted to greater than stoo. coo for the time period from January 1989 throush September 1989.
On or about January 5,1989 EPRI. NUMARC and 81soch 21.
at Rosemount with a representative from Rosemount met headquarters to di'acuss the failures and possible causes and e
i 1
resolutions.
k Rosemount did not acknowledge the exictance of a 22.
$,3j potential seneric problem, but did admit that it was aware of at 45g least 7e confirmed failures in U.S. nuclear power plants.
g2, Rosemount stronaly objected to Northeast utilities 23.
f management about the Blanch communications and caused 81apah to be severely chastised by his immediate supervisor.
24.
On or about February 4 1989. Blanch called Dr. C.
of Northeast utilities, and-Fredric Sears Vi'ce president informed $aars that he suspected some type of " cover-up* was and that the safety issues were not beins properly underway i
addressed by Northeast Utilities as a result of Rosemount p'ressures on NU top level manasement.
1989 Blanch bontacted Willias 25.
on er,ebout March 10, located at the Hilletone Raymond, Senior Resident NRC Inspector.
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site, informing Raymond of what appeared to be suppression of vitat information.
26.
On or about March 10. 1989, Raymond roeuested a presentation by Northeast Utilities as to their knowledge of the Rosemount failures.
Blanch became aware of the meetine and reeuested to 27.
be allowed to attend, as he was the only individual within the g,
industry and Northeast Utilities who had a complete I-understandins of all the technical issues.
This request was I
denied by Blanch's manager, Arnold.Roby.
E on or about March 30. Raymond callad a meetine at a
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53 The 1"g Northeast ~ Utilities headquarters in Berlin. Connecticut.
,i meeting was promoted by Slanch's concern stated to the NRC on g
+l.y March 10, 1989.
29.
During the meeting. Blanch presented the technical d
l details associated with the failure of the Rosemount I
transmitters.
on April 3. 19e9 slanch was confronted by his 30.
9 Manager.
A. R. Roby who uns not in attendance during the 4
\\
During this session, Roby criticized meetino of March 30. 1989.
' Blanch and-defended Rosemount.
31.
On or about April 13. 1989. Blanch" and other management personnel from Northeast Utilities made a formal public presentation in Rockville, Maryland held by NRC to I
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i discuss the safety and technical issues associated with the s
failure of Rosemount transmitters.
32.
Rosemount also made a presentation at thi1ir meetins and disputed,some of the data presented by slanch.
33.
On or'about April 14, 1999. Blanch was instructed by Dr. Sears not to pursue the safety issues.
34.
Upon information and belief this directive refiested
[
the continuins pressure from Rosemount officials upon Northeast t
. utilities officials to dounerade the competency and I
professionalias of slanch as well as suzzle his efforts to i,
e j
alert the industry and NRC to the defects in Rosemount gg-g!
..uip.ent.
I 35.
On June 28, 198p Blanch was requested by a i
e "l.g technical induscry group to act as the chairman for a committee to address the safety and technical issues related to the ti l
Rosemount failures.
This request resulted from the industry I
uide held belief that Blanch had unique experience and b'acksround in the problema presented by the Rosemount failures.
36.
Blanch received written permission in July,1999 -
6 from his -senior Vice President. Edward Mroczka, to act as-chairman of the technical committee.
ourina, late July or early August, 1999 a handwritten 37, meno was. written by the defendant's Director of Engineerins to a hiortheast Utilities executive.
The meme stated that, according w
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Blanch was ' destroying Rosemount's reputation and to Rosemount.
utsed that Blanch-be removed as Chairman of the committee.
after this memo was generated. Blanch was 38.
Shortly not'only removed as chairman of the committee, but was also removed as a voting member of the committee..
In accordance with the requirements of 10 CFR 50.7 39.
Blanch filed a formal complaint with the U.S. Department of' Labor ( COL ).
wrote a On October 5. 1987 N.U.'s Vice President I
40.
l memo to the senior Vice President criticizing Blanch's role in N,,
the Rosemount controversy. based primarily on misleading and R5!
biased information supplied by Rosemount.
In or about October 1989 Or. Sears contacted a high 41.
level executive at EPRI conducting his own personal
[ '-
implying that investigation of Blanch's contract work with EPRI, i
it was improper.
)
Blanch's ability to obtain future contracts has been I
42.
destroyed by this action, which upon information and belief. was a result of Rosemount's preesure as hereinafter set forth:
On or about January 1988. Rosemount a.
representatives contacted Northeast Utilities representatives to convince them there was no generic defect with Rosemount supplied equipment A
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2 and that the f ailures experienced et Northeast l
Utilities were not reportable under 10 CFR 21.
b.
In early 1989. Rosemount encouraged Northeast..
Utilities personnel to obstruct sianch's
..t:
continued investisation into the significance of
".Y:
the safety issue.
In March 1989 Rosemount convinced Northeast c.
i Utilities that Blanch's acr. ions in addressing g
E l-the safety issues were unprofessional and that l
he should be removed from the investigation.,
I y
d.
In early 1989 Rosemount convinced EPRI that j
- 4I:!
Blanch was not acting in the best interest of I.,
EPRI and exerted pressure upon EPRI management to cancei its contract work with Bianch.
l e.
In er about.!uly or August 1999, Rosemount j
convinced Northeast Utilities manasement that
't 2
a I
Slanch should not be chairman of the technical committee chartered uith the responsibility of.
.As a resolvine the safety and technical issues.
result of this interference by Rosemount. 53.anch.
i was removed as chairman and his future in this ar,sa.of expertise uns severely ~dasiased.'
I k
e.m aan ei se AcGE.012
4
.'.uo yj. _yo g y:<1,[3;,g.a%. ti.r.'.ijes ec::. sue e
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'43.
we a' result of continuine influence by Rosemount'in Q
a.
cquestioning the motivation and creditability of Blanch.
- / /..f M
.. r.
- .y, Northeast Utilities management acted in a manner to hinder
/*Il
-I@l
.pi Blanch and caused severe damage to the reputation and the future 3.9,
' livelihood of Blanch.
h.
f*
WHEREFORE, the plaintiff claims 1.
Money damages in compensation.for damages set forth
[
in the complaint:
I 2.
Punitive damages for uronsful conduct and I
interference with contractual rightas E
o
'I 8 3.
Counsel fees as may be applicabia under the law; an.d d
\\*g 4.
Such other relief as to law or equity may appertain.
I 6
THE PLAINTIFF:
"eg PAUL M.
BLANCH l
OO e
Sys IgorQIF sikdraky, Jr.
{
1092 Elm Street - Suite 202
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Rocky Hill CT 06067 (203) 529-7474 l
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september 1 1992 :
$UPERIOR CCURT J.D. OF HARTFORO/NEW BRITAIN PAUL M.
SLANCH AT HARTFORD VS.
AUGU5T 7, 1992 ROSEMOUNT. INC.
STATEMENT epr AMOUNT TN DEMAND The amount. legal interest of property in demand, and costs is more ti.an s15.000.00.
exclusive of i nte r.ast.
E THE FLAINTIFF:
3 PAUL M. BLANCH I
I By:
r 1.o v. m.+s ax,,,.
!,i lo92 Elm street - suite 202 3
Rocky Hill, CT 06067 Iil-(203) 529-7474 g
Juris No.:
57775 g
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7/28/92 l
8/4/92 I
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9 1o ggc 13 EHBI Tc MEETTEE_IQ_EEEE1YE_GOMMEEIE_GE 12 EQEIEEEEI_HIlblIIEE' 13 EEEEGEMAEGE_EEEAEGEMEEI_EEGEEAM 14 15 East 1,yme Community Center 16 East I.y m e, Connecticut 17 November 5,
1992 18 7:30 p.m.
1.9 20
-NRC Members Present:
21 Jacque Durr, Paul Swetland, Randy islough, 22 James Wiggins. 1awrence Doerflein, Dave Jaffe 23.
X 24 1
1 bfl 25'
- marz2co,e d w i
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(
)
1
- t. h e panel and others members of Northeast. U t.111 t i e s.
1 2
MR. WTGGINS:
Before we start, in order to 3
make it move, if you would present your prepared 4
statement, and if it is beyond the five minute time 5
frame we will go to the next. individual.
6 MR. BLANCH:
T t h.i n k we are going to lose 7
the t.r a i n of
- t. h o u g h t, but, i t.
is your show.
8 Good evening, my name is Paul Blanch.
9 I am Supervisor of I n s t ru me n t.a t.i nn and C o n t. r o l
)
10 Engineering for Northeast Utilities at the home office 11 in Berlin.
I am making
- t. h i s a t. a t e m e n t.
as a p r i v a t. e 12 citizen and my opinions may or may not he consistent 13 w i t. h those of Northeast U t i l i t. i e s.
I am here to 14 express my concerns about nuclear performance, not 15 only Mi l l s t.on e, but. the rest of
- t. h e i n d u s t.r y as t.h e y 16 relate also to the performance of plants, and 17 performance of the N u cil e a r Regulat.ory Commission.
18 1.a s t spring I was requested by the 19 NRC's Inapector General's Office to provide my 20 perspective about the NRC Special Review Group which 21 was t.r a n s m i t t.e d
- t. o Mr. Ellis on April 6,
- 1992, 22 chairman of Northeast Utilities on April 6,
1982.
s.
23 This is the initial document which eventually resulted 4
24 in the acceptance of the Performance Enhancement 25 Program.
19 I
1 on April 20, 1992, my comments were 2
formalized to the Inspector General in writing.
T 3
felt as though the recommendations for a Perfarmance 4
Enhancement Program completely missed the target.
In 5
my opi ni on the Performance Enhancement Program will 6
result in an enormous amount of paperwork, demoralize 1
7 employens, which it has already done and, divert A
critical manpower resources from the more critical i
l 9
safety issues.
As I s t.a t e d to the Inspector 10 General...
"The solution to NU's problems is not a j
11 paper exercise r e l a t.e d to the Performance Enhancement 12 Plan nor a reorganization that shuffles four Vice
.33 P r e s i d e n t. s.
It must. be an entire c u l t.u r a l change that i
1 14 restores the trust and integrtty at the uppermost 15 levels within Northeast Utili ti es. "
16 After my communication with the NRC 17 T n s p e c t. o r General T had the opportunity of meeting i
18 with Mr. Ellis to provide him with my viRWs as to hoW 19 Northeast U ti l i t.i e s could best improve our performance J
20 without the large expenditure of vital manpower and j
21 ratepayer's dollars.
In my opi ni on, there is only one 22 way to improve the performance of NU personnel, and 23 that is to reinst.ill the morale, faith and trust in 24 management.
With this will come a significant 25 increase in prod u c ti vi t.y and a desi re to become a team
20
.1 l
l 1
player, e v e n t.u a l l y resulting in increased performance 2
and a true improvement in nuclear safety.
Unless our 1
3 PEP program is founded on a s t.r o n g foundation of l
4 trust,- integrity and respect for our management and 5
NRC r e g u l a t.o r s, our true performance and safety wi))
6 continue to deteriorate.
From my understanding of the 7
PEP program, I have seen no sincere effort. to attempt 8
to address this morale issue as a high priority and 9
t.h e r e f o r e, I see the enti re program as a complete 10 waste of money and manpower.
Il pue
- t. o
- t. h e l i mi t.e d manpower available 12 to Northeast Utilities we can only react to the 13 desires of
- t. h e NRC, w h a t. e v e r t.h e y happen to be a t. this 1
14 particular moment.
As a result of this reactionary J
15 mode of o p e r a t. i o n we are not able
- t. o address
- t. h e real 16 issues, but only produce more meaningless paperwork 17 which will be lost in the files forever.
18 With respect to the NRC's ability to 19 properly regulate the i n d u s t.r y, they have been and j
20 still are a complete failure.
We have a regulatory 21 organizat. ion concerned only about providing an 1
)
22 illusion of action, and assuring that all paperwork is 23 in order to create good feeling in t.he eyes of the 24 general public.
It appears to many people that the 25 NRC's measurement. of safety is based solely upon the
21
'l 1
, amount of paper and n o t.
on
- t. h e actions of the i
2 licensee.
3 T can provide many examples of thin 4
failure, but. the
- t. w o most prominent. examples occurred 5
during the last few months.
Tn May of this year, 6
Millstone ti n i t.
3 personnel j d e n t.i f i e d a potential 7
error on one instrument which could have resulted in a 8
one-half inch (0.5 percent) error.
I was personally 9
criticized in an NRC inspection report because it took 10 me 13 whole days ta finally resolve this problem.
In 11 the end there was no additional error, however, the 12 NRC st.ill issued this strong cri ti ci sm of my 13 performance.
To my knowledge, the NRC has still not 14 r e q u e s t. e d any other ut.ility to address this problem.
15 Now contrast this with a potential 30 16 foot (100 percent) error for the most. v i t. a 1 instrument 17 on a boiling water reactor (BWR), and the NRC refuses 18 to require u t. i l i t i e s to address'this p a r t -i c ti l a r
.19 problem.
In' June of this year, at the request of the 20 NRC, I personally identified the fact that reactor.
21.
level monitoring systems and boiling water reactors 22 (BWR) would not f unct.i nn during accident conditions 23 for which they are required.
T immediately reported 24 this
- t. o ' N il management., and prompt and responsible 25 action was taken to resolve this critical deficiency I
I
r L
e 22 l
1 l at M i l l s t.o n e tini t 1.
T applaud the people at l
l 2
Millstone for this responsible action.
l 3
A t.
the same t.i m e, I reported this 4
problem to the NRC which included personal discussion 5
kith Mr. W113 i a m Russell, the D i r e c t.or of Nuclear 6
Regulation in Washington, D.. C.
This conversation 7
occurred in mid-June of this year.
After Mr. Russe))
8 ignored my plean to take action to notify other i
9 u tili ti es, a 1etter was w r i t. t e n on my behalf
- t. o the 10 i Chai rman of the NRC with copies to news media and 11 v a ri ou s members of the Congress.
Only after this 12 drastic action did the NRC respond.
13 Mr. Russell event.ually called a meeting 14 on July 29th. 1992, approximately a month and a half 15 after my initial discunnions this meeting was held in i
16 Washington, D.C.
and he stated that he had just become 1
17 aware of the magnitude of this issue nine days prior 18 to this meeting.
This is a material false statement, 19 as I had two phone conversations with.him in mid-June 20 about this very topic.
I also met with members of his 21 staff and your staff reldted to these identical 22 problem for PWR's.
Tf it were a licensee making this 23 type of false statement there would be criminal action 24 brought against the licensee and individuals.
Because 25 there is a ccou n t a bi l i ty for this agency, the NRC, T i
i 23 l.
1 don't. expect. any a c ti on a.
a result of this 1
2 intencional false statement.
3 To further d e mon s t r a t.e the 4
ineffectiveness and total disregard for nuclear safety i
5 by
- t. h e NRC, I have pleaded'with them to determine if 6
these water level measuring. devices are considered 7
" operable" as defined by the plant Idcensee.
The NRC
)
8 han absolutely refused to even respond to my written 9
r e q u e s t. s, which include requesta
- t. o t.he chairman, 10 because T believe they know that the response to this i
11 q u e s t.i o n may result -i n the t.emporary s h u t.d ow n of many 12 nuclear plants.
.13 The Millstone tin i t i reactor level 14 measurement. problem is one of the most significant 15 nafety problema iden ti f ied over the past few years.
16 This in the most v i t. a 1 instrument used during a c c i d e n t.
17 conditions and is required by 'che plant technical 18 specifications.
Mi l l s t.on e ' s a c t. i o n was to 19 immediately declare these derices inoperable, and they
~
20 determined that. the problem must be resolved prior to 21 restart.
After denigning, installing and testing a 22 technical sol u ti on to this vital innue, the NRC then 23 decided to innue a violation because I personally 24 authorized a con t.r a c t.or t.o commence work prior to 25 formal issuance of a purchase order.
(-
1 24 l
l l
I 1
This ja like a fireman ri s ki ng his life
)
2 saving 10 people from a burning building, only to have a
l 3
the fire inspector issue a vi ol a ti on
- t. o him because l
4 his fire base had not been tested in the last 30 days.
5
-This is t.h e only en f orceme n t.
action taken by the NRC
{
l 6
on this issue while 36 other boiling water reactors 7
violate their license requirements and the NRC refuses 8
to request any operability determination.
9 The reason I am bringing these points 10 to the public attention is to demonstrate that the NRC i
11 has no real i n t.e r e s t in nuclear saftey, but is only 12 interested in their public image.
The NRC holds each 1
13 license and individual re spon si bl e for f a i r. e 14 statements and wrongdoing but it appears that no one I
15 is willing
- t. o require any a c cou n t.a bi l i t y of the NRC.
16 I am not alone in my views, and, in l
1 17 fact, many NRC
- t. e c h n i c a l and management. personnel have
{
j 18 expressed their frustrations to me with respect to I
19 this i ne f f ec t.$ ve regulatory c11 mate and actual 20 coverups of significant safety issues.
21 While.the PEP program at NU will have 22 some benefits in. areas requiring additional 23 d o c u m e n t.a t.i o n, I believe that i t.
completely misses the 24 target, which is inspire the NU-individuals 25 responsible for nuclear safety.
j e
e 25 s
f 1
I t.
is the NRC that desperately needs a
~~
2 Program to Improve Mangement Performance to review all 3
p o t. e n t. i a l safety issues and e s t.a bl i s h a priority for 4
resolving these major issues.
They need to 5
concentrat.e less o ri the p e r f e c t.i o n of paperwork and 6
aggresively address the real. safety programs.
Do we 7
have any org a ni z a t.i on which will require a program for 8
the NRC or have they already achieved perfection as 9
they profess?
10 T pray that the new administration will 11 recognize the po t.e n t i a l v i t. n l con tri bu ti on of nuclear 12 power and provide some rent leadership and d i r e c t i n's 13 for the Nuclear R eg ul a t.ory Comm i s si or and the rest. of 14 the industry.
Thank you very much.
15 MR. WTGGINS:
Thank you for your comment.a.
16 Can T ask a question before you leave?
17 MR. BbANCH:
Yes.
18 MR. WTGGINS:
On the basic topic of the 19 meeting you i n di c u t.e d
- t. h a t. you believe that the PEP 20 ought to focus more on butiding morale, building i
21 leadership; is that. an accurate characterization?
i 22 MR. BLANCH:
That is my biggest problem with 23 the e n t. i r e Performance Enhancement Program.
I realize 24 it is a small part of the program.
As T said to Mr.
25 Ellis last May. T believe that. the entire program I
n
-