ML16340C380

Board Notification 82-16 Info from Rl Cloud Associates & Teledyne Engineering Svcs Re Design Verification Program

ML16340C380
Person / Time
Site:	Diablo Canyon
Issue date:	02/23/1982
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	Bradford P, Gilinsky V, Palladino N NRC COMMISSION (OCM)
References
TASK-AS, TASK-BN-82-16 BN--82-16, BN-82-16, NUDOCS 8203110518
Download: ML16340C380 (86)

Text

Docket Ho.:

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MEMORANDUM FOR:

Chairman Palladino Commissioner Gilinsky Commissioner Bradford Commissioner Ahearne Coreissioner Roberts

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Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation IHFORMATIOH ITEM - INFORMATION FROM R. L. CLOUD ASSOCIATES ON DESIGN VERIFICATIOH PROGRAM FOR DIABLO CANYON UNIT 1

t BOARD NOTIFICATION HO. 82-IS)

In accordance with present HRC procedures regarding Board Notifications, the enclosed letters from R. L. Cloud Associates, dated February 10, 1982 and February ll, 1982 are provided to the Commission for information.

Also included is a letter from Teledyne Engineering Services dated February 5, 1982.

Enclousre:

R. L. CLoud Associates, Inc.

Submittal dated Feb.

10, 1982 cc:

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. R.Tedesco BJYoungblood ASchwencer FHi rag 1 i a JHi 1 1 er EAdensam DCrutchfield MRussell TIppo1 ito RUollmer HThompson RHattson SHanauer BSnyder RHartfield, MPA OELD JScinto (2)

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(5 DISTRIBUTION OF BOARD NOTIFICATION 82-16 Diablo Canyon - ASLB Docket Nos.

50-275, 50-323 Atomic Safety and Licensing Appeal Panel Atomic Safety ard I.icensing Board.

Panel Docketing and Service Section Document'anagement Branch Mrs. Elizabeth Apfelberg Andrew Baldwin, Esq.

Richard E. Blankenburg Wayne A. Soroyan Mr. Glenn 0. Bright Herbert H. Brown, Esq.

Dr. John H.

Puck Philip AD Crane, Jr.,

Esq

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Mr. Frederick Elssler David ST Fleischaker, Esq.

Mrs.

Raye Fleming Arthur C. Gehr,

Esq, Bryon S. Georgiou Mr. Mark Gottlieb Mr. Richard B. Hubbard Dr.

W.

Reed Johnson Janice E. Kerr, Esq, Lawrence 0. Garcia, Esq./

Dr. Jerry Kline Mr. John Marrs Thomas S. Moore, Esq.

Bruce Norton, Eyq.

Joel R. Reynolds, Esq.

John R. Phillips, Esq.J Mr. James

0. Schuyler Mr. Gordon Silver Paul C. Valentine>

Esq.

Harry M. Willis, Esq.

John F. Wolf, Esq.

ACRS Members Mr. Myer Bender Dr, Max M. Carbon

'r.

Jesse C. Ebersole, Mr. Harold Etherington Dr. Milliam Kerr Dr. Harold M. Lewis Dr. J.

Carson fiark Mr. Milliam M. Mathis Dr.

Dade M. Moeller Dr. David Okrent Dr. Milton S. Plesset Mr. Jeremiah J. 'Ray Dr, Paul G,

Shewmon Pr.

Chqster P. Siess Mr. Dgvis A. Ward Dr. Robert C. Axtmann

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TRANSCRIPT CORRECTIONS FOR RLCA

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(pg c 10 I will discuss the scope, our QA program, ouz I

am sorry, I am not going to discuss the QA program 3 but I vill discuss the vay it fits in-1 vill discuss 4 the approach that we have taken to independent 5= calculations, the approach that ve have taken to 6 sampling, including ouz methodology and our criteria..

roe very brieziy, et+I vi11. try to oo 8 quick'.y through the introductory sli'des, 10

( SliCe)

'he scope of our program, as delineated in the 11 order includes the seismic design or qualifica ion vork 12 done prior to '78 by service-related contractors

.14 18 internally and internally to PGCE.

(Slide) 15 That is what our scope includes 16 Our scope excludes and I want to make this 17 very clear so that there vill not be any mistake about 18 it there is a great number of contractors that are 19 doing vork for PGGE.

Those contractors vhose vork did 20 not af ect the design at all vere removed rom the 21 list-These vould be primarily in many cases single 22 people, independent

people, professors and the like, who 23 a'ttend a meeting or do some bit of vork that does not 24 change the design.

25 The second<group that ve have excluded aze ALOERSON REPORTING COMPANY, INC, 400 VIRGINIAAVES.W., WASHINGTON. D.C. 20024 (202).554.2345

those contractors whose work vent totally into the 2 definition of the Hosgri ground motion.

And our basi" for doing that is the Hosgri ground motion was a

4 consensus decision betveen the electric company and the

~ HRC and their host of respective consultants And we do 6 not think that needs to be reviewed now Thirdly folloving the vording of the orderi

~ ve ha.ve excluded work done by vendors and, lastly the 9 vork done after June of '78..

10

, (Slide) k Following through on that scope of vork, the 12 primary contractors that fit into that category are EDS Pyle Lab, AMOCO, Earthquake Engineering Systems -- who l"y'<NP,:

'4 recently changed, their name to ~ma-and URS/Slume 1< and Harding-Tawson soil consultant for Blume and PGCE.

17

( Slide)

Hov, our program rests upon these points.

18 Following the vord.ing of the order, our one thrust is 19 the quality assurance review for adequacy and audits of 20 all of those contxac.ors and PGCE for the implementation 21 of the program.

And Hr.

Reedy vill describe that 22 subsequently-The second point of the program is that we 24 will pe form an independent analysis of the sample of 25 structures and equipmgnt, as was described to you ANDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVES.WWASHINGTON,D.C. 20024 (202).554.2345

16 MR.

CLOUD:

Ho. I am sorry about that Me 2 started out on an uneven footing with a numbering 3 scheme Let me describe it when we get there.

Our plan is following the quality assurance Wv~~

aCies 6 work or following the independent calculation, that we 6 wil perform additional verification -99 times ou of

%00 T or 90 times out of t00 Mditional verification will 8 mean the recalculation of an independent sample.

However, in certain circumstances, it may be 10 better to, chase a particular error through the work 11 rather than redo a lot of samples 12 So in anY case, any of those will be 13 justified, but, in general, when you see the words on 14 the slide "additional v'erifi'cation," in.'general, it 16 means an independent calculation of an additional 16 sam pie.

17 MR. VOlLMKR:

Before you leave that par icular 18 one, additional verification, is that just if errors 19 were found in other than nonconservative or conservative 20 direction or something is found to be beyond. the access 21 margin or something like that?

Zn other words, if you 22 f'd someth'g that has an error in it but it is in a 23 conservative direction, would you look further to see if 24 that error is not prevalent somewhere else?

25 MR CLOUD: lf we get a significant which I ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W., WASHINGTON, D.C. 20024 (202).554-2345

1

equipment, it is one of the most complex structures,

and, 2 it gives us a large sample of engineering calculations 3 And, thirdly, keying into our pre'iminary program there 4 vas an open item, for those fev of you vho may have read 5 that report..

Really the only other choice vas the 7 containment building, and ve fe1t that the containment 8 building was under separate scrutiny because of the.

9 annulus there but in addi ion to that, it is a simpler 1o structure.

That is the basis for our sample 12 (Slide)

Our approach toward the review, first~ to 13 review the model to assure that it is a satisfactory E

I 14 dynamic representation and calculate the model 15 properties, the masses stiffness, shear areas and the 16 like-Me vill make the comparison to the des'gn 17 analysis at that stage 18 Then ve have alreade made the decision to go WOO~

19 on and compute the floor spectra, the frequencies, P~'0 shapes and get the spectra.

And then ve vill compare 21 the spectra to the design spectra 23

Now, how are we going to do these things?

(Slide) 24 Looking at the model and. using the regular 25 considerations in modeling, ve w'll look at'he number ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVES,WWASHINGTON,D.C. 20024 (202).554-2345

27 of dynamic degrees of freedom, were the masses lumped t.~ &~~~5 2 properly it is a

. model and were the h,

3 stiffnesses correctly represented, were eccentricities 4 considered And we are in the process of that

~ examination at the moment-Our criteria are that we will accept a

15

?'ercent variation on model properties And generally 8 our program considers a

15 percent variation in 9 engineering calculations acceptable These are lengthy, 10 calculations, and we would. expect it to be done by 11 separate engineers, that we could end up with a 15 12 percent variation.

13 Similarly, on the peak frequencies

'rovided, 14 that the mode shapes

agree, and we wi13. look at the 16 participation factors Me-are thinking in terms of 15 16 percent for variations there.

And that in the spectral 17 accelerations, provided the shape of the spectra which 18 would follow from the mode shapes, is the same 19 That is our approach to the building 20 KP, CHEHS:

Excuse me a

moment On that one, 21 you said. earlier that the only other choice was the 22 containment building-How are you suggesting there are 23 no other structures?

HB. CIOUD: I certainly did not mean to -- I 25 certainly did. not mean to mislead you on that, Lr.

AI.DERSON REPORTING COMPANY, INC.

400 VIRGINIAAVES.W WASHINGTON, D.C. 20024 t202)$ 54 2345

28 Crevs.

There are several structures at the plant.

Mhat 2 I meant was that the only other logical choice from the 3 point of viev of verification.

Thank you for the 4 clarification-HR.

DENTON:

Mere you just getting into this 8 one, or had you put a lot of effort into this?

HR.

CLOUD:

Me put a fair amount of effort 8 into the building vork Me still have the model under 9 reviev But ve have gone ahead vith the calculation of

~ rig 10 the model properties, and ve are ~~ done-vith that.

11 HR.

DENTON =

Could you characterize the level 12 of effort that you have put into the overall 13 verification to date in terms of man-hours?

14 HR CLOUD" Mell the vhole business of level 15 of effort we put

a. lot of vork in'to it, but the level 15 of effort in the organizat'on I thought ve vere going to 17 reserve for items 5 and 6-18 19 20 HR.

DEHTON:

All right.

(Slide)

KR.. CLOUD.

As 'I mentioned, the next largest 21 class of vork on the plant is the piping..

Our thought 22 vas that first vithin the scope of the program, as ve 23 talked about it initially, there are about 230 24 analyses Our thought was-that if we completely redid 25 10 of these, that ve-.would get a pretty good ALOERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S,W. ~ WASHINGTON, O.C. 20024 (202),554-2345

0

43 29 verification of the piping vork and particularly if ve 2 do it completely from scratch.

You have to look at a lot of.that data to do a

3 4 piping problem Our criteria for the sample vas to

~ attempt to obtain a sample from each building, from each 6 elevation in the buildings, and from

a. diversity of 7 systems and from the lines that vere more important to 8 safety And E vill shov you the ones ve chose 10 (Slide)

~ Re have piping problems in these systems and 11 in these locations.

And the building is the second 12 column The first column is our own notation-The 13 second column is the building that the system is in-14 The next 'column is the system in which our 1~ problem is contained And then the last column is gust 16 the drawing.

You can see that we have a couple of vJ 17 problems in the aux feedvat er 1'es ~2-the HHB sys em <~ I 19 Hov do ve do this'ov are ve doing it2 20

( Slide) 21 Our first step. is to go into the field and 22 perform a field verification of the draving So our 23 engineers go into the field and valk dovn the line l

24 vas going to say before that I was advised that they 25 valked dovn the 1'ne'.

They cravled dovn the line and, ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVES.W., WASHINGTON, D.C. 20024 (202I.554 2345.

30 in some cases, they squirmed down the line It is 2 fairly congesteD in some cases.

Re developed models from the drawings that we 4 had veri ied ourselves And our loading following the 5 Hosgri criteria is the deadweight> pressure and seismic pg)L P! pE co~8-MA<cg ~s 7

Now, there is a discussion on'omputer codes.

8 Qe are using a different computer code than was used for 9 the design analysis..

And for the piping work we used 10 it is a question on benchmarking He are presently, tracking down the documentation on that But we believe 12 it is well benchmarked, and we believe that it is one of 13 the most widely used, piping codes in the country.

So I I

14 do not foresee any problem there.

15 I would like to emphasize on the field 16 verification that every item in our sample is 17 field-verified as to its installation by our people.

18 And even the building was checked~

and the 'dimensions on 19 the building.

Although not 100 percent, a

good sample 20 of those measurements were made 21 HH.. VOLLLfEB Does this verification include, 22 I assume, hanger location, hanger types actual routing 23 of the pipe and so on'P Do they have criteria beforehand 24 from which they can determine whether or not an 25 exception should be mised?

ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVES.W.~ WASHINGTON, O.C.'0024 (202).554 2245

I

36 quest NR-EXSENHUT:

Z have one simple, very trivial 3 question, in a sense Do you know whether the algebraic 4 sunmation vas one of the verification codes'?

I R

5 RR CLOUD:

Ry memory vas that ttrv~ vms~

e 8 code that had that si.tuation in it for a couple of 7 years<

and they fixed, it way back when's that right 8 or wrong?

KR. BOSNAK=

That is right.

Before you get 10 into the supports can you help us bridge -- I do not 11 know if you call it apparent discrepancy but you are 12 tryi.ng to see how you can decouple supports from the 13 piping system, so would you try to cover that?

14.

HR CLOUD Rel'l I was coming to that 15 immediately because we really cannot Me are going to 18 take 20 supports out of our piping saIIIple and. then 17'erify those and, using the loads that we calculate rom 18 the piping work.

20 (Slide)

Our methodology for doing this, you asked 21 about the uniformity of the design method-Xn general~

I ad 22 except other than the components, w~phghangers and 23 spring hangers and snubbers, the supports a t D'blo 24 Canyon are designed essentially in a very uniform way.

They are,.even though they perhaps, or many o

ALDERSON RPPORTING COMPANY, INC, 400 VIRGINIAAVE S.W., WASHINGTON, D.C. 20024 (202).SS4-234S

0

e 40 And ve reviev it to see that the requirements of the 2 IEEE 344, which in this ca.se was applicable, are 3 satisfied..

8B. BAGCHI:

Is there any equipment, that needs 5 to be sequentially tested due to the XEEE requirements' Do you have to qualify the equipment not only for 7 seismic but for the harsh environment2 Have you found, 8 ind.ications that the equipment ought to be qualified, by 9 IEEE-3232 10

~

KB CLOUD:

Ho Me are only verif'ying the 11 seissic ort"'ops of that sort-

~~XQhCLT.ht1~ ~~ P~ g PQ4s~~

18 Raceway supports ve have some experience with I

14 these from the preliminary'effort Me are taking a 'nev 15 sample, putting the supports, but in addition ve felt 16 that it vould be desirable as vith the small-bore piping 17 to perform a separate review of the design methodology.

18 So we will be verifying the field 19 installation.

Me vill verify the PGGE methodology, 20 which is differen, and taking a sample.

And ve <<ill do 21 an independent analysis o" the supports, usihg the PGCE 22 met ho do logy 23 The criteria that ve vant to assure is that"'it 24 accounts or all dynamic effects and the seismic loads 25 are adequately considered in suppo ts or adequa.tely.

ALDERSON REPORTING COMPANY, INC, 4OO VIRGINIAAVE., S.WWASHINGTON, D.C. 20024 (202).554 2345

50 just described?

2 MR. CLOUD:

Yes, that is righ.

Me are not 3 breaking them down urther ~ter.

by these classes.

But 4 probably would, in describing it you knov, if ve 5 found one and ve knev it vas a systematic error and we 6 tracked. it and found it occurring in several

places,

" veil, in the description of it ve would. certainly 8'escribe it as such.

DR DENTON Mhy don't ve move to your 1o remaining slides?

MR CLOUD: I only have one that most, of you, 12 I am sure,. have seen, and let me take this opportunity 13 to mention tha ve started vith our first vas number 14'910, and the reason.fo',that is that our filing system I

16 vas set up -- we thought veil, ve would put them in file 16 910 and then the next one would 920 and then 930, and 17 then ve realized that that vasn't going to work ~

So we 18 went back a.nd started doing it. one at a time, so we vent 19 back to 921, 22, et cetera So that is the reason.

20 (Slide

)

21 So the system begins at number

910, and ve 22 have 23 MR DENNISON:

Excuse me-Me vent 910,

920, 24 930, then 931 25 MR. CLOUD:

Thank you.

That was Hr Dennison ALOERSON REPORTING COMPANY. INC.

400 VIRGINIAAVE S.W., WASHINGTON, D.C. 20024 (202).554.2345

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52 questions, or my hope is that I have answered all of 2 them.

But I hope that I have answered.

some of them, and 3 that that vould provide a framework for subsequent 4 discussion DR DENTON It has been helpful I think it 8 vill also be helpful i ve hear maybe from the other

" consultants 8

lfR-CLOUD:. If that is the case, I would like Poc~G k, 9 to introduce AeberW Reedy~

vho is doing our quality 10 assurance vork and he can describe hov ve. do the audits and vhat his program consisted. of 12 13 (Slide.)

HR REEDY:

This slide is to demonstrate the 14 overall-approach to our QA 'reverification.

Ne started.

18 out vith ini. ial meetings vith these contractors, PGCE+

18 ANCO+ et cetera to introduce ourselves, vho ve vere@

17 the type of effort that ve vere taking on-And this vas 18 important because some of the contracts had expired vith 19 PGCE, so it vould seem 'appropriate or an independent 20 consultant to valk into someone's office and say "shov 21 me your records."

So the purpose vas to introduce 22 ourselves, tell the type of audit that we would. be 23 making, and try to identify the type of material that ve 24 vould need.,

such as contracts, scope of the vork 25 performed with PGCE

-and the appropriate manuals.

ALDERSON REPORTING COMPANY INC 400 VIRGINIAAVE S.W. ~ WASHINGTON D C. 20024 (202).554 2345

Mith respect to the initial task, that which we are now performing, we have reviewed the NRC order and letter, the PGCE responses to those, we have briefly 4 reviewed a preliminary review of the

FSAR, and we have 5 had available to us the first six Cloud semi-monthly 6 reports, also his preliminary report, so-called, and we T have reviewed these on the basis of those reviews Re last Friday were in a position to submit to 9

PGCE our project plang and that would be invoked, in a 10 project QA program It is a

PGGE requirement that we 11 receive approval of this project QA program before we 12 can go on to the other tasks.

As I say, last Friday we 13 vere about, ready to do that.

Me have been doing things 14 at arm's, length Qe h'ave had'ne approximately one'-hour Cl OUD 15 meeting when Bob ~~stopped by our office and wanted l6 to see it since we moved into a

new building in 17 November, too, to hand us some things that he carried 18 with him for our background, namely his bi-monthly or 19 semi-monthly reports for our review.

And then there 20 were meetings yesterday and todav that of course have 21 been referred to and will be mentioned 22 Now, last Friday when it became obvious that 23 this meeting was going to be held this week, I 24 recommended to Hr Naneatis that we not transmit this 25 information to

PGCE, but rather that we wait for this ALOERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE S.W., WASHINGTON, O.C. 20024 (202),554 2345

87 MB. BOSNAK:

Now, vhen you went through and 2 did your own analysis, what assumptions~

vhat model'ng 8 techniques did you use?

MR.

CLOUD

'Hell, first, we are using, ve are 8 reproducing the methodology that was employed, agreed

~ upon and employed in the Hosgri reviev, for tvo 7 reasons.

In the first place, in order to verify the 8 vork that vas done you have to do the analysis in the 9 same way In the second place, that methodology was in 1o place for that vork, and ve are not, changing it Hith respect to hov models are prepared and so 12 forth, I think I can say nov that ve are using vhat we t of'he ot~~~

models HR BOSHAK:

In other vords, are you using 18 vould consider to be regular good practice in the pg~Pt PK 14 devel'opmen th 16 today's techniques in coming up with your model, or are 17 you using what might be considered to be techniques that 18 were used when the plant vas designed7 For instance, 19 vhat criteria did. you use for specifying supports 20 rigidi y?

21 MR CLOUD:

The piping supports and the vay 22 they are handled are part of the methodology used in the 23 Hosgri reports an" that's one of the items I was 24 referring to when I said we are attempting 'to reproduce 25'their methdology, their detailed,methodology.

The

'I ALDERSON REPORTING COMPANY. INC, 400 VIRGINIAAVES,W., WASHINGTON, D.C. 20024 (202).554.2545

I3 99 HR-SCHAUER:

What I'm getting at here, let me 2 elaborate.

This sequence of questions is really 3 designed to lead you down the primrose path of course 4

HR. CLOUD=~8 s getting a little edgy.

(Laughter.)

HR SCHWA UER:

The issue that I'm trying to 7 bring out here is that the vertical response factor 8 probably should not be modified by the Tau effect, and 9 it looks to me like the way you 're doing it right now 10 you are afodifying the horizontal for the Tau effect, and then you are including that modi ication indirectly into 12 the vertical component 13 HR. CLOUD:

Yes, okay.

I understand your I

1'4 question

~ I don't believe that is done However, the 15 response spectra. that we are verifying the equipment to 16 aze.unambiguously defined in the Hosgri report.

17

Secondly, there does exist of course in 18 certain areas some issues regarding the response spectra.

19 themselves, and so at the conclusion of our work with 20,the auxiliary building, we expect to separately obtain a

21 veri ication one way or the other of the overall 22 response spectra.

23 25 ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE, S.WWASHINGTON, O.C. 20024 (202).554.2345

0

104 things

One, you vould determine what is required by 2 the licensae ~mrs "~~ independ.ent of anything else/

8 and then you will determine vha is in fact the true 4 input for the equipment qualification, and the third 6 thing is vhatever the vendor has supplied meets the 8 first tvo steps.

You are not going to examine the 7 qualifications procedure in detail, but at least you 8 vill see that, the vendor,. has made a commitment that the 9 qualification is part of the standards and he indeed has 10 the input that is appropriate HB.

HOCH-Hr. Bagchi, I said I vasn' going 12 to interrupt if.I cou3.d he3.p it, but I think I have to 13 to. clarify your question, I think, and put it in t

\\

14 perspectve Let me indi,cate" hov equip'ment was in 16 genezal qualified for the Hosgri event, and I think what 16 I am going.to say may 1ead.

you avay in some cases from 17 your question about procurement.

18 This vas done in several ways.

The vendor in 19 question vas still active in the business.

The vendor 20 who supplied the equipment.

He may have been contracted 21 with to provide service to upgrade the equipment< to 22 re-analyze it, to re-test it, to in some way requalify 23 it-In general+

and I think almost exclusively, this is 24 the case.

The original purchase contract didn't have

'25 any kind. of a commitment 'n it to provide his service AU)ERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE.~ S.W.. WASHINGTON D.C. 20024 (202).554 2345

110 KR - CLOUD: It is included, Franz, only by the QA work <

and, -- only by the QA work and the review of C,ha,I ~

3 the seismic design ~>p as spelled.

out in the first 4 part of the program-5 lfR. SCHAUER:

In regard. to 14, could You 5 discuss a bit the procedures by which you are going to

~ 7 make the independent field verification and structures, 8 and in particular do you plan or have you d.one this 9 field verification or requalification prior to anY 1o requalification actions2 That is< have you gone out and looked at what is there prior to doing your 12 requalification2 13 5R.

CLOUD:

Yes I think in all cases.

.HR

'SCHAUER 'et me turn the. mike over to Er>>

15 Crews for, I guess his restatement or elaboration on 16 Item 15.

17

".R. CREVS:

Okay.

On Item 't5, that refers to 18 the scope of the program as it relates to the 19 safety-related seismic program.

And the question has 20 come up in my mind with regard's to all of the contracts 21 or all of the seismic design activities during the 22 period covered by this, and you spoke of including, at 23 least w'thin the QA and, I presume, under the 24 reverification program as well, only six contractors or 25 companies.

ALDERSON REPORTING COMPANY. INC.

400 VIRGINIAAVES.W WASHINGTON. D.C. 20024 (202),554.2345

NR.

CLOUD:

Excuse me-Me verified in the 2 case of back -- this is referring to the preliminary 3 vork now, but we verified that the cor"ect spectra vere 4 in fact used -

. I am going to let Ned answer this KR DEN ISON:

Vhat we verified, John,

vas, 5 for example, in the case of the major equipment that 7 Hestinghouse had been sent the correct and applicable 8 Hosgri spectra for the different areas of the plant 9 vhere their major equipment.

vas located.,

and what ve 1o vere going to do in Phase One is verify that for the rest of the Qestinghouse scope they vere sent the 12 appropriat and applicable Hosgr'pectra.

13 5R. PAIR:

But not go to their actual I

h 14 ca.lculations?

15 HR.

DEN ISON:

He vill not go to their actual un/HOG 16 calculations aa'~ that is the only method.

by vhich ve 17 can do it.

18 KR HORRILL: I guess the only other thought I 19 had on this vas, vhat do you intend for the final 20 disposition of the er or open item reports?

Or hov do 21 you close t,hese out?

NR.

CLOUD:

Yes.

Pell, as I discussed this 23 morning and I vill amplify it again, ve sent, once it 24 was clear that there vas either an error or an open item 25 that required some action on the part of the u il'y to ALDERSON REPORTING COMPANY. INC.

400 VIRGINIAAVE., S.W.. WASHINGTON D.C 20024 (202).554 2346

shakeout of the program.

HR.

HERRING:

Would this require you would 3 you expand your sampling in any vay based upon these 4 types of concerns?

lfR CIOUD: It vould depend upon vhat came out 6 of. it, but in terms of reporting, if there is no 7 question it would be reported We vould discover it n equally fast Our grugram is designed and set un sn I@5 g that these kinds of things are

out, and the 1o reason we set up the EOI procedure is simply to avoid 11 having people ask us these kinds of questions 12 HR-HOCH: I guess, Hr Herring, without 13 getting into any debate on the technical merits of the 14 three things you just. stated because I think neither 15 you nor I understand the technical details of the crane 16 analysis vali enough for us o debate i:t here, I think 17 the characterization is a little different than you 18 stated, vithout getting into the merits of hat one vay 19 or the other 20

Yes, indeed.

when there has been an error 21 discovered, such as the

'77 versus

'79 spectra 22 difference problem in the auxiliary building that 23 difference should be reflected by an update in the 24 Hosgri evaluat'n report 25 ZR-HERRING:

Well, in the case of the intake ALDERSON REPORTING COMPANY. INC, 400 VIRGINIAAVES.W., WASHINGTON. D.C. 20024 (202).554.2345

0

138 And that is to be kept in mind, particularly 2 on the conduit supports and in the other area where we 3 have again a modest

sample, on the small bore piping.

4 And ve are going on The thing I vant to emphasi e is 5 don't be misled by the smallness of the sample Re are 8 going through the methodology itself to determine if in 7 fact the use of that methodology vill produce a soundly 8 supporter@

set of small bore pipes.

g)IMC QhovT tg 9

I am not sure ifpI have just been talking+or" 1o ansvering your questions

< but 11 HR.

BOSHAK-Mell, I vondered if you had given 12 any thought to putting some of this justification that 13 you have heard this morning and again here nov into the

<<plan 'n an append'

~ to the plan, to give a little better 15 idea to )hose vho read it that it is not just based upon 16 what it appears to be, vhen you are just looking at 17 Table 1

18 HR.

CLOUD:

Yes, I understand.

I vould hope 19 th t the transcript of our meeting might be helpful in 20 tha.

regard.

Gr do you think you might vant ve vould 21 ce tainly plan to docume'nt these points in some detail 22 when ve prepare our report on this work If you elt 23 that if additional things were needed, of course, it 24 could alvays be done.

25

~R.

BOSNAK: I think that is'omething we vill ALOERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S,W., WASHINGTON, O.C. 20024 (202) 454 2345

139 probably vant to talk about when we see wha t various 2 people on the staff believe might be necessary in this 3 area.

HR-CLOUD:

Okay.'

would like to come hack

~ to one thing myself, because there vere several 6 questions this morning relating to under vhat 7 circumstances vill you expand your plan, et cetera Ve have included additional ve've included 9 the provision for additional verification vork because 1o we found <<from our preliminary effort tha this is many times required in order to develop an understanding of 12 the engineering vork ~

13 However, I vant to make sure that nobody h'as

'14 any wrong impressions now, because on, the wor'k that ve=

1~ have done so far, ve have not done enough

~

Re have not 16 Cone the comparisons with the design analysis, and we 17 are not clear on vhat our recommendations for additional 18 verificat4 on vould. be.

19 As I mentioneC, ve Cid earlier make a

20 recommendation for a very widespread requalification of 21 the racevay supports-

Hovever, on each item and each 22 class of equipment, ve vill make the justification for 23 our action. It vill stand, on its merit and stand on its 24 ovn feet, and it will be so documented when ve get 25 around to pulling oux reports together.

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149 HR-CLOUD:

"es, that is true.

NR.

BAGCHZ:

Mould you like to share with us wha t process you waded through to determine you needed 4 to look at four pumps as opposed to only two valves2 HR. CLOUD:

Our basic reason was that in the

~ first place, ther is one thing in fact, I am sort of

~ glad you asked the question because there is one thing I 8 intended to mention this morning that slipped my mind-I 9

Me have in our ten sample~ piping problems, so 10 we have in that.3.ine, we have in those lines 24 valves.

And of those 24 they are divided into

'10 and 14.

There 12 are 14 that are remotely operated and 10 manual, or 13 perhaps it's 10 that are remotely operated and 14 manual.

'14 But'in any event',. it is roughly 50-50.'split+

16 and we will be verifying the acceleration loads that go 16 in o those 24 valves, relative to their qualification 17 load.

So the sample is deceptive in that regard.

18 The valves that we are looking at here are two 19 fairly large motor-operated

valves, and we are looking 20 at the analytical qualification of them in depth -

On

'1 the

pumps, we are look'ng at no other pumps than these, 22 and we feel that the pumps are fairly significant items 23 of equipment.

24 I don't know i tha" helps you or not, but 25 that is some of the things that we e going on in our

~ 0 ALDERSON REPORTING COMPANY, INC,

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177 would review all the notes that we had taken and go 2 through the forms-And we send the final report with a 3 cover letter to Mr Cloud

~

Mr ~ Cloud then takes it and 4 handles it on from there MR. HAAS:

Mhat do you do next?

MR. CLOUD:

My job in this verification 7 program is two-fold:

One is to organize and manage.the 5el9 ~ ~~

8 program And second, on these ~~ problems>our 9 organization performed that But my relationship with 10 the review organiza.tion is strictly a hands-off program 11 management relationship.

And hat is, very clear.

MR HAAS:

You give him no guidance?

13 MR. CLOUD: I could not if I wanted to.

14 MR HAAS: I did not see anything in the 15 background of your organization 16 MR CLOUD:

-In QA our big struggle is to just 17 keep our own organizat'on running in the right way-18 MR.

HAAS; I can see in the way you have 19 described your workings this morning and tliis afternoon 20 that you do have to work together in a

way because there 21 is some overlap and interaction between you And yet 22 the functions can be independent to an extent.

23 MR. REEDY:

I do not real" y look at this as a

24 normal QA audit I thought this was brought out this 25 morning -- because we are going'ack into history.

And ALDERSON REPORTING COMPANY. INC, 4OO VIRGINIAAVE S W WASHINGTON, D.C. 20024 (202I 554.2345.

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6 222 any.

KR.

COOPER:

Then the ansver is no.

HR. SKJEI:

Thank you The last question that I have I think is 5 focused directly on Dr Cloud Would you please 6 describe the present relationship between Robert Cloud, P,D

>dP SCIL,AADSH AR P 7 Robert Cloud Associa zbns and URS/Blume7 HR.

CLOUD:. I vould be glad to.

I had

planned, 9 to raise that myself.

10 I think I have no relationship with URS/Blume+

11 and I have no relationship vith EDAC, and I have no 12 relationship vi"h Roland Sharp 13 Does that cover all the bases'P 14 HR. SKJEI:

- I think that does it.

15 HR CLOUD: I could ampli "y. I intended to e4.

16 bring that up, and I'G~num~ discuss~this matter 17 vith your. regional office.

But vhen I left, when I 18 firs vent

"'o the West Coast in '79 I joined EDAC vith 19 the intention of joining the company, and after I had 20 been there a couple of months I decided that what I 21 really wanted to Xo was to open my own officei so I set 22 about in a nev direction.

But I do have a reasonable 23 personal relationship with the presiden, the now 24 president, of EDAC.

25 And I made..-an a rangement once we got into ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W.. WASHINGTON, O.C. 20024 (202).554 2345

220 actual fact there was absolutely no conflict in any way, 2 manner, shape or form.

The work that the EDAC people 3 were doing was on the review of th'ngs that were not 4 analyzed.

by Blume-And further, the people that were 5 doing it had never worked for Blume.

But nevertheless, 8 and. in spite of every other consideration, we called ~

7 two hours later and told them that it would be necessary 8 to terminate the relationship, and. that has been done 9 And l have discussed that at some length with Hr.

10 Shackleton-E think it's a

shame that we have to do our 12 business in this way, but never heless, that's the way iso 14 ER SKJEI:

Thank you 15 tfR DENTON:

These factors 'that the Commission 16 has spelled out apply to-individuals, I think, who a,

e 17 doing the work, and since they.may be employed by youi T.

18 wouldn't expect you to be able to answer today whether 19 they meet this cr'erion, but T think that we should get 20 rom Yo'u an indication of what the answers wil" be to 21 these things, these ive areas, by the employees who are 22 actually doing the work.

Maybe you have already checked 23 on some of these "actors.

24 5R CLOUD:

Yes.

Pith respect to question 2,

25 none o

the people in our organization have been

~ 0 ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVFS.W., WASHINGTON. D.C. 20024 (202).554.2345

43 247 NacÃeil> vho may be knovn to some of you.

Some years P.

P)P0PP)$ '

>ggP@

ago he was vith 3~~5

".~~>'

and he recently has 3 left his job at Sandia and, is nov in the consulting.

4 business.

And he vill be helping us in soils-I have resumes for all of these

people, and I 6 vill'e glad to give them to you ERE YOLLZER: I think one of the reasons that 8 the item 2 in particular came up was it appeared from 9 our reading of the material submitted that from your ovn 1O particular background and that of Reedy and also the resumes that ve received from Teledyne, there vas not a 12 great deal of strength

anywhere, or there vas limited 13 strength in areas o civil and structural.

14 Did we have 'a vrong reading from Teledyne?

15 HR ~ CLOUD; If I can control these men on my 16 left but what I vanted to acknovledge vas I can 17 unders and hov you might have felt that way.

18 19 (Laughter)

HR.

REEDY; I vould like to point out that I 20 graduated as a civil engineer more than 25 years ago 21 And l am a reg'tered structural engineer in the State 22 of Illinois-23 HR.

VOLLEYER:

Any commen "s from the 24 originators of the questions?

25 5R.

DENTO/i:: I d' not originate it,. but I ALDERSON REPORTING COMPANY, INC, 4nn vIRreINi~ -v>-

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TRANSCRIPT CORRECTIONS FOR R.

F.

REEDY

53 The next itern that ve would. consider then 2 vould be the program review.

This is vhere ve take the 8 manuals or the documentation that was appropriate and do 4 a review to identify vhether or not that manual fit the 6 requirements of 10 CFR 50, Appendix B.

Then ve prepared.

a simple questionnaire after

~ our first cut at the manual or procedures, or other 8 documentation,

.to get a better feel for what vas going 9 on Sometimes ve had questions; ve did not understand.

1o vhat vas 'going on lt should be understood that some of this vo'rk started in 1966 and went on. up to our period

~2 of review vhich vas

1978, so it left us a span vhere 18 there vere questions that had to be ansvered in order to

<< have a proper review 16 Then the next item vould be to finalize the 18 program review Come back and.

compare and step-by-step>

17 the manual to the 18 criteria, as appropriate.

Prepare 18 an audit checklist.,

go in, audit the company, and then

~9 vrite up the final report.

And I vill get into a little I'0 more detail on tha.t-21 22

( Slide-)

ln our program review, regardless of when the 28 work was done ve made a comparison to the requiremen s

24 of Appendix B of 10 CFR 50, the, 18 criteria We also I

26 considered, as app ooriate, since this vas primarily ALOERSON REPORTING COMPANY. INC, 400 VIRGINIAAVESAV..iVASHINGTON,D.C. 20024 (202I.554 2346

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ynv design revise, the requirements of ANSI Nn5.211 anu for 2 some of the vork such as the subsurf ace investigations~

/e useu the provisions of N.n5.2.20, vhich is 4 appropriate to that type of vork.

Me concentrated on 5 the cont'rol of interfaces to insure ourselves that there 6 vere proper interfaces between PGCE and the 7 subcontractors the people that we vere investigating 5 to see that the information vas floveu correctly

~put 7

9 ve also had a very thorough overviev of the vhole 1o program.,

The last item vas to identify that we vere 12 looking at all manuals and procedures from as earlY as 1966 in some cases, all the vay up to June 1978, vhich 14 vas the end of Phase I-15 (Slide

)

16 To illustrate in a little more detail, these 1~ are the 18 'criteria.

The X 's shov vhat ve felt vas to 18 be the appropriate points to consider in our reviews f (I

19 and the NA is our idea of vhat vas not applicable-I 20 Since ve vere interested in design, it is obvious that, 21 some of these points of the 18 criteria are not 22 applicable 23 MR VOLLMKR:.

Did. all of these organizations 24 have procedures that were in existence at that point in 25 time that you could review?

AI.OERSON REPORTING COMPANY, INC,

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400 VIRGINIAAVE., S.W. ~ WASHINGTON, D,C, 20024 (202).554-2345

this'?

Did you have to consult with Mr. Cloud before you 2 held these interviews, or did you do it on your own recognizance or howV MR REEDY: I never checked with Mr. Cloud as 5 to how T. was going to do the interviews, or never showed 8 him our method of attack our checklist or anything like' that, if tha,t is the. question.

We did, have a schedule 8 that was set out so that we could, go in, and this was, 9" required because it takes time to get the manuals, to 1o review the manuals, to get your checklist together.

You v

don '

do it in one weeki believe me 12 So we had to go on a schedul

basis, but that 18 i.s the only basis that we had as to who we were going to 14 approach at*what time.. ~

PGCE never looked at our 1~ method of attack.

they never looked at our checklist; no

'Is one approved anything that'e did.

ge just deveioped El<a P+f 17 ourselves and went in and performed the audit and wrote 18 the report Does that answer your question?

And then we produced a formal report

~

We have 20 an introdu tion that will cover the scope of the 21 activities performed.

by the contractor a list of the 22 contracts performed from 1966 all the way t hrough June 23 1978 r the criteria that we used our conclusions, our 24 methods of review, our step-by-step method of approach k ~

25 We have a summary of findings and observations, and hen AI.OERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W., WASHINGTON, D.C. 20024 (202).554 2345

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55 HR REEDY The ansver to that is no.

NR.

YOLLHER:

So hov vas that conducted, then?

3 HR. REEDY:

Where there were no procedures ma1" 5d 4 that ve felt the intent of 10 CPR 50, Appendix B,>we 5 looked to see if we could find some basic elements to 6 address those criteria.

We tried to see if there vas Hie

+a aJJr~ss 7 anything that we could 5 a controlled 8 system for doing the design vork controlled sign-offs 9 and. things like that 10 (Slide-)

Qe prepared our audit checklist, and. these 12 vere prepared from reviewing the details in the manual 13 vhere they wqre available, and pulling out

'. g,he~

14. question@a ~a we did not have manuals to use~

+o mak'e 1~ up a good checklist~

ve used vhat we call a generic 16 checklist, which just says 2.dentify or verify the lt 17 calculations that they vere done this'ay or that vay.

18 It i;s a pretty standard generic checklist.

19 Sometimes we had to modify the checklist 2o during the audits that ve had As a summary, typically ve had about 15 ma jor items in our checklis't, tvo to 22 four subitems under each of the major items, and a total 23 of 50 to 60 to entries that ve vould try to find 24 verification for.

25 (Slide-)

ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W., WASHINGTON, D.C. 20024 (202).554'2345

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56 During the a.udits, ve used

~ these checklists 2 where they vere applicable~

and we did arrive at some 3 places where ve found that our checklist that ve had 4 prepared just didn't cut the mustard..

So then ve had. to 5 use an interviev technique to see if ve could find how 6 the woxk vas done at the time it was performed, and then 7 vhether or not we could. verify through documentation i I4 6'hat 4zt'id occur 9.

Me reviewed. all of the objective, evidence from 1o the contracts that vere existing between that company and..with PGCE during the timeframe that we vere 12 interested in-Me got a list, of contracts from PGCE~

13 and.

ve also got a verification of thati by the list of 14 the contractors'ontracts withPGCE and, then made a

15 comparison of the tvo 16 Qe emphasized the contxol of 'he criteria, the 17 interfaces, input and output, computer program 18 verifications, calculations, et cetera.

ht the end of 19 each audit ve would have an exit interview vith the 20 quality" assurance ma'nager or a principal of the company 21 and. identify to them vhat ve found in the interviews

~

22 In every c se that we have had so far ve have identified 23 vhat we felt vere the problems and the interviewees vere 24 in agreement 25 DR.

DEHTON:

Hov. independent vere you in doing ALOERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W. ~ WASHINGTON, O.C. 20024 (202),554.2345

58 h<<<

ve had. attachments vhich includeg attendance list, the Coi~+M~

p~garJ~n f 2 audit finding reports which bed the questions Mha we 3 vere'ooking for4ae4 the responses and our summary as to

+re. P W)I"aN 4 vhether ox not i+ vas adequate-.

Me had our program reviev which was the reviev 6 of the manual as it compared, to 10 CPR 50, and then ve 7 had our checklist all filled out DR - DENTON:

Now, this area does not lend 9 itself to remedial vork very veil. These are almost 1o stand-alpne findings as to what happened during

~ the, design process.

And if you found deficiencies.

that 12 finding cannot readily be corrected~

there is no way you 13 can go back to a program in 1978.

So E assume that that 14 finding has to bear, on the ultimate decision that Mr.

16 Cloud. vould, make regarding certain systems.

16 MR. REEDY:

That is correct-As Mr Cloud 17 shoved in his slid.e, one of the reasons for increasing 18 the reverification, or increasing the sample size, is 19-inadequate QA audits, so ve have finished two audits 20 Tvo reports have come in, and on the basis of those, I

Mr. Cloud is considering hov to feed. that impg7 22 into the system.

C~l(d~)

23 No w in reporting to Mr. Cloud, ve used two 24 terms, two definitions One is a ZinCing vhich is 26 something that has tp do vith inadequacy of the program t~

ALOERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W., WASHINGTON, D.C. 20024 t202),554-2345

59 or inadequacy of implementa.tion, which has an effect on 2 the quality of the product.

In other words, if we have 3 a finding, it is based.

on something having an effect on 4 the quality of the work that was done.

The other is an observation, and an 6 observation is someplace where the company may not have

~ met thel manual,, but has achieved.

what was intended or 8~<~ i~>

1 8 did not have an impact on quality And I can give you 9 one such observation as a sample 10 One of the companies that we went into it 12 was a requirement that

a. copy of the interface document 1~ be given to each of the project engineers associated 14 with doing the work, or each of the engineers associa'ted

<< with doing the work In fact, it was not.

However, in cubi" o+

16 checking ver-evidence, we were able to verify that each 17'ngineer signed. off as having read.'hat document and 18 having understood the document, and it was filed, in a

19 central place where it was available at all times So 20 that has no effect on quality in my mind., but it is a

21 glitch in their program, so that was an observation.

Then our final report is established.

And Hr 23 Cloud will take action after that on the basis of what 24 we found-25 5B.

HAAS

..Dx-Beedy, I assume you axe doing ALOERSON REPORTING COMPANY, INC.

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vi 156 by determining that there vas a specific problem with a 2 specific transfer of information across the specific 8 interface.

Nov, the question I still have is, vhy 4 vouldn't one sample to determine exactly vhether or not 6 there are other to gain some confidence that there 6 are not other problems out there in a rational manner 7 vith respect to specific interfaces, of vhich there is a 8 lot of them out there?

HH HEEDY:

maybe I could take a stab to try 10 to clari&y vhat has happened Of the six contractorsi 11 tvo of them vere involved in piping analysis, and that 12 vas after the Hosgri came along, and that was EES(or 13 CYGKA) and EDS.

Arid those tvo neceived intonsation, y(PfA 14 isos', dravings, from PGCE, vere requested to check For 16 the loads that vere. given tnidor'nI~hon 16 They did. their analysis and that< went back-d F~~~c 7!'-~M VJMg 17ery simple interfaces on that count 18 The other one vas Harding-Lavson, who did the 19 soil and surface information, and there vas a lot of and f-Ot4$ >5UCIIIaS

+/e 20 transmittals back the results of ee" soils 21 tests Eut again, it was kind, of a one-vay street 22 because they were digging samples out running analysis 23 and sending results back to PGCE.

24 Rhen ve get to ANCO, they did tests in situ.

25 They set 'up their vibrating machines in the field and AI.OERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W., WASHINGTON, O.C. 20024 (202).554.2345

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1 g 157 shook some equipment to try to get the frequencies, et 2 cetera Again, simple interfaces 3

Riley did. some shaker table tests in the lab; 4 very simple, again It was just, this is the equipment, 5 they modeled it, they ran the shaker table 6

And then Blume had a lot of interfaces.

That

~~dn' goes back from 1966> all the vay That is the last eae-8 that we have ~ finished.

Me haven't gotten a report 9 together on that-Me have been in there.

'Re do not 1O have the.report together~

but there is a tremendous number of interfaces on that one.

12 And we are in PGCE now, and those are vhere 14 13 the interfaces really come "to bear

~

\\

Does that ansver the question?

15 16 KR. SCHAOER:

Yes, it does.

AIR BOSNAK: I believe there is one other area 17 that, we haven '

touched on, and that 's expansion of 18 sample size, if you need. to.

Is it your intent that you 19 will take the sample size in table one and if you have a

20 failure, whatever your failure is, then'you vill repeat 21 the entire sample size?

Or vhat is your definition of 22 expansion there?

23 NR.

CLOUD =

Let me repeat something I did say 24 earlier.

It is our ir tent vhen we find an error to do 25 increased. verification How, so far ve have not ALOERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W., WASHINGTON, O.C. 20024 (202).554.2345

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sometimes ve have to ask people vhat they did.

But we were looking for verification and 3 written do"umentation.

Me are not taking anyone's vord 4 that this is vhat vas done but we used the interviev to eoufcf 5 lead us to documentation that ve +ca put our hands on

,6 MR HAAS:

The staffing, I presume, ve vill 7 get into in the next session.

And ve already talked 8 about criteria.

You basically said that vhen you go to 9 an organization you look at all of the items of vork 1o that they. perform and the QA controls that vere applied.

12 MR.

REEDY:

That. is correct.

13

'R. HAAS:

Hov, vhen you do an audit and you I'4 find problems>

what do you do next?

15 MR. REEDY:

Qe identify the problem either as 16 to an observation or as to a finding-Nov, for example j 17 on one ve found five observations.

There vere no 18 findings There vas nothing that hurt the program or 19 had any impact on quality whatsoever.

20 gave an example of one of the observations 21 that we have, and there were several more of the same 22 type of thing.

En fact, I believe, out of five 23 observations that ve had with that 24 organization, three.had already been correct'ed in their 25 post-1978 manuals.

So ve just found what had happened ALDERSON REPORTlNG COMPANY, INC, 400 VIRGINIAAVF S.W.. WASHINGTON. D.C. 20024 (202) 554-2545

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significance mean both or just one?

MR HOCH:

To me that means both You have to 3 consider both.

Certainly, the primary consideration is 4 whether it is safety-significant, but certainly an area

~ that is systematic and. affects a broad, category is in 8 the same situation.

PGGE has existing formal tracking. systems, 8 including a computer-based commitment control system, 9 which I talked about a

moment ago<

which we'ill'use to 1o track the following items:

RLCA's error and open-item reports Teledyne Engineering Services open-item and j.'os-sa 12 error reports, Ra4~

F-Reedy's open-iten and error 13 reports, and items identified by"PGCE internally-A 14 PGCE is modifying these systems to identify 16 and track all items for which significance is not a 16 determinate 14 days, in addition to items that have been 17 determined to be significant 18 Okay-The tracking system will be modified to 19 also provide and print out the information outlined in 20 item Y of yo ur letter, the items you mention there.

And 21 this information will be included in our semimonthly t

22 status reports'3 Now, the only problem that leaves us with is 24 the problem about timing.

And I am not sure how to 25 structure the number..of days of the

'ming, but let us ALDERSON REPORTING COMPANY, INC, 400 VIRGINIAAVE., S.W., WASHINGTON, D.C. 20024 (202).554 2S4S.

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P i>,)

225 employed by PGGE.

None of the people in our 2 organization ovns or controls significant amounts of 3

PGKE stock.

The father of one of our engineers ovns 63 4 shares.

None of the members of the present household of 6 any of our people are employed by PGEE, nor do they'ave 6 relatives in a management capacity-MR-REEDY; I can speak for myself and for the 8 individuals.vho have been vorking vith me and. state that 9 none of us have been previously hired by PGCE to do any 10 work of any kind previously, and that is in any aspect 11 of the company we are presently vith or have ever been 12 vith for all individ,uals in my company and for anyone 13 vorking vith me-14

'R DENTON:

That last statement was rather 16 broad.

16 17 18 MR. REEDY: I researched it quite thoroughly MR-DEHTOH:

Do you mean GEV MR REEDY:

I said none of the individuals 19 have done any work for PGGZ.

Hone of the individuals 20 vho have vorked for me have done anywork for PGCE 21 MR DENTON:

22 the companies that you 23 any vork I though

. ou said that none of have vorked for have ever done 24 MR.

REEDY:

I'm sorry if I gave you that 25 impression.

Hhat I meant was either in my capacity now

, ~ >

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