ML20087P888
| ML20087P888 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/05/1984 |
| From: | Richard Anderson, Jacobson M, Leppke M, Shipley L PACIFIC GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20081B795 | List: |
| References | |
| NUDOCS 8404090491 | |
| Download: ML20087P888 (98) | |
Text
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i i O UNITED STATES OF AIERICA NUCLEAR REGULATORY C0fmISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of ) Docket Nos. 50-275
) 50-323 PACIFIC GAS AND ELECTRIC )
COMPANY ) (Design Quality Assurance)
)
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
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AFFIDAVIT OF R. C. ANDERSON, M. J. JACOBSON, M. E. LEPPKE, L. E. SHIPLEY O STATE F CAU FORNIA )
) ss.
CITY AND COUNTY OF S'Ji )
FRANCISCO )
The above, being duly sworn, depose and say:
I, Richard C. Anderson, am Engineering Manager for the Diablo Canyon Project.
I, Michael J. Jacobson, am Project Quality Assurance Engineer for the Diablo Canyon Project.
! I, Myron E'. Leppke, am Onsite Project Engineer for the Diablo Canyon Project.
I, Larry E. Shipley, am Technical Consultant for Piping .or the Diablo Canyon Project.
O_ 8404090491 840306 i PDR ADOCK 05000275 l G PDR _
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O By letter dated February 7,1984 (PGandE Letter No.: DCL-84-046) we fontarded to the NRC a response to questions raised as a result of the recent NRC investigation into allegations regarding small bore piping design (attached hereto as Exhibit 1). We supervised and participated in the preparation of this response, and it is true and correct to the best of our knowledge, infomation, and belief.
Dated: March ,1984
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R. G. ANDERSON wor M. J. J AGOBdon
,= W kb M. E. LEPPKE
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L. Y 5HIPLEY
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Subscribed and sworn to before me this ti d day of March,1984.
M SEAL l(ancy J. LeetasteW Notary Public in and for the City and County of San Francisco, State of California.
fiy conmission expires April 14,1986, i
,x:o:xxxeco:xxxeco:mxx>em NANCY J. LEMASTER
[.! NOTARY PUSUC CAUFORNIA g M
CITY AND COUNTY OF h I SAN FRANCISCO
- . My Commission Expires Ap if 14.1986 A**.C*.XXX*CCO:MMMMXMMX:C"X"CC(%
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. O tist or exsisits Exhibit 1. PGandE letter dated February 7,1984.
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PACIFIC GAS AND ELECTRIC COMPANY ...
O COPY 1 1 4 February 7, 1984 .
PGandE Letter No.: DCL-44-046 1 Mr. Darrell G. Eisenhut Director i Division of Licensing Office of Nuclear Reactor Regulation
- U. S. Nuclear Regulatory Counission Washington, D.C. 20555 l Re: Docket No. 50-275, OL-DPR-76 i Diablo Canyon Unit 1 Small Bore Piping
Dear Mr. Eisenhut:
During the recent NRC investigations into allegations listed in SSER 21, the Staff raised several questions with respect to the design of small bore piping. These questions were discussed by the Staff at the Diablo Canyon Power Plant exit interview on January 19, 1984 and at the January 31, 1984 O meeting in San Francisco between the NRC and PGandE.
The Staff questions and PGandE's responses are documented in the enclosure.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely, J. O. Schuyler by J. D. Shiffer GCWu/BSL/JDS/JOS:naw Enclosures cc: T. W. Bishop G. W. Knighton J. B. Martin H. E. Schierling bec: Diablo Distribution 0174d/0007K
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I PGandE Letter No. DCL-84-46 I. INTRODUCTION
- 1. General
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This submittal is provided in response to questions raised as a result of the recent NRC investigation of allegations regarding small bore piping design by the Onsite Project Engineering Group (OPEG). This submittal sets forth the questions raised, responses to those questions, conclusions, and if applicable, the corrective action being taken by the Project.
To prepare this submittal, the Project reviewed the information, developed by the NRC investigators and noted the explanations and conclusions provided by the investigators during exit meetings and the public meeting of January 31.
After~1nvestigating the facts giving rise to these concerns, basic causes of discrepancies and generic implications were carefully considered. Conclusions have been derived as to adequacy of the design, effectiveness of the quality i
assurance program, and needs for corrective action and for strengthening the ,
progrM.
The questions appear to encompass the following issues:
o Adequacy of small bore pipe design
'O o uf-tive-s of the guaiity murance progr- for oPcG l
o Generic implications from discrepancies found ,
o Corrective actions which might be necessary or desirable It is important to recognize that none of the evidence demonstrates that there were inadequate designs or that the overall quality assurance program was ineffective. At most, concerns were raised which create a need for additional information to provide requisite levels of assurance. The investigation also identifies where improvements are desirable in Project programs and practices.
- 2. Nature of Concerns The concerns raised cover a wide range of small bore piping design activities that are more thoroughly explained and evaluated in the individual sections or subsect4ons to follow. However, it is possible to provide some statements and j
perspectives regarding the review effort:
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- a. Discrepancies have been found in the small bore piping design work.
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- b. Such discrepancies are of a minor nature and, when revised calculations or analyses were performed, all of the piping and Thus,
- O- supports fully met the licensing criteria and casumitments.
it can i.e concluded that there is no technical or safety concern with the as-designed and constructed safety-related small bore piping.
- 2. c. The presence of these discrepancies raised concerns regarding the control of the engineering work within the OPEG small bore piping ,
group and its overall level of quality. Such concerns have been l addressed by the explanation and discussion given for each specific concern and by the corrective action being taken.
- d. The major corrective action to date57 involves the review of the more of 110 complex small bore pipe support analyses:
(couputer analyzed) safety-related small bore pipe support designs; l 25 of the simpler (hand calculated) small bore pipe supports; and
, the 28 calculations identified by the NRC during its investigation. Additionally, certain strengthened training and l
procedural requirements and commitments have been made. i
- 3. The OPEG Organization The OPEG is organizationally a part of Project Engineering, but is located at i the site and thus physically separated from the San Francisco engineering group. It was established to meet construction's need for expeditious
,- responses from design engineering, to provide more direct feedback to desi O engineering on construction and startup matters, and to perform certain engineering activities (e.g., small bore piping design) that are bestThe OPE performed in proximity to the physical plant. substantial autonom construction and operations, and because its scope was rather closely defined. This was intended to make it more responsive to a need for on-the-spot resolution of problems.
The scope of OPEG's responsibilities is limited by Engineering' managemen -
matters within its capabilities, considering such number factors of aspeople.
staff suppet.
This facilities, abilities of assigned personnel, andTypically, the work performed by OP scope is clearly set forth in writing. includes design of Class I small physical interferences, resolution of non-conformances, and assistance in startup problems. It serves the needs of both Units 1 and 2.
greatest proportion of its work is related to design of saml1 bore pipe supports. No other major design work or analysis was performed by OPEG.
The OPEG organization is headed by an onsite Project Engineer, reporting to the Project Engineers for Units 1 and 2 and receiving assignments from them.
The number of people has varied widely, ranaing from several dozen, up to almost 300. Because of the unique requirements of this group and the nature of their work, more than 505 of its technical personnel were comprised of W .
non-permanent engineers provided by contract firms. The engineers are, however, carefuly screened for technical competence by PGandE or Bechtel, and by the contract fire prior to hiring.
- 4. Conclusions It is clear that the results of the reviews completed to date establish that there is reasonable assurance that the as-constructed sus 11 bore piping meets all design requirements and, thus, poses no safety concerns. Strengthened controls will minimize recurrence of similar issues.
Specific cor.c1'usions are as follows:
o Based on reviewing a sample of 110 piping support designs, it is concluded that final designs were not affected by the number of approximations and minor mistakes in the calculations of pipe supports and reasonable assurance of the adequacy of small bore pising design does mittal,'6 of exist. It should be noted that as of the time of this su the 110 support analyses are not complete.
o Because of the unique features of the OPEG Small Bore Piping Group (e.g.,
work scope and how it functioned), there is no reason to believe that similar concerns exist elsewhere, i
o Compliance with NQAM requirements, including numerous audits, plus the lack of significant errors, show the engineering quality assurance program was effective, but would benefit from strengthening in areas of training, technical audits, and procedure control.
(C o Perjorative charges in small pipe design work cannot be supported.
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II. TECHNICAL ISSUES ,
IItC Question: The NRC has raised a question a$ut Code Break designations (Allegations 55, 86, and 88, SSER 21). This matter was further addressed by i
Dr. Hartzman at the p'ublic meeting on January 31, 1984.
! . Response
' system where The term " code break" is used to describe the section of a piping (Class II) the safety-related piping (Class I) changes to nonsafety-related piping (see the figure below). This " code break" section is always located on the C' ass II piping and starts at the valve which is the point at which the fluid system class changes from Class I to Class II. Within the " code break" section is a system of supports or an anchor that dynamically isolates the 4
Class I piping from the remainder of the Class II piping. The " code break" i
The <
section of the pipe ends when dynamic isolation has been accomplished.
criteria used to achieve the desired isolation, as discussed in the Phase I Final Report, require that the system of supports that provides dynamic isolation be made up of either: (1) an anchor or (2) at least two lateral supports in each direction and one axial support. The anchor, or supports, are denoted as Class II* supports and are designed to the same criteria that are used for Class I supports.
Class I = Safety-related ,
Class II* = Nonsafety-related 1
" Code break" section OI t. but supported to achieve !
END OF isolation of the Class I piping VALVE CODE BREAK (" Code Break" section)
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Class ! .
Class II*
CJass II- Class II = Nonsafety-related nonseismic design In the above schematic, the length of Class II* piping is not important as loag as the. code break requirements are met by providing supports or an anchor. .If the. length of the Class II* section of piping can be shortened by '
relocating the class II boundary closer to the Class I boundary, the system would then require fewer Class II* supports; this relocation is only 1 l
accomplished by adding supports or an anchor to the cods break section closer to the Class I' boundary. As an example, assume that following the valve, the code break section included five bilateral supports (these provide support in both lateral directions at one location) and then an axial support. All these supports would require Class 1 qualification. Two alternatives for j improvement of the design that are acceptable and meet all ifcensing criteria are: (1) to add an anchor at the location of the first bilateral support, or (2) to add an axial support at the location of the second bilateral support. l Both alternatives reduce the length of the code break and the number of l
supports requiring Class I qualification.
The allegation that the code break boundaries were relocated in violation of some engineering precept, project instruction, or licensing criteria is fallacious. While it is true that the length of Class II* piping was
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minimized wherever possible by modification or addition of supports, there is nn reason not to reduce the amount of the Class II* piping to the minimum.
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i IstC Question: The IstC has raised a question about including as-built gaps to d7s.sscazi> Ta$= *trw-O r c tar iiad=(Aiiit4 55 further discussed by Mr. Yin at the January 31, 1984, public meeting.
Response
When performing small bore piping stress analysis for thermal expansion or
- . thermal anchor motion, actual restraint clearances or as-built gaps are sometimes included in the qualification calculations as described in Piping Procedure P-11 (Section 4.6.2). The gaps that are included are physical clearances that exist between the pipe and a structural element. Themai loads can be eitainated by gaps in pipe supports and, therefore, the inclusion of gaps in the qualification analyses is completely appropriate. In each case where gaps are included to reduce thermal loads, adequate assurance is available that the gap can be relied on to be present throughout the plant lifetime.
Before any gaps were included in a piping stress analysis. Piping Procedure P-11 required as-built reverification. Accordingly, a plant walkdown was conducted to establish the actual gap configuration. The gap configuration was modeled and included in the documentation of the stress analysis calculation. This practice of including gaps to reduce thermal loads is used in the industry as a method of accounting for actual plant conditions.
As a result of this llRC question, a review 'of all small bore pipi stress analyses was conducted. The results of the review demonstrated th t as-built gaps were included in 25 piping analyses affecting a total of 64 pipe
=eparts- Ta 64 ==9, arts r ar. at about as of ta. ==99 arts aantrz d. ^
(O reported in the Project's supplemental letter to the Staff dated December 28, 1983. 16 of the 25 piping stress analyses involved piping with service conditions below 200aF. In these 16 analyses, thermal movements are minor and not of technical concern. The 9 remaining pipe stress analyses affect only 16 supports (see Table 1) which are less than 15 of all the small bore -
pipe supports analyzed.
A description of the 9 pipe stress analyses in which as-built gaps were modeled into the computer analysis and the piping system temperature exceeds 200*F for normal thermal load cases was presented in the December 28, 1983, letter. These 9 analyses fall into two categories. Category 1 gaps were modeled to acconnodate thermal anchor movement (TAM) of large bore piping.
Since these gaps are caused by the thermal movement of large pipes and equipment expected to have repeatable thermal growth, the gaps are expected to be present throughout the plant's lifetime. All but one support falls in this category. Category 2 consists of gaps modeled to release thermal loads and stresses induced by two opposing supports restraining the pipe in the same direction. Because of the piping configuration that exists it is clear that the as-built gaps will remain throughout the plant's lifetime.
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The consideration of actual restraint clearances, as described in the i supplemental December 28 letter, is a reasonable and adequate technique for l i
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the piping geometries involved. This method is consistent with the licensing criteria for Diablo Canyon and has gained widespread use in the nuclear industry where the more conservative approach of ignoring as-built gaps results in excessive thermal loads. Finally, the use of actual restraint clearance involved a very small part of the small bore pipe and supports that
,_ uere analyzed.
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Table 1*
Q-Small Bore Support Small Bore Piping Corresponding Gap Modeling No. for which Gap -
_ Calculation No. Category (See Note)
- . Piping Analysis Data Point J
was Modeled f
1 63-7 15 S118 1 181-84 550 1 ;
181-96 556 I
1 53-1 50 3-302A 65 1 l 53-1 1 53-1 67 1
53-1 70 3-3028 1
42-6 198 4-302 1
2152-09 20 8-310 1
47-19 100 8-312 1 47-24 175 ,
1 66-22 24 8-314A 1 2185-1 44 1
58 66-25 1 1 66-24 78 1
66-51 32 2
2157-14 34 8-328 1
181-20 105 9-309 1 181-42 200 NOTE: Category 1 = Gaps were modeled to accommodate thermal anchor movement (TAM) of large bore pipe whose movements are determined to be repeatable.
Category 2 = Gaps were modeled to release thermal loads and stresses induced by two opposing supports restraining the pipe in the same direction.
- Isometrics for this table were previously submitted with letter of . .
December 28, 1983.
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c sc Question:for The surinesses M C has raised questions about the use of different the same rigid supports in static and dynamic pipe analysis
.h (Allegations 55 and 88, SSER 21). . This issue was also addressed by Dr.
- Hartzman during the January 31, 1984, public meeting.
Response
. Piping support flexibility was modeled in 4 of 129 analys occurs during thermal expansion of the piping and to reduce calculated thermal loads. The nature of thermal expansion produces only static (displacementInclusion limited) loads and not dynamic loads such as the seismic loads.
support flexibility in the thermal piping system analysis is,an acceptable method of more accurately predictini. the load that will be produced at any This approach <s consistent with accepted engineering given pipe support.
practice.
l The Hosgri Report Section 8.2, states that seismic Since supports may be considel the natural rigid if the natural frequency is greater than 20 Hz. frequenc considered them to be ri id.
The support itself is qualified for the combined thermal plus seismic loads.
Further, these loads are derived from two totally different loading phenomena:
one static (thermal), and one dynamic (seismic).
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',C Even though these calculations have met all licensing criteria, we have :
l U reperformed the 4 original analyses mentioned abo l appropriateness of the original assumption.
analyses demonstrate that the stresses and support ;
and dynamic piping analyses.
f In summary, the apparent inconsistent treatment of support stiffness forThe 1 static and dynamic analyses is technically justified. l approach was largely dictated by the desire to consistently implement se j licensing is greater than 20 Hz.
criteria which analyze supports as rigid if their naturl l criteria even if support stiffness is included in both static and dynamic ;
analyses.
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NRC Question:
The NRC has raised a question about computation errors and These
- unas nng seticiencies in small bore pipe support design packages.
' issues were discussed by Dr. Hartzman and Mr. Yin at the public meeting held en January 31, 1984.
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Response
l i The following response discusses and puts into perspective the calculational errors, the modeling anomalies, the engineering judgments, and the
- documentation inconsistencies found in small bore pipe support calculations.
The analytical approach is reviewed to give perspective as to significance of real and perceived deficiencies. The necessity for precision in sma11 bore calculations is discussed and a summary of the additional review effort that has been undertaken to address the NRC's concern is presented. l Although there are discrepancies in the calculaticn packages, one must recognize the large number of decisions that an analyst mu
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Small discrepancies discovered by the NRC reviewers and by our own reviewers.
bore pipe supports are designed with adequate precision to achieve the design function. The primary reason for the acceptability of this level of precision in small bore piping design is due to conservatises and structural redundancy in the small bore piping and supports completed with the low magnitude of loads which they experience. Nevertheless, the need for originating and checking engineers to more rigorously document acceptance of minor calculational errors is acknowledged.
So e of the ,1,e supports reviewed by the #RC inspectors are a ong the ost O~ The discrepancies found in our complex small bore supports in the plant. study of the NRC review actu number of decisions / actions that must be performed to arrive at a complete analysis. These analyses have been reviewed by the Project in detail and it has been determined that no modifications are required as a result of the discrepancies. This review is described below. The fact that no modifications were required confirms a conclusion that the design process and l conservatisms are tolerant to minor anomalies and that the engineers responsible for the design of supports have ensured that significant errors do ,
not exist.
- a. Pipe Support Design Process In the case of frame structure supports, the design generally consists of two phases. The first phase consists of the analysis of the frame structure and the second phase consists of the analysis of the associated ,
ba'te plates. Associated steps include evaluation of welds and qualification of standard components (struts, snubbers, U-bolts, etc.).
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l During the analysis of the frame structure, the analyst must translate a support drawing into a three-dimensional reoresentation describina the placement, orientation, and properties of the steel members and the i
directions and combinations of the applied aiping loads. Upon completion the analyst must perform a final check of tte overall results to assure compliance with design criteria.
- A moderately complex small bore pipe support at Diablo Canyon consists of, for example, approximately 10 discrete steel structural members and connections. In addition, the support has many supplementary items The such as U-bolts or other small meters which act to restrain the pipe.
model eventually developed by the engineer will contain approximately 30 joints and 25 elements. To develop the model, the engineer has had to specify 30 directional (x-y-z) coordinate points and define the connectivity of the elements to these joints. This means ensuring that approximately 90 numbers are correctly calculated, all digits and signs are correct, and indicatini the proper ntmerical combinations to define member connectivity are inc icated. Also, the engineer has to indicate the orientation of the strong and weak axes of the member. When the analysis is completed, the engineer applies the loads to the support model.
Typically, small bore supports are bilateral (supporting the pipe in two directions) and many are gang supports (supporting two or more pipes).
For example, consider a frame that acts as a support for two pipes.
Given the number of loads that must be specified (deadioad, tributary mass loads, normal and accident thermal loads, and three different seismic loads), one arrives at a total of 32 individual loads that must h be correctly transferred from the piping analysis, including directional sign. Also, he must specify parameters, such as unbraced length, for code checking purposes. The engineer then submits the input for computer analysis. Upon receipt of the computer analysis, the engineer reviews the ouput for appropriateness of deflections and stresses. Up to this point, the engineer has had to correctly develop and specify at a minimum approximately 300 numbers, assuring that all digits and signs are correct. In addition, he has had to review numerous pages of computer output. ,
After the engineer has completed his frame analysis, he must now begin the task of analyzing the base plates. For the evaluation of base plates, the analyst must similarly deal with hundreds of numbers or combinations of numbers.
combinations the sets of forces and moments to be input into the p14te/ anchor bolt analysis. The local coordinates of the baseplate model must be correlated with the local / global coordinates of the frame model.
The plate size, thickness and shape, in addition to anchor bolt location, and derated capacity edge distances, must stiffness, capacity, spacing,Taken also be reviewed and input. as a package, it is not difficult to conclude that the engineer in the above discussions has had to deal with and review up to 1000 numbers. )
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The judgment and capability of the engineer throughout the design process helps assure a safe design. His engineering training, experience, and insight are important in visualizing the model and loading conditions, as well as deciding that the results are acceptable. The engineer is responsible for assuring that the support desig, is free of significant error by applying his experience from performing analyses of many pipe supports.
Additionally, the reviewing engineer provides an important function in assuring that major errors do not exist by applying his general experience in evaluating the final piping system. The small size of these components allows good visualization and a heurestic understanding of the adequacy of a design, even without formal calculations and analyses. The engineer's understanding and experience lead to the identification of any major error by observing any obvious inconsistencies such as undersized members from that provided for other pipe supports.
The broad responsibility of the reviewing engineer is to assure that the calculation is sufficiently accurate for its intended purpose, i.e., to documient how the support meets the design requirements. Therefore, minor discrepancies in areas of the calculation that would not lead to a criteria exceedence would not be expected to be documented. The fact that when the discrepancies were addressed the supports were acceptable without modification substantiates the adequacy of the design process.
Nevertheless, discrepancies uncovered should have been documented.-
Docimentation of Small Bore Support Design Q b.
There are apprcximately 4000 small bore pipe supports which were designed and qualified in the field. Of necessity the process used to design and qualify these supports was a production-oriented process. The flow of work required a receipt of a set of loads and displacements, design of the support, preparation of design calculations, checking cf the design calculations, and review and approval of the as-built drawings. Both the originator and reviewing engineer focused on the parameters of primary importance to the adequacy of the support. Although satisfactory for criterion and safety considerations, the level of rigor associated with these supports was different from that achieved in other parts of the plant. In general, this variation in rigor is clear to those fast 11ar with design practices in power plant and industrial plant facilities throughout the country. More importantly, the rigor of design documentation varies according to (1) the importance of the system (2) the degree to which the system design may be challentled (large loads vs.
small loads), and (3) the conservatism which exists <n the design.
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The level of rigor of the small bore design documentation was technically consistent with the number of supports and the conservatism and I
structural redundancy inherent in the designs; however, compliance 1th quai 1ty program docissentation was less than fully achieved in some instances.
- c. Design Characteristics The previous section described the design process and the conservatism inherent in small bore design. The fact that the margin is very large for this class of piping is often discussed but its importance must not be underestimated. Sea 1 bore piping is fabricated from materials with duct 111 ties into the 305 to 405 range (resulting ductilities from the The supportinti systems des 10n analyses are typically less than 15).
prov'de for a highly redundant set of supports in which def"ection of an individual support results in the transfer of load to adjacent supports.
Additional conservatisms exist and are frequently tabulated in the I methods used to calculate small bore loads on supports, especially when span tables are used for calculating stresses in the supports. The result is that the small bore piping system and supporting structures are highly conservative in design and highly insensitive to variations in the details of individual support designs.
- d. Review of Supports A significant number of small bore pipe support calculation packages have been reviewed in detail. Some were reviewed prior to the January 31, 1984 meeting and many have been reviewed since then. The IDVP reviewed The a ;
total of 19 calculation packapes as documented in ITRs 60 and 61.
Project has reviewed 110 smal bore pipe support analyses: 57 of the more couplex (computer analyzed) safety-related small bore pipe designs; 25 of the simpler (hand calculated) small bore pipe supports; and the 28 calculations identified by the NRC during its investigation.
Q This Project review has been conducted to reverify the adequacy of the small bore piping design and to define the necessity for further improvement in documentation of the design adequacy. Each calculation package has been subjected to a detailed engineering review This by review the Project to identify all possible deficiencies or errors.
has, of course, been far more rigorous and detailed than that performed in the original checking process.
Each of the selected calculation packages was reevaluated by a reviewer and reconfirmed by a checker. A checklist was used to aid in the review process. Results of the review were documented on the checklist and supplemental comments sheets, if required.
The reviewers verified that the structural model was adequate and cospiete, that the loads used in the calculations were properly applied, and that the structural model reflected the latest as-built drawing.
Calculations were reviewed for required documentation, such as weld calculations, anchor bolts, base plate, spring variability, frequency, and structural analysis, to demonstrate compliance with appropriate project criteria, procedures and instructions.
The results were summarized into three categories.
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The first category, " Hanger Acceptable As Is or With Minor Supplemental Calculations or Comments " is used to indicate those support calculation
$X packages that were found to contain complete and acceptable information or to indicate those support calculation packages that vers found to be l
acceptable, but which, for example:
(1) Lacked certain statements needed to document the conclusions
- ? reached.
(2) Did not contain documented evidence of the evaluation of certain items which the reviewer felt was prudent to include in the calculation package.
(3) Contained information from which the reviewer could not make an assessment and thus deemed it necessary to perform supplemental calculations in order to support his evaluation and conclusions.
' It is not surprising that, due to the detail in the review, minor supplemental calculations or comments were required. Other engineers, rigorously looking after the fact, will generally always comment on some aspect of someone else's design calculation.
The second category, " Hanger Acceptable With Detailed Calculations," is used to indicate those support calculation packages that were found to be acceptable, but where, for example:
(1) The reviewer believed that it was advir;able to perfons additional analyses or modify and rerun the existing computer analyses.
O The term " Hanger Acceptable" indicate:; acceptability to the design criteria which were originally used to qualify the supports. The methods and criteria were not modified for this evaluation. Highly sophisticated analysis, such as plasticity calculation, was not used to qualify any of these supports.
The last category, " Hanger Unacceptable " is used to indicate those support calculation packages that were found to contain errors which,
' upon reanalysis, showed that the hanger required modification.
There were 129 support calculations included in the review. The results are as follows:
Category 5 of Supports i '
Acceptable with Minor Supplemental Calculations or Comments 785 Acceptable with Detailed Calculations 175*
Unacceptable 05
- Detailed calculations for 6 supports (55) have yet to be completed.
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1 These results are significant. Of the 129 small bore supports, some among the most complex in the plant, the fact that no modifications were required indicates the minor impact of the anomalies noted.
It is also interesting to characterize the discrepancies themselves. The discrepancies noted in the review were tabulated into one of three categories. These categories were (1) modeling, input, or calculational
. . .. error (2) modeling or engineering judgment (verified by subsequent
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calculation), and (3) documentation discrepancy.
The first category includes such items as mis-modeling a beam property, t
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having the wrong sign on an applied load, or performing a mathematical calculation incorrectly. The second category includes items which the ,
reviewer noted as a modeling or engineering judtpment, but felt that a l' j
' supplemental calculation was necessary to verify the conclusion, and subsequently performed the calculation and verified the judtynent. The third category includes reference to non-Project documents and a clear engineering judgment made but not explicity stated as such.
The conclusions drawn from this categorization are as follows: ,
Category Percent of Discrepancies l Modeling Input, or Calculation Error 745 Modeling or Engineering Judgment 75 Documentation Discrepancy 195 Q.
The desisjn process for small bore piping presents a large number of ,
opportun' ties for the support designer to err in both the analysis and documentation of that analysis. On the other hand, the design process provides sufficient conservatism to assure that such deficiencies do not result in supports that do not meet licensing criteria. An extensive review program of the documentation for the design of pipe supports was conducted.
The results of this program demonstrate that, while the level of documentation.
of these calculations should have been better, the small bore piping supports are adequate and met design requirements when the documentation discrepancies were corrected.
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The NRC raised questions about the placement of new restraints IRC Question:
aajacent to old restraints as a means of qualifying the old restraints (Allegation 88. SSER 21).
Response
. .Ilow pipe supports were added to small bore piping forcases In some many reasons; these
. aset code break, valve acceleration, or thermal criteria.This approach would
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new supports were located near existing supports. The obviously have the effect of reducing loads on the existing supports.
small bore piping program was explicitly conducted to ensurewhere that all supports met the licensing criteria. In some cases, conditions were modeled For example,a structural restraint that was not a pipe support was present.
there restraint.
are several instances in which a penetration was or restraint physically existed in the plant or a new support point wasIf a new modeled in the stress analysis calculation. documentation numb throughout the desigjn, construction, as-building, and final engineering approval cycle. Thts documentation trail ensures that the support is constructed in accordance with the design.
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-is-CC
The RC raised questions about snubbers located adjacent to RC Cuestion:
rig m restraints being inoperative during dynamic loading (Allegation 88 SSER 21). This question was discussed further by Mr. Yin at the public meeting held on January 31, 1984.
l
Response
l
. During a site visit, the RC identified 16 snubbers that Therewerewaslocated concern in close that
' proximity to rigid restraints (proximity restraints).in the event of a snubber from actuating. The *1ost motion" or dead band", resulting from mechnical clearances in the snubber, must be overcome before the snubber will These clearareces are typically very saali and a begin to restrain the piping. review of the test results for the Diablo snubbers band of 0.021 inches (roughly the thickness of 5 sheets of paper).
We agree that there are snubbers located in close proximity to rigid It has restraints at Diablo Canyon just as there are at other nuclear plants.
been industry practice to ignore the dead band when perform analysis.by the small dead band described above are not sufficient to affect the results of the seismic analysis. Further, seismic stress is induced in a piping system only when large movements of the piping occur relative to the building structure. If the piping is allowed to move 0.021 inches, the It is recognized that induced stresses will be of an insignificant nature. i loads on pipe supports may change.
Q Therefore, in order to address the potential changes in pipin(I stresses and support loads and to provide assurance to the RC that there ndicating the coupletion or approval
' original assigned analysts.
date, the informal log was never. updated to reflect the reassignment of the calculations to tha new analysts ar.J checkers. The informal log was not, l however, the record calculation index ot master log, but rather a management tool which we.s not required to indicate- the information contained in the master lof. .
D Both the calculation index and the master log properly decumented the approved calculations for W -988 and MP-944. In accordance with applicable procedures, calculations are not indexed in the calculation'index or logged on the master :
- log until they are approved. Because the original calculations had never been '
approved they were,neither indexed in the calculation index nor logged on the master log. Thus; in neither case were official calculations, nor calculations "necessary to support and verify final design," destroyed.
l Based on comments unde by the NRC. Staff at the January 31, 1984 public i meeting, Allegation 55 seems to be Wased'on two calculations. W -072 and W-345. Calculation 2-072. Rev. O, analyzed hanger 2171-16 and showed that a U-bolt would be overstressed. The originator suggested the use of a cut plate bracket instead of a U-bolt. The recommenced design modification was checked and approved according to written procedures. Prior to issuance for construction, the stress analysis was redone and new loads were issued. An )
analyst was given the hanger to review. Our investigation has not positively -
determined who wrote the phrase "too costly to fabricate" on the original design but?it is believed it was the analyst who also did Rev.1 of the calculations which also indicated overstress of the U-bolt. Thereafter, Rev.
2 of the calculations was performed analyzing the' support showing an angle iron ip lieu of the U-bolt. This analysis was also performed by the original j analyst. The'caleslation was checked, approved, and issued for construction.
During construction the support was further modified and an as-built was t
issuedAyConstruction. Our That as-built condition was approved pursuant to appifcable procedures. review indicates that all design and construction settvities concerning W-072 set all procedural requirements and criteria.
4 e
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2182-74. The originator of on to the support because the
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The second calculation. W-345, analyzed hanterthis 049243. Rev. 11. calculation The axial thermal movement exceeded that allowed by drawing oad. The group leader support was otherwise capable of accepting the piping L approved the calculation as " preliminary" without modification, but not the end of the calculation that a modification was not requiredThis duenote to an insignificant uploading in the support (less than 45 of allowab
'" was signed and dated.
049243, which would support his decision.
of a pending revision to drawing Thus, the calculation indicated the design adequacy 049243.ofThis the hanger in accordance with the to-be-approved revision In each of of dra revised drawing and was then approved.
" altered current documentation" in our review of this calculatio l
the above instances there was some initial iteration with applicable procedures.
In conclusion, our analysis of Allegations 55 and 87 any instances of alteration of documentation in the pejorative sense.
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i MC Ouestion: The RC has raised questions about the extent and timeliness of O training of onsite pipe support engineers (Allegation 82. SSER 21). Concern was also raised that the responsibility and authority of small bore piping 1
Y group personnel did not appear to have been de11 nested in writing.
I Response :
i ; s. The Project provides formal training in the Engineering Manual Procedures ,
- ('EW") which implements Project QA requirements. Those requirements meet QA '
Criterion II of 10 CFR 50. Appendix B, and are set forth in Nuclear Quality ,
Assurance Manual. ("NQAM") and Bechtel quality Topical Report, Rev. 3A i
("BQ-TOP-1") which has been approved by the NRC for the Project. Each ;
engineer assigned nuclear safety related work receives indoctrination and '
training in EMP in accordance with Procedure 2.1 of that manual. This course i
for the engineers identifies and describes the procedures applicable to their ;
work. It includes a review of procedures on design criteria memoranda, design calculations, design changes, drawing control, discrepancy reports and l
nonconformance reports. .
PEI-15 specifies that the indoctrination and training are to be given within !
30 days of assignment to the Project. Training records indicate that approximately 705 of all OPEG design engineers on the current OPEG roster received Eaqineering Manual training within 30 days of assignment as :
required. Approximately 955 received such training within four months of I assignment. The majority of those instances where an engineer did not receive '
training within 30 days of assignment occurred early in the Project. Project Audit 28.4 conducted in February 1983 and closed in May 1983, resulted in the correction of most of these discrepancies. Since May 1983, only five OPEG pQ design engineers have exceeded the 30-day training requirement by more than a few weeks. As 1005 compliance is required, administrative changes are being made to assure that all engineers receive required indoctrination and training j within the prescribed times.
The training program covered by DE' 2.1 is consistent with QA Criteron II and is directed at the process of design control, design change, design calculation, discrepancy and nonconfonnance procedures. EMP 2.1 1s not addressed to the professional qualification of engineers and designers, and therefore does not encompass'the technical education necessary to enable an engineer to properly perform design work. To ensure technical competence, pipe support engineers are hired in large part on the basis of interviews, <
educational qualifications, and previous experience. For permanent or temporary employees, the professional credentials of all are required to be verified by either the Personnel Departments of 8echtel or PGandE. For contract employees, such verification is a contractual Areovirement thorough review for the of the contract fire. This process is detailed in Table I.
engineer's work experience is confirmed through technical interviews conducted by senior Engineering personnel. Additionally, tha engineer's first assignments are carefully selected to provide an adequate opportunity for the designer to gain familiarity with project calculation format and methods, and 34 i
his work is closely monitored to assess the designer's capabilities. Future -
assignments are determined on the basis of assessing the engineer's O performance on these early assignments.
A review of the technical background of the engineers in the small bore pipe support group at the site shows that experienced, technically qualified
. engineers had been hired, with little or no need for additional instruction in small bore piping calculations other than that normally provided to familiarize them with the proper design criteria and Project calculational ;
methodology. Of all the pipe support engineers employed at OPEG, more than Most of 415 (36) had greater than five years of nuclear related experience. I the engineers had worked on two or more other nuclear power projects, with many having worked on five or more plants. All have at least a BS in i Engineering or equivalent, and their minimum professional experience is one '
year, the maximum professional experience is 14.5 years, and the average professional experience is greater than five years.
In SSER 21 (Allegation 82), the Staff identified five individual engineers who ;
had not received procedural training within 30 days of commencement of their assignment as required by PEI-15. The project has reviewed the work of those individuals along with all of the pipe support engineers. The apparent discrepancies in calculations that are currently being reviewed are being correlsted with indoctrination and training coupletion dates for persons For each such originating and checking the discrepancy checked to date (questioned calculations.the 23 St completed the QA orientation program prior to approval of the final ,
calculation under review. t While some individuals did not receive indoctrination and 1rocedure training within the 30 day specified period, the records indicate tiat the discrepancies in calculations that have been observed are not related to l either indoctrination and training or professional experience, but rather are !
random events. Consequently, the delayed completion for the training of a few design support engineers does not appear to relate to the discrepancies detected.
In order to better implement Project training requirements, the Project proposes the following new actions for OPEG:
1
- 1. Training records of all entlineering personnel working on the Project have smediately, any person who currently does not been reviewed. Effective <
have the required training in QA and engineering procedures will not be allowed to continue engineering design work until such training is completed.
. .t
- 2. Weekly training sessions in QA/ Engineering procedures will beginA immediately to train new arrivals.
three times a year for all engineering personnel who complete or who have coupleted QA/ Engineering procedures.
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- 3. No person newly assigned to OPEG will be permitted to perform, check, or i= i *$ a atii *a aa'sasia ria' ar d r *r $aias a =
O aaar been coupleted.
ax
- 4. Failure to complete a refresher course within 30 days of requirement will 4
disqualify an engineer from performing, checking, or approving any ;
l calculation. ,
- 5. All training personnel will utilize a formal syllabus which shall be l - reviewed and approved by engineering and QA management. Initially, the training sessions shall be monitored by engineering and QA management to assure that required matters are properly addressed. Training sessions will give special attention to changes in procedures that have been implemented in the last year.
- 6. All such training requirements will be formalized and documented, and compliance will be verified by QA audits.
Concern also has been raised that the responsibility and authority of small l bore piping group personnel did not appear to have been delineated in writing. The small bore piping design group personnel authority and duties are delineated in writing throu0h the DCP QA Program, procedures applicable to the engineering work, and organ' zation charts.
OPEG is an extension of the home office project engineering organization which is located in a different geographical area. This relationship is defined in the DCP Nuclear Quality Assurance Manual (NQAM) Section 1 No. 7. As part of the project engineering team. OPEG carries out the Engineering Department's (Q responsibilities outlined in NQAM Section 1 No. 7. as directed by the Project Engineer to whom 0 PEG reports (Reference NQAM Section I No.1. Figure 7).
The specific duties, responsibilities, and authority of WEG at The the Diablo Canyon jobsite are delineated in procedure PEI No. 9. Rev. O.
accomplishment of these duties and responsibilities is delegated through the organizational chain from the Onsite Project Engineer / Assistant Onsite Project Engineer to lead discipline engineers, then to the discipline group engineers. Assignment of these duties and responsibilities is made by the OPE /A0PE and lead discipline engineers. The organizational chain within OPEG is defined both in PEI No. g and in a written organization chart maintained by the Onsite Project Engineer.
The authority and duties of personnel shown on the established organization chart are delineated in writing as follows:
a? Onsite Project Engineer /Onsite Assistant Project Engineer responsibilities and authorities are defined in PEI N0. 9 Paragraphs 3.3 and 3.4. Signature authority of the OPE /0 APE is defined in PEI No. 9 paragraph 4.3, and responsibility for
-4 ...
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_ _ _ _ _ ____ - -_ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ __ . _ _ _ _J
i approval of design changes initiated by GPEG is defined in PEI No. 9, 9, paray aph 4.2.4. Additional duties are defined in other procedures app 1' cable to design of piping and piping supports, consisting of Engineering Manual procedures; Piping Group controlled Procedures, Instructions and Criteria; and Project Engineer's Instruction '
(Reference PEI No. g. Paragraph 4.2.1).
Lead Discipline Engineers are jobsite r eseNatives from the Home
-[. b.
Office Engineering Group Supervisors (E . The Lead Discipline Engineers receive technical direction from the Home OfficeThese EGS and administrative direction from the Onsite Project Engineer.
authorities and responsibilities are documented in PEI No. 9 Paragraph 3.5. Authority for sign-off of OPEG originated design changes is documented in PEI No. 9. Paragraph 4.2.4.
In representing the EGS for activities within OPEG's scope, additional duties of the EGS/ Lead Discipline Engineer are defined in other procedures applicable to design Forofexample.
piping and piping Engineering supports as listed in item (a) aboya.
Manual Procedure 3.3 Rev. 5 and Piping Procedure P-6 Rev. 2 require l the engineering discipline group leader or Forsupervisor OPEG pipetosupport approve design calculations for pipe supports.
calculations, the Lead Discipline Engineer has this duty as i
described above.
- c. Area Leaders and Squad Leaders are responsible to assist the Lead Discipline Engineer in the performance of his duties and to work under his direction. This organizational responsibility is
' O delineated in the OPEG organization chart.
- d. OPEG engineers work under the direction of the Lead Discipline All work ~
Engineer as defined in the OPEG Theorganization discipline char supervised by the Lead Discipline Engineer.
engineers do not have any other authority and duties except to follow the direction of the Lead Discipline Engineer inTheir spe i accomplishing the assigned task. !
duties with respect to assigned tasks are delineated in the The procedures applicable to !
procedures that apply to their work. l design of piping and pipe supports are defined in PEI No. 9 For example, an engineer assigned to check a
, Paragraph 4.2.1. calculation has authority to recuire r.orrections to as delineated in Engineer Manual Procedure 3.3, Paragraph 4.2.6,
- and he has the duty to perform checking in accordance with Engineering Manual Procedure 3.3, Paragraph 4.2.2.
The more general authorities and dutiesGenerally., expected and delineated in accordance with established Bechtel practices.
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they cover three categories of personnel: (1) permanent employees. (2) contract (job shop) personnel, and (3) temporary personnel. The process for each is suemarized in Table I.
In light of the foregoing, it is evident that the onsite small bore piping design group authority and duties are established, and are described in witing to the extent necessary to fulfill the requirements of Criterion I to 10 CFR Part 50, Appendix B.
Attachments:
Table I Attachment A - Example Job Description
'O S
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i TABLE I r A. Permanent Personnel
- 1. Opening is identified and and related to Job Description (e.g.,
Attachment A), by Project.
- 2. Chief Engineer either provides a proven indivihal from elsewhere U ' in the organization, or finds a new employee through Personnel Department. ,
- 3. In hiring a new employee, the Chief Engineer makes selection based upon personal interviews, reviews of experience and educational background, other credentials, and as much inquiries of former employers or supervisors as he can make.
- 4. After hire, the Personnel Department confims key parts of esployment and educational background to the extent practical. ,
- 5. Three (3) months after hire, the employee is given a formal performance evaluation, followed by another in nine (9) months, and thereafter one every twelve (12) months or upon change of supervisor.
- 5. Contract (job shop) Personnel
- 1. Same as A-1, above.
- 2. Chief Engineer requests Personnel Department to have contract agencies provide resources of candidates.
- 3. Chief Engineer reviews resumes, conducts interviews, and selects most suitable candidates (typically one out of eight candidates).
- 4. Personnel Department executes agreement with contract agency to provide selected personnel, which includes responsibility of contract agency for accuracy of background infomation and ,
credentials. l l
- 5. Personnel are initially indoctrinated and closely supervised. They I are also periodically ranked, and those with lowest rankings are replaced.
C. Temporary Personnel
- 1. Same as A-1.
- 2. Chief Engineer identifies personnel for temporary status from among contract personnel, having made selection as above.
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- ATTACHMENT - A
. JOB DESCRIPTION (Example)
'tros muunsa ovem com 7ms 300A,190A EST
/ SENIOR ENGINEER
=
-.wv as, M
en.
ENGINEERING SUPERVISOR spective enti ennamannon July 5,1988 ENGINEERING -mucas sanommon enveo OE7 ICE ENGINEERING SUROSAR1f:
Mens and conducts independent work requer',no lodgment in the evolustion, essection, ap engineering techniques, procedures and criteria. Devises new approaches to problems.
Por salary grade determination, ese attached addendum.
JOB DEMENSIONS: J A. L t'n Resolved
- Performs most assignments independently with instruction proposed project plans. .
- s. Supervleien Eaereined
- Provides technical direction and assigns work to engineers, desleners, drafters, techn performing specific assignments, however is not responsible for statt planning or salary acti I
C. Contacts
- Independently contacts vendort m,,,x:v,atives and project field personnel to Gather o g ellent counterparts as alrected.
PRINCIPAL RESPONSIBILITIES:
- 1. Plans, schedules, conducts, and coordinates detalled phases of oneineering work u or etaff group. Performs work which involves conventional e requirements. *
- 2. Plans, ocordinates or prepares equipment or work apacifications, bid evaluations equipment.
- 3. Coordinates engineering efforts in assigned areas between specialty and other en the silent, supp46ers, and contractors and between other divisional groups-
- 4. When delegated, assumes a lead role over oiher en0ineers or project aut> groups fo S. Aeslots in on the job training of assigned personnel and provides input for their performa S. Prepares letters to vendors and cI6ents.
- 7. Reviews bid analyses and makes recommendations.
S. Prepares or assists in preparation of conceptual studies, designe, reports or proposals.
- 9. Performs or assists in the performance of problem analysis and original design.
- 10. Reviews project'aontrols, cost estimates, quantity take offin and manpower r ehenes onsors.
- 11. Reviews and checks work of subondinate engineers.
JOS ENOW 12DGE i A thorough knoudedge of entineerin0 tecimiques, the design of RJnN systems tions. A locad knowledge of the application of engineering to plant constructab meterials. Up40<lete knowledge of computer applications to engineering and d
.' pienning and control methods includin0 computerland methods.A technical areas.
A knoededge of reisted construction practices and the economics involved l
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m'aoveo se ennes mu N. M
~
SENIOR ENGINEER A current knowledge of industry or regulstry standards and design ortteria pertinent to the pa socipline.
skm in oral and written communicetion.
The above is normally acquired tfwough e A recognized degree in an engineering or scientific decipline from an accreated college o OR d
e A ,,; :::': . : license in an appropriate engineering Wacipline from a recognized licensing b OR
- Sufficient number of specialized courses in relevant general engineering or appropriate eng meet job requirements.
AND d types of engineering e Practical work experience in design engineering or relevant equ!valant experience in allie sufficient to demonstrate competence as a trained engineer.
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o a m ovso em.am enam ON SENIOR ENGINEER g, g ADDENDUM Salary Grade Determination for SENIOR ENGINEER Grade 5 Mans ano coordinates Independent work requiring judgment and experience in the application and substantial adapta of engineering techniques. Devises new approaches to technical problems.
Provides technical direction for specific tasks and assigns work to subordinate senior engineers, engineers, designers drafters or project sut> groups Requires experience and demonstrated skill in handling professional work M tM grade 5 IW and a M Ww precedents in the industry.
Grade N Mans and conducts independent work requiring judgment in the application of engineering techniques. Normally conventional approaches to technical problems encountered.
Prov6 des technical direction and assigns work to engineers, designers, and drafters who aeslet on specific assi f
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IstC Question: The NRC raised questions about various aspects of document control for small bore pipe support design (Allegations 55, 79 and 84. SSER Q 21).
Response ,
w The DCP QA Program requires formal control of implementing procedures.
Detailed requirements are contained in Engineering Manual Procedure 5.2.
Implementing procedures are required to be logged into a control system by ,
title, date of approval'and revision number. All holders of implementing procedures are required to formally acknowledge receipt of revisions by -
returning a signed acknowledgement.
Special implementing procedures, instructions and criteria for the small bore piping design verification effort were authored by the Project Team Piping Group, and the control of their distribution was managed by the Project Administration Group using a system of signed, returned receipts.
A master document distribution matrix was prepared to establish which manual holders receive specific documents in accordance with the requirements of their job assignment. A specific set of defined documents is assigned to a pipe support engineer; a different set of documents is assigned to a pipe stress engineer $ and so forth.
a) Out-of-date Procedures The staff identified three instances of out-of-date procedures contained
^= = r ==it-(O. within the coatro11 4 Proc dur ==a==is ==5at fa d la th orca a discrepancy report (DR 83-47-5) was issued by Project Engineering. This DR addresses corrective action, impact on final design and actions to prevent reoccurrence.
A 1005 review of all control procedures, instructions and criteria assigned to OPEG personnel was coupleted by December 15, 1983. Sixty-three (63) manuals containing 133 criteria documents 412 procedures and 451 instructions were reviewed. The results showed that 905 of the documents assigned to the -
manuals were correctly in place. The review results have been evaluated to determine the possible impact on the small bore reverification work. Most of the instances found involved documents missing from certain controlled manuals, in which case the appropriate requirements are available to the j engineer through other controlled annuals in the work area. Each instance of an outdated procedure or instruction was evaluated and determined to not impact the completed design work. The documents found to be outdated were characteristically documents that the assigned manual holder would not be using irIperforming his specific assignments.
I All 63 controlled manuals have been brouilht up to date. They now contain only l current copi" of those documents specif<ed by the easter document distribution matrix..
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l The Staff also expressed the concern that since Piping Procedure Manual B-075 was presumably the only controlled manual assigned to the OPEG Stress Group, there was a possibility that Stress Group engineers had been without access to l edures for an extended period of time. However, our up-to-date investigati has shown that other controlled copies of the manual had been i
assigned er available to members of the Stress Group since the inception of the WEG gh oup. For example, the October 14, 1982 Distribution List for Piping Grob Presedures Instructions and Criteria for Diablo Piping Design shows thatV 1 members of the Stress group were assigned controlled manuals.
Although number of manuals assigned to the Stress Group has varied, at no time were there less than three controlled manuals assigned to this Group.
On a broader level, the Sta'ff concern relates to Allegation 84 in SSER 21 dealing with lack of management responsiveness to an engineer's recuest for a copy of controlled design procedures. The allegation was discussec. and resolved in SSER 21, with the Staff concluding that the
- spirit of the allegation was substantiated" and that "manarament must improve its i
sensitivity in addressing safety concerns and improve commiunication with workers." In late 1982, there was an acknowledged shortage of copies of the manual, such that all engineers did not have individual copies. However, sufficient numbers of the controlled documents were avaffable as discussed above and the engineers were able, and required, to use them. Additional copies have subsequently been made available, consistent with the goal of avoiding unnecessary complications in document control due to the distribution of more copies than necessary to accomplish the work.
' h.
V Because the controlled design documents were, in fact, available to the alleging engineer, there was no violation of procedures or adverse affect on the small bore piping analyzed. Nevertheless the Project has perceived the desirability of improvement in this area, and,has taken several actions toward this end:
- 1. Document Control Procedures and practices are being reviewed with onsite
. Engineering personnel. They have been notified of the importance of complying with document control procedures and of their responsibility to update manuals and return acknowledgement forms.
- 2. Procedure P-1 was revised in Rev. 4 dated January 30, 1984 to require a monthly supervisory review of controlled manuals to assure that procedures, instructions and criteria are kept current. ,
- 3. For future revisions to design procedures, the supervisor will discuss the content of the revision with engineers under his supervision to be sure everyone is aware of changes and how they are to be implemented.
Alternatively, procedure changes which are now routed to all manual holders will be formally routed to all engineers and will require an acknowledgment signature.
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Also as a part of the resolution of DR 83-047-5, the possible effect of outdated design criteria doceents on the final design has been reviewed. j l
There were no instances found of out-of-date. criteria in the manuals. All l individuals, including those missing criteria documents, had access to current '
controlled copies of applicable criteria in order to correctly perform their design work. ,,
As a separate effort, a Project QA review of configuration control of otiher manuals at OPEG (i.e., Engineering Manual. PEls) has been coupleted. No deficiences were identified in this review. .
, b) Use of External Documents The staff questioned whether references, such as the following, in tha possesion of Pipe Support Engineering personnel were used in lieu of approved
- work procedures:
o An ION dated March 21, 1983 " Guidelines for Calculating Design of Skewed Welds" o Westinghouse Nuclear Technology Division Data for calculating double cantilever supports o Bechtel GPD STRUDt. II Computer Program Users Manual CE-901 November 3, 1983 o Bechtel GPD 10tl dated Novesbar 11, 1980, "GPD Pipe Support Newsletter No. 5. Beta Angle" o Control Data Corporation (CDC) Bechwl National Support Manager to Civil / Structural Projects staff " Baseplate II User Aids." ,
o Midland " Pipe Deflection Formula" o UE & C Pipe Support Design Standard, August 15, 1979.
Experienced engineers commonly have general reference material as a part of their personal and professional library. This type of material includes textbooks and handbooks, and typically provides standard formulas and tables, code discussions, example calculations, rules of thueb and other simpilfied, conservative methods in common use in the industry. As general reference material, they are not controlled and do not constitute acceptance criteria.
Project Engineering Procedures (E!9-3.3) provide for the use of references j such as textbooks, catalogs, monographs and other such accepted industry techniques in specific calculations. The reference must be documented when necessary to provide details of the design sufficient to allow independent revieu. In such cases, it is required that they bo documented as formal references with the calculation in which they are used. Their use then is l
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checked and approved via the calculation review and approval process. In the future, approvals of this material will be provided where general project standardization in their use is applicable. These materials will se formalized, controlled, and included in procedures manuals with appropriate instructions, qualifications and limitations. ..
De above identified documents are references of the type normally found in an We know of no instances where the exterienced engineer's references were improperly used. personal library.In one instance, a non-project document was referenced asItthe source of a double cantilever deflection formula used in a was a standard engineering fonsula, not unique to any calculation.
particular project, and need not have been referenced in the calculation.
c) Out-of-date Procedure Listings The staff also noted an instance of out of date procedure listings. An occurrence was observed where a controlled manual Table of Contents dated October 28, 1983 was in the possession of the Onsite Project Engineer, while other supervisors had the previous version dated September 15, 1983.
This specific instance, ironically, resulted from management's efforts to improve the methods for distribution of revisions to controlled manuals.
Distribution of the October 28, 1983 revision was held by the Onsite Project Engineer upon receipt for two weeks while these improvements were being formulated. The revised practices have since been incorporated into Piping
(' Procedure P-1.
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The NRC questioned whether the use of interoffice memoranda O
L IEtC Question:
1ssued oy sne Project may have reflected inadequate design change procedures.
Response
. .:The Project has in place formal procedures for requesting and. approving design
< e anges. These procedures do not peraft design changes to be made on the
basis of an interoffice memorandum (IOM). The lutC's concern apparently As discussed
, relates to two identified IDMs issued by Project Engineering.
below, however, neither of the two memoranda constituted design changes.
The first ION involved the use of the welding code (AWS) for calculation of skewed welds. The Pipe Support Group Superv'sor issued an IOM dated March 21, ,
1983, for the purpose of providing guidance in modeling skewed welds in l The 10M did not change any design documents, nor confonaance with the code. i did it violate either good engineering precepts or approved QA procedures or requirements.
The second IOM of concern to the Staff was an 10M issued by Engineering on ,
October 20, 1983, to General Construction, approving a request to revise a contractor's installation procedure. The change involved installation tolerances in the contractor's procedures which had been previously approved by Project Engineering in accordance with Project procedures for approval of contractor documents. General Construction and the contractor formally )
executed the change. Neither the request nor the ION approving the change
' resulted in a change in the Project's approved design drawings or (O =eecific inapplicable. tions. **==. tae <>>= nce of e Oesiin ca nie notice w = Proje the change in the contractor's procedures, were consistent with Project procedures for review, approval, and amendment of contractor documents.
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The NRC noted that design input had been received via telephone Os istC Question:
ana usea wunout written confirmation.
Response
Engineering Manual Procedure 6.1, Section 4.4, specifically provides If that the all design information provided verbally must be confirmed in writing.
data are used prior to such confirmation, the calculations must be marked This
" preliminary," and cannot be finally approved without such confirmation.
requirement is an additional measure to assure that preliminary data are confirmed before the calculations are reviewed for final approval.
The calculations for Support 2156-200 noted the use of input loads received via telephone, but the originator failed to mark the calculation
" preliminary". When written confirmation of the input loads was was The calculation received and performed compared to the input used, an error was noted.
again with correct inputs, and the support design remained acceptable.
Investipationandreviewofpastauditsshowthisoccurrencetobeanisolated ch was clearly in violation of the engineering procedures.
case wh O
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nac ouestion: The nac has ex ressed a concern that errors detected in severai calculations which had been elecked and approved may indicate that checking l has not been properly performed.
Response
7 tie nature and significance of the errors found have been previously
' discussed. The broad responsibility of the checker is to assure that the calculation is sufficiently accurate and sufficiently free of errors to serve its intended pur mse, i.e., to document that the support meets the design requirements. Tie minor nature of the errors detected and the fact that the calculations in question were corrected and still demonstrate support acceptability is a strong indication of the overall adequacy of the checking
- function.
Notwithstanding such a conclusion, the Project wishes to dispel the implication that discrepancies are " allowed" to exist or somehow disregarded, evn though upon further analysis they do not affect the design adequacy.
Therefore, two actions are underway and will be coupleted by March 1, 1984. ;
First, it will be re-emphasized to Engineering personnel in writing, that calculational and documentation discrepancies will be dealt with seriously.
t Originators of documents are responsible for eliminating discrepancies. ,
Accordingly, they may not depend on the checker to accomplish this.
Second, recognizing that, in some cases, it is not economically justifiable to reperform an extensive calculation because of a discrepancy which will not affect the results or conclusions derived from the results, the Engineering Procedure on calculations will be modified. This modification will require that if the checker of a calculation detects an error which, in his judgment, can be classified as described above, the checker will identify the error, designate it as such, and initial the designation. This action is consistent with the requirements of ANSI M45.2.11-1974 which requires that analyses be sufficiently detailed that an experienced person can review them and accept the results without recourse to the originator.
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Oy isic ouestion: The NaC has raised a auestiaa renardini ticensee techaicai oA avaits and surveillances with respect to the saal1 bore piping support program.
Response _ l the NRC has l In implementing Criterion XVIII of 10 CFR Part 50, Appendix 5 endorsel ,
document provides requirmeents and guidance for establishing a system of audits of quality assurance programs, and provides definition of various types of audits. Criterion XVIII mandates audits to verify compliance with the QA program and to determine its effectiveness. None of the above-cited references establish requirements for the performance of technical g audits.
I On the Diablo Canyon Project, QA audits are conducted (in fulfillment of
. Ifeensing commitments) to verify compliance with the project quality assurance program requirements.
)
The Project audit program has been developed and implemented to comply with requirements of the Project Nuclear Quality Assurance Manual. This program, la turn, has been approved as being in compliance with Project requirements and Criterion XVIII of Appendix 5. It calls for a system of audits, the scope of which has been widely accepted in the nuclear industry, to assure that the QA program is properly functioning. Relative to the OPEG group, this audit scope has included all the major areas of design activity such as control of calculations, control of desi n drawin , indoctrination and training, and design change control. In ad ition P ndE, as the licensee, has conducted a series of Activity Audits covering 0 PEG activities.
Since 1982 there have been some nineteen (19) audits of OPEG to verify )
compliance with Project QA requirements. Closecut and corrective actions related to audits is documented in the Project audit files.
The verification of technical requirements in design output documents is performed by Engineering as part of the design control process. The type of '
verification can vary from csecking to independent review by the Chief Engineer or an outside agency, depending on the significance of the document.
Specifically, reference is made to Procedure No. 3.4 (Design Verification),
. Procedure No. 3.11 (Computer Programs), and other procedures related to specific design documents (e.0., design calculations and drawings). These are all the responsibility of Eng neering, are part of the design control process, and are subject to Quality Assurance audit.
WhiletheProject'sauditprogramisinfullcompliancewithQAreguirements in implementation of Criterion XVIII, we believe that there is merat to the suggestion of formal, technical audits for OPEG. It is therefore planned that a program of such audits will be immediately developed for OPEG, on the
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personnel (for technical aspects) and of QA personnel (for proce****"" ' '"'" ' " dural ;
aspects).
o The audits will be formally conducted and fully documented. They will
- include all the features normally associated with QA program audit?, such
, . . as entrance / exit meetings, checklists, and reports to management.
o The initial audits will give special attention to those areas of most sophisticated analysis, use and understanding of codes, use and understanding of computer programs, independent checking, and technical review of conventional work.
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O L PROFESSIONAL QUALIFICATIONS OF RICHARD C. ANDERSON My nane is Richard C. Anderson. I an the Engineering Manager in the Diablo Canyon integrated project organization consisting of Pacific Gas and Electric Conpany and Bechtel Power Corporation employees. I an a Registered Mechanical and Nuclear Engineer in the State of California. I hold a BS degree in Mechanical Engineering fron the University of California at Berkeley.
I have been with Bechtel for nore than 26 years and for five years was assigned as an Engineering Manager in Bechtel's San Francisco Power O oivision, res,onsihie for engineering wore in the Pacific Northwest and Japan. I have been assigned since March 1982 specifically to the Diablo Canyon Project to act as the Project's Engineering Manager. Prior to these Engineering Manager assignnents. I was the Chief Nuclear /Environnental Engineer for Bechtel's San Francisco Power Division, involved in nuclear power plant design, safety, and operation.
Prior to that, I was assigned as an Assistant Project Engineer on a proposed nuclear power plant project for PGandE and as Mechanical Group SLpervisor, and later Project Engineer, on another large nuclear power plant project in the United States. These assignments ir...uded supervision and coordination of design, specification, procurement, and quality control activities.
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\ I also served as Senior Mechanical Engineer for various other nuclear power facility projects in the United States and abroad, which included work in systens, safety, and equipment engineering.
I have been an instructor in Bechtel's power plant courses for over 10 years and have given nunerous talks and lectures in California on nuclear power and energy issues.
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' PROFESSICNAL QUALIFICATIONS OF FRED C. BREISMEISTER My name is Fred C. Breisneister. I an Manager of the Research and Engineering / Materials and Quality Services (MAQS) group in Bechtel's San Francisco Area Office. _In this position I supervise and provide consulting services to the Diablo Canyon Project. I an a Registered Professional Quality Engineer in California.
My educational background is as follows: BS,1962, and MS,1964, in Metallurgical Engineering, Rensselaer Polytechnic Institute, New York.
Prior to my duties as Manager in M&QS, I was supervisor of the Welding Engineering Section, where I was responsible for the development and technical content of Bechtel welding procedures and field fabrication standards, as well as technical support and airection to engineering and construction regarding welding, heat treatment, fabrication, inspection, and code problens.
I joined Bechtel in 1972 as a Metallurgical / Welding Engineer. I an an AWS D1.1 Certified Welding Inspector and a member of the American Welding Society, the Structural Welding Code Subconnittees 2 and 3, and the Preheat 1
Task Force and Toughness Testing Task Group.
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O PROFESSIONAL QUALIFICATIONS OF EDWARD M. BURNS l
l My name is Edward M. Burns. My business address is Westinghouse Electric Corporation, P.O. Box 355, Pittsburgh, Pennsylvania,15230. I an employed as a Lead Engineer within the Nuclear Safety Department of the Nuclear Technology Division.
From 1967 through 1971, I attended the Milwaukee School of Engineering and received a Bachelor of Science Degree in Mechanical Engineering. Following graduation I entered the United States Army and served O a ealistea a. 'ieutea at aa c Pt ia t = ver 1 1ac tiaas withia the United States and Europe. Fron March 1977 to August 1979, I served with the US Army Amor and Engineer Board as a project officer responsible for the planning, conduct, analysis and reporting of operational tests of ground nobility, equipment, and ordnance.
I enrolled in 1977 in the University of Southern California night school progran and received in March 1979 a Master of Science Degree in Systems Management. On leaving the Army in September 1979, I attended the University of Wisconsin and received a Master of Science Degree in Nuclear Engineering in Decenber 1980. Additionally, from May to December 1980, I worked as assistant to the head of the University of Wisconsin Fusion Studies Progran. In this capacity, I was responsible for coordinating parametric l O stuai = <aPut <ar coac Pt i h vr iaa h a <=>iaa reactor-l 1270A
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O Following graduation, I was employed by Westinghouse ~ Elect"ic Corporation in the Nuclear Safety Department. From initial employnent to Novenber 1983, I was a Senior Licensing Engineer, responsible for evaluating the compliance of engineered safeguards fluid systems and components with applicable safety and design criteria. Specifically, I reviewed the implenentation of cold shutdown design improvements for five domestic and three foreign nuclear power plants. During this period, I also acted as the Westinghouse coordinator of licensing and safety activities related to the US NRC draft Regulatory Guide 1.139 and Unresolved Safety Issue A-45 prograns.
In December 1983, I was promoted to my current position of Lead Engineer, responsible for coordinating licensing services in support of O nuclear power plants.
I an a menber of the Anerican Nuclear Society and the Anerican Society of Mechanical Engineers.
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O eaoresstoaa' ouatir1carioas or DANIEL J. CURTIS l l
My name is Daniel J. Curtis. I an a Onsite Project Engineering Group (OPEG) Plant Design Group Supervisor for the Diablo Canyon Power Plant. I have held the position since November 1983. My responsibilities have included the supervision of the small bore piping qualification activities at the Diablo Canyon Jobsite under the technical direction of the San Francisco hone I office. Small bore piping qualification activities include snall bore pipe stress analysis, small bore pipe support design, and piping isometric approval. I am a Registered Professional Civil Engineer in the State of !
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My educational background is a follows: BS in Civil Engineering, 1973, California State University, Chico.
I joined Pacific Gas and Electric in January 1974. From January 1974 to March 1976 I worked in the Design Drafting Departnent perfoming structural analysis and design of miscellaneous structures. From March 1976 to June 1980 I was assigned to the Mechanical and Nuclear Engineering Departnent. Duties have included review and approval of pipe supports, developing design criteria for supports, coordination of work with consultants, ani perfoming piping analyses.
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O In July 1980, I joined Science Applications, Inc. % duties included-the seismic qualification of equipment and perfoming time history and j response spectra analyses of piping.
In February 1981, I joined Bechtel Power Corporation. From I
February 1981 to March 1982 I worked on the Pipe Support Staff. Duties included providing technical assistance to projects, perfoming employee interviews, review and approval of project criterias, and other routine supervisory duties. From March 1982 to November 1983, I worked on the Diablo Canyon Project as the Project Large Bore Pipe Support Group Leader. %
responsibility was the overall supervision of the pipe support calculations being perfomed on-project.
O In November, I was assigned to the Onsite Project Engineering Group.
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l Q PROFESSIONAL QUALIFICATIONS OF KENNETH C. DOSS My nane is Kenneth C. Doss. As an employee of Pacific Gas and Electric Company since 1952, I am currently Senior Nuclear Generator Engineer participating in the systematic and independent review of Diablo Canyon Power Plant activities, which includes the review and evaluation of the technical adequacy of procedures and review and evaluation of design changes and modifications. I an also involved in the evaluation and assessnent of Diablo Canyon's and similar plants' operating experience and perfomance as related to nuclear operating safety.
My educational background is as follows: AS in Electronics, Q
Cuesta College,1969. ,
I joined PGandE in 1952 as a member of a line crew in the Electric Transmission and Distribution Department.
In 1955 I was assigned to the Morro Bay Power Plant as an Instrument Repairman and participated in the Startup of Units 1 and 2.
Subsequent assignments at the plant included Test engineer and Instrunent Maintenance forenan and participation in the startup of Units 3 and 4 and pre-startup check of plant control systems.
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In 1970, I was transferred to the Diablo Canyon Project as a Q
menber of the Diablo Canyon Task Force engaged in ,startup preparation vork at Humboldt Bay. ,/ '
In 1971 I went to the Project jobsite as Instrument,and Control
, Supervisor and was pronoted as Senior Instrument and Control Supervisor in 1977. .
~
Since Septenber 1977 I have been a Senior,Nu61 ear Generation Engineer Instrunent and Control Supervisor on the Diablo Canyon Onsite Safety Review' Group (OSRG). My. responsibilities included preparation of training naterials fer operators and technicians, including description of training materials for operators and technicians, and instructions for control systens, nuclear instrunentation, and computers. I also participated in specifying test equipment and spare parts supplies for all instrument and control systens.
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PROFESSIONAL QUALIFICATIONS OF O RICHARD D. ETZLER i
i My name is Richard D. Etzler. I am Project Superintendent at Diablo Canyon. I have held this position since September 1978. I an responsible for managing the onsite construction and startup activities at Diablo Canyon.
My educational background is as follows: BS in Mechanical Engineering, California Polytechnic State University,1967.
Prior to my duties as Project Superintendant, I was Resident Mechanical Engineer. I held that position from March 1977 to September 1978.
As Resident Mechanical Engineer, I was responsible for nanaging the nechanical type of construction activities such as installation of piping, ventilation O systens, turbine / generator components and nuclear stean supply system components.
Prior to my duties as Resident Mechanical Engineer, I was a Field Engineer and Group Leader reporting to the Mechanical Resident Engineer. I held this type of position and level of responsibilities fron 1971 to 1977. My responsibilities included supervising installation of the nuclear stean supply and turbine generator systens.
Prior to my duties as a group leader for the Mechanical Resident Engineer, I was a Startup Field Engineer beginning in December 1969. My duties as a Startup Engineer included preparing preoperational startup testing procedures and scheduling tests.
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Prior to my assignnent to Diablo Canyon, I was in training to be O a startup engineer since October 1968. This training included approximately 9 nonths startup experience at the Robert E. Ginna nuclear power plant near Rochester, NY, and 6 weeks, reactor operator training at Westinghouse's Waltz Mill facility near Pittsburgh, PA.
Prior to October 1968, I was a field engineer at PGandE's Round Mountain 500 kV Substation for 3 nonths. Duties included planning construction activities, "as-built" drawings, and assisting in testing components.
My first assignment with PGandE was as a Field Engineer on the Construction of the Moss Landing Power Plant Units 6 and 7. This assignment started in June 1967 and continued to July 1968. My duties included assuring installation of piping systens was in accordance with engineering specifications and drawings.
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PROFESSIONAL QUALIFICATIONS OF
% HOWARD B. FRIEND My name is Howard B. Friend. I have been employed by Sechtel since 1952. Since 1982 I have been employed by Bechtel Power Corporation as Project Completion Manager for the Diablo Canyon Project, an integrated effort between Bechtel Power Corporation and Pacific Gas and Electric Company. My responsibilities include managing the effort required for completion of the renaining services necesary to bring Units 1 and 2 of the power plant into corswrcial operation. The effort includes detemination of manpower and other resources for engineering, ifcensing support, procurement, construction, startup testing, project cost and scheduling and related services, as required. I am a registered P. ,sional Engineer in the State of California.
My educational background is as follows: BS in Mechanical Engineering, Heald Engineering College,1952.
From 1981 to 1982 I was employed by Bechtel as Manager of Projects for the San Francisco Power Division. I also served as Project Manager for the South Texas Project (two 1250 MW pressurized water reactor [PWR] units),
responsible for the takeover of engineering, procurement, construction annagement, and related services.
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Fron 1979 to 1981, I was employed by Bechtel as Manager of Division
\ Engineering. In that position I was responsible for directing all engineering of the San Francisco Power Division, including the design of both fossil-fuel and nuclear power plants. My department was responsible for more than 22 major design projects.
From 1974 to 1979 I was employed by Bechtel as Engineering Manager.
In that capacity, I was responsible for Bowline Units 1 and 2, Skagit Unit 1 Syncrude utility plant and other utilities for the Syncrude Tar Sands Project, among others.
From 1972 to 1974, I was employed by Bechtel as Project Engineer on other major projects, including Peach Botton Units 1, 2, and 3.
s' Earlier assignments covered a variety of fossil-fired and nuclear power plants in supervisory and technical capacities and in field assignments.
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O 1 k PROFESSIONAL QUALIFICATIONS OF l JOHN M. GISCLON i
My name is John M. Giscion. I am the Technical Manager at the Diablo f Canyon Power Plant. I have held this or equivalent positions since February 1979. I an responsible for plant staff review and approval of plant modifications. I an a Registered Professional Mechanical Engineer in Nevada and a Registered Professional Mechanical and Nuclear Engineer in California.
I hold an NRC Senior Reactor Operator's license on Diablo Canyon Unit 1. i My educational background is as follows: BS in Mechanical Engineering, University of Nevada,1961.
\.
After graduating from the University of Nevada, I served four years in the U.S. Navy as an officer. I joined PGandE in 1965 and was assigned to the Pittsburg Power Plant as Engineering Trainee.
In 1966, I was tranferred to Hunbolt Bay Unit 3 with assignnents in nuclear power plant nuclear engineering, testing, and technical operations.
In 1968. I joined Westinghouse Electric Corporation (NRF - Bettis Atonic Power Laboratory) as a Plant Engineer. I held various assignments in maintenance and modification ut equipnent and systens and served as design l
liaison for the liquid radwaste disposal systen.
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( In 1970 I rejoined PGandE and was assigned to Humboldt Bay for startup preparation as a imenber of the Diablo Canyon Task Force. As a member of the Westinghouse startup team I was assigned to the H.8. Robinson Power Plant for three months.
I was a Power Production Engineer (Nuclear) fron 1971 to 1974. I participated in the preparation and review of licensing material for Diablo Canyon Units 1 and 2, including the FSAR, Technical Specifications, equipnent description and operating instructions, testing procedures, a&iinistrative procedures, and operational quality assurance manual.
Prior to sqy current duties as the Technical Manager, I was a Senior O Power Production Engineer (Nuciear) from 1974 to ig79. I ,articipated in the
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startup testing progran and was responsible for supervising a staff of engineers (including persons experienced in nuclear engineering instrumentation, radiation protection, and chemical engineering) engaged in preparation of material required for plant startup, and in perfoming tasks related to startup.
I have completed the following fomal training courses: Reactor Physics for Engineers and Nuclear Reactor Engineering (University of Idaho l NRTS Graduate Education Progran) Nondestructive Testing (General Dynamics /Convair), Nuclear Power Plant Opera.r Simulator Training (Westinghouse Nuclear Training Center, Zion, Illinois), Diablo Canyon Design Lecture Series and Station Nuclear Engineering Applications (Westinghouse),
and Management for Excellence Program (University of Santa Clara).
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\ PROFESSIONAL QUALIFICATIONS OF JOHN 8. H0CH My name is John B. Hoch. Since January,1982, I have been employed by PGandE as Diablo Canyon Project Manager. % responsibilities include managerial and supervisory duties, and providing coordination and direction of the Diablo Canyon Project organization. I am a Registered Professional Engineer (Mechanical and Nuclear) in the State of California.
% educational background is as follows: BS degree in Mechanical Engineering fron the University of Idaho,1959; graduate studies in Engineering, University of California, Berkeley,1961 to 1962; MBA, University
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of San Francisco,1969.
Fron 1980 to 1982, I was enployed as Manager of the Nuclear Projects Department at PGandE. W responsibilities included managerial and supervisory duties, and providing coordination and direction of the Nuclear Projects Department in matters related to PGandE's nuclear power plants.
Fron 1977 to 1980 I was employed in PGandE's Engineering Department as Project Engineer for Diablo Canyon. % responsibilities included l coordination of all Diablo Canyon Engineering activities.
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\_. Fron 1962 to 1977, I was enployed as a Mechanical Engineer and as a Senior Mechanical Engineer in PGandE's Engineering Department. My responsibilities included engineering design and analysis work for both fossil-fueled and nuclear power plants. In addition, I was responsible for NRC licensing activities for PGandE's proposed Mendocino Power Plant and for the Diablo Canyon Power Plant.
From 1959 to 1961, I was employed by PGandE in its Department of Electric Operations with responsibilities which included engineering analysis, supervision of instrument maintenance activities, and start-up activities associated with new fossil-fueled generating units.
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O k PROFESSIONAL QUALIFICATIONS OF f MICHAEL J. JACOBSON My name is Michael J. Jacobson. I am the Project Quality Assurance (QA) Engineer for the Diablo Canyon Project consisting of the integrated organization of Bechtel Power Corporation and Pacific Gas and Electric company. I an a Registered Professional Quality Engineer in the State of California.
My educational background is as follows: Sacramento State College, BS in Civil Engineering,1970; and Golden Gate University, Business Managenent Certificate in Managenent,1979.
\ I joined Bechtel Power Corporation in 1970 as a Quality Assurance Engineer responsible for various aspects of the design phase quality assurance on a nuclear power plant project. I was subsequently responsible for perfoming structural design and seismic analysis activities on the project.
Later, I was assigned as Project Quality Assurance Engineer responsible for supervising project QA activities, including direction of quality audits of construction activities.
Subsequently, I was assigned as Project QA Engineer on various other I
nuclear power plants, where I was responsible for directing project QA prograns. I was responsible for ensuring that project construction and site l
activities, as well as quality control aspects, net applicable QA regulatory Og requirenents.
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O I was assigned to the Diablo Canyon Project in 1982 to direct and control the DCP QA program.
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MYRON E. LEPPKE My nane is Myron E. Leppke. I am the Onsite Project Engineer on the Diablo Canyon Project consisting cf the integrated organization of Bechtel Power Coorporation and Pacific Gas and Electric Company responsible for direction and control of the multidiscipline Onsite Project Engineering Groups at the Diablo Canyon jobsite. Prior to that, I was the Assistant Onsite Project Engineer of the same organization with the primary responsibiltiy for the Plant Design, Record Matagenent, and Docunent Control Groups. I an a Registered Professional Mechanical and Nuclear Engineer in the State of California. .
O My educational background is as follows: BS in Mechanical Engineering, University of Wyoming,1970; and MS in Nuclear Engineering, University of Wyoning,1971.
In August 1971, I became a Mechanical Systems Design Engineer employed by Pacific Gas and Electric Company on the Diablo Canyon Nuclear Project.
In September 1977, I was transferred to the Diablo Canyon jobsite to becone the a1 site Quality Assurance Supervisor. I had responsibility for nonitoring quality assurance activities in Construction and Operations, l O E
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In August 1979, I was transferred to the Diablo Canyon Construction Organization and assumed responsibility for direction and control of the inechanical and piping construction activities.
In June 1981, I was transferred to the Nuclear Power Generation Department with responsibiltiy for formation of the Onsite Safety Review Group. This group was formed in order to provide independent review of operational activities and plant design with a view towards engineered safety improvements.
In March 1982, I was transferred to the Onsite Engineering Group as a Senior Piping Engineer responsible for the Small Piping Design Reverification O Program.
In Septenber 1982 I became the Assistant Onsite Project Engineer.
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PROFESSIONAL QUALIFIC.S.TIONS OF LEO MANG0BA My nane is Leo Mangoba. I have been enployed by Bechtel since 1976.
Since October 1982 I have been a pipe support group leader at Diablo Canyon where I have been responsible for managing the design of small bore piping supports.
I graduated with a Civil Engineering degree from Feati University, Manila,1972.
Prior to 1974 I was an engineering estinator with Calderon Construction Company.
Fron 1974 to 1976 I held a variety of assignments working in pipe support engineering.
In 1974 I began working as a job shopper for Bechtel in the capacity of Pipe Support Engineer where I worked on design calculations for both large and snall bore pipe supports. In 1976 I was hired directly by Bechtel to perfom the sane function. In this capacity I was involved with the Fast Flux Test Facility and the Linnerick and Skagit projects. !
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From 1977 to 1979 I was an Assistant Pipe Support Group Leader Q
working on the design of large and small bore pipe supports. In 1979 I becane the Pipe Support Group Leader, managing the design of small bore pipe supports for the Monticello, Point Beach and Susquehanna projects. In October 1982, I accepted an assignment in the same capacity with Diablo Canyor..
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\ PROFESSIONAL QUALIFICATIONS OF GARY H. MOORE My name is Gary H. Moore. I am the Unit 1 Project Engineer of the Diablo Canyon Project consisting of the integrated orgnaization of Pacific Gas and Electric Company and Bechtel Power Corporation. I have held this position since January 1982. I am responsible for the project engineering work related to the design and analysis of Diablo Canyon Power Plant nit 1. I an a Registered Professional Mechanical and Control Systens Engineer in the state of California.
My educational background is as follows: BS in Mechanical O Engineering, San Jose State University,1968; and MS in Mechanical A
. Engineering, San Jose State University,1969.
I joined PGandE in 1969 as a Mechanical Engineer in the Mechanical and Nuclear Engineering Departnent, designing instrumentation and control (ISC) systens for conventional fossil plants.
In 1977, I was naned a Senior Mechanical Engineer supervising the I&C Group assigned to the Potrero Unit 7 Project.
In 1979, I was named Supervising Mechanical Engineer, supervising ihe Mechanical and Nuclear Engineering Department's entire IAC Group, including f
responsibility for the 14C design of the Diablo Canyon Power Plant.
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' I have completed the following fornal training courses: Sinulator Training, Westinghouse Nuclear Training Center, Zion, Illinois; and Westinghouse PWR Infomation Course.
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O PROFESSIONAL QUALIFICATIONS OF ROBERT G. OMAN My name is Robert G. Quan. I am an Assistant Project Engineer on the Diablo Canyon Project consisting of the integrated organization of Bechtel Power Corporation and Pacific Gas and Electric Company, responsible for the direction and control of the mechanical, electrical, instrumentation, and HVAC engineering groups. Prior to that, I was the Onsite Project Engineer with responsibility for overall direction of multidiscipline engineering group at the Diablo Canyon jobsite. I am a Registered Professional Mechanical and Nuclear Engineer in the State of California.
O My educational background is as follows: BS in Naval Science, U.S.
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Naval Acadeny,1966; and U.S. Navy Nuclear Power School,1968.
After qualification as a supervisor of operations of Westinghouse PWR reactors, I served for three years as an engineering officer aboard a nuclear-powered submarine where I was responsible for the operation and naintenance of various reactor plant electrical and fluid systens.
l I joined Bechtel in 1972 as a Nuclear Engineer on the Trojan Nuclear Project, becoming Nuclear Group Leader a year later, and Mechanical Group Supervisor a year after that. My duties included perfoming and supervising nochanical system design, licensing activities, and field coordination through 1 startup to comercial operation.
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( % next six years were spent in Spain as Nuclear Group Supervisor, Mechanical Group Supervisor, and Assistant Project Engineer on the Vande11os Nuclear Project. % duties included supervision of systens design, technology transfer, and assisting g Spanish counterpart in implementing project managenent tools and production controls, and developing procedures for engineering interface with construction.
In 1982 I was assigned to the Diablo Canyon Project.
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1 PROFESSIONAL QUALIFICATIONS OF ROBERT PATTERSON l
My nane is Robert Patterson. I am Plant auperintendent and Assistant Plant Manager at Diablo Canyon. I have held this position since April 1980.
I am responsibla for directing all activities of the Maintenance, Operating, and Chemistry and Radiation Protection Departments at Diablo Canyon.
Prior to my duties as Plant Superintencent, I was Supervisor of Operations. I held that position from 1971 to 1980. As Supervisor of Operations I was responsible for supervising the operating staff in the O PreParattaa or e9uiP = at oPer tias Procedures ad rei ted teri i Prior to the startup of the plant. I participated in the preparation and review of
l Technical Specifications. I was also responsible for directing the operating staff in performance of preoperational tests and three separate hot functional test prograns. For the Unit 1 startup, I received an NRC Senior Operator's License.
Prior to my duties as Supervisor of Operations, I was a member of the i
Diablo Canyon Task Force from 1970 to 1971 engaged at Humboldt Bay in Diablo Canyon startup preparatica, % duties included preparing training materials, l initial loading, and low-level testing procedures for pre-startup activities.
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O From 1969 to 1970 I was assigned to Pacific Gas and Electric Company's (PGandE) General Office in license preparation for Diablo Canyon.
During this period, I was assigned for seven months to the R. E. Ginna Power Plant. There I conducted a training program for operators taking the AEC Operator License examination and participated in the preoperational testing program and review of test results for acceptance of systens. During my R. E.
Ginna assignnent, I also participated in initial loading, low-level physics testing, and power operation testing programs.
Prior to this I was on special assignment for preparation of PGandE power plant operator's training program and related manual. I served in this capacity fron 1%8 to 1969.
O Prior to special assignment, I was assigned to the Potrero Power Plant for startup of a 220 MWe conventional unit. I held various other assignnents in power plant engineering and other technical operations at Potrero. During this period,1964 to 1968, I was also reassigned to Humboldt Bay Power Plant during refueling outages to participate as a Shift Nuclear Engineer. At Hunboldt Bay I participated in prestartup activities including preparation of training materials, initial loading, and low-level testing procedures. I directed the preparation of reactor refueling procedures O.-
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O subsequent to initial fueling and directed the prefomance of this work on shift. I was responsible for the theoretical analyses of reactor core nuclear and thermal-hydraulic perfomance plus evaluation of the perfomance of plant safeguard and other auxiliary equipment. From 1961 to 1964, I was assigned to other technical operations at Humboldt Bay and served in various assignments I
in power plant nuclear engineering.
Prior to my Humboldt Bay assignnents, I was a staff engineer from 1959 to 1961. In this capacity I was assigned to both the Vallecitos and i Dresden projects. At Vallecitos I observed various phases of plant operation including the initial startup of the AVBWR. At Dresden I participated in initial loading and low-level testing and half-power to full-power testing.
O Prior to Vallecitos and Dresden I had various assignments from 1955 to 1959 involving power plant engineering and technical operations. I was involved in a conventional power plant startup.
I graduated fron Cooper Union School of Engineeing, New York, in 1953 with a BME. I an a registered Professional Nuclear Engineer in California.
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l PROFESSIONAL QUALIFICATIONS OF R. KEITH RHODES My name is Keith Rhodes. I am Technical Services Supervisor with the General Construction Station Department Instrument and Control (I&C) Group. I have held this position since January 1,1980. I an currently assigned to the Diablo Canyon Project Startup Department and am responsible for directing activities of the Instrument and Control Group.
My educational background is as follows: AS degree in electronics, Cuesta College, California,1976.
During the period fron June 1980 until May 1983 I was assigned to the Technical Services IAC Group in Emeryville, California. I was responsible for supervising the 18C personnel at various job sites on work assigned to General Construction Station Department, including the Diablo Canyon, Geysers, and Helms Projects.
I was made a Field Engineer in 1975 and was responsible for supervising activities of the Diablo Canyon General Construction I&C Group. I was also responsible for directing contractor instrument installation and valve maintenance work.
In 1972 I was made a General Construction Technical Subforeman and assigned the responsibility of directing the contractor, S&Q Construction perfoming instrument installation work.
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O rro 1967 uatii 197o 1 s i ir- P orea.
I initially joined PGandE's East Bay Division in 1962 and was an Apprentice Instrument Repaiman at the Pittsburg Power Plant.
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l A PROFESSIONAL QUALIFICATION OF JAMES 0. SHIFFER My nane is James D. Shiffer. I am the Manager, Nuclear Plant Operations, and as such provide line management support to the Diablo Canyon Power Plant. % organization is responsible for all operations, maintenance, operational engineering, training, security, quality control, energency I an a Registered planning, and radiation protection activities at the plant.
Professional Mechanical and Nuclear Engineer in California.
My educational background is as follows: BS in Chenical Engineering, Stanford University,1960; and MS in Nuclear Engineering, Stanford University,
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I joined Pacific Gas and Electric Company in 1961 as a Nuclear My Engineer assigned to the startup preparations for Hunboldt Bay Unit 3.
duties included preparation of training material, initial and low-level testing procedures; training of operating personnel for AEC license examinations; directing initial loading and testing programs as Shift Nuclear Engineer, and various other operational engineering assignments during the period between 1961 and 1969.
In 1969 I was transferred to the startup preparation for the Diablo l
Canyon plant which included a seven-nonth assignment to the startup and i
initial testing of the R.E. Ginna PWR plant. 1 0, l l
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( In 1971 I was assigned to the Diablo Canyon plant as Power Plant Engineer and becane Technical Assistant to the Plant Superintendent in 1978.
In 1980, I was appointed Manager of the newly forned Nuclear Plant Operations Department.
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O PROFESSIONAL QUALIFICATIONS OF LAWRENCE E. SHIPLEY My name is Lawrence E. Shipley. I am a Technical Consultant to the piping program at t!;e Diablo Canyon Project. I have held this position for sixteen months. My primary responsibility is in the review of piping systems to licensing corsnitments and newly developed sefsnic criteria.
My educational background includes the following: BS in Mechanical Engineering, U.S. Merchant Marine Academy, New York,1965.
I joined Bechtel Power Corporation's San Francisco Power Division in O i967 in the fieid of piping stress anaissis. ny responsinines inciuded technical direction of 150 engineers and designers on projects that included nuclear and fossil-fired power plants and the liquid metal fast breeder reactor at the Fast Flux Test Facility at Richland, Washington.
In 1981, I becane the Assistant Project Engineer on the Susquehanna Steam Electric Station in Pennsylvania, responsible for engineering in the civil-structural, architectural, and piping and plant design areas. The work I directed included: structural analysis review of all Seismic Category I butidings, piping / stress analysis review of all Seismic Category I buf1 dings, piping / stress analysis and pipe support design, valve qualification, welding and NDE, and materials selection and qualification.
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O In 1982, I was appointed Technical Consultant to the Diablo Canyon Project for the piping program.
In 1983, my- duties were expanded to include those of Assistant Chief Engineer for Plant Design in the San Francisco Power Division.
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O PROFESSIONAL QUALIFICATIONS OF AZR. SHUSTERMAN My name is Azriel Shusterman. I have 23 years of experience as a mechanical engineer, the majority of it in the design of piping and pipe supports. Since August 1982, I have been employed by Bechtel's San Francisco
-Power Division and have worked on Diablo Cr.nyon Unit 2. In October 1982, I worked with the jobsite's small bore piping design group in a supervisory capacity.
I graduated with a Mechanical Engineering degree from the University of Riga, Latvia, in 1961.
From 1%1 through 1964 'I was a Mechanical Engineer employed by the Diesel Manufactaring Plant of Riga, Latvia.
From 1964 through 1978 I worked at Riga's Special Project Institute of 011 and Industry where I was responsible for the engineering and design of piping, piping layout, pipe supports, and pipe stress analyses as well as the fabrication and installation of pipe supports. I also had interim assignments as a Senior Engineer in a plant that manufactured special tools, molds, and 1
dies.
From 1980 to 1982 I was c1 ployed by Quadrex as an engineer on the Zimer and Susquehart.1a ptojects. In this capacity, I was responsible for pipe 1270A ,
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I accepted employment with Bechtel on the Diablo Canyon Project in August 1982.
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O k PROFESSIONAL Qt!ALIFICATIONS OF ROBERT C. THDRNBERRY My name is Robert C. Thornberry. I an Plant Manager of the Diablo Canyon Power Plant. As such, I an responsible for ensuring that the plant is operated in a manner consistent with the safety of the plant personnel and the general public and in.accordance with the license granted by the Nuclear Regulatory Cobaission. I an also re:4ponsible for direct supervision of all I am a Registered Professional Nuclear Engineer in administrative functions.
- My educational background is as follows: BS in Chemical Engineering, O 1962, and MS in Nuclear Engineering,1963. Georgia Institute of Technology.
t I joined Pacific Gas and Electric Company in 1980 as Project Design Coordinator for the Diablo Canyon Power Plant, responsible for the project design activities.
Prior to that, in 1979. I was an engineer with Atonic Energy of Canada, Ltd., responsible for safety studies for 600 MW CANDU reactors.
In 1976, I was employed by the San Diego Gas and Electric Company as -
Supervisor of Nuclear Licensing responsible for all aspects of licensing, including directing the support efforts of the NSSS supplier, architect 4ngineer, and other project consultants in the licensing process. ,
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( In 1972 I joined the General Atonic Company where I worked on high-tanperature, gas-cooled reactor safety analysis reports.
After graduation in 1963, I joined the E. I. Dupont Company where I spent four years at the Savannah River Plant, monitoring the daily perfomance and safety of heavy water reactors, investigating unusual operating conditions, reviewing operating procedures, and calculating core operating paraneters. For the five years subsequent to this, I was assigned to the Savannah River Laboratory where I worked on the design and analysis of fuel and target assemblies and directed a study and redesign of the energency core l
cooling systen.
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PROFESSIONAL QUALIFICATIONS OF MICHAEL R. TRESLER My name is Michael R. Tresler. I as the Assistant to the Unit 1 Project Engineer on the Diablo Canyon Project, consisting of the integrated organization of Pacific Gas and Electric Company and Bechtel Power Corporation. In this position I am responsible for assisting the Project Engineer in directing all engineering on the unit with the exception of I have also been licensing-related efforts and other special activities.
l associated with the Project as Resident Mechanical Engineer, Project l l
Superintendent, Assistant Station Construction Superintendent, Project Control Engineer, and Piping Design Coordinator.
My educational background is as follows: BS in Mechanical Engineering, California Polytechnic State University,1964.
I joined PGandE in 1964 and perfomed pSe analysis and support design, and construction inspection, design, and startup of large fossil-fired ,
units.
In 1969, I spent a year participating in the startup and initial testing of the R.E. Ginna PWR Plant in Rochester, New York.
In 1970, I became PGandE's Lead Engineer in the piping design and quality assurance areas.
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l I joined the Diablo Canyon Project in 1972 as Resident Mechanical Engineer, becoming Project Superintendent in 1977.
In 1979, I spent a year as Assistant Station Construction
- Superintendent with responsibility for Diablo Canyon and miscellaneous fossil-fired construction work.
In 1980, I returned to Diablo Canyon as Project Control Engineer and was appointed Piping Design Coordinator in 1981 with the responsibiliy for controlling all piping and support design work on the Project.
I assumed my present duties in October 1983.
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PROFESSIONAL QUALIFICATIONS OF WILLIAM N. WHITE My name is William N. White. I am an Assistant Project Engineer in the Diablo Canyon integrated organization consisting of Pacific Gas and
. Electric Company and Bechtel Power Corporation employees. $ responsibilities
. include supervision and direction of seismic-related engineering analyses for the Diablo Canyon Unit 1 Project Engineering Organization. I am a Registered I Professional Civil Engineer in Oregon and member of the American Society of Civil Engineers.
O + educationai nac= ground inciudes: BS. Civii Engineering, University of Idaho; MS, Civil Engineering, University of Colorado; PhD, Civil Engineering, University of Colorado. ,
For the past seven years, I have been an engineering specialist with Bechtel's San Francisco Power Division working with the Chief Civil Engineer's staff in the area of seismic analysis for several Bechtel projects.
Earlier, I was a Structural Engineer with the Tennessee Valley Authority where I was responsible for seismic analysis of all Category I structures for a twin-unit nucle:.r power plant, including seismic foput for ;
the design of the nuclear steam supply system.
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I was an Assistant Professor at Oregon State University where I taught undergraduate and graduate courses in structural mechanics and analysis and computer applications. I perfomed a special study for Bechtel on soil-structure interaction for the proposed Mendocino nuclear power plant while teaching at Oregon State University.
While egloyed at the Bettis Atomic Power Laboratory. I was a Senior Engineer working on shock analysis of nuclear reactors aboard submarines and was involved in programs to assess the shock resistance of reactor internals subjected to long-tem irradiation damage.
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