Reverse Engineering Is Dangerous

Name and address of the individual or individuals in forming the Commission.
Tad Gray
General Manager
Curtiss-Wright - Nuclear Division
Nova Machine Products
18001 Sheldon Road
Middleburg Heights Ohio 44130
(ii) Nature of the defect or failure to comply and the safety hazard which is
created or could be created by such defect or failure to comply.
Nova did not establish adequate design control measures to verify and check
adequacy of the Reversed Engineered HCU accumulators used in control rod
drive systems of boiling water reactors. This deviation potentially could create a
SSH by not allowing the accumulator to perform its intended safety function under
certain conditions.
During the recent NRC inspection of Nova performed 12/4/2015, it was
determined that HCU accumulators using the reverse engineering EPRI
guidelines process had not been fully qualified per Criterion III, "Design Control" of
Appendix B. This was identified as Nonconformance 9990105/2015-201-02.
(iii) The date on which the information of such defect or failure to comply was obtained:
December 4th, 2016
(iv) The corrective action which has been, is being, or will be taken; the name of
the individual or organization responsible for the action; and the length of
time that has been or will be taken to complete the action.
The corrective action associated with this verification testing has been entered
into the Nova Corrective Action system as CAR # 279. Nova Machine has
initiated Design Verification testing to be performed on the HCU accumulators to
assure that design input/output requirements have been met. This is being
accomplished through alternate calculations, and qualification testing to
demonstrate design performance against design input requirements. Completion
is targeted for April 30th, 2016.