Text

Forwards Decision ALAB-811,which Determined That No Further Hearing on Design Verification Issues Required.Issuance of Full Power OL Authorized Subject to Conditions,Including Requirement for Jet Impingement Analyses
	ML20210U740
Person / Time
Site:	Diablo Canyon
Issue date:	07/03/1985
From:	Cunningham G; NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Harold Denton; Office of Nuclear Reactor Regulation
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References
	FOIA-86-197 ALAB-763, ALAB-811, NUDOCS 8610100168
	Download: ML20210U740 (3)
	v • d • e

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l JUL 3 1985 Note to:

Harold R. Denton, Director Office of Nuclear Reactor Regulation From:

Guy H. Cunningham, III Executive Legal Director

SUBJECT:

DIABLO CANYON - APPEAL BOARD DECISION ON UNIT 2 DESIGN VEP.IFICATION On June 27, 1985, the Appeal Board issued its Decision on design verification issues related to Diablo Canyon Unit 2, ALAB-811, copy attached.

In this Decision, the Appeal Board first determined that no further hearing on design verification issues is required and that the existing record is adequate to enable it to make the necessary findings. The Appeal Board explicitly re-jected the Joint Intervenors argument that the results of the Unit 2 verifi-cation are required prior to making any findings, concluding, instead, that the NRC's licensing process has long recognized the legitimacy of predictive findings. The Appeal Board noted that the process for verifying the design of Unit 2 was already a matter of record as a result of the hearing held in October / November 1983 which addresed both units and that, given the essential identity of the two units, the extensive record developed in connection with Unit 1 design verification (including the results of that effort) provides an adequate basis for making the necessary findings for Unit 2.

Oversight of PG&E's implementation of the Unit 2 design verification is a matter properly left to the Staff.

Second, the Appeal Board, relying in part on its comprehensive Decision of March 1984, ALAB-763, in which it made findings regarding Unit 1, rendere'd -

favorable findings on the contested issues with. respect to Unit 2.

In par-ticular, it addressed the adequacy of the scope of the verification efforts (IDVP and ITP), specific seismic and nonseismic issues and QA-related issues.

The Appeal Board thus lifted the stay of the effectiveness of the Licensing Board's August 1982 full power Initial Decision (imposed in ALAB-763) and authorized the issuance of a full power operating license for Unit 2 subject to two conditions:

a requirement for jet impingement analyses for certain 8610100168 860930 PDR FOIA HOLMF:386-197 PDR

.g.

. JUL 3 Log 5 lines inside containment and imposition of a technical specification con-cerning CCW operability based on ocean water temperature; each of these conditions had likewise been imposed at the Appeal Board's direction (in ALAB-763), in the Unit 1 operating license, 4

m Guys.Cunningham,g'I Executive Legal _1 rector B

cc w/ Encl.:

William J. Dircks John B. Martin, Region V James Taylor

Enclosure:

ALAB-811 w.

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pem l teutb<^t IW 6 ;A UNITID STATES OF AMERICA

th NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOARD Administrative Judges:

Thomas S. Mocre, Chairman June 27, 1985 Dr. W. Reed Johnson (ALAB-811)

)

In the Matter of

)

PACIFIC GAS AND ELECTRIC COMPANY

) Docket Nos. 50-275 OL

)

5G-323 OL (Diablo Canyon Nuclear Power

)

Plant, Units 1 and 2)

)

Joel R.

Revnolds, John R.

Phillies, Eric R.

Havian and Ethan P.

Schulman, Los Angeles, California, and David S.

Fleischaker, Oklahoma City, Oklahoma, for the San Luis Obispo Mothers for Peace, et al., joint intervenors.

John K.

Van De Kano, Attorney General of the State of California, Andrea Sheridan Ordin, Michael J.

Strumwasser, Susan L.

Durcin and Peter H.

Kaufman, Los Angeles, California, for George Deukmejian, Governor of the State of California.

Robert Ohlbach, Philio A.

Crane, Jr.,

Richard F.

Locke tnd Dan G.

Lubbock, San Francisco, California, and Arthur C.

Gehr, Sruce Norton and Thomas A.

Scardazio, Jr.,

Phoenix, Ari cna, for Pacific Gas and Electric Company, applicant.

Lawrence J.

Chandler and Henrv J. McGurren, for the Euclear Regulatory Cc= mission staff.

DECISION In ALAS-763, we set forth our findings of fact and conclusions of law on the centested issues concerning the adecuacy of the design of Diablo Canyon Unit 1 in this

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4 2

O recpened operating license proceeding.1 We then specifically deferred our findings on those same issues for Unit'2 and, in effect, stayed the full power license authorizatien for that unit granted previously by the 2

Licensing Board's initial decision until we made our findings with respect to Unit 2.3 This decision contains our findings on Diablo Canycn, Unit 2.

I.

The detailed history of the reopened Diablo Canyon cperating license proceeding is recited in ALAE-763 and need not be repeated fully here.4 For present purposes, it suffices to note that, shortly after the Director of Nuclear Reactor Regulation (NRR) issued a low power license for Diablo Canyon, Unit 1, the Commission suspended it.

The Commission acted after Pacific Gas and Electric Ccepany (PG&E) reported errors in the assignment of a number of seismic design spectra for the Unit 1 contcinment and the NRC staff found significant weaknesses in the implementation cf PG&E's design cuality assurance program.

The Commission then directed PG&E to undertake an independent design 1

19 NRC 571 (1984).

2 LEF-82-70, 16 NRC 756 (1922).

3 ALAB-763, suora, 19 NRC at 619.

4 See id. at 573-82.

3 verification program of certain seismic-related design activities.

In addition, the agency staff instructed PG&E to provide it with the results of a further design verification program so that the staff would be able to determine whether to recommend operation above low power.

As pointed out in ALAB-763, PG&E's " verification efforts.

expanded far beyond those originally envisioned" and took more than tuo years to complete just for Unit 1.5 While the design verification efforts were ongoing, we granted the motions of the joint intervenors and the Governor of California to reopen the operating license proceeding on the issue of the adequacy of PG&E's design quality assurance program.

We also acceded to the recuest of the parties that we preside over the reopened proceeding.

Alciough the evide.}ce supporting the recpening motions consisted largely of the program deficiencies that had led to the suspension cf the Unit 1 license, the focus of the recpened proceeding necessarily went beyond the past 5

d. at 574.

The structure of PG&E's verification programs is set forth in ALAB-763, id. at 578-82.

Those details will not be repeated other than Eo note that PG&E's verification ef forts included an Independent Design Verification Program (IDVP) utilizing the services of independent companies and an Internal Technical Program (ITP) comprised of PG&E employees and those of PG&E's completion manager, Bechtel Power Corporation.

See also id. at 591-92.

Additionally, because the seismic design was essentially redone as part of the Unit 1 verification (pursuant to a quality assurance program meeting the requirements of 10 C.F.R. Part 50, Appendix B), we found there was reasonable assurance that there are no safety significant seismic desien errors in that unit.

See id. at 583-86, 619.

29 Id. at 583.

30 Id. at 584.

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15 systems and components at Diablo Canyon Unit-1 is proper and meets licensing criteria."31 L'e also determined that the Unit I nonseismic design met appropriate licensing criteria.32 In particular, we found that the original nonseismic design process for Unit 1 was efficacious in producing a design in which "[t]he errors found were fewf of minor significance, and did not indicate a pervasive 3

weakness in any design area."

And, we found that PGLE's nonseistic verification efforts provided a degree of assurance comparable to that which would be furnished by a properly functioning quality assurance program."4

Finally, ue ccncluded that "the Unit 1 safety-related strurtures, i

systems and ccmponents are designed to perform satisfactorily in service and that any significant design deficiencies in that facility resulting frcm defects in the applicant's design quality assurance program have been remedied.""5 PGsE established the Unit 2 v.erification program to consider the applicability of the Unit I design verification 31 -Id.

at 586.

32

_I_d.

at 592-93.

3

_I d. at 593.

34

_I_d.

35

_I_d.

at 619.

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16 for Uni; 2 and to ensure the proper resolution of each Unit 1 issue for Unit 2."6 The program is managed and run within the ITP by a Unit 2 project engineering group that operates under the same design quality assurance program meeting the provisions of 10 C.F.R. Part 50, Appendix B, as the rest of the ITP.37 Pursuant to the procedures for the Unit 2 verification, the project engineering group receives each finding from the Unit 1 verification and determines whether it is applicable to Unit 2.

Any inapplicable finding is documented and the basis for the decision recorded.

If the finding is determined to apply to both Units 1 and 2, a decision is made whether the Unit 1 resolution also applies.

Where the resolution is applicable, the program contains procedures to ensure the resolution is implemented for Unit 2 and, if the resolutien involves physical modification, the procedures provide for the issuance of appropriate design change documents.

In those instances where the Unit 1 item is not identical for both units, the ITP evaluates and documents the differences and determines the applicability of the item to Unit 2.

The ITP then ascertains whether the item needs resolution and the effect of the differing 36 Anderson et al. Tr. fol. D-224 at 29-30; Knight et al. Tr. fol. D-2649 (Contention 1) at 25.

37 Anderson et al. Tr. fol. D-224 at 29; Dick et al.

Tr. fol. D-847 at-24.

1 i

17 resolution en the review of the item for Unit 2.

Before the resolution is implemented, however, the ITP reviews it to confirm that the resolucion is consistent with the applicable licensing criteria and that all appropriate steps are in place to ensure the Unit 2 requirements are met.

The Unit 2 verification process is directed by explicit procedures that require complete documentation.38 The entire program is periodically audited by PG&E as well as the NRC staff to ensure the Unit 1 verification issues are identified, addressed and resolved for Unit 2 so that unit is in conformance with applicable licensing criteria.39 In brief, the Unit 1 verification established that the design process (i.e., the design criteria, methodology, analyses and procedures) used in the final seismic and nonseismic design of Unit 1 was efficacious in meeting applicable licensing criteria.

Because the same seismic and i

nonseismic design process is applicable for Unit 2, we find the Unit 2 program sufficient to verify the adequacy of the Unit 2 design.

Accordingly, we conclude, en the basis of our review of the entire record, that no further hearings are necessary and the existing evidentiary record is 38 Anderson et al. Tr. fol. D-224 at 29-30.

39 Id.; Dick et al. Tr. fol. D-847 at 24; Knight et al.

Tr. fol. D-2649 (Contention 1) at 25.

18

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i sufficient to support findings on the contested issues for Unit 2.

III.

We also cenclude from our review of the record that the findings in ALAS-763 on the contested issues for Unit 1 are applicable to Unit 2.

Therefore, we will not reiterate those findings and we need add little to the discussion of the issues already contained in ALAB-763, other than to address the issues aimed exclusively at Unit 2.

Twenty-two contested issues remained after the hearing and five of them, issues 1(a) through 1 (e), challenge various aspects of the IDVP review.4 In particular, issue 1 (e) explicitly addresses Unit 2, claiming that the scope of the IDVP was too narrow because it did not verify the design of Unit 2.

Although the verification efferts of the IDVP were directed at Unit 1 and the IDVP's findings formed a significant component of our conclusion that Unit 1 met its licensing criteric, those efforts also must be considered as having verified, in significant part, the design of Unit 2.

First, the IDVP reviewed the ITP's seismic redesign of Unit 1 that included, inter alia, the structures common to both units.41 Hence, these common structures -- whether labeled 40 See n.6, supra.

41 J:d. at 583-86; Cranston Tr. D-385.

19 Unit 1 or Unit 2 structures -- were verified by the IDVP.

Second, the IDVP reviewed the other Unit 1 structures that are basically the same as those for Unit 2 and that review included an examination of the criteria, methodology and analyses used in the seismic design of these structures.42 Because the same criteria and methodology (i.e., the basic design process) used in the design of Unit I were used for Unit 2 structures, the IDVP verified, to that extent, the design process e= ployed for Unit 2.43 Similarly, the IDVP reviewed a sample of the Unit 1 safety-related systems and found the design process that produced the ncnseismic systems efficacious.44 The Unit 2 safety-related systems are identical from a design standpoint, and the same design process that the IDVP found satisfactory produced the design of the Unit 2 systems.45 Further, nothing developed during the course of the IDVP Unit 1 verification to indicate a need for expansion of the IDVP to include Unit 2.4

Thus, 42 ALAB-763, suora, 19 KRC at 583-86; Anderson et al.

Tr. fol. D-224 at 28-29.

43 Schierling Tr. D-2772-73.

i 44 ALAE-763, sucra, 19 NRC at 589-93.

45 Anderson et al. Tr. fol. D-224 at 28-29; Enight Tr.

D-2774.

46 Knight et al. Tr. fol. D-2649 (Contention 1) at 24-25.

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20 we find that there was no necessity to replicate the IDVP for Unit 2.47 Six of the centested issues challenge the seismic analysis and modeling used in the verification of various facility structures.

Five of them deal with structures which are common to both units: the auxiliary building (3 (f) (iv) and 3 (f) (v)), the fuel handling building (3 (o) ),

the buried diesel fuel oil tanks (3 (q) ), and the intake (3 (r)).48 Hence, these issues have been fully structure resolved by ALAB-763.

Similarly, our findings in ALAS-763 on the sixth issue (3 (f) (iii)), which questions the effects of seismic uplifting en the Unit 1 containment, are fully applicable to the Unit 2 containment because of the similarity of the two containment structures.48 Three of the contested issues concern discrete aspects of the nonseismic systems design review performed as part of 47 Four of the contested issues, issues 2 (a) through 2 (d), dispute '*arious features of the ITP verification but enly issue 2 (d) refers to Unit 2.

That issue claims that the ITP review was too narrow because it failed systematically to verify the design of Unit 2.

The joint intervenors and the Governor, however, failed to file preposed findings on issue 2 (d) and thereby waived it.

ALAB-763, suera, 19 NRC at 577 and nn.19 & 21.

In any event, as we found in Part II, suora, PG&E's Unit 2 verification program is sufficient to verify the adequacy of the design of Unit 2.

48

_I_d.

at 595-601.

49

_I_d.

at 593-95.

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i 2'1 the PG&E verification program.

Specifically, they deal with fire protection for the auxiliary feedwater pump room (4 (1) (1) ), jet impingement effects of three lines inside containment (4 (1) ), and the nameplate ratings for three 4160 volt circuit breakers (4 (t)).50 Pursuant to PG&E's Unit 2 verification program, the resolution of each of these issues will be examined and, if appropriate, applied to Unit 2.

Moreover, the interpretation of the Final Safety Analysis Report that we adcpted in ALAB-763 and the condition we attached to the Unit 1 license authorization requiring PG&E to analyze certain lines inside the Unit 1 containment for jet impingement effects are equally applic=kla +c Unit 2.51 Therefore, we attach the same condition to the license authcrization for Unit 2.

$he last contested issue referring explicitly to Unit 2,

issue 5, charges that PG&E's verification efforts failed to substantiate that Units 1 and 2 "as built" conform to the design drawings and analyses.

With regard to Unit 1, we fcund that PG&E's reconciliation of design documents with the plant and with design analyses was in compliance with the Commission's regulations.52 We determined that, 50

_I_d. at 601-04.

51

_I_d. at 603, 619.

52

_I_d.

at 607-08.

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22 although PG&E had had difficulties in the past with configuration control, those problems were primarily caused--

1 by PGLE's inability to revise affected documentation in a timely manner, and that PGLE had significantly modified its configuration control procedures to remedy this deficiency.

We then found that experience under PGLE's modified procedures demonstrated their effectiveness, that all modification work on the site conformed to the new i

procedures, and that an audit of the modified configuration i

control process found the program was being effectively implemented.

We also concluded that discrepancies cited by i

the intervencre as purported ecidence of the inadequacy of the system demonstrated neither a pattern of inadequate control procedures nor insufficient configuration control.53 Cur findings in AL.j.B-763 were directed at Unit 1 but those findings and the evidence underlying them established the effectiveness of FG&E's present configuration centrol process for ensuring that the facility, as built, conforms to the actual design drawings and analyses.

That same configuration control process is applicable to Unit 2 and all completion and modification work on that unit will be s

4 53 Id. at 605-07 & n.179.

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subject to the control procedures.54 Therefore, we are satisfied with respect to Unit 2 that PG&E's reconciliation of design documents with the facility and with the design analyses complies with the Commission's regulations.

None of the remaining four contested issues is particularized as to unit and our findings in ALAB-763 on these issues are thus equally applicable to Unit 2.

Issue 6 claims PG&E failed to verify that Westinghouse-supplied safety-related equipment met licensing criteria.

In ALAB-763, we foun'd that there was no need for PG&E to verify this equipment because the Westinghouse quality assurance program, under which the Diablo Canyon nuclear steam supply system':(NSSS) was designed, was adequate at all relevant times.55 The Unit 2 NSSS was also designed by Westinghouse

/

under the same quality assurance program and our earlier findings resolve this issue for Unit 2 as well.

Similarly, issue 7 asserts that PG&E's verification program did not identify the root causes of the failures in PG&E's original quality assurance program and determine whether these failures raise generic concerns.

In ALAB-763, we found that PG&E had identified and analyzed the root causes of the 54 Anderson et al.

Tr. fol. D-224 at 32; Applicant Exhibit 161, Procecu?e 3.7 at Attachment A.

55 _Id.

at 608-10.

e

24 i

failures in its design quality assurance program.56 Because both Diablo Canyon units were originally designed by PG&E l'

under the same quality assurance program, PG&E's investigation and analysis of root causes were not unit-specific but necessarily aimed at ~5e deficiencies in the program.

Therefore, our previous findings also resolve this issue for Unit 2.

Issue 8 maintains that the ITP failed to develop and implement an adequate quality assurance program for perfcrming the verification functions and any modifications to the facility.

In ALAB-763, we found the contrary to be the case and that the ITP quality assurance program was i

adequate."

The same quality assurance program is central to the Unit 2 verification program so no further findings are necessary.

Finally, issue 9 asserts that PGLE failed to provide assurance of compenent cooling water system (CCWS) heat removal capacity to meet licensing criteria.

In ALAB-763, we found that a PG&E proposed technical cpecification to moniter ocean water temperatures and to take prescribed steps in the event ocean temperatures reach certain levels was adequate to meet the requirements of the Commission's. regulations.

Consequently, we imposed the 56

_I_d.

at 610-13.

57

_I_d.

at 613-17.

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technical specification as a condition on license authorization.58 Once again, because the CCWSs of both units are essentially identical, our previous finding is fully applicable to Unit 2.

Likewise, the same condition is imposed on Unit 2.

IV.

For the reasons set forth in Parts II and III, we find that PG&E's Unit 2 verification program is sufficient to establish that the design of Diablo Canyon Unit 2 meets its licensing criteria.

That program provides adequate confidence that the Unit 2 safety-related structures, systems and compenents are designed to perform satisfactorily in service.

Accordingly, we conclude that there is reasonable assurance Unit 2 can be operated without endangering the health and safety of the public and the license authorization previously granted to the Director of 1;EP. by the Licensing Board's initial decision re=cins effective.59 Before exercising that authority for Unit 2",

the Director shall ensure that PGLE has met the same two conditions we previously imposed on the licensing authori:ction for Unit 1.

58

_I_d.

at 617-18.

59 See LEP-82-70, suora, 16 NRC at 854.

e 26 It is so ORDERED.

FOR THE APPEAL BOARD Of% &~mnQb C.QJean Snoemaker Secretary to the Appeal Board 3

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3 flote of Explanation

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To the extent practicable, I have delineated for comparison, areas of differences between the October and November 12, 1981 Cloud reports.

4 That is, where changes were made, I show the earlier paragraphs and/or sentences and later corresponding paragraphs.

I have not yet, attempted to evaluate the significance of the changes made nor have I made an attempt to evaluate i

what changes were made, if any, as a result of PG&E's comments on the October, 1

1981 Cloud Report.

The format used was for example;

'l. October 1981. Cloud Report The third paragraph oT Section 1.0 of the earlier report read as follows:

"This report has been prepared in response to the NRC request for a prelininary report on the URS/31ume - PGandI Seis=ic Design Interface.

It has been co=pleted on a priority basis and must be considered a preliminary report, as, requested and as birled.

Any ocissions -of significant infc =ation or other inco=pleteness will be addressed in the overall reveri-fication program."

Changes shown in November 1981 Cloud Report.

It appears in the later report as the fourth paragraph and reads as follows:

"This report has be'en prepared in response to the NRC request for a preli=inary repo;-t on the URS/31use - ?GandE' Seis=ic Design Interface.

The cu:-off date for the prelizinary re-view of all builcing, structures and eenip=ent axcept hear-ing, ventilation and air conditiening (WAC) cecponents and ducting is October 28, 1981.

For the WAC cc ponents and ducting, the cut-off date is November 2, 1981.

Any o=issicns of significant Mer=ation or other ince=pleteness. rill be l

addressed in the overall reverificarica pro,gran."

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2.

(Repeat above for next change),

i r 6. mhc.h 0-I B. C. Buckley

o.

i The title page of the earlier Cloud report was changed from:

"A PRELIMINARY REPORT ON THE DESIGN INTERFACE REVIEW OF THE SEISMIC REVERIFICATION PROGRAM" to

" PRELIMINARY REPORT SEISMIC REVERIFICATION PROGRAM" Earlier Cloud report was dated October 1981, the later report was. dated.

v. '.'ilit.;; *2N'NhSEE$'5N# 'h*iii8$.N'

I' d' 1

The following differences w2re nottd betw22n Cloud report forwarded to Mr. Rocca (PG8E) on October 21, 1981, and the Cloud report dated November 12, 1981, which was forwarded to Mr. R. A. Engleken, by PG&E letter dated November 18, 1981. For convenience, the reports above will be identified below as the " earlier" and "later Cloud report.

The following notation which was stamped on every page of the later report did not appear in earlier report:

"NPG Licensing Log Number 0666."

On page (iii) of the earlier report, Section 4.0 labeled " Summary and Conclusions". This was changed to read " Summary and Discussion".

Page (iv) of the earlier report was entitled " APPENDICES". Page(iv)ofthelater report was entitled " Log Books". The word " Appendix" which appears seven times on page (iv) of the earlier report did not appear on page (iv) of the later report.

(Section 1.0) Earlier report, Section 1.0, the first paragraph of this Section reads as follows:

"As a result of the discovery of a misapplication of seismic floor spectra to the annulus area of the Diablo Canyon Power Plant Unit 1, a Seismic Reverification Program

was estab-lished to determine if further errors exist in seismic qualification of the plant for the Hosgri 7.5 M earthquake.

This program was presented verbally to the U. S. Nuclear Regulatory Commission in a meeting at Bethesda, Maryland l

on October 9, 1981. The NRC felt the program was presented verbally to the U. S. Nuclear Regulatory Commission in a

" Seismic Reverification Program," Robert L. Cloud Associates, Inc., Berkeley, California, October 12, 1981.

12/21/81 1

HOSGRI REPORT i

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Plant Unit 1, a jeistnte Re' verification Progr4m* was estab-lished to determine if further~ e'rrors exist' in seismic quali-fication of the plant for the Hosgri 7.5 M earthquake. This program was presented verbally to the U. S. Nuclear Regulatory Commission in a meeting at Bethesda, Maryland on Detober 9, 1981. The NRC felt the program was valuable, but requested a prelimihary report on part of Task 3 of the Reverification Program on a priority basis."

It now reads:

"As a result of the discovery of a misapplication of seismic floor spectra to the annulus area of the Diablo Canyon Power Plant Unit 1, a Seismic Reverification Program was estab-lished to determine if further errors exist in seismic qual-ificatioh of the plant for the Hosgri 7.5 M earthquake. This program was presented verbally to the U. S. Nuclear Regula-tory Commission in a meeting at Bethesda, Maryland on October 9, 1981. The NRC felt the program was useful, but requested a preliminary report on part of Task 3 of the Reverification l

l Program on a priority basis. This program was then expanded to include Tasks 1 and 2 insofar as they relate to the design l

informati.on flow and seismic qualification of structures and l

equipment.

The following footnote, which appeared in the earlier report was deleted from this 'Section. However, it does appear at the bottom of Pg. 3 of the later report.

" Seismic Verification Program, Robert L. Cloud Associates,

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The third paragraph of Section 1.0 of the earlier report read

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as follows:

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This report has been prepared in response to the NRC reque for a preli=idary report on the URS/Blume - FGandE Seis=i:

Design Interface.

It has been complecer on a prioriiy has and =ust be considered a preli=inary report, as reques:ed

' and as citiled.

Any omissions.cf significant infor=ation c other incocpleteness will be addressed in the overall reve fication program."

~

It appears in the later report as the fourth paragraph and reads as follows: -

"This report has been prepared in response to the NRC reque:

for a prel4"4 nary report on the URS/31u=e - FGandE' Seis=ic Design Interface.

The cut-off date for :he prel# dnary re-view of all building, sc uctures and equipment excep: hea:-

ing, ventilation and air conditioning (HVAC) components anc ducting is October 28, 1981.

For'the HVAC co=ponents and ducting, the cut-off date is Nove=ber 2, 1981.

Any omissi:

of significant information or other incompleteness will be addressed in the overall reverification program."

The follow [ng paragraph (para. 3), which did not apocar in the earlier report, was inserted before paragraph four above.

" Task 1 of the original program is titled " Study of Qualifi-cation Based on Symetry" and consists of examining the flow of information used in qualifying the Diablo Canyon Unit 1

~ safety related structures and equipment.

This effort will enco= pass that work based on opposite hand application or other sy==etry conditions.

In a parallel effort, Task 2,

" Review of Steps in the Seis=ic Design Process" will be

' addressed by defining and exa=ining the design process.

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,4, The fo,llowing paragr h,whichIs'th'elastparagraphofthisSection in the later report, did not appear in the earlier report:

?Through out the report references are made to logs. 'This log information'is maintained in the form of log books whic are available for authorized examin'ation at the office of.

Robert L. Cloud Associates."

~

(Section 2.0).

- Insert all of page 3 and the top three lines of page 4 of the later report, delineated below, ahead of Section 2.0 of the earlier report.

"The objective of the original Seismic Reverification Program

was to consider the following three tasks:

Task 1.0:

Study of qualification based on symmetry Ensure that all work applied to Diablo Canyon Power Plant (CCPP) Unit 1 that is based on opposite hand application or other syrr.11etry conditions is correctly applied.

Task 2.0:

Review of steps in the seismic design process Chart the seismic design process for the DCPP and review the steps in the process or the links in i

the seismic design chain.

l

"" Seismic Reverification Program", Robert L. Cloud Associates, Inc., Berkeley, CA, October 12, 1981.

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Task 3.0: Design';I' niter'faf:e Review-s s

Review the ' app 1'i'cability of seismic qualifica-tion work passing between PGand E and subcontractors.

The objective of this task is to review the applic--

ability of design information that pa'sses across.

design interfaces.

For Ta,sk,_1.0 all seismic qualification of safety related buildings and equipment that has been performed only one time, but is applied to both Units of DCPP by utiliz& tion of opposite hand or other symetry shall be reviewed. Qualification documents take the form of stress reports, design evaluation reports, data sheets, test reports, and certification reports.

For Task 2.0, the flow of the seismic design process.shall be reviewed.

The. flow begins with approved Hosgri earthquake i

ground motion and ends with a qualification document.

Delete the following first three. lines of page 2 of the earlier report:

i "The objective of this preliminary part of the verification

~~

program wts to examine Seismic Design and Qualification in-fonnation of three categories:"

i and insert the following:

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"The scope of 't.he pEesent' effort for Task 3m0 is limited to the review of the design int'erfac~e of PGand E with URS/Blume, specifically for the three categories:"

The first sentence of the second paragraph.of the earlier report read as follows:

"The requirement was to perform an engineering review of this infomation in a selective manner, as described below."

It now reads:

"The overall requirement was to perform an engineering review of' this information in a selective manner, as described in Se'ction 3.0."

The third paragraph in Section 2.0, whicheread as follows:

" Design spectra, building loads and other output of URS/Blume as transmitted by URS/Blume and received by PGandE'were sche-duled for examination with the objective of checking to see that URS/Blume-generated information was prsperly applied.

The methodology employed in this task is described in Section 3.2'herein."

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Now reads:

-. l Design spectra, building loads and other output of UR2 l as trans=1::ed by URS/Blu=e and received by PGandE we:

'uled for examination 'with :he objective of checking :: !

that URS/Bl"-a-generated infor=acion was properly app'.

buildings and equipment r'eviewed in :he present effor:

those reluirod faR nafn anM nhwAsmMd wero -pawa

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(Section 3.0)

Insert the, fol. lowing bene Section'3'1 'of themorlier report.

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"The program tasks as defined in Section 2.0 will be addressed thrcugh the following process:

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a) Definition of Seismic Qualification Interfaces b) List Categories of Infomation Flow through Interface c) Review Interface Design Informa.t. ion Flow for Structures d) Review Interface Design Infomation Flow for Equipment Task 3.0, the Design Interface Review, is directly addressed through the format of the above methodology. Tasks 1.0 and 2.0 are also addressed although.somewhat indirectly. Task 1.0, the Study of Qualification Based on Symmetry, is accomplished by examining the seismic qualification of cold shutdown required safety related structures and equipment.

This examination consists primarily of reviewing the seismic qualifications for applicable seismic inputs.

Task 2.0, Review of Steps in the Seismic Des'ign Process, is addressed by tracing the flow of design infomation through PGand E and their subcontractors. Although this report deals primarily with PGandE and URS/Blume information flow, substantial work was performed to examine the flow within PGandE.

The methodology process is described in the following subsections."

(Section Delete the word "herein" from the last paragraph of Section 3.2.2 3.2.2) of the earlier report. such that it now reads "The interface design infomation was studied separately for'each building and is reported,_ _

separately."

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(Section The first sentence 6f Seition '3.2.3 of the earlier report which r 3.2.3)

"The overall cognizant responsibilities for the Hosgri requalif of equipment was divided by PGandE and Westinghouse, as liste Figure 3.2.3-1."

was replaced with the following:

"Although the overall cognizant responsibility for the Ho

' qualification of equipment was PGandE scope, the analy divided between PGandE and Westinghouse, as listed O

Delete the word " Appendix" in third paragraph of the ear report and insert " Log".

O The following paragraphs, which appear in the earlier report:

"The spectra t'ra'nsmitted to Westinghouse for the Contain Structure on March 16 and 23,1977 were superceded by the spectra issued June 5, 1977.

Spectra could not be located in PGandE files.

On August 9,1977, PGandE transmitted vertical spectra for t Containment Structure to Westinghouse.

These spectra were thought to be valid until October 1981.

No record was found of any Turbine Building spectra ever to Westinghouse."

were replaced with the following paragraph:

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"The spectra for the3xUr'ior'a'nd Interior C$nta.inment Structu were respectively transmitted to Westinghouse on March 16 an 1977.

The Exterior Containment spectra were superseded by the URS/Blume ' report issued on June 5,1977.

However,, no transmittal to Westinghouse of this spectra could be locat5d in the PGandE

. files.

On August 9,1977, PGandE transmitted vertical spectra for the Containment Structure to Westinghouse."

0 Figure 3.2 of earlier report, Column 1 (Interface I}

, insert the words " Seismological and Geologic" before the wotds " Definition o Ground motion" o Figure 3.2.3-1 of earlier report insert " Piping, Primary and" before the words " secondary systems".

(Section 3.3)

The first sentence in Section 3.3 of the earlier report which read "The review of interface infomation for structures and equipment was perfomed using the methodology described'in Section 3.2" was changed to read: "The review of design chain, opposite hand sy and interface infomation for structures and equipment was perfomed using the methodology described in Section 3.2".

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(S ction 3.3)

The second paragraph of'}he eftrlier report rea(as follows:

" Sections 3.3.1 through Sections 3.3.7 discuss in detail the interface information for the above. mentioned categories."

It now reads:

5 "The Containment and Intake Structures were given a higher priority.

Thus, these were reviewed in more depth. Sections 3.3.1 through

-3.3.7 discuss in detail the design information reviewed for the above-mentioned categories.

(Section Delete " investigated" in the first line and " investigation" in 3.3.1) the third line of the first paragraph in Section 3.3.1 of the earlier report and insert " analyzed" and " analysis", respectively. Al s o,

delete the words "re-evaluated" and "re-evaluation" and insert 1

"re-analyzed" and "re-analysis", respectively.

1 1

l The following paragraph was deleted from earlier report:

"The following sections describe the transfer of information between PGandE and URS/Blume for the Containment Struc'ture and five major peices of equipment. Generic equipment, such as cranes, piping, heating, ventilating and air conditioning, etc. are covered in Section 3.3.5 through Sections 3.3.7. "

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,pa.,;a andreplacedwiththef(Dowiig The design chain and the opposite hand symetry are discussed in the following sections, which describe the transfer of information between PGand E and URS/Blume for the Containment Strpeture and five major pieces of equipment. Auxiliary equipment, such as cranes, pihing, heating, ventilating and air conditioning, etc. are covered in Section 3.3.5 through Section 3.3.7.

(Section Delete the word " Appendix" everywhere it appears after line 5 of 3.3.1.1) the first paragraph and insert " Log".

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(Section Delete the following from pg.14 of the earlier report:

3.1.1)

The criteria established to check the referenced drawings are tabulated as follows:

1.

These are Containment Structure - Unit 1 drawings.

2.

Since the reference drawings had no revision numbers, it was assumed that the drawings were current in July 1970.

3.

When the drawings had no revisions dated later than July 1970, they were marked "O.K."

If revisions were made, these were so noted.

A review of the above men'tioned drawings was performed, and it was found that revisions made after 1970 were minor (Appendix 1.1, item #14),

and would not affect the model in the horizontal direction.

and insert the following:

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To verify that the doi (u.m'ents u' sed by URS/Blumg. tq develop th'e original

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dynamic model (used subsequently 'for'thi Hosgri re-evaluation) were correct, a list of drawings was checked. This list, given in Log 1.1, Item #14, was obtained from the July 1970 report on the Containment Structure (Reference 1). A review of the ab'ovd-me'ntioned drawings

~

was performed to check that the referenced drawings:

were Contaiment Structure - Unit 1 drawings, and when the drawings had revisions dated later than July 1970, these were so noted in the field work (Log 1.1, Item #14).

It was found that revisions made after 1970 were minor (Log 1.1, Item #14), and do not affect the model in the horizontal direction.

(Section Delete the fol. lowing paragraphs (Last paragraph on pg.14 and first 3.3.1.1) paragraph on pg.15 of the earlier report.)

Thus, for the Hosgri re-evaluation report (Reference 11) the containment dynamic model used was a Unit 1 interior and exterior and a Unit 2

, annulus. According to URS/Blume this posed no p'roblem as they were under the impression the Unit 1 and Unit 2 were identical. This is identified in Appendix 1.1, item #18. Use of Unit 2 annulus and Unit 1 interior should have no affect on the shape of the annulus spectra, because of the axisymetric interior, as discussed in Appendix 1.1, item #18.

The only change in the annulus regions covered l

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mirror image opposite hand configuration from the U' nit 2 model.

and replace with the following:

"As a result, the dynamic model in the Hosgri re-evaluation report (Reference 11) was a composite of Unit 1 interior and exterior structures and a Unit 2 annulus structure. Therefore, the five

. conceptual frames shown in the sketches are correct for both Units 1 and 2 except in their circular orientation. The frame orientation sketch used to locate the spect.ra was correct for Unit 2 but was incorrect for Unit 1.

The computed floor response spectra corresponding to the particular frame location and elevation in the annulus are used to determine vertical seismic inputs for the seismic qualification of systems and equipment supported by the annulus structural steel at that location.

Because the annulus layouts of Units 1 a~nd 2 have an opposite hand relationship and the vertical spectra are dependent on polar i

orientation, certain systems and equipment were analyzed using in-appropriate spectra. The orientation error resulted in the use of vertical spectra for Unit 1 evaluation that are in some cases lower, and in other cases higher than those that should have been used.

Itshouldbenotedhowever,thatitemsquklifiedusingFrame3 spectra are not affected by the orientation error because this frame has identical locations in Unit,1 and Unit 2.

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(Section '3.3.1.2)

This Section in the ear'$er r'eport' read as follews:

"Unlike the informal transmittal documentation from PGandE to URS/Blu=e, the. documentation from' URS/31tme to PGandE was more fornal.

This is verified by reviewing the transmittal 'docu:[ents listed in Appendix 2.1.1.

This Appendix contains transmitral documents sent to PGaridZ from February

'1977 to the present.

These do_cu=ents were obtained

,from URS/Blume during the week of October 13, 198,l'.

The contents of the transmittal documents marked s-ith an asterisk are in Appendix 2.1.2. "

It now reads:

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"Unlike the sparse trans=ittal docu=entation from ?Gand?.

to URS/31e=e, the docu=entation from URS/31u=e to PG andE was relatively complete, This is verified by reviewing the trans=ictaI documents listed in Log 2.1.1.

This Log contains trans=1ctal documents sent to PGandI from February 1977 to present.

These documents were obtained from URS/Blu=e during the week of October 13, 1981.

The contents of the trans=iccal documents marked with an asterisk are in Log 2.1. 2."

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(Section 3.3.1.3)

Delete the word " Appendix'".abd ' insert the word,"!:eg" (Section Delete tne word " Appendix" and insert the word " Log".

3.1.4)

. The fol'owing paragraph was deleted:

"Because of the recent development due to t,he discovery of an error in the annulus spectra, no conclusion can be drawn. on the structural adequacy of the annulus.

As this structure supports many equipment and piping systems, further in-depth review is necessary in the overall reverification program."

and the following inserted:

"Another design review of the Containment Structure was completed by PGandE on 1/22/79. This design review addressed the structural adequacy of the Containtrent Structure for the postulated 7.5 M Hosgri seismic event (Log 2.1)."

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To check the use of i:orrect. seismic inputs for the Containment Structure qua'lification, Two class I pla.tforms in-Containment were chosen at random. The Hosgri seismic accelerations used to qualify these platforms were found to be correct (Log 7).

"Because of the recent developments in the annulus area, PGandE is presently re-evaluating the structural adeqvacy of the annulus."

(Section Delete the words " qualified" and " qualification" and insert the words 3.3.1.4.2)

" analyzed" and " analyses", respectively.

. Delete the word " Appendix" and insert " Log".

Delete " vessel" in second line (RCS) and insert " system".

. In regard to Containment Purge Valves the following sentences were e

deleted:

"The zero period accelerations used in analysis are more conservative than the current Hosgri spectra.

Considering that the computations were 1

correct, the containment purge valves are qualified to the 7.5 M Hosgri earthquake. "

l and the following inserted:

"The accelerations used in analysis were reviewed, and are more conservative than the current Hosgri spectra."

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. In regard.to. Regenerative Heat Exchanger, the following was deleted:

"... using the Hosgri spectra as discussed in Appendix 3.1.2."

This qualification will require close scrutiny to properly evaluate the conclusion of the review."

and the following inserted:

" Examination of the information in-the W report, "Sunnary Report, Seismic Evaluation of Westinghouse Equipment for Postulated 7.5 M HosgH Earthquake" shows that the correct free field, tau filtered horizontal response spectrum was used in the qualification analysis."

For the vertical' direction, the W reoprt states that two-thirds of the filtered horizontal spectrum was used in the analysis. However, the Hosgri report states that twd-thirds of the unfiltered horizontal response spectra is to be used as the reponse spectra for the vertical direction (Reference 6, page 4-3). The vertical spectra input used by Westinghouse is in error."

A safety factor of 1.0 currently exists for the as-performed Westinghouse analysis. Use_ of the unfiltered spectrum in the vertical input would increase the vertical load by approximately 15% and invalidate the seismic l

qualification.

(SeeLog3.1)n (Section This paragraph was inserted innediately in front of Section 3.3.2.1:

3.3.2)

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"The Intake Structure, which serves both Units 1 and 2, is a seismic Class II structure.

However, because it houses the four Class I auxiliary saltwater pumps, two for each unit, it was reviewed by URS/Blume for the postulated 7.5 M Hosgri motions.

Except for the auxiliary saltwater pumps, safe shutdown in the event of a major. earthquake distribance is not considered essential for any part of the structure or its four main circulating water pumps."

(Section 3.2.2.1)

In first and second paragraphs delete " Appendix" and insert " Log".

(Section 3.2.2.2)

. Delete the word " Appendix" and insert " Log" in all three paragraphs.

. The following sentences, which appear in the bottom of the third paragraph:

"It was found by comparing the drawings used in developing the mathematical model of the Intake Structure with those in the PGandE file, that the PGandE file has later revision drawings.

The revisions are based on spot checks.

These minor changes will not affect the mathematical model used in the seismic analysis."

were changed to read as follows:

"It was found by comparing a few of the drawings used in developing the mathematical model of the Intake Structure with those in the PGandE file, that the revisions are minor and shall not affect the mathematical mod used in the seismic analysis."

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The following sen,tence.hhib is he only' stat 8 ment 7n this Section (Section 3.3.2.3)

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"No information was found to be given to equipment suppliers".

was deleted and the following inserted:

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"Because the Auxiliary Salt Water Pumps are the only major, equipment of the Intake Structure which were qualified by PGandE using the site design spectra, no design information to.equiprrent suppliers and qualifiers was required."

(Section

. Delete the word " Appendix" and insert " Log".

3.3.2.4.1)

. The following sentences, which appear at the bottom of the paragraph, were deleted:

"However, the design review of the Intake Structure (Appendix 7) was dated

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September 1976, and has not reflected the Hosgri seismic requirement.

Further investigation will be performed to determine the process of l

building qualification in the overall reverification program."

and the following inserted:

t "The design review of the Intake Structure for the Hosgri event was performed by URS/Blume in April 1979 and verified by PGandE in May 1979

)

(Log 7). The design review for the auxiliary saltwater pump compartments was dated September 1976 (Log 7).

It was later qualified for Hosgri as a 3

part of the Intake Structure. However, no formal documentation has been found to date."

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. Delete the word "hpendi3(" i,nd' insert " Log".

3.3.2.4.2) s s

. The following, which begins at the ce er of the paragraph, l

i "Although the 5/9/77 and 5/16/79 reports by URS/Blume differ in seismic structural responses, there is no need,to requalify the auxiliary salt water pumps if the building is truly rigid since the site seismic design spectra were used to qualify these" pumps. Rigidity of the building appears to be a good assumption based upon a cursory examination of the drawings, but this assumption will be verified in an engineering sense in the reverification study."

were modified to read as follows:.

"Although the 5/9/77 and 5/16/79 reports by URS/Blume differ in seismic structural responses, there is no need to requalify the auxiliary salt water pumps if the building is truly rigid. The rigidity of the building is documented in the URS/Blume report ('May 1979, Revised)."

(Section Insert "and the Component Cooling Water Heat Exchanger" at the end of 3.3.3.3) the first sentence of..the first paragraph.

That is, the sentence now reads:'

"In the Turbine Building, the major safety related mechanical equipment systems are Diesel Generator Systems and the Component Cooling Water Heat Exchanger."

. Delete " Appendix" and insert " Log" in paragraphs (3) and (5).

. The following new paragraph was added at the end of this Section:

"The Component Cooling Water Heat Exchanger was qualified by analysis by PGandE mechanical file 140.062G.. The analysis was reviewed for correct t

seismic input.

Results of the review show that the analysis used current Hosgri spectra.

The analysis is included in Log 3.1.5."

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3.3.3.4) l

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. The following sentence appeared !in the center of the second paragrap "PGandE implemented modifications to qualify the building frames, inte block and concrete walls and anchorage that were not qualifie.d by URS/

This was rewritten as follows:

"PGandE implemented modifications to qualify the floor beams, interior columns, interior block and concrete walls and anchorage that were not evaluated by URS/Blume."

Table 3.3.1 Drawing Nos. 463684 and 465131 were deleted from earlier report.

(Section The following' paragraph has been inserted ahead of Section 3.3.4.1 of 3.3.4) report:

"The Auxiliary Building is a Class I structure and houses service area both Units 1 and 2 of the Diablo Plant.

In this building are located facilities as the control room and the fuel-handling area. The buildi a reinforced concrete structure except for a steel-framed portion ove

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fuel-handling area at elevatio'n 140 feet.

The design ' chain and opposi symmetry is indirectly addressed in t'ie following sections on the desi interface between URS/Blume and PGandE."

(Section The last sentence of the first paragraph read as follows:

l 3.3.4.1)

"In thik memo, the steam anchorage drawings of the Auxiliary Building were discussed (Appendix I.4)."

This was changed to read as follows:.

l "In this memorandum, the main s, team line anchorage for the G Line in t

~ Auxiliary Building was discussed (Log ld)."

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..,.w p.x The second paragraph in theyearlisr report read agfollows:

"After discussions with the lead engineer of PGandE who was responsible for the seismic analyses of Auxiliary /Fue) Handling Buildings, it was learned that during the DDE analysis, PGandE developed, with the assistance of URS/Blume, computer programs "Dybox-2" and "Shewal-4" to compute the mass and stiffness properties of the mathematical model for the Auxiliary / Fuel HandlingBuilding(Appendix 1.4). The computations by computer were done at PGandE and the output was given to URS/Blume as input to compute the seismic reponse of the buildings (Appendices 1.4 and 2.4.2 - May 9,1977, pp.8 and 9)."

It now read as follows:

"After discussions with the PGandE responsible engineer in charge of the Auxiliary / Fuel Handling Building design, it was learned that, during the DDE analysis, PGandE developed - with the assistance of URS/Blume -

computer program "Dybox-2" and "Sherval-4" to compute the mass and dynamic properties of the mathematical model for the Auxiliary / Fuel Handling Building (Log 1.4)."

The fourth and fifth paragraphs in the earlier report read as follows:

"However, an examination of some telecon records (from 3/9/77 to 3/24/77 Appendix 1.4) kept in URS/Blume's file reveals that there were discussions on discrepancy of, weights computed by P0andE in the E-W and N-S directions for the DDE model, and a difference of 35% in the weight at Elevation 140',

computed by PGandE for the DDE model. and URS/Blume's computation in March 1977.

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of DDE model at Elevation 140' were fina11f"used in the Hosgri analysis, with no explanations as to how the weight difference was resolved. A detailed examination of the above will be performed in the overall reverification

~~

program."

and were replaced with the following:

"However, an examination of some telecon records (,from 3/9/77 to 3/24/77, Log 1.'4) kept in URS/Blume's file reveals that there was controversy of weights for the DDE model computed by PGandE in the E-W and N-S directions for all elevations except at E1.140. A difference of 35% in the weight at Elevation 140', computed by PGand E for the DDE model and URS/Blume's computation in March 1977 (Log 1.4) was also discussed. According to the pGandE responsible engineer, the weight controversy was resolved with URS/Blume. However, no documentation of resolution has been found to date."

Some building plans used in developing the dynamic model as reported in the URS/Blume report (Oct.,1979) were checked with the as-built building drawings. Although minor differences exist the dynamic model used in the analysis reasonably represents the structural configurations."

(3ection The third paragraph read as follows:

3.3.4.2)

"During the qualification of the Auxiliary Building it was decided to make a separate more detailed finite element model of the control room due to its importance. This model is the baisis for the control room qualification (Appendix 2.4.2).

Since the final control room spectra are higher than the preliminary spectra, a detailed review of equipment

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qualification will be herformed in'the final program,to be sure the'

' preliminary spectrd were not used.".

It now reads as follows:

"During the qualification of the Auxiliary Building it was decided to make a separate and more detailed finite element model for"d'etermining the vertical response of the control room floor due to its relative flexibility. This model is the basis for the control room qualification (Log 2.4.2).

Since the final vertical control room spectra are higher than the preliminary spectra, a detailed review of equipment qualification will be necessary in the overall re-verification program to ensure that the equipment was conservatively qualified."

(Section The following bottom half of the paragraph which read :

3.3.4.4.1)

"In the full length verification study, seismic input loads used for building verification ' report dated 1974, of the Aux [liary Building is in PGandE's Civil Engin-ering file (Appendix 7). The design verification report has an attached note indicating revision for Hosgri. This will be investigated further in the Reverification Program."

now reads:

"Because of the reported controversy of weights in the DDE model, a detailed review of the seismic analysis of the Auxiliary Building and its qualification should be' performed in the overall re-verification program."

The foklowing Table 3.3.4.4 did not appear in the earlier report.

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.Componejst 7.5 H llosgri Review I. j IdentifJcation Seismic Analysis By Coimnents I

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1; Borip Acid Transfer W

None

. Pump.

3 5.*CenthifugalChargingPunip W

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3.'ResidualIfeatRemoval.

W None

!$ ump' I 4'l Residual Heat Removal Heat None W

j.: Exchanger

5. Seal Water injecti,on Filter W

None 6

Boric Acfd Filter

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None

7. Boric Ac'id Tank W Review W Judged to posses correct

,i Auxiliary Building spectra based

8. Componentacooling Water Pump W Review on previous. seismic qualifications and correspondence history.

9. Auxiliary Feed Water Pump W Review

.(Hotor Driven)

10. Auxiliary Feed Water Pump Hotor PGandE Calcu'lations on file (See Appendix 3.1.4)

11. Auxiliary Feed Water Punip PCandE (Turbine Driven)

12. Auxiliary' Feed Water Pump Turbine PGandE r-E 03 na O

TABLE 3.3. 4.4 Seismic Qualification $nalysis of

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Hechanical Equipment. in Auxiliary Building I

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(Section Section 3 3.5.-l.1 as it appeared in the. earlier report. read as follows:

3.3.5.1.1)

" Containment Polar Crane The Containment Polar Crane is a gantry crane with trolleys and consists primarily of welded structural steel members a'nd fuIl moment resisting bolted connection. Results of a 3-D non-linear sdismic analysis are presented in the URS/Blume report, "Diablo Canyon Nuclear Power Plant.

Containment Polar Cranes Evaluation for the 7.5 M Hosgri Earthquake",

datedJ1y1979(Appendix 2.5.2).

The drawings and other design infonnation utilized for the modeling of the cranes are not referenced in the report. Nor are there any transmitti documen' ting'the transfer of these from PGandE to URS/Blume.

At present the only documentation that substantiates the above mentioned report are the calculations (Appendix 2.5.2).

These documents basically reflect that the design review was completed by URS/Blume and that the resultr concluded are valid.

The drawings include'd in the Appendix of the July 1979 report were checked against the model in the report (Appendix 2.5.2).

This. preliminary review 'shows that the info:mation was transformed correctly from the drawings to the model.?

This section was substantially changed and now reads as follows:

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Contain=ent Polar Cran'a

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The Containment Polar Crane is a gantry crane with trolleys and consists primarily of welded structural steel members and full moment resia -

ting connection.

The seismic analysis of the crane as presented in the Hosgri repo'rt consists of a 3-D elastic analysis of the crane in a parked position and a 2D inelas-

~

tic analysis of 'the crane in an unlocked position.

These f'inal results were transmitted to PGandE by URS/Blu=a through a letter dated September 6, 1971 (Log 2.5).

Results of the 2-Dl inelasti'c seismic analysis of the crane are presented in the URS/Blume report, "Diablo Canyon Evaluation for the 7.5 M Eos'gri Earthquake Progress Report", dated December 1978 (I.og 2.5.1).

The drawings and other design infor=ation utiliced for the =odeling of the crane are not referencec in the report.

Nor are there any transmittals documenting the transfer of these from PGandE to URS/31ume.

These above docu=ents reflect that the design review was completed by URS/31ume and that the re-suits concluded are valid.

Two drawings from L.

PGandE files were checked against both models in the report (Log 2.5.1).

This preliminary review shows that the information was transferred correct-ly from the drawings to the models.

In addition, the seismic input to the report was reviewed and

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is identical to the current Hosgri spectra.

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. ;& 'sQ f (Section This section was essentially totally revised. This hetion, which 3.3.5.1.2)

-J appeared in the earlier report, read as follows:

", Dome Crane The dome service crane is a maintenance crane located on top of the polar crane.'

PGandB was '

~

in the process of designing modification to comply with the 7.5 M Hosgri Evaluation.

As of May 5, 1981, PGandE halted this. process and is presently considering retaining a consultant to evaluate the consequences of assu=ed failure.

This is documented in the letter dated May 5, 1981 given in Appendix 1.5.

The docmancation of seismi.e qualification of this crane for the Hosgri requirement was not found in the current effort.

It will be verified in the overall re verification progra=. "

It now reads as follows:

" Dome Service Crane The dome service crane is a maintenance crane lo-cated on top of the polar crane inside.contain=ent.

Information available to date shows that the crane has been seismically qualified for the Hosgri requirements when it is in the parked position (URS/Blu=e Report, Log 2.5.1).

i Modifications are currently underway to isolate the.* dome service crane from =ovements of the polar crane during a seismic event (PGandE Memorandum, Log 7).

The crane has been qualified for this modified design for all modes of operation (Log 7).

The displacement time histories used in the qualification has been verified.ns being applica-bla."

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w: spwp; (Section The last sentence of Oe paragraph,of the earlier report read as 3.3.5.2.3) x follows:

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"However, spot checks need to be made to insure that modifications to

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construction drawings were properly done."

It now reads:

""As-built" drawings of the crane incorporating the field modifications have, been made.

Checks are required to compare the "as-built" drawings to the drawings used in analysis. This will be addressed in the long term program."

(Section The last sentence in this section of the earlier report, which read as 3.3.5.3.1)

~

follows, was deleted:

"Besides this design information, no other transmittals were found."

(Section The following first two sentences of this section read as follows:

3.3.5.3.3)

"The qualification of Turbine Building crane wa's jointly perfor=ed by ?GandE and URS/Blu=e.

Based upon design infor=ation presented in 3.3.5.3.2 above, URS/31u=e =odified the crane design to provdie tiedown of the crane trolley to the, bridge girder and lateral seis=ic res-traint to distribute the lateral seis=ic loads to both horizontal crane support girders (des-c !. bed in the 'dosgri report given in 3.3.5.3.2

.sbeve). "/

It now reads:

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"PGandE qualifi.ed the Turbine Buil' ding cranP with a rep $rt on the seismic arialysis and structural evaluation by URS/Blume.

t 3.3.5.3.2 above*, URS/Blu=e modified the crane design to provide tiedown of the crane trolley to the bridge girder and lateral seismic res-

~~

traint to distribute the lateral seismic loads to both horizontal crane support girders (des-cribed in the Hosgri report given in 3.3.5.3.2 above g The word " spot" was deleted before the word " checks" in the third line from the bottom of this section.

(Section The last sentence in this section reads as follows:

3.3.5.4.1)

"Some spot checks need to be made to check the accuracy of design information transmitted."

It now reads:

"Some checks need to be made in the overall reverification program to check the applicability of design information transmitted."

(Section The last sentence of the paragraph reads as follows:

3.

4.3.3)

"Some spot checks will be made to insure that these modifications were properly done."

It now reads:

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"In the scope of the 'overall reverification program,some checks will be made to insuri that these modifications were done2" -

(Section The following' sentence did not appear a.t the end of the earlier repor 3.3.6.2)

"This task will be accomplished in the overall revenification program."

~

(Section 3.3.7.1)

The first sentence in the second paragraph read as follows:

"As was noted in a summary by the PGand E Piping Group, the piping analysis was assigned to consultants URS/Blume and Earthquake Eng Sys tems ( EES). "

It now reads:

"For the initial. Hosgri re-evaluation effort, the piping analysis was assigned to consultants URS/Blume and Earthquake Engineering Systems (EES)."

The first two sentences of the third paragraph in the earlier report reads as follows:

"For support evaluation the seismic design input consists of either a 1

spacing table with seismic factors or the actual support force output from a piping analysis computer model.

PGandE uses a design guide for the seismic factors which they transmit to the consultants."

It now reads:

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"For support evaluation the fe'.ismiEdesign input cons.tsts of either a table listing seismic load factors as a function of suppo' rt spacing and building location or the actual support force output from a piping analysis computer model.

PGandE uses a forma 1 deskgn guide for the seismic factors which they transmit to the consultants."

The last; sentence of the fourth paragraph in 'the earlier report was deleted:

"This' task may be accomplished by further examination of PGandE files or perhaps by examining EES files."

(3 2)

Delete " valve qualifiers" at the end of the first sentence of this section and insert " testing organizations".

. " Appendix 3.2" located at the very end of the earlier report was deleted and "(Log 3.2.2)" inserted.

l The following sentence appeared at the end of paragraphs numbers 2 and 4.:

"Results were-then returned to PGandE."

The later report deleted the word " returned" and inserted " transmitted."

(Se'ctio n The last paragraph in the earlier report read as follows:

3.3.7.2.3)

" Copies of transmittals located thus far are located in Appendix 3.2.2."

It now reads:

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.-. c.. g y y "The documentation of i$ formation ti'ansferred will be,further addressed

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in the long term reverification program? ' Copies of transmittals identified thus far are located in Log 3.2.2."

(Scction The following sentence did not appear at the end of the second paragraph 3.3.7.2.4) of the earlier report:

"also q0alification analysis of several valves -was included in a Westinghouse report" (Ssetion The last sentence of the first paragraph read as follows:

3.3.7.2.5)

"Therefore, the validity of a valve. qualification depends on information transferred two steps earlier: from PGandE to the piping analyst and from the return of the analysis results from the piping analyst to PGandE."

It now reads:

"Therefore, the validity of a valve qualification depends on information transferred in earlier steps, from PGandE valve qualifiers to the piping analyat and the analysis results from the piping analyst."

In items numbered 3 and 4 of this section delete " valve qualifiers" and insert " testing organizations".

(Section The following appeared in1he earlier report:

3.3.7.3)

"An independent engineering review of the seismic qual-ification was perforced for the Safety Related EVAC equipcent (References 7 and 8) by EDS. Nuclear, Inc.

This EDS review concluded that the =ajority of the EVAC equipment is seis=ically ' qualified to the Hosgri re-quirement, and that with =inor mo'difications, the re-mainder will also be.#

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"As part of ttris interface review, the-seismic accelerations that'were used as input was checked for correctness. Out of 5 inputs checked, one of them was incorrect.

"The field work is given in Appendix 3.3.1.

Since the qualification accelerations are larger than the Hosgri accelerations, these particular errors were not of consequence."

'i It was replaced with the follcuing:

" PGandE qualified the ' sixteen groups of co'.d-shut down

~

required HVAC equipment with the analysis report pre-pared by.EDS Nuclear, Inc. (Table 9-1, Reference 6).

One group of' equipment was chcsen for review frem each of the four buildings: Intake, Tuibine, Auxiliary, and Contain=ent.

The qualification analyses of the HVAC equipment, listed below, were checked for correct use of current Hosgri spectra.

Intake - exhaust fans E-101, 102, 103, and 104.

Turbine - supply fans S-67,68,and 69.

Auxiliary - supply fans S-31 and 32.

' Contain=ent - forced draft shutter damper 1

The two equipment groups in the Intake and Turbine Buildings were found to have used correct Hosgri-spectra.

However, calculations for supply fans S67, 68, and 69 were found to have used incorrect and un-conservative seismic inputs.

In addition, the forced draft shutter da=per qualification showed incorrect l

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aseis=ic definitiori because gr.avity had not been added to the vertical. accelerati5tr (Log 3. 3.'l).

The'?orced draft shutter damper has a sufficient facto'r of safe'ty and is not affected by this error.

The safety factors in the calculations for supply fans S67, 68, and 69 are not

~

clearly determined.

Therefore, the significance of the input error has yet to be established.#

(Section The following sections 3.3.7.4)

3. 3. 7.4, 3.3. 7.4.1, 3.3. 7.4.2, 3.3.7.4.3, 3.3.7.4.4 and 3.3.7.4.5 appear in the earlier report:

"3.3.7.4 Heating, Ventilating and Air Conditioning Duct 3.3.7.4.1 The majority of HVAC ducts required for cold shutdown has been qualified by PGandE, with, the remainder of the engineering being done by EDS Nuclear.

?GandI architects, HVAC engineers, and civil engineers all colla-borated on the duct design.

InformatioE flow between these groups is docu=ented in Appendix 3.3.2.1.

3.3.7.4.2 The HVAC information.in Appendix 3.3.2 was supplied by the responsible ?GandE engineer.

Containment duct computations could be easily be' found.

This will be reviewed at a later date. #

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3.3.7.4.3 A random sampling.of.the duct qualification m~

calculations was. checked.for, seismic input (Appendix 3.3.2)., Six of the twenty-seven HVAC details listed in Appendix 3.2.2.2 wei e chosen at random.* In contrast to the randon sampling shown above,_all, seismic inputs to.

the Fireproof Ducts were checked against current Hosgri Spectra (Appetidix 3.3.2).

3.3.7.4.4 Five HVAC Details have Hosgri accelerations.'.

correctly.used and one (Detail 4, Drawing 50'566) has Hosgri accelerations. greater than 4

the value in the calculations.

All spectra for the Fireprorfed Ducts were found to be correctly used (Appendix 3.3.24 3). "

3.3.7.4.5 One HVAC Detail (Detail 4, Drawing 504566) will be analyzed at a later date.a t

I The above replaced with the following:

"3.3.7.4 HVAC Duccini; The HVAC ducts required for cold shutdown have been qualified by PGandE.

Architects, HVAC and civ5.1 engineers of PGandE all collaborated on the duct design.

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Information flow between these groups is docu=ented in 1.og 3.3.2.1."

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Class I duct at Diab-lo. Canyon. Nuclear Power Plant is u

qualifie,d, by analyri-Jg its supports.

lome HVAC systens in each of the four buildings '(Intake, Turbine, Contain-il

. ment, and Auxiliary) were checked -for required cold shutdown.

A random sample of the ducting qualifications in the Auxiliary Building was selected and checked for the l

applicability of seismic input. - Five of the twenty one HVAC support details listed in Log 3.2.2.2 were re-viewed.

All were found to have used correct Hosgri seismic accelerations.

The only piece of Hosgri required HVAC' equipment in the Containment Building is the Forced Draft Shutter Damper (Table.9-1, Reference 6).

All ducting in this area is Class II, therefore the seismic inputs were not checked (Log 3.3.'2.3).

Hosgri duct support qualifications for the 4KV Switch-gear Room HV System have not been located as of October 28, 1981.

This is the only FVAC System required for cold shutdown in.the Turbine 3cilding.

The reverifica-tion program will address this area further.

Addition-ally one of three shop modified duct supports in the Turbine Building was checked for seismic input.

The calculations were found to have used correct accelera-tions.

The HVAC System servicing the Auxiliary Salt b'ater Pu=p Rooms in the Intake Structure is required for cold i

shutdown (Table 9-1, Reference 6).

Class I ducting to

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the exhaust fans is'lnstilled under specification

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a 8841 (L6g f.3.2.3).

The duct support q'ualifications I

for Hosgri seismic inputs were not available on October 28, 1981.

PGandE calculations dated November 2; 1981 use correct accelerations (Log 3.3.2.3).

Additionally, the seismic input to the fireproof duct-ing was reviewed and found to be qqrrectly, applied in all cases.*

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Section 3.3.7.5.1

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Insert the word "Athouth" at the very beginning' Bf the firs't' paragraph of th earlier report.

Also delete the word " qualifying" in the fourth line of hte-first paragraph of the earlier report and insert " analyzing".

The second paragraph of the earlier report read as follows:

~~

The interface betweca PGandE and Westinghouse allowed PGandE se spectra information to Westinghouse, and for Westinghouse to send the results back to PGandE.

The later report inserted " analysis" between "the" and "results" in the third and fourth line cited above.

The third paragraph of the earlier report read as follows:

The Wyle Labs and'PGandE interface allowed PGandE and Wyle Labs to exchange informtion regarding Hosgri spectra, test spectra and test procedures.

Also, Wyle transmitted test results back to PGandE across this interface.

It now reads:

The Wyle Labs and PGandE interface enabled PGandE and WVie Labs to exchange information regarding Hosgri spectra, and allowed WVie Labs to transmit proposed test procedures.

Also, Wyle transmitted formal test reports back to PGandE across this interface.

Section 3.3.7.5.2 The earlier section read as follows:

12/17/81 1

HOSGRI INSERT

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Document Name:

HOSGRI INSERT

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Requestor's ID:

KATY Author's Name:

Buckley Document Comments:

PIIASE RETURN THIS SIEET WHEN YOU SUBMIT CORRECTIONS 2E i

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t No documentation has been found in the current work regarding the transmittal of information from PGandE to estinghousN.'

N It how reads:

4

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Documentation of one transmittal of seismic information from PGandE to Westinghouse has been found to date (PGandE Project Letter 1962).

However, this transmittal contains only the Newmark earthquake acceleration time histories for the Containment inte'rior af certain elevations.

22 Section 3.3.7.5.3 The earlier section read as follows:

The only evidence of transmittals from Westinghouse to PGandE encountered to date is the existence in the PGandE files of the Westinghouse report

" Summary Report on Seismic Evaluation for Postulated 7.5 M Hosgri" (Reference 9).

It now reads:

Results of the re-evaluation for Hosgri requirements of Westinghouse supplied equipment were submitted to PGandE in the Westinghouse report

" Summary Report on Seismic Evaluation for Postulated 7.5 M Hosgri" (Reference 9).

One transmittal from Westinghouse to PGandE has been found to date (Westinghouse letter PGE-4231, dated 9/5/80).

It describes the results of an evaluation of Westinghouse supplied equipment to assess the affect of a fifty percent increase in the Hosgri vertical ground spectra (Log 3.4).

Section 3.3.7.5.4 The earlier section read as follows:

12/17/81

'2 HOSGRI INSERT

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r r spectra or test procedure information frbii PGandE to'Ny'id'~llb([~#'#'

It now reads:

+

No documentation has been found to date regarding formal transm spectra from PGandE to Wyle Labs.

Seismic inforation and requirements

~

4 were informally exchanged between PGandE and Wyle Labs du July 9 and July 13 of 1977 (PGandE/Wyle meeting agenda Ju'ly 9,1 reference to meeting in Wyle letter dated July

, and 15, 1977, both in Log 3.4)

~

Section 3.3.7.5.5 The earlier section read as follows:

The only transmittals from Wyle Labs to PGandE found thus far are Labs test reports and test procedure's.

Two of these that were examined are Wyle Labs Test Procedure No. 3642 and Test Report No. 58255 (Referenca 10').

It now reads:

Two documents that Wyle Labs transmitted to PGandE have been found.

These are Wyle letter dated July 15, 1977 and Wyle Feasibi'loity/ Trip Report dated August 5, 1977.

Thes.e do not contain specific technical data, but discuss general approaches proposed for qualifiction of Class 1E electrical equipment.

Other transmittals from Wyle Labs to PGandE are Wyle test reports and test procedures.

Two of these that were given cursory review are Wyle Labs Test Procedure No. 3642 and Test Report No.58255 (Reference 10}.

Section 3.3.7.5.6 The earlier section read as follows:

12/17/81 3

H0SGRI INSERT

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No documentation has been found to date regarding requalification of e

electrical equipment or instrumentation if analysis,'b'y eTIMr'PYdidFor other Parties.

+

It now reads:

~

~~'V Requalifiction of electrical equipment and instrumentation (other than Westinghouse NSSS equipment) by analysis was done in-house at PGandE.

Section 3.3.7.5.7

'~'

The earlier title of this section was " Westinghouse Requalification" this was changed to " Westinghouse Requalification of Electrical and Instrumentation Equipment".

The last sentence of the earlier section read as follows~:

The positive results of this comparison were communicated to PGandE by Westinghouse in Westinghouse Project Letter PGE-4231, Revision 1, dated September 5, 1980'sent to D. V. Kelly (Reference 12).

It now reads:

Westinghouse also assessed the effect of a 50% increase in the vertical Hosgri spectra on Westinghouse supplied equipment.

Results of this evaluation were transmitted to PGandE in Westinghouse Project Letter PGE-4231, Revision 1, dated 9/5/80 (Log 3.4).

Section 3.3.7.5.8 Item 1 of the earlier section read as follows:

A PGandE memo, dated 11-9-77, from O. Steinhardt contains comments on test i

spectra contained in Wyle Test Report No. 26286.

i It now reads:

12/17/81 4

HOSGRI INSERT

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..1-A PGandE memorandum, dated 11-9-77, con.

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r tains comm nts on proposed test e

spectra contained in Wyle Report No. 26286.

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d' # 'M Item 2 of the earlier section read l,7as f611o' wsi *

~

,e-Wyle Test Procedure No. 3642, dated 11-30-77, is signed and approve PGandE personnel.

It now reads:

Wyle Test Procedure No. 3E42, dated 11-30-77 is, signed and approved appropriate PGandE personnel.

The last. paragraph of this section read as follows:

PGandE internal memorandum indicate that General Electric w Wyle Labs requaLIFICATION TESTS OF THE $.!$KV Vital Switchgear (Appendix 3.4).

Furhter investi.gation will be required to determine General Elect'ric's role on requalification.

If necessary, information transmittals across that interface will be examined.

It now reads:

PGandE internal memorandum indicates that General Electric was Wyle Labs requalification tests of the 4.16kV Vital Switchgear and provided input to the test procedures.

Test requits are included in Wyle Labs Test Report No. 58255-1, dated 8/22/78.

Section 3.3.7.6 This earlier section consisted of three subsections (3.3.7.6.1, 3.3.7.6.2, and 3.3.7.6.3) which appear below.

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12/17/81 5

HOSGRI INSERT

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Section 3.3.7.6.1

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The supports for the Electrical Raceways a're found indiscriminate 1y throughout the main buildings...With in exiess of six%undred unique types of support detalls.'

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The PGandE Civil Engineer responsible for, electrical Raceways provided the qualification documentation.

Each support detail is qualified to the Hosgri by simplified computation.

Each Detail is assumed to span a maximum of eight feet.

Section 3.3.7.6.2 With such a large volume of material, a random sampling approach was employed.

The Hosgri seismic accelerations were checked for ten support details (Appendix 3.4.2.3).

In addition the program employed in' September 1981 by PGandE to requality the raceways in the Annulus section of Containment was

~

checked.

The Annulus region was closely examined for the following three reasons:

No transmittals of Annulus drawings from PGandE to URS/Blume were located and URS/Blume does not, at present, have the drawings.

Preliminary

~

spectra differing from the 5/9/77 spectra was issued for Containment.

Different spectra (7/21/77) superceding the 5/9/77 Hosgri Report was issued (Appendix 2.1.2).

Seven of the ten calculations checked (S86, S93, S166,,5251, S370, 5415, S432) did not use correct seismic accelerations for 4% damping.

The bolted cable trays can take advantage of 7% damping for the Safe Shutdown Earthquake (Regulatory Guide 161, Appendix 3.4.2.3).

The Hosgrispectra for most locations lists only 2%, 3%, and 4% d'aming.

Possibly the incorrect accelerations resulted from interpolations of the 4% Hosgri spectra.

Detail 5415 used Hosgri spectra issued before May 9,

)

1977.

12/17/81 6

HOSGRI INSERT

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PGandE's Electrical Raceway Seismic Requalification Program for Unit 1 (Appendices 3.4.2.2, Item 1) was also chic'ked Apperidiin.Tf3pYtFN

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using the same Raceway. Details as above. 'Four of the ten calculations examined were incorrectly notW on,the check list (Appendix 3.4.2.2,

. Item 1).

~

l'

Section 3.3.7.6.3 In summary, two of the ten Raceway Details (5414, S432) were stiesced above allowable factor of safety (Appendix 3.4.2.3, Item 3).

Two additional Raceway Details (593l S147) show no requalification after the Hosgri spectra were issued on May 9, 1977.

The earlied section was repla.ced with the following:

Section 3.3.7.6 Electrical Raceways The supports for the Electrical Raceways are found throughout the main buildings.

Originally it was understood that about 600 individual unistrut support designs were de'veloped.

In practice however, only about 400 were act*: ally used and re-evaluated for the Hosgri earthquake.

The PGandE civil engineer responsible for electrical Raceways provided the' qualification documentation.

Each support detail is qualified to the Hosgri by a i

quasi-static seismic analysis.

[

This analysis is keyed to' the PGandE design standard that requires supports to be placed at 8' intervals or less.

With such a large volume of materia-1, a random sampling approach was employe The Hosgri.seis.mic accelerations were checked for ten support details (Log 3.4.2.3).

In addition, the program employed in September 1981 by PGandE to requalify the raceways in the Annulus section of Containment was checked.

"~

The Annulus region was closely examined for the following three reasons:

No transmittals of Annulus drawings from PGandE to URS/Blume were located and URS/Blume does not, at presetn, have the drawings.

Preliminary i

12/17/81 7

HOSGRI INSERT

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spectra differing from the 5/9/77 spec........

tra were issued for Containment.

New spectra (7/21/77) superseding the S/9/11 Hosgri' (Log 2.1.2).

ei i

The quasi statit qualification was based upon applicat

~~

~

response spectra.

floor spectra, assuming that each conduit w to no more than 40% 'of the cross sectional area e amounting they were filled to less than 40%.

On the average however, The qualification plan provided for using 7%. damping if sat results were not obtained in the original analysis.

ory use of R.G. 1.61 damping for bolted structures.

This is based upon Of the ten calculations that were reviewed one was explicitly based upon accelerations with 7% damping.

associated Six of the sample of 10 used acceleration values that did not corr the Hosgri floor spectra for the location of interest spond with Of the 6 it appeared that possibly 2 used reduced spectra consistent with 7% dampin explicitly stating that this was done.

, but without Four of the sample of ten used acceleration values that did not cor the Hosgri floor spectra.

respond with design spectra.

These cases appear to be an incorrect application of values corresponding toFurther checking showed that 2 of these 4 7% danping curves of a preliminary issue of the des spectra.

No design spectra corresponding to 7% damping were routinely issue Acceleration values for this damping were obtained by taking 70% of damping values.

e 4%

As a. result of hte use of inapplicable spectra in the first sample additional random sample of ten support details was checked.

, an It was found that five of the sa'mple of ten used acceleration values that did not co the Hosgri floor spectra.

with 12/17/81 g

~.

HOSGRI INSERT

~

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c 1

e. ;.

In summary, nine of the twenty raceway support seismic calculations were to have been done with inapplicable spectra. 'Eurther chick'ihg#indic'iNfik5at

' ~

two of the nine may have exceeded allowa.ble stresses if the correct spectr values were used.

Since the quast static calculatiion method employed is quite conservative, the 6v'erstress may be reduced to'w'ithin allowable stress if a refined method is used for design.

9 E

o e

0 e

e 12/17/81 9

HOSGRI BSERT e

SECTION 4.0 I

g.

To simply identifying.the changes between the earlied and later sections below

\\

Ihavedesignatednumberedmarginal,lineswhichcorrespondswhere]changewas made in the later section.

For example marginal line No. 1 in earlier report should be compared to marginal line No. 1 in later report.

. Summary and Conclusions (Earlier Report)

.i This report has been prepared in response to the NRC request for a prelimin report on the PGandE Hosgri Reverification Program. As requested, it covers a

{

review'of the applicability of scismic design and qualification information for 8-the Hosgri eqrthquake that may be considered to be associated with design interface.between PGandE and URS Blcme. As illustrated in Figure 3.1, the design applicability was reviewed for the entire seismic chain beginning with basic plant design information developed at PGandE, through the URS/Blume interface, then back to PGandE and on to the equipment qualifiers.

S In this preliminary report,'the goal was to review applicability of all major

4..

design issues and identify all detailed equipment qualifications for later

. review, although a certain level of sample checking was performed.

To accomplish teh basic cbjective, the review was performed on a building by building basis.

The findings by building are reported below.

W Summary and Discussion (Later Report)

N This report has been prepared in response to the NRC request for a preliminary report on the PGandE Hosgri Reverification Prognam. As requested, it covers a review of the design chain, opposite hand symmetry and the applicability of seismic design and qualification information for the Hosgri earthquake that may be considered to be associated with design interface between PGandE and URS/Blume.

As illustrated in Figure 3.1, the design applicability was reviewed for the entire seismic chain beginning with basic plant design informtion developed at PGandE, through the URS/Blume interface, then back to PGandE and

{S on to the equipment vendors and consultants.

12/17/81 10 H0SGRI INSERT

In this preliminary report, the goal was to review the design chain, opposite hand symmetry and applicability of all major desigri issues and identify all

+

detailed equipment qualifications for later review.

Because of a large number of these, a certain level of sample checking was performed.

To accomplish the

~

basic objective, the review was performed on a buildign by building basis, 1

except i the case of general equipment, such as piping systems, HVAC systems, etc., whcih were grouped together for all buildings.

Thefindings,bybuilding[f and general equipment, are reported below.

.. ~

Containment (Earlier Report)

The Hosgri evaluation was performed using the original models for the DDE evaluation based upon 1970 drawings.

These drawings were reviewed against

,4 current revisions.

No CHANGES WERE SUFFICIENT TO REQUIRE RE-MODELING.

There were few formal transmittals from PGandE to URS/Blume in the early time period, because engineers from the two organizations were workirig together as though in one organization.

The annulus area lacked formal transmittals and was found to have been model using the Unit 2 configuration, as was known.

With the exception of the aonulus, the containment buildin'g models were' based upon applicable drawings.

URS/Blume performed the seismic analysis of the containment building and I

supplied several well documented reports to PGandE.

PGandE received the well documented seismic results from URS/Blume. Building response spectra were supplied to equipment suppliers to permit equipment qualification.

The applicability of the design informtion for the following major equipment was verified:

12/17/81

'll HOSGRI INSERT

=-

Reactor Coolant System (RV, SG, PCP, Piping)

Hydrogen'Recombiner Containment Purge Valves RegenerativeHeatExchangers\\1 Containment Fan Coolers Other equipment is discussed subsequently.

Containment (Later Report)

The Hosgri evaluation was performed using the original models for the DDE evaluation based upon 1970 drawings.

Current drawings were reviewed for Q revisions and changes.

No changes were sufficient to reuqire re-modeling.

There were few formal transmittals from PGandE to URS/Blume in the early time period, because engineers from the two organizations were working together as though in one organization.

~

The annulus area 1,acked formal transmittals and was found to have been modeled using the Unit 2 conf.iguration, as was known.

With the exception of the annulus, the Containment Building models were based upon applicable drawings.

URS/Blume performed the seismic analysis of the Containment Building and supplied several well documented reports to PGandE.

PGandE received the well documented seismic results from URS/Blume.

Building respone spectra were supplied to equipment suppfliers to permit equipment qualification.

The applicability of the design informtion for the following major equipment was verified:

Reactor Coolant System (RV, SG, PCP, Piping)

Hydrogen Recombiner Containment Purge Valves Containment Fan Coolers 12/17/81 12 HOSGRI INSERT l

---,.-,~[,-

.--[._-

--,.--. --._------_r, e-<--_

,,---m_

~

For the case of the Regenerative Heat Exchanger, Westinghouse used an incorrect vertical response spectra in the seismic analysis.

Use of the correct vertical spectra would increase the loads and could reduce the safety factor to unacceptable levels.

Other equipment in the Containment Building is discussed in the equipment section.

1 Intake Structure (Earlier Report)

The seismic analysis of the Intake Structure was based upon information contained in a transmittal from PGandE in 1976.

This transmittal was examined.

P URS/Blume issued a report on the seismic analysis of the Intake Structure in April 1977.

After modifications, it was finalized in 1979. The drawings used to prepare the model were outdated, but building revisions were minor and did not affect the' analysis.

The qualification of auxiliary salt water pumps was based upon the ground level motion, which conside,rs the building to be rigid.

Dur to the low elevation of g

pumps within the buildihg itself, this is considered a sound assumption.

Nevertheless, it will be checked in the reverification effort.

Intake Structure (Later Rep rt)

The seismic analysis of the Intake Structure was based upon information contained in a transmittal from PGandE in 1976.

This transmittal was examined.

URS/Blume issued a report on the se.ismic analysis of the In,take Structure in April 1977.

After modifications, it was finalized in 1979.

The drawings used to prepare the model were outdated, but building revisions were minor and did not affect the analysis.

Turbine Building (Earlier Report)

There was no design interface between PGandE and URS/Blume in the initial aspect of the design and qualification because UR Blume had design 12/17/81

~13 HOSGRI INSERT

gil d yg f k ni k h responsibility for the building, the drawings were prepared by PGandE Design i

Drafting.

The building had to be modified to qualify it for the Hosgfi earthquake.

All relevant drawings have been obtained, and a complete design verification effort completed by PGandE was documented.

The in-depth verification was left to the final program since this building is lessimportant than certain others.

N The diesel generator, including the fuel syst'm and starting air' reviewers, was e

reviewed.

The correct seismic input informtion was used for this safety related equipnient.

Turbine Building (Later Report)

There was no design interface between PGandE and URS/Blume in the initial aspect of the design and qualification because URS/Blume had complete design responsibility for the building.

< d.

The building had to be modified to qualify it for the Hosgri eqrthquake.

All relevant drawing nurrberY have been obtained, and a complete design verification

. effort completed by PGandE was documented.

The in-depth verification was left to the final reverification program since this building is less important than certain others.

~

The diesel generator, including the fuel system and starting air receivers, was reviewed.

The correct seismic input information was used for this safety related equipment.

I Auxiliary / Fuel Handlina Building (Earlier Report)

The Hosgri requalificaiton of the Auxiliary Building was performed with the same models used in the earlier DDE analysis.

This model was developed jointly by PGandE and URS/Blume using specialized computer programs for computing building properties.

Reports of reviews of building. properties and configurations were noted prior to initiation of the Hosgri analysis.

The applicable drawings were use dnad referenced in the building analysis.

Records 12/17/81 14 HOSGRI INSERT

--g

,,,----g--

,,,n_

s,

~

of discussions on model properties, however, suggests that limited checks on mass and stiffness should be made in the verification study.

In additioi, a separate refined fini. e element analysis was.used for the control

'X t

Spectra from this' refined analysis which were higher than the i

room.

preliminary spectra were used for qualifiction (mainly by Westinghouse) of i

control room equipment.

~

Auxiliary / Fuel Handling Building The Hosgri requalifiction of the Auxiliary Building was performed with essentially the same models used in the earlier DDE analysis.

These models were developed jointly by PGandE and URS/Blume using specialized computer programs for computing building properties.

Reports of reviews of building properties and configurations were noted prior to initiation of the Hosgri l

analysis.

Some building plans used in developing the dynamic model a's reported in the URS/Blume report were checked with the as-built building drawings.

~

Although minor dif,ferences exist, the dynamic model used reasonably represents the structural configurations.

Records of discussions.on model properties however, suggests that" limited checks on mass and stiffness should be made in 1

the verification study.

Cranes (Earlier Report)

For most of the cranes, the design information was provided to URS/Blume on an informal basis.

For each of the major cranes in the plant, URS/Blume issued a complete design report.

In addition, a design review was c,ompleted by 4

URS/Blume,for the Containment Polar Crane.

These are positive findings, however, in some cases the qualification report does not have a complete record of drawings upon which models were based.

Alo during the Hosgri requalification, some of the cranes were modified with the addition of holddowns, lateral restraints, etc.

Additional checks to ensure analysis reflected the as modified drawings would be beneficial.

12/17/81

'15 HOSGRI INSERT

t...

..o Cranes (Later Report)

For the most of the cranes, the design information was provided to URS/Blume on an informal basis.

For each of the major cranes in the plant, URS/Blume issued a complete design rep' ort.

In addition, a design review was completed by URS/Blume for the Containment Dome Service Crane.

These are positive findigs, d

however, in some cases the qualificaiton report does not have a complete record sf drawings upon which models were based.

Also during the Hosgri requalificaiton, some of the cranes were modified with the addition'of holddowns, lateral restraints, etc. Additional checks to ensure analysis reflected the as-modified drawings would be beneficial.

Outdoor Water Storage Tanks (Earlier Report)

The informtion transmittal from PGandE to.URS/Blume for qualification of the outdoor tanks was done on an informal basis since the,two organizations were working together as a team., Substantial modifications were made to these tanks in the course of the Hosgri requalifications.

Indirect interfaces existed in the analysis of these O nks via Harding-Lawson, soil consultants, Since one of

'the modifictions was to dig out under the tank foundation and strengthen this structure.

Communications were informal in many cases.

Based upon the information that has been reviewed, there is no reason fo.r concern.

However, this area will be reviewed in much more detail in the final program because there was an indirect interfacecand because of information communications.

Outdoor Water Storage Tanks (Later Report) i The information transmittal from PgandE to URS/Blume for qualification of the outdoor tanks was done on an informal basis since the two organizations were working together as a team.

Substantial modifications were made to these tanks in the course of the Hosgri requalifications.

Indirect interfaces existed in the analysis of these tanks via Harding-Lawson, soil consultants, since one of the modifications was to dig out under the tank foundation and strengthen this

.j 1 structure.

Communications were informal in many cases.

However, this area c

Y 12/17/81 16 HOSGRI INSERT

,--+------i-.w---

,w

,.ww-,----

-.--------,-------,-----,-.g-,s.---

g-

.-ew--

,w----

=

will be reviewed in much more detail in the final program because there was an indirect interface and because of informal communications.

General Equipment and System (Earlier Report)

None General Equipment and Systems (Later Report) 1.

Piping and Valves s

A large number of transmittals were documented in which information was exchanged between PgandE and consultants.

However, the contents of the transmittals have not yet been located, and therefore, the correctness of analysis results output could not be verified at this time.

2.

HVAC Components and Ducting HVAC components and ducting qualification were revi'ewed for correct seismic inputs.

In two cases, HVAC components were qualified with incorrect seismic inputs.

One of the two cases dod n,ot consider gravity in the computation of vertical r:sponse.

But because of a large safety factor, this qualification is satisfactory.

For the second case, additional review shall be necessary.

For the HVAC ductings reviewed, qualifications for two cases were not found prior b.0ctober 28, 1981.

However, one of these two HVAC ductings has sinct. been qualified.

3.

Electric Equipment, Instrumentation and Conduits A cursory review of qualificaiton procedures for electrical equipment and instrumentation show no error for the seismic inputs.

In the case of electrical conduits, nine of the sample of twenty support designs checked did not use seismic acceleration values consistent with 12/17/81 17 HOSGRI INSERT

1 the Hosgri spectra.

PgandE is currently reviewing qualifications of all conduti support details.

The annulus zone of the Containment Building was not studi.ed as part of this effort since zone is" undergoing re-analusis at the present time. The annulus zone vertical response model is mainly composed of structural steel and equipment.

It is estimated to have the highes,t ratio of equipment to structure

weight of any part of the plant. The annulus horizontal response,is coupled with and dominated by the response of the Containment intbrior structure.

Elsewhere in the main safety related buildings.

Containment, Auxiliary and Intake, the floor response spectra will be relatively insensitive to equipment weight since the models are dominated by the mass and stiffness of structural concrete.

x The applicable building drawings were found to be used in developing the

- dynamic models.

Although minor differences exist between building drawings used in the dynamic analyses arid the as-b'uilding drawings, these differences

-will not appreciably change the building response as it is insensitive to minor

, changes in building dynamic model parameters.

~

Conclusion (Earlier Report) i In the course of this preliminary work a great deal of material has been examined.

A certain amount of assurance has been established that there are no j

additional explicit errors, and,several areas have been found that suggest more detailed review in the reverification effort.

As discussed ~at the outset, this review was conducted on the engineering material itself.

The poresent findings and conclusions are independent of the normal convplutions of the design process, and whether work was done formally of informally, with the exception of course that informal transmittals, etc.

[

t require additional verification of the end product.

I 1

T'he analysis of the major buildings in the plant were based upon drawings that

/

represent the correct building configuration, even though in many cases drawings were revised after the analysis was complete.

The major items of HOSGRI INSERT 18 12/17/81

safety related equipment in the Containment Building were qualified with correct response spectra.

The Containment Building and Intake Structure were i

scrutinized in more depth than the other buildings.

The Inlet Structure and the safety related auxiliary pumps were qualified using applicable drawings and spectra.

As with any review of any design pmject, some errors and some mistakes real or apparent will be found.

In the present limited effort certain such findings In one case, an item of HVAC equipment was qualified wif.h the wrong arose.

spectra.

The reviewer compared it to the correct spectra and found it was satisfactory in view of a large safety. factor.

l The documentation on the unistrut design details were misleading to the reviewer arid one or two conduti supports appeared to be qualified with the wrong spectra.

There will be reviewed thoroughly in the final report, but _it is expected tat resolutions will result, since deeper iriquiry did pro' duce resolutions in other cases.

In conclusion, the limited review performed to data s'howed explicitly that the reactor coolant system ~and other major equipment were qualified using correct design information and no information has come to light thus far that calls the safety of the plant into question.

Some areas have been foend where further review is indicated, primarily because of a lack of ready documentation of the applicability of the design information.

Section 5.0 Conclusins (Later Report) s In the course of this. preliminary work a great deal of material has been i

reviewed.

The review was conducted on the engineering material itself.

The present findings and conclusins are independent of. the normal convolutions of l4 the design process, and whether work was done formally or informally, with the i'

excepti5n, of course, that informal transmittals, etc. require additional verification.of the end product.

l 12/17/81

'19 HOSGRI INSERT

. ; s ?..

.-b

~

q The design information reviewed that was transmitted to and used by URS/Blume was found applicable.

The design information transmitted from URS/Blume to PGandE was also found applicable.

In general, correct spectra were transmitted from PGandE for' equipment qualifiction.

At this interface, cases of inapplicable seismic response spectra for equipment qualifiction were identified. These appear to be isolated cases.

The overall concluysion drawn from the work to date is that the seismic qualificatiori'fo Diablo Canyon for the postulated Hosgri Earthquake is satisfactory in its main features.

The building responses are based upon use of applicable design information and seismic responses of the buildings are not overly sensitive to minor changes in parameters.

Therefore, the floor response spectra are not expected to change in a significant way in the futture if additional desing discrepancies are found.

The design interfa,ce between PgandE and URS/Blume for the Hosgri requalification of Diablo Canyon Nuclear Power No. I has been sufficiently reviewed.

ThisreviewiasmettheNRCrequesttoensurethatthereareno

' systematic or major design discrepancies.

A more complete review

will be performed from the present time to power ascension.

The completion of this program will constitute a detailed reverificatio of the seismic adequacy of the Diablo Canyon Nuclear Power Plant No. 1.

" Seismic Reverification Program, October 30, 1981, Robert L. Cloud Associates, Inc., Berkeley, CA I

)'

I 5

e e

12/17/81 20 HOSGRI INSERT

.

ML20210U740

Text

SUBJECT:

Enclosure:

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