IA-85-171, Responds to Appeal Re Denial of FOIA Request for List of Validated Computer Programs Used for Rate Calculation. Appeal Unappropriate as No Documents Subj to Request Denied. NRC Does Not Validate Licensees Software Computer Program

Responds to Appeal Re Denial of FOIA Request for List of Validated Computer Programs Used for Rate Calculation. Appeal Unappropriate as No Documents Subj to Request Denied. NRC Does Not Validate Licensees Software Computer Program

ML20133A463
Person / Time
Issue date:	05/22/1985
From:	Felton J NRC OFFICE OF ADMINISTRATION (ADM)
To:	Reytblatt Z WARREN WILSON COLLEGE, SWANNANOA, NC
References
FOIA-85-171, FOIA-85-A-16 NUDOCS 8507200090
Download: ML20133A463 (1)

Text

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Dr. Zinovy V. Reytblatt Department of Applied Mathematics and Computer Science Warren Wilson College MAY 2 21985 IN RESPONSE REFER 701 Warren Wilson Road TO FOIA-85-A-16E Swannanoa, NC 28778-2099 (F01A-85-171)

Dear Dr. Rey?blatt:

This is in response to your letter of April 17, 1985, in which you " appealed" our initial Freedom of Infomation Act (F0IA) response to FOIA-85-171 in a letter to you dated April 4, 1985.

Your letter of April 17, 1985, is not an appropriate " Appeal from an Initial F0IA Decision" as no documents subject to your request were denied.

Inasmuch as the staff of this office is not involved in technical issues, we contacted the staff of the NRC's Containment Systems Branch about your April 17, 1985, letter. The staff of the Containment Systems Branch infomed us that the NRC does not validate licensees' software computer programs for leak rate testing and, thus, has no records concerning " validated" Volumetrics software. While not subject to your request, the NRC provided in the April 4,1985, letter a sample of Regional inspectors' uses of calculators to confirm results of licensees' integrated leak rate testing. Regional inspectors may comment on this activity in inspection reports, which are maintained in the plant docket files in the NRC Public Document Room, Washington, DC, for public inspection and copying. For your information, we were informed that the staff intends to develop a computer program to be used by Regional inspec-tors to confirm results of licensee leak rate testing, but this will not be used to validate licensee software.

This completes NRC action on your request.

Si erely,

. M. Felton, Director ivision of Rules and Records Office of Administration l

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March 9, 1985 Mr. J. Felton, Director, Division of Rules and Records FREEDOM OF INFORMATION Office of Administration ACI REQUESI US Nuclear Regulatory Commission Washington, DC 20555 hh-%"'f }

PETITION M Q

SUBJECT:

FOIA REQUEST REGARDING CERTAIN RECORDS IN POSSESSION OF THE NRC AND/OR ITS CONTRACTORS, OR SUBCONTRACTORS, CONCERNING THE SOFTWARE EMPLOYED FOR LEAK RATE CALCULATIONS

! Pursuant to the Freedom of Information Act, as amended, 5 USC 552, and the

[ Privacy Act of 1974, 5 USC 552a; based on the provisions of 10 CFR, Chapter I, Subpart A, Paragraph 9.4 where the definition of " Record" is used as in 10 CFR, Chapter I, Subpart A, l Paragraph 9.3a, (b);

l I hereby request that (1) the list of of all (validated) computer programs employed for leak rate calculations be made available to me, and (2) that all the records in possession of the NRC, its contractors or its subcontractors or utility companies concerning the Volumetrics software as specified below, be made available to me for inspection and copying.

Reccrds requested ir. p. (2) of the present Petition, in accordance with 10 CFR, Chapter I, Subpart A, and with associated regulatory documents must include but are not limited to 1) list of all pertinent documents: 2) listing of the validated computer program; 3) data base for validating calculations including but not limited to punch cards, magnetic tapes, and disks; 4)

user's manual and validation act (s); 5) records of telephone conversations,

- minutes, transcripts or if unavailable, summaries of all meetings including technical meetings involving the subject.

Please include an explanation of the appeal procedure in your Decision.

t The Atomic Energy Act of 1954 and Operating Licenses provide that some of the

( information in question may not be in the immediate possession of the NRC.

k However such information must be made available to the NRC immediately upon b request. In accordance with 10 CFR, Chapter I, Subpart A, Paragraph 9.4, I urge you to immediately request from the depositories (for example, j Commonwealth Edison Co) any and all the information not in the pocsession of the NRC, on the subject, with an option to substitute a physical delivery of records by a contractor / subcontractor for an on-site inspection.

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BACKGROUND My concerns are with the safety of citizens (including my relatives and friends) residing in the area vulnerable to a radioactive contamination from the nuclear power plants. Upon learning about fraudulent Zion tests which had to be repeated to assure compliance of the leak level with the legal limits, and with the intent to perform an independent review of the existing test methodology, I examined the materials submitted to me by the CANP of Chicago, by the NRC and ORNL, and materials from the PDR. Although these materials do not contain the complete raw data, they enabled me to establish beyond any reasonable doubt that any leak rate can be " determined" from any set of the raw data using the present methodology and testing practicles. That the conservative estimates of the leak rate are in excess of values specified by the operating License, has been established for the Zion Plant. My conclusions were conveyed to Mr. Rehm and, subsequently, a review by the NRC has been initiated. It appears that the software in question does not perform sometime the elementary arithmetic operations of addition and/or division which, possibly, has contributed to deficiency of Zion tests, as it might have according to theoretical analyses. To accomplish a noble work of identifying potential deficient tests and the extent of damage to the public safety due to the faulty computer programs, I need the records in question.

FEE WAIVER REQUEST I am petitioning for the waver of the fee on the ground that the people of the USA will benefit from the release of the information as explained below.

The present leak rate testing methodology allows to " determine" any leak rate value from any set of the raw data. This has been proven beyond any reasonable doubt analytically, by worked examples and on actual data (Zion,

Unit 1). Fraudulent Zion, Unit 1, tests have been officially found deficient.

These tests employed the Volumetrics computer program. An independent review of the tests is of an important concern of citizens. A computer program e plcyed for the test data processir.g may, sometimes, be a scurce of errors in test r e sul +.s . It is, therefore, in the best interests of the people of the USA that the subject records be made public and that no fee be charged for their release.

I shall expect to hear from you within ten (10) working days as provided by

< 1aw.

Sincerely #

b h.n Zinovy V. R tblatt, Chair Department of Mathematics and Computer Science t

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\ UNITED STATES NUCLEAR REGULATORY COMMISSION s wAsHawoTom.o.c.seems APR 04 #

Dr. Zinovy V. Reytblatt Department of Mathematics and Computer Science Warren Wilson College 701 Warren Wilson Road IN RESPONSE REFER Swannanoa, NC 28778-2099 TO F01A-85-171

Dear Dr. Reytblatt:

This is in response to your letter of March 9,1985, in which you requested, pursuant to the Freedom of Information Act (FOIA), (1) a list of validated computer programs used for leak rate calculations and (2) records concerning Volumetrics software for leak rate testing.

In response to category one of your request, the enclosed appendix lists programs used by Region III staff during integrated leak rate testing.

In response to category two of your request, the staff has infomed us that it has no records concerning Volumetrics software.

This completes NRC's action on your request.

Sin rely,

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. 1. elton, Director Division of Rules and Records

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Enclosure:

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APPENDIX List of Procrams used by RIII ,d,u,r,1,ng. ILR,T's EE..67 ,C,a.l.cu.l e to r

1. Uses ANSI 56-P, mass point method. User can enter time and either mass or dry air pressure and weiuhted temperature to calculate leak rate and UCL.

2. Uses ANSI 56.8 ness point method. User must enter time and mass to calculate leak rate and UCL.

3. Uses BN-TOP-1 total time method. User can enter time and either mass or dry air pressure and weighted temperature to calculate leak rate and UCL.

4. Dewpoint. Calculates vapor pressure from dew cell temperature readine.

.T_1. ,59 ,Ca_l cul ator

1. Uses ANSI 56.8 mass point rethod. User enters tire and rass to calculate leet rate and UCL.

2. Dewpoint. Calculates vapor pressure from dew cell terperature readine.

3. Reference Vessel leak rate. Calculates leak rate and UCL for containments that use reference vessel (nonc at present) 4 i

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