Text

Confirms 820217 Meeting to Present Governor Views Re Seismic Reverification Program & Selection Procedure for Consultants,Per 820205 Telcon.Related Documentation Encl
	ML20212A076
Person / Time
Site:	Diablo Canyon
Issue date:	02/05/1982
From:	Greenberg P; CALIFORNIA, STATE OF
To:	Harold Denton; Office of Nuclear Reactor Regulation
Shared Package
ML20211Q614	List: ML20211Q609; ML20211Q667; ML20211Q903; ML20211Q958; ML20211R025; ML20212A005; ML20212A076; ML20212A521;
References
	FOIA-86-151 NUDOCS 8703030278
	Download: ML20212A076 (12)
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flate of California I

aovannon s orrica SACRAheENTO 988f 4

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(916) 323-6237 February 5,1982 Mr. Harold Denton, Director Office.of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission Washington, D.C.

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Dear Mr. Denton:

Per'our telephone conversation today, this letter confirms that at 9 :45 a.m., Wednesday, February 17, in San Francisco, the Governor's representatives will meet with the NRC staff to present the Governor's views regarding the seismic reverifica-tion program for Diablo Canyon. and the procedure by which con-sultants to perform that reverification should be selected.

The NRC will arrange for transcripts of the meeting to be prepared,and made available to all interested parties.

We understand that the NRC staff will make no recommenda-tions to the Commission regarding these matters prior to this meeting, since the meeting is an integral part of the process by which the Governor's comments will be conveyed.

Finally, we appreciate your confirming that although the Commission has asked that the Governor submit his comments on this matter within seven days of the Commission's issuing its " Phase II" report, scheduling conflicts have necessitated the February 17 date.

Therefore, in the event the seven-day period expires prior to February 17, the Commission has agreed to accept our comments on the 17th.

l Thank you very much.for your efforts to work with us to j

accomodate our mutual scheduling problems, and I look forward to seeing you in San Francisco.

Sine 1

/Y 0703030270 060304 Philli A. Greenberg PDR FOIA Assistant to the Governor HOLMES86-151 PDit ggr Energy and Environmen cc:

Governor Edmund G. Brown Jr.

Byron Georgiou Herbert Brown 0

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Washingtot. 0.C. 20024 Attention:

Mr. Ray Heer l

Subject:

Transcript of February 3,

1982, NRC Meeting with PGLE, Seismic Design Review, Diablo Canyon Unit 1.

Dear Mr. Heer,

I have reviewed the subject transcript as it pertains t'o the accivities of my employer and offer the following revisions.

PAGE LINE REVISE TO READ 8

6 Engineering Services; Roger Reedy, imediately to his 60 5

Cooper 'from Teledyne Engineering Services, and I think he has a 61 16 doing, is reverification. What we are doing it to is 61 23 the TES design reverification as wa understand it. The 62 25 the letter.

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two separate tasks in our program. One is to review 63 3

the Cloud-managed program. The other task is to 63 14 which said we are signing the contract-- start. 3 63 15 January Sth the contract witn PG&E was signed. This 64 10 Project QA Progr'am.

It is a PG&E requirement that we 64 11 receive a; proval of this Proje,ct QA crogram before we

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64 15 meeting when Bob Cloud stopped by our office and wanted 6

22 Engineer's method, rather~we'Fe using " structural" 65 to include seismic, piping stress analysis, component ENGINEE:S AND 9,*ET ALLURGiSTS v

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SWEC 66 11 of the program or the way it is being conducted, to 69 13 review work of the Cicud-managed pro' gram our people 69 23 Unoer the evalaation pnase, in the prograta 70 24 if an item is questionable, it is optional 75 17 be necessary that we look at the plan and see if in 141 12 precedure is ' applicable; tecause you just pull it out of 142 1

almost impossible to descri:e it in a generic way, as to 144 15 all installed by different contractors, and too different 186 13 MR. COOPER: We have a QA manual. Because we 186 14 have so many projects of so many different types, for 186 17 manual apply and if there is any supplemental material.

It 188 12-13 (Slide) 188 14 the " questionable" line for the review evaluation suttask. They have as a result of the 188 15 adequate, uncertain, errer.

188 17 In every case, somethir; that is uncertain, will te 188 18 rereviewea er go dcwn to thi supoleTentary effcet.

It 188 20 errcneous.

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" questionable". Having an 138 21 c::en-item report in tne review subtask is us'ng i~t very differently than l

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1 PAGE LINE REVISE TO READ 190 12-management tasks; and I had others assigned to review 190 13 Reedy and the QA activity, Cloud and the design chain, and n- -

190 21 the evaluaticn task -- and I used my terminology 191 23 conceived under the supplementary effort subtask, but it was not true of the one under the review evaluation-subtask. And so 194 8

Now, in our QA program, 194 10 a contrclied document in our QA system. Our QA people do 194 18 controlled document l

226 17 project involving two days' consulting by D.F. Landers 231 9

MR.' COOPER: Those we call reports 232 15 The intent of my remarks earlier would have j

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MR. COOPER: We certainly would not perform 260 7

reverification with respect to that.

In my. opinion these revisions clarify the original intent or correct minor errors in tne proceedings or in the recording.

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Very truly yours, i

Ii TELEDYNE ENGINEERING 7

W.E. COOPER Project Manager WEC/ao cc: George A. Maneatis (PGLE) i !

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SUBJECT Criteria ATTN Ken Herring PR'0 JECT Seismic Reyerification NUMBER P 105-4 Transmitted herewith is/are the following:

One copy of file P105-4-594-009

.(1) Criteria and Methodology for Independent Calculations (2) Criteria for Independent Evaluation Via: Hand Delivery X

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Seismeic Re-Verification Program l Project No. P 105-4

Subject:

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Criteria and Methodology for Independent Calculations 2)

Criteria for Independent Evaluation u

MemoEandum to File by'P.C.'Cheni,z Daite ~1/4/82 This memorandum documents the criteria and methodology which have have been used for sample independent calculations and evaluation of the seismic reverification program.

1)

Criteria and Methodolo'gy for Independent Calculations

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The criteria and methodology. presented in the " Seismic Evaluation for Postulated 7.5M Hosgri Earthquake, Units 1 and 2, Diablo Canyon Site, PGandE, Vols 1-7, U.S. NRC Docket Nos. 50-275 and 50-323", (termed as Hosgri Report) have since November, 1981, been applied to the independent calculations of the seismic reverification program.

They are described below:

(a)

Seismic Design Criteria and Floor Response Spectra The Hosgri seismic design criteria independently developed by URS/Blume and Newmark are accepted as the basis for independent calculations.

Except for the Containment Structure which is be.ing intensively scrutinized, the floor response spectra of all other structures are conditionally accepted pending the results of sample independent calculations of Auxiliary Building.

If the results of independent calculations of Auxiliary Building. indicate any question about the applicability of floor response spectra inside the Auxiliary Building, the applicability of floor response spectra of all other buildings will be investigated.

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It is understood that PGandE is investigating the differences of floor response spectra between the

.Hosgri Report and the 1979 URS/Blume report.

Should PGandE decide to use the floor response spectra in the 1979 URS/Bluma report for piping and equipment

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qulification, the scope of the seismfE revsrification program will be expanded to independently evaluate such a decision.

(b) Seismic Analysis Methodology The seismic analysis methodology for the independent calculations of the Auxiliary Building, piping runs, equipment, etc. is the same as that described in the Hosgri Report.

The methodology includes analysis approach, damping values, mode combination, modal superposition, load combination and stress and oper-ability criteria.

The detailed description of method-ology is presented in various relevant chapters of the Hosgri Report..

The as-built drawings of chosen structures, piping runs and equipment will be field-verified and used for the independent calculations.

2)

Criteria for Independent Evaluation The criteria for the independent evaluation of seismic qual-ification for the chosen sample of Auxiliary Building, piping runs, equipment, etc. are:

(a)

Acceptance Criteria If the seismic responses from the independent calcu-lations and PGandE's seismic qualifications differ y

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less than 15%, the seismic qualifications are acceptable.

(b) Design Safety Margin Criteria If the seismic responses from the independent calcula-tions and PGandE's seismic qualifications differ more than 15%, but the independently calculated seismic responses are within the allowable limits, the seismic qualifications-are said to have enough design safety margin.

Every engineer on the seismic reverification program has read the above crit.cria and methodology for independent calculation and evaluation.

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FEB171982 c : w> m o m m oint sna February 10,.1982~

5511.-5 CONTROLLED DOCUMENT Mr. G. A. Mancatis Senior Vice-President, Facilities Development Pacific Gas and Electric Co.

77 Esale Street San Francisco, California 94106 Seeject:

DCNPP Design Reverification Program:

Responses to Mr. Skjei (MC) Questions

Dear Mr. Manentis:

During the February. 3,1982 NAC-PGEE meeting,' Mr. 5. Skjei,.WiC Econceic Analysis Branch, requested that TES respond to PG&f with respect to the folleging questions:

1.

Question:' Does Teledyne, Inc. ow: or control any stock.in PS&E7 Res'ponse:

I aci advised, by our Division Controller who inquired of our corporate offica, that the answer is yes, tnere are 400 shares of 1.12 preferred stock.

'l hat'is the magt.itude of investor-owned utility business at 2.

0:.est ion:

TES?

.Resoonse:

Based on nambers provided by our Division Controller, 64%

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of TES's 1981 business was with,invester-owned utilities.

3.

Question: Provide a statement regarding potential or. apparent l

conflict-of-interest of ir.dividuals assigned to this e ffort.

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1 Rescorse: TES will. respond shortly in accordance with the require-ments of our EP-1-007 which was transmitted to you by cur letter 5511-3.

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Very truly yours, T- 'OYNE ENGINEER 1'f 6 SERVICES

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5511-5 CONTROLLED DOClJMENT Mr. G. A. Maneatis Senior Vice-President, Facilities Development Pacific Gas and Electric Co.

77 Beale Street San Francisco, California 94106

Subject:

DCNPP Design Reverification Program:

Responses to Mr. Skjei (NRC) Questions

Dear Mr. Maneatis:

During the February 3,1982 NRC-PG&E meeting, Mr. S. Skjei, NRC Economic Analysis Branch, requested that TES respond to PG&E with respect to the following questions:

1.

Question:

Does Teledyne, Inc. own or control any stock in PG&E7

Response

I am advised, by our Division Controller who inquired of our corporate office, that the answer is yes, there are 400 shares of 1.12 preferred stock.

2.

Question: What is the magnitude of investor-owned utility business at TES?

Response: Based on numbers provided by our Division Controller, 64%

of TES's 1981 business was with investor-owned utilities.

3.

Question: Provide a

statement regarding potential or apparent conflict-of-interest of individuals assigned to this effort.

Response

TES will respond shortly in accordance with the require-ments of our EP-1-007 which was transmitted to you by our letter 5511-3.

Very truly yours, 1

TELEDYNE ENGINEERING SERVICES William E. Coo

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F.E C I V E D Pacific Gas and Electric Company 4

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2 San Francisco, California 94120 T. s a mm a n:n m 1/

rsa nu.m a Attention: Mr. Philip A. Crane, Jr.

Assistant General Counsel e

4 itu Gentlemen:

Subject:

NRC Inspection of Diablo Canyon Units 1/2 This refers to the inspection conducted by Mr. J. F. Burdoin of this office on January 4-8 and 13, 1982 of activities authorized by MRC Construction Permit Nos. CPPR-39 and 69, and to the discussion of our findings held with Mr. R. D. Etzler and other members of your staff at the conclusion of the inspection.

Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

Based on the results of this inspection, it appears that one of your a~ tivities c

was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A.

Your response to this notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violation.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).

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ACCESSION NoR:a20329022e OuC.DATE: 82/03/01 NOTARIZED: No DOCKET s FACIL:50-275 Diaolo Canyon Nuclear Powee' Plant, Unit 1, Pacific Ga 05000275 50-323 Diaolo Canyon Nuclear power Plant, Unit 2, Pacific Ga 05000323 AUTH.NAME AUTHOP AFFILIATION FAULKENBERRY,8.

Civision of ResIcent, Reactor Proj ect R Encineerino program RECIO.NAME RECIPIENI AFFILIATION CRANE,P.A.

Pacific Gas 1 Electric Co.

SUBJECT:

Forwards IF Inso Heats 50-275/82-01 & 50-323/82-01 on 8201na-08 & 13 6 notlce ef' violation.

COPIES RECE.IVED:LTR,]_ EhCL a

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DISTRItiuTION CODE: IE018 TITLE: Genenal (50 Okt)-Insp Rect / Notice of Violation R'esponse NOTES:J Hanenett icy PuR Occurents.

05000275 J Hanenett icy AUR Occuments.

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APPENDIX A POTICE OF VIOLATION Pacific Gas and Electric Company Docket No. 50-275 77 Beale Street Construction Permit No. CPPR-39 San Francisco, California 94106 Based on the results of inspections conducted during the period of January 4-8 and January 13, 1982, it appears that one of your activities was not conducted in full compliance with Construction Pemit No. CPPR-39, as indicated below.

A.

10 CFR 50, Appendix 8, Criterion III, as implemented by Section 17.1.6 of the FSAR and the PG&E Quality Assurance Manual Section VI states.

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y-in part, that: " Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces."

The Pacific Gas and Electric Quality Assurance Program manual,Section VI,

" Document Control," states in part: " Policy: To assure that those individuals who perfom activities affecting quality are provided with the current, approved documents required for their work."

The Pacific Gas and Electric Company initiated the electrical raceway support verification program in " hotline" (telefax) letter dated November 6, 1981 from E. Larsen to I. Sokoloff and O. Steinhardt (with copy to D.Rockwell). This program entails field measurements to be made on various types of hangers for maximum span, horizontal and vertical dimensions, and requires identification of the size / type of conduit (rigid pipe /EMT). Licensee procedure, entitled: " Electrical Raceway Support Field Verification Instruction," of December 8,1981, states that EQC (Engineering Quality Control) is responsible for any audits i

required.

Contrary to the above, as of January 6,1982, Engineering Quality Control was not informed of the verification program, and consequently, did not perform any audits or surveillances of the activity, nor did they have any audits formally scheduled.

This is a Severity Level V Violation (Supplement II) and is applicable to Docket No. 50-275.

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Pacific Gas and Electric Company MAR 1 1982 Should you have ar.y questions concerning this inspection, we will be glad to discuss them with you.

The responses directed by this, letter and the accompanying Notice are not subject to the clearance procedures of the Office of Managenent and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, p

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B. H. Faulkenberry Chief Reactor Construction Projects Branch

Enclosures:

A.

flotice of Violation C

B.

Inspection Report Nos.

50-275/82-01 50-323/82-01 cc w/ enclosures:

ti. A. Raymond, PG&E R. C. Thornberry, PG8E (Diablo Canyon) bec: DMB/ Document Control Desk (RIDS)

Distributed by RV:

Resident Inspector Sandra Silver (Report only)

RHE (w/o enc B)

A. Johnson (w/o enc B)

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U. S. NUCLEAR REGUL'ATORY COMMISSION REGION V 50-275/82-01 Report No.

50-323/82-01 Docket No. 50-275, 50-323 License No. CPPR-39, CPPR-69 Safeguards Group Licensee:

Pacific Gas and Electric Company P. O. Box 7442 San Francisco, California 94120 Facility Name:

Diablo Canyon Units 1 and 2 Inspection at:

Diablo Canyon Site, San Luis Obispo County, California & Corp. Offices Inspection conducted:

January 4-8, and 13, 1982 Inspector:

2 -//, - 72 s

F. Bttrdoin, Reactor Inspector Date Signed Approved by:

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Date 51gned T. W. Bishop, Chief, Projects Section 1 Reactor Construction Projects Branch Sumary:

Inspection during the oeriod of January 4-8, and 13,1982 (Report Nos.

50-275/82-01 and 50-323/82-01)

Areas Inspected: Routine unannounced inspection by regional based inspector of construction and modification activities including: a site tour, licensee actions on a 50.55(e) item, and investigation of allegations- (1) improper use and handling of " Class 1" steel plate and (2) no impartiality / audit in re-verification of electrical raceway supports.

The inspection involved 36 inspection hours by one inspector.

Results: One item of noncompliance was identified. The licensee failed to provide quality engineering coverage during the electrical raceway support verification program (paragraph 4.b).

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Appendix A ~ MAR 1g y

i,i Pursuant to the pr6 visions of 10 CFR 2.201, Pacific Gas and Electric Company is here.by required to submit to this officeNithin thirty days of the date

-s of this ' Notice, a written statement or explar.ation in reply, including:

(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further itens of noncompliance:

and (3) the date when full compliance will be achieved. Consideration may be given to extend.ifig your response time for good cause shown.

.s MAR 1 1982 0 0 Y hl N dated

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i T~PMIg~oin,ReactorInspector Reactor construction Pro,1ects Section 1 e

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s DETAILS 1.

Individuals Contacted a.

Pacific Gas and Electric Company (PG&E)

.f J. B. Hoch, Nuclear Projects Engineer

R.,D. Etzler, P.roject Superintendent D.'A. Rockwell, Resident Electrical Engineer

J. A. Ammon, Resident Mechanical Engineer C.'L. Braff, Piping Hanger Group Supervisor

J. R.;Eratton, Lead QC Engineer i

J. J. Nystrom, QC Engineer

C. M.J.Seward Acting QA Supervisor T. E. Pierce, QC Engineer

V. A.'$ mart, Electrical Inspector

I. L. MacDonald; Electrical Group Supervisor R. V. Bettinger, Chief Civil Engineer G. C. Lenfestey, Supervisinij Civil Engineer I. Sokoloff, Senior Civil Engineer E. R. Kahler, Senior Quality Engineer s:'

Various other engineering and QC personnel.

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H. P. Foley' Company (Foley)

A. E. Moses, Project Manager V. H. Tennyson, QC Manager J. L. Thompson, QA Engineering Group Supervisor

8. J. Anderson, QC Engineer

'J. W. Strait QC Supervisor L. C. Fryckman, QC. Inspector J. L. Nighswanger. QC Inspector D. C. High, QC Inspector R. A. Simas, QC Inspector I

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Ju11 man Power Products Corporation H. W. Karner, QA/QC Manager

Cenotes attendees at exit meeting on January 8,1982.

NRC Resident Inspectors Messrs. J. D. Carlson and M. M. Mendonca iI attended exit meeting.

2.

Plant Tour A site tour of Unit 2 auxiliary building was made.

In the' charging pump area at elevation 73, two pipe han,gers were inspected:

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2-23-73R in System 8, the suction piping to the positive displacement (charging) pump 2-3, is a recently completed hanger, having been accepted by QC on September 4,1981; and (2) hanger 23-80R in system 8 (piping associated with charging pump 2-2) is incomplete.

The installation packages for these two hangers when examined in the Pullman Power Products offices for accuracy and completeness, reflected the correct status of the hangers. No deviations or items of noncompliance were identified.

3.

Licensee Action on 50.55(e) Items a.

(Closed) Modifications to Unit 1 Containment Spray Piping Hangers The three incomplete hangers identified in inspection report 50-275/81-26 dated November 16, 1981 have been completed. The licensee submitted a final 50.55(e) report, dated December 22, 1981, regarding the re-evaluation of the hangers for Unit 1 containment spray piping. In all, fourteen hangers required modifications.

All but three of these hangers were reported in inspection i

report 50-275/81-26.- The inspection packages for the modifications to these three hangers (hanger 176-36A, elev. 256'; hanger 176-89A, elev. 256'; and hanger 176-113G, elev.190') were examined for completeness and accuracy. No items of noncompliance or deviations were identified. This item is closed.

4.

Allegations of Improper Quality Assurance Practices by the' Licensee's General Construction and Civil Engineering Departments Two allegations filed in December 1981 were investigated during the January 4-8, 1982 fnspection.

a.

Allegation: ingf Class 1 Steel plates as Temporary Covers for Road Evacuations On December 1, 1981, a local newspaper reporter telephoned the Resident Inspector to report a concern involving use of " Class 1" steel plate as temporary road construction covers. This situation was reviewed with licensee representatives where it "4: determined that the problem had been previously identified ono adequate corrective measures were in progress. On December 3, 1981, i

l the newspaper reporter called again stating that the plates were to be moved to a certain contractor's storage area (Pullman area No.1) but that licensee representatives changed the location because storage area No.10 did not meet regulatory requirements (pipes uncapped, etc.).

Findings: The allegations were substantiated in part.

Licensee's road crews who maintain the.coads at the Diablo Site and who are not acquainted with the rigid requirements I

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1 and controls for handling. nuclear materials went into the H. P.TFoley and Pullman Power Products Company's Class 1 storage. areas and removed six steel plates to use them to bridge two excavations'in the roadways. Upon learning of the situation, the licensee's contractors filed nonconfomance/

discrepancy reports for the six steel plates and declassified the plates. Foley's nonconfonnance report 5422-59 describing the disposition of two plates and Pullman's discrepancy report 4436 describing the disposition of four plates were examined. The plates were also inspected in the field. Two of the plates had been removed from the road and stored in the road crew's storage area.

In the declassification process, the identifications on the plates have been obliterated from the plates with a grinding wheel. As declassified plates, these steel plates are no longer required to be stored in Class I storage areas.

To prevent recurrence of a similar event, the road crews have been reinstructed and restricted from entering the Class 1 material storage areas.

l Two Foley and three Pullman Class 1 material storage areas were inspected and the licensee's, Foley's, and Pullman's applicable quality control procedures for storage of Class 1 materials were reviewed. The Pullman storage areas had recently been relocated to make way for a new storage building (spare turbine mtors). All the storage areas inspected satisfied the requirements of the quality control procedures.

This allegation is closed.

b.

Allegations: Regarding Inadequate QC Audits During Verification of Electrical Raceway Supports On December 14, 1981, the NRC Resident Inspector was contacted by an individual who alleged there was a breakdown of Foley's quality control program in the verification of electrical raceway supports for Unit 1 and the handling of discrepancies identified during the process of taking field measurements.

It was further alleged that the licensee's electrical contractor (Foley) who was doing the work was not seriously interested in identifying discrepancies, but was more concerned with getting the field measurements as expeditiously as possible. Another allegation filed by the same individual, which has not been fully investigated, will be reported in a sutsequent report.

i Findings: The allegations were partially substantiated.

About November 9,1981, the licensee's Civil Engineering Department requested that (eneral construction verify selected l

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Class 1 electrical raceways supports (hangers) by going into the-field and taking measurements for maximum span, horizontal and vertical dimensions of struts for seismic bracing, and requires identification of the size / type of conduit (rfgid

'. pipe vs. EMT). This information when forwarded to the Engineering Department will be used to update the drawings and records of the raceway supports to become permanent "as built" records of s

these systems.

As of this.date, there were some forty one packages (each package contains records on several types of supports) in various ' stages'of completion, in preparation for transmittal to the Civ.11 Engineering Department.

The following applicable documents, which establish the procedures for control and. approval for the field verification of electrica.1, raceway supports, were examined.

(1) Licensee's QA Procedure GCP-5.1 Rev. O, Approval and Control of Field Procedures (2) Licensee's. Electrical Raceway Support Field Verification Instruction (3) Foley's Support Reverification Program Infonnation Sheet The procedure an'd instructions were adequate and sufficiently

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thorough in detail to insure compliance with NRC requirements.

A data sheet, Attachment A to the licensee's instruction, is used to record.the field measurements, list the date' verification was made and signature of person making the verification. A

" remarks" portion of the data sheet was provided to identify any unusual conditions with regard to the support. The contractor's "Information Sheet" directed the workers to

" indicate by writing or sketch any unusual conditions, i.e.,

(no tag number) S-6 brace missing, welded to plate, etc."

The licensee's " Electrical Raceway Support Field Verification Instruction" identified the Engineering Quality Control Department as the responsible organization for quality control for the program.

During the course of the investigation of this allegation, the NRC inspectors were made aware of a 1978 handwritten memorandum addressing the conduct of PGE maintenance personnel wh6n they deal with NRC inspectors. The memorandum was written by the maintenance supervisor to his staff and may not reflect a completely free policy of communication. Discussioris with the author of the memorandum indicated that the document was written following a situation irr1928 when a PG&E employee informed a passing NRC inspector of a problem but did not ee s-y-

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i' 5-inform PG&E of the same problem.. Subsequent to the investigation, licensee representatives issued a memorandum to Plant Operating Personnel (dated February 5,1982), clarifying the policy of communications with NRC representatives. This memorandum was reviewed and appears to provide adequate guidance in this area.

i During the investigation of these allegations during the week i

of January 4-8, 1982 at the Diablo plant and at the licenseet's general offices on Wednesday January 13, 1982, it was detennined that the Engineering Quality Control Department was not aware of their responsibility for quality control of the field verification program until our phone call with them on Wednesday, January 6, 1982. The Civil Engineering Department failed to notify the Quality Control Department when the electrical raceway support verification program was initiated. There does not appear to be a prescribed procedure to insure that quality control is notified whenever their services are required.

The failure to notify Engineering Quality. Control of their responsibility in the electrical raceway support verification program is an apparent item of noncompliance.

(275/82-01-01) 5.

Item of Concern On December 14, 1981, an employee at the Diablo site discussed a concern with the resident inspector..He stated he was not filing an allegation, but wished to understand the difference between the two methods of attaching pipe supports to the containment liners in Unit 1 containment and Unit 2 containment.

Findings: This concern grew out of the 50.55(e) item discussed.in paragraph 3 of this report. Originally, the containment spray pipe supports (hangers) in both units were welded directly to the steel liners of the containments. Following the reanalysis of the supports, modifications to the pipe hangers were made to allow heavier loads to be transmitted to the concrete containment. The method to accomplisn this was to drill through the containment steel liner and into the concrete containment and install a 3/4" shell type anchor. A stud screwed into the anchor and back welded at the liner secures the pipe hanger to the containment. This method was used on only two hangers (73-39S1. and 20-89R) in Unit 2 I

containment. Another method of securing the pipe hangers to the concrete containment was used in Unit I containment. This method entails locating the existing steel liner concrete " Jay" bolt anchors by ultra-sonic techniques and welding the 3/4" pipe hanger securing studs to the liner directly over the " Jay" bolt anchors.

This later method for securing containment spray pipe hangers to l

the containment was used in both Units 1 and 2.

This explains the above identified concern.

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Management Interview A meeting was held with the licensee representatives (identified in Section 1) on January 8,1982. The scope of the inspection and a sunnary of the findings, as noted in this report, were discussed.

The licensee acknowledged the apparent ii.am of noncompliance discussed in paragraph 4.b above.

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ROBERT t C1. CUD ASSCC!ATES. INC.

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ISS UMtVERSITY AVENUE SERKELEY. CALIFORMIA 94710 uisie4i....

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Mr. Harold R. Denton, Director

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Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission D

7920 Norfolk Ave.

Bethesda, Maryland 20114

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Dear Mr. Denton,

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MAR 0 Enclosed please find a copy of:

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DESIGN VERIFICATION PROGRAM as SEISMIC SERVICE RELATED CONTRACTS PRIOR TO JUNE 1978

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Revision I Phase I 1

February 27, 1982 This program is designed to address the requests of the

" Order Suspending License", CLI-81-30.

In addition, this Revision I description includes modifications to the original program description to account for changes due to NRC meeting of February 3, 1982, cocments o'f Dr. W. E. Cooper, and progress made to date.

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'4 REGULATURY INFORMATION DISTRIBUTION SYSTEM (RIOS) t&C' CESSION NbR A203030575 00C.0 ATE: 82/03/01 NOTARIZED: NO 00CKET s FACIL:

AUTH.NAME' AUTHOR AFFILIATION CL000,R.A.

Rchget L. Cloud Associates, Inc.

GECIP.NAME R{CIPIENT AFFILIATION OENTON,M.R.

Office of Nuclear Reactor Reculation, Cirector

SUBJECT:

Porwards " Design Verification Pr'oaram, Seismic Syc Related Contracts Refor to June 1978," Revision 1,Rhese I.

DISTRIBUTION CODE: P0013 COPIES RECEIVED LTR O ENCL d SIZE:_ %

TITLE: RSAR/PSAR AMOTS and Relatec Correspondence NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE /NAME LTTR ENCL 10 CODE /NAME LTTR ENCL 4

ACTICN:

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0 PM 01 1

1 INTERNAL: ELD 1

0 IE 06 3

3 IE/DEP/EPOS 35 t

i IE/0EP/EPLS 36 3

3 MAA 1

0 NRR/0E/CES 11 1

1 NRR/0E/EQ8 13 3

3 NRR/CE/GB 28 2

2 NRR/0E/HGES 30 2

2 NRR/CE/MES 18 1

1 NRR/0E/MTES 17 1

1 NRR/0E/QA8 21 1

1 NRR/0E/SAR 24 1

1 NRR/DE/SES 25 1

1 NRR/0HPS/HFEB40

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NRR/0HFS/LG8 32 1

1 NRR/0MFS/CLS 34 1

1 NRR/0HFS/PTR820 1

1 NRR/OSI/AEB 26 1

t NRR/OSI/AS8 27 1

1 NRR/OSI/CPB 10 1

1 NRR/OSI/CSB 09 1

1 NRR/CSI/ETSB 12 1

t NRR/OSI/ICS8 16 i

i NRR/OSI/PSS 19 1

1 NRR/D6I/RA8 22 1

1 NRR/OSI/RSS 23 1

1 NRR/OST/LG8 33 1

1 REG FILE 04 1

1 EXTERNAL: ACRS 41 16 16 SNL(AMOTS ONLY) 1 1

FEMA-REP OIV 39 1.

1 LPOR 03 1

1 NRC POR 02 1

1 NSIC 05 1

1 N1IS r*%4 1

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Distribucion list:

Mr. Harold R. Dencon, Director OfficeofNuclear,ReacgorRegulacion Mr. R. H. Engelken, Regional Administracor Nuclear Regulacory Commission, Region V Mr. George Maneatis, Senior Vice. President Pacific Gas and Electric Company Mr. Roy Fray, Program Manager Pacific Gas and. Electric Company

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Mr.

R.' F. Ready, President R. F.-Reedy, Inc Mr. Carl 05 Richardson, Jr.,

Assistant Engineerin'g Manager Stone E Webscar Engineering Corporacion

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Dr. W. E. ddoper

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Teledyne Engineering Services

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DESIGN VERIFICATION PROGRAM SEISMIC SERVICE REI.ATED CONTRACTS PRIOR TO JUNE 1978 REVISION 1 Phase I February 27, 1982 Project 105-4

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Appyoval./Date Robert L. Cloud Associstes, Inc.

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125 University Ave.

?.0. Box 687 Berkeley, CA 94710 West Falmou:h, MA 025"4 (415) 841-9296 (617) 540-5381

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DESIGN VERIFICATION PROGRAM SEISMIC SERVICE RELATED CONTRACYs PRIOR TO JUNE 1978 Phase I

i TABLE OF CONTENTS t

i 1.0 Introduction & Scope........................

1 2.0 Development of the seismic Design Chain............................... 3 2.1 The Seismic Design Chain....................

3 2.2 Development of Seismic Design Chain......... 3 2.2.1 Information to Seismic Design Chain.......

3 2.2.2 Seismic Design Chain Map..................

4 3.0 Quality Assurance Program Review............

5 3.1 Controlling Documents.......................

5 3.1.1 Specific. Documents to be Reviewed......... 5 3.1 Review...................................... 5.

3.2.1 Design contro1...~.........................

6 3.2.1.1 Design Input............................

7 l

3.2.1.2 Design Process..........................

7 3.2.1.4 Change contro1..........................

8 3.2.1.5 Interfaca Control.......................

8 3.2.1.6 Documentation and Records............... 8 3.2.2 Instruction, Procedures and Drawings...... 8 i

3.2.3 Document Control.......................... 9 4.0 Review of Implementation of Quality Assurance Controls..............

10 4.1 Development of Audit Plan..................

10 4.2 Audit Scop e and D ep th...................... 10 -

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4.3 Quality Assurance Results..................

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5.0 Independent Sample Calculations..............

13 5.1 Typ e s o f S amp le s............................. 13 5.2 Sampling Philosophy and, Criteria...........

13 5.3 Additional Verificacion.................... 14 4

5.3.1 Additional Verificacion Resulting from Quality Assurance Reviews............

15 5.3.1.1 Cricaria................................

15 5.3.2 Additional Verificacion Resulting from Independent Calculacion Program...... 17 5.3.2.1 Deficiencias resulting from field inspeccion..............................

17 5.3.2.2 Deficiencias resulting from the independent calculacion program.........

18 5.3.2.3 Deficiencias resulting from inspplicable seismic inpuc..............

19 5.3.2.4 Deficiencias in design machodology...... 20 5.4 Independene Requalificac1on................. 20

5. 4.1 3n w hgs................:................ 20 5.4.1.I Sample................................;..

20 5.4.1.2 Machodology.................:...........

21 5.4.1.3 Acceptance Cricaria.....................

22 5.4.2 Piping....................................

22 5.4.2.1 Sampla..................................

22 5.4.2.2 Mechodo1ogy.............................

23 5.4.2.3 Acceptance Cricaria.....................

24 5.4.3 Pipe Supports.............................

25 5.4.3.1 Samnia................................. 25.

5.4.3.2 Machodology.............................

25 l

5.4.3.3 Acceptance Cricaria..:..................

26 l

5.4.4 Small Bore Piping.........................

26 5.4.4.1 Sample..................................

26 5.4.4.2 MethodoloS7 27 5.4.4.3 Acceptance Cricaria.....................

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4 5.4.5 Equipment:. Analysis......................

28 5.4.5.1 ' Sample................................

28 5.4.5.2 Methodology...........................

28 5.4.6 Equipment Qualified by Test.............

29

.5.4.6.1 Sample................................

29 5.4.6.2 Methodology........................... 30 5.4.6.3 Acceptance Cricaria...................

30 5.4.7 Conduit Supports.......;................. 30 5.4.7.1 Sample...............>.................

30 5.4.7.2 Machodo1ogy........................... 31 5.4.7.3 ' Acceptance Cricaria.................. 31 5.4.8 HVACSupports............................. 32 5.4.8.1 Sample................................

32 5.4.8.2 Machodo1ogy...........................

32 5.4.8.3 Acceptance Cricaria...................

32 6.0 Field verificacion........................

33 7.0 Hosgri Spectra............

............... 33 8.0 Seismic Service Related Activities of NSSS Vendors...........................'. 3 3 9.0 Program Approach..............

........... 34 10.0 Reporting Procedures...................... 3 4 11.0 Conclusion................................

34 Figure 1 Table I Table II Table III Attachmanc I Accach=mnc II Attachment III e

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DESIGN VERITICATION PROGRAM SEISMIC SERVICE RETlTED CONTRACTS PRIOR TO JUNE 1978 Phase I l'. 0 Introduct'on & Scope i

on September 28, 1981 Pacific Gas and Electric Co.

reported that a diagram error had been found in a porcion of che seismic qualificacion of the Diablo Cmtyon Unic 1 Nuclear Power Planc (DCNPP-1).

This error resulted in an incorrect applicacion of the seismic floor response spectra in the crane wall-containment shell annulus of the Unic 1 Conta % enc Building.

The response spectra were choughc ce be computed correctly for Unic II, but as a result of the diagram error were applied to the opposite hand geometry of the Unic 1 buiiding.

The origin of the error was in the cransmiccal to a consultant of a sketch of the Unic 2 oppostca hand geometry identified as Unic 1 geometry.

4 The effects of the error were being rectified and'a re-verificacion program was iniciated and underway during the months of October and November.

The NRC Commissioners mac dur-ing the weele of November 16, 1981 to review the situacion.

On November 19 the Commission issued an Order Suspending License, CLI-81-30, which suspended License No. DPR-76 issued to che Pacific Gas and Electric Company to load fuel and conduce low power cases un to 5% of raced power ac che DCNPP-1.

In Accachment 1 to che order certain accions were specified chac would be required before the suspension would be revoked.

These accions consist primarily of an independent Design verificacion Program and cocolecion of a cachnical recovery program.

The NRC Scaff further clarified the required accions

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dusing a meeting in Bethesda on Fabruary 3, 1982.

This report. presents Revision 1 of a description of the Des 1 n Verification Program on seismic work performed by 5

service related contractors and PGandE prior to June 1978.

This program is designed as Phase I of an overall Design i

verificacion Program.

Phase II of the sverall program will

'l include the remaining safety related work.

This Revision 1 l

description. includes modifications to the original program descripcion to account for:

Changes due to NRC meeting of Feb. 3, 1982, Comments'of the program reviewer, Dr. W. E. Cooper of Teledyne Engineering Services, and Progress made to date.

The present description is a picture of the program as of Feb. 27, 1982.

The Design Verification Program includes only the safety related Design Class I buildings,. equipment, piping and com-i ponents that were requalified considering the Hosgri 7.5M earthquake.

Emphasis was placed on items important to public safety, as opposed to operational reliability.

The scope of chis Design Verification Program includes the design and anal-ysis work performed associated with seismic-related service j

contracts in efface prior to June 1978.

This'date serves as a convenient separation poinc for the Quality Assurance por-cion of the design verificacion.

Part of the engineering i

work done prior to June 1978 has been superseded, therefore che engineering verificacion for Phase I will involve review of some work performed after June 1978.

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2.0 Davalopment of the Seismic Design Chain 4

2.1 T:ia Seismic Design Chain The'carm "saismic design chain" designatas the separata but linked process of providing seismic design for a nuclear plant.

Each step in the process is usually linkad to another step via flow of information.

The design results obtained in one step may affect the design of systems or components i

in another step of the process.

i'or example, the floor re-

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sponsa spectra obtained in building analysis are used as input to che analysis of piping syscam of the parricular floor.

The piping analysis providas puping suppor loads which. in turn are used for the design of piping supports.

Figure 1 illustracas a typical seismic design chain for a nuclear power plant based. en the sica seismic design cricaria.

2. 2.

Deva'lopment of Saismic Design Chain.

The saisde design chain applicable to the Diablo Canyon Nuclear Power Plant will be deval.oped by the following ap-preaches 2.2.1 Informacion to Seismic Design Chain.

The information nacassary to develop the seismic design ch=4n for cha Diablo Canyon Nuclear Power Plant is as follows:

Names of PGandE's contractors involved in the seismic safaely-related work prior to June, 1978.

Work scope of each contractor.

Commencamanc and' ending dacas of each contraccor's

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Design groups within PGandE responsible for the work of contractors.

Interfaces of design groups within PGandE.

2.2.2 Seismic Design Chain Map The map of the seismic design chain involving service-related contraccors prior to June 1978 will be developed using information described'in Seccion 2.2.1.

This map will illustrace all interfaces (both with and within PGandE), describe che infor.sation passing between inter-

faces, and list the responsibilices of all contractors at each step of the seismic design process.

When the entire chain has been mapped, it will facilicate che review of incerfaces when design information was crans-micted between PGandE incarnal design groups, and between

PGandE and each contractor.

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5 3.0, Quality Assurance Program Review The objective of this portion of the Design Verification Program is to evaluate the appropriate QA Programs against all eighteen criteria of 10CFR50, Appendix 3 and the applicable ANSI Standards.

All 18 criteria of 10CFR50 Appendix 3 were considered and applicable criteria for each contractor were selected (Table III).

3.1 ' entrolling Documents The review team,of R. F. Reedy, Inc. shall collect con-trolling Quality Assurance related documents associated with each of the organizations identified in the seismic design chain in Section 2.0.

These docu=ents shall include the applicabla revisions during the period prior to June 1978.

3.1.1 Specific Documents to be Reviewed The specific documents to be reviewed during this pliase of review shall, as a =d Ne, include:

a)

The PGandE Diablo Canyon Safety Analysis Report b)

The Quality Assurance Manuals and Quality Assurance / Quality Control Procedures of each of

~ he organizations in the design chain which were.

t applicable during this design period.

c)

The applicable procurement and design specifica-tions used by each of the organizations in the I

design chain.

3.2 Review

"'he review team of R. F. Reedy, Inc. shall conduct the review of the docurants listed i:r Sectica 3.1.1 for co=cliance w--r

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with the requirements of 10CFR50, Appendix B, and the applic-

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able ANSI Scandards.

In general, che i= mediate criteria 1

applicable-to design groups will include Instruccions, Pro-cadures and Drawings, and Document Control.

However, there may'be some organizacions in the design. chain, e.g. a cast 4 1

lab, whose design activicies include functions such as casting, equipment calibration, and controlling macerial. When reviewing-

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these types or similar organizations it will be necessary for che review team to include applicable Appendix B criteria in the review.

Each such case will be evaluated to assure that

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all appropriate 10CFR50 Appendix B and ANSI critaria are includ-ed in the review and implementacion audic.

3.2.1 Design Control The Review of the Quality Assurarce Manual and Proca-durea shall determine whether:

a) applicable regulatory requirements (and che design basis were correctly translaced into specificacions, drawings, procedures and instructions) and the appropriate quality standards were specified and included in the design process azid that deviacions from such scandards were controlled; b) che control of design interfaces and the coordina-cion among participacing design organizacious was adequece and included the establishment of procedures among participacing design organizacions for the review, approval, release, distribution, and revision of documents.

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, c) control measures were provided for verifying or checking the adequacy of design, such 'as by the performance of design reviews, by the use of

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alternate or simplified calculation methods, or by the performance of a suitable testing program and that the verifying or checking process was performed by individuals or groups other than those who performed the original designie d) design changes were subject to design control measures commensurate with those applied to the original design and. approved by the organiza-tion that performed the original design.

3.2.1.1 Design Input The review team of R. F. Reedy, Inc. shall determine whether applicable design inputs, such as design bases, performance requirements, regulatory requirements, codes and standards were identified, dqctunanted, and their selec-cion reviewed and approved, and whother the design input was specifi.ed and approved to the level of detail necessary to permit the design activity to be carried out in a correct manner and to provide a consistent basis for matc4ng design decisions, accomplishing design.verifica-tion measures and evaluating design changes.

3.2.1.2 Design Process The review team of R. F. Reedy, Inc. shall determine whether design control measures were applied to verify the adequacy of design, such as by one or more of the following:

the per-formance of design reviews, the use of_ alternate calculations, or the perfor=ance,of cualification tests.

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3.2.1.4 Change Control The review team of R. F. Reedy, Inc. shall determine whether changes to final design were jgstified and subjected to design control measures commensurate with those applied to the original design and approved by the same affected groups or organizacions which re-viewed and approved the original design docu-ments.

3.2.1.5 Interfaca Control-The review ccam:of R. F. Reedy, Inc. shall determine whether design interfaces were identified and responsibility defined, lines of communication established and the design efforts coordinated among the participating organizacions.

3.2.1.6 Documancacion and Records The review ceam of R. F. Reedy, Inc. sh'all determine whether design documentacion and records, which provide evidence that the design and design verification processes were properly performed, were collected, scored,.

and maintained in accordance with documanced procedures.

3.2.2 Instruccions, Procedures and Drawings The review ceam of.R. T. Reedy, Inc. shall deter.,dne whether activicies affaccing seismic deaign were pre-scribed by documanced instruccions, procedures, or

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drawings of a type appropriate to the circumstances and accomplished in accordance with chase instructions, procedures, or drawings.

3.243 Document Control o-i The revi_ew casm of R. F. Reedy, Inc. shall determine whe~chif'~mlas'utes were established to centrol the is,

suance of documents, such as instruccions, procedures, l

and drawings, including changes thersco, which pre-scribed activicies affecting quality and that documents, including changes, were reviewed for adequacy and approved for release by authorized. personnel and are properly distributad.

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' i 4.0 Review of Implementation of Quality Assurance Controls The objective of this porcion of cha Design Verificacion Progrr.m is to evaluace che implementacion of the appropriate QA Programs assessed.in Seccion 3.0.

i 4.1 Development of Audic Plan The review team of R.F. Reedy, Inc. shall develop and con-duct on-site verificacion audics to assess the design con-crol implemenced by each contractor and PGandE.

hre the review of Section 3.0 shows a machod of controlling design activities in. an organized and documanced manner which meets the requirements of 10CFR50, Appendix 3, and the applicable ANSI standards, che audic will consist of a review of obj ective evidence to verify chac che program was adequately implemenced and documanced.

hra che program r'aview caan considers chac che contraccor's program does not contain the controls of l

-10CFR50, Appendix B, and the applicable ANSI scandards, the audic will consisc of a determinacion whether the design ace-ivities were controlled in a menner consonant with the criteria requirements of Appendix B and. cha applicable ANSI standards.

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4.2 Audic Scope and Depch l

The scope of chese audits will include a review of the imple-mancacion of Qt=11cy Assurance Procedures and controls used by and for:

a)

PGandE internal design groups that interfaced with che seismic contractor b) each contraccor's design group; D 6 6

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d) cransmiccal of,contraccor developed information within PGandEs a) and contraccor incarnal interfaces and interfaces with subcontraccors when applicable.

Qualified engineers will be used to review at least some of the calculacions and analysis of ?GandE and each design contractor.

The review may consist of reviewing design input and output

- for consistency, or a check review by use of simple calcu-lacions to approximate resules, or a deca 11ed check of a portion of the calculacions for analysis to assure che results are correcc.

The results of each audic will have a dirace bearing on che type and depch of additional verification.

l See also last paragraph, Seccion 5.2.

'If any contraccors sublec design activicies, it will also be necessary to review that subcontraccor ahd his interfaces with others.

Design interfaces will be reviewed whether chey are internal or external to che group. Again, cha'depch of additional verification will depend upon the results of the implemencacion audie.

Some of the specific items to be addressed during chase audies are:

Correct application of design input data Documentation of design assumptions Applicability of quality requirements Identificacion of applicabla codes, standards, and regulatory requiremanes Adequacy of design interfaces l

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Verificacion chac' acceptance criteria was mac 4.3. Quality Ass'urance Results The results of the program reviews and audits of PGandE and each contractor will be presented in a report.

Quality Assurance Findings, together with the results of the independent sample calculacions,~will form a basis for deter-mination of the need for additional verification.

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5.0 Independent Sample Calculacious 5.1 Types of Samples The sample of equipment, piping, buildings, and components l

co be design verified by independent calculacions is shown in f

Table 1.

This sample-is carmed generic and covers the entire planc.

The generic sample will cover the significanc design activities of PGandE and. che seismic-safety related contractors. -

However, to provide' der the case where deficiencias are found by means of either the Quailty Assurance review or independenn sampla calculacions, provisions have been mada for additional verificacion.

(Sea Seccion 5.3).

5.1 Sampling Philosophy and Criceria Since che current effore'is.'a. review of engineering work, che objec*:ive will be cci perform enough independent cal'eulacions to ensure no significant errors are propagated through any parts of the work. This will be done by determining the sources.of errors, whether due to machod, mathematics, incorrece input data, omission of informacion or other.

In cases of discovery of errors, additional verificacion will be required to determine che nature and quality of the engineering work, so that a clear scacement can be made on the.need for improvements or modifica-cions.

The size of the sample, and the buildings, piping, equipment and components contained in the sample have been chosen on a judgement basis.

,iudgement sampling is discussed in " Sampling Manual for Auditors", The Inscicuca of Internal Audicors, New York, j

N.Y., where it is noted that certain types of audicing are best done using judgement sampling.

In che current situac:.on, subscancially i

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more assurance can be gained by the development of an informed understanding of the engineering work and a follow-chrough to determina the possibility of arror propagation, than would be gained by an attempt to apply formal statistical procedures, which would be difficult in any case due to the diversity of the work.

The specific items of buildings, piping,, components and equipment were chosen:

to obtain a sample from all seismic-safety related contractors to obtain a sample significant to Public Safety to obtain a sample from all areas of the plant to-obtain a sample analyzed by means of different me,thodologies.

The size of the sample was determined on the basis chac the cross-section of the total engineering work provided is more than sufficienn to establish the adequacy of the seismic de-sign or indicate if significant errors exisc.

Additional verification will be required. if errors or QA. deficiences are determined.

i 5.3 Additional Verification Additional verification is performed if deficiencias are found by means of either the QA review or the Independent Calculations M e 6

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5.3.1 Additional Verification Resulting from Quality Assurance Reviews Deficiencies in the Quality Assurance Program adequacy or istplementation of PGandE or service related contractors will be cause for additional technical verification of design work.

This review will cover the technical work done under the deficient QA program.

QA deficiencies are reported as findings or observations.

For present purposes chase are defined as :

Finding:

A nonconformance with respect to the Quality Assurance Program adequacy or implementation that requires corrective action due to potential impact on quality.

l Observation: A noncomformance which does not require

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corrective action. This nonconformance does not have an apparsnt impact on quality.

Additional technical verification of the subject design work will be performed for all Findings as defined above.

(Observations will.not require additional verification).

5.3.1.1 Criteria.

Depending upon the nature of the design work done under inadequate Quality Assurance, one of the follow-ing approaches will be taken.

Design Review i

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l Technical work of a qualitative nature will be verified by review, by means of the following steps:

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-Define scope of work.

-Establish an independant review program.

-Perform review to establish whether work is satis-factory based upon scace-of-che-art machods applicable to the original design work.

-Write review report and draw conclusions as to whether i

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Independent Calculatimts l

Technical work of a quanticative nature will be veri-fied by means of independent calculacious.

The following steps will be followed:

-dscablish scope of work.

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-Develop a verificacion program based upon independent calculation of a suitable sample of the work, based upon state-of-the-are machoda applicable to the originar design work.

-Perform verificacion progran to est.611sh whether work is satisfactory.

-Write verification report.

An example of this verification chac covers both qualitative and quanticative review is given below.

i Deficiency:

The Harding-Lawson QA Report by R. F.

Reedy, Inc. contained three Findings (QA Findings 968, 969,.md 970).

Additional Verification.

RLCA and Robert McNe'ill are currently assessing the scope of the' Harding-Lawson work.

A program.will be developed to verify this by design review, independent calculacions or a ecmbination of the two.

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5.3.2 Additional Verificacion Resulting from Independent Calculacion Program 1

The independent calculation program entails four cac-i agories of verificacion:

1.

Field inspection co'decermine whether the as-installed configuration conforms to the design j

configuration.

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Independent calculations to determine che correct-ness of the design calculacions.

3.

Verificacion that applicable seismic design input was employed.

4.

In certain cases, design machodology is separately verified,.

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Deficiencies identified by any of the above will result i

in additional verification.

5.3.2.1 Deficiencias resulting from field inspeccion The objective of performing additional verification as a. result of identified deficiencias in the as-buile configurations will be to discover the excent of such deficiencies.

One of the two following machods will be used for such additional verificacion.

,- Repeated field inspections of additional samole configurations.

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Establish the cause or reason for che'dsicrepancy; chen crace down other di,screpancies that could l'

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An example of this verificacion is given below:

Deficiency:

An ambiguous design noce led to a com-munication problem between engineering and the field concerning additional cubing weight on raceway sup-ports (E0I 910).*

Additional Verification:

PGandE has set up a program to an=4na all raceway supports with accached cubing.

Prel4=4= 7 indicacions show accached cubing on about 100 of the 20,000 class IE raceway supports.

5.3.2.2 Deficiencias resulting from the independent calculacion program The objective of performing additional verification as a result of identified calculational deficiencies will be to discover the excene o'f such deficiencias.

This will be accomplished by one if the following means.

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-Performance of additional independent calculacions until che reasons for discrepancias are understood and a clear basis exists for all remaining safecy-related. discrepancies to be remedied.

-Determinacion of the cause or reason for the dis-crepancy:

chan crace down other discrepancies chac result from such cause or reason.

An.txample of this verificacion follows:

Error and Open Icem Report. These reporcs are being sent

. semi-monthly to PGandE and the NRC as of January 1982.,

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Deficiency:

The buckling of the tank skirt and.

sloshing loads on the rood were not evaluated by PGandE for the Boric Acid Tank (E0I 1030).

i Additional Verification:

RLCA will verify that other Hosgri tanks are not affected by the above. iJams.

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5.3.2.3 Deficiencies resulting from inapplicable seismic input The objectiver of performing additional verification as a. result of the use of inapplicable seismic input will be to discover the extent and significance of such deficiencies.

This will be accomplished by one of the following means:

- Determination of the cause.or reason for the discrepancy:

then trace down other discrepancies that result from such cause or reason.

- Performance of additional checking of seismic inputs.

An example of this verification is given below.

Deficiency:

Nine of twenty electrical raceway support calculations checked for the Preliminary Report used inapplicable spectra (E0I 983).

Additional Verification:

PGandE is currently reviewing all the class II electrical raceway support calculatione.

RLCA will select a sa:nole of these re-done supports for independent calculations to close out_IGI 983.

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This will be accom-plished by two methods:

- A critique of the machodology in question will be issued.

- When.. the machodology has been imoroved or justified, the design work will be re-verifled relative co-the new or revised design methods.

5.4 Independent Requalification In this phase of the program the seismic qualificacion of the

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sample (buildings, piping, components and equipment) will be performed att an. independent basis.

In each case, the starting point will be the engineering drawing which will be field checked.

All data required for the qualification will be obtained or cal-culated independent of the PGandE analysis to guard against common data errors.

Verified computer codes different from

. chose used by PGandE will be used.

The verification of buildings represents a special case, as described below.

5.4.1 Buildings 5.4.1.1 Samole There are four safecy-related structures:

Incake Structure, Turbine Building, Containment'and Auxiliary Building.

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seismic design of the Auxiliary Building.

This building includes the Fuel Handling Structure and the control room.

Except for the Cont =4"=="c Building, The Auxiliary Building is the most important structure with regard to overall safety.

The choice of a structure for independent calculation logically was between the Contain= ant and Auxiliary Building.

The latter was chosen for the following reasons:

The Auxiliary Building contains the largest amount of safe shutdown piping, equipment and components.

The building itself involves the Fuel Handling

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Structure and tha control room.

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The structure is quite complex with both a concrete shear wall section and a steel frama sectiion.

As discussed in the prel4=4"=7 report on the

,s review of the URS/Blume-PGandE interface, there appeared to be some controversy on one mass point in the seismic model of the building (E0I 985).

The Contains mt Building is under separate scrutiny due to the error discovered in the annulus nodil.

5.4.1.2 Methodology The plan for verification of the Auxiliary Building follows.

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Review the =odel used by URS/Blu=e for the dynamic analysis of the building.

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Independently calculate the building properties

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Independently calculate the modes and natural frequencies.

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Independantly perform the time-history analyses and calculate the floor response spectra.

e.

Independently analyze a sample of the building members.

The independent results will be compared with the PGandE results for b, c, d, and e above.

5.4.1.3 Acceptance criteria Additional verification will be required if the results vary by more than:

15% for the building dimensions and properties.

For the building,.15% for the frequencies, provided the mode shapes agree.

-- For the response spectra 15% in peak accelerations and 15% for the peak frequencies 5.4.2 Piping 5.4.2.1 Sample Table II contains the piping problems chosen for independent. verification.

This sample of 10 piping 1

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1 analyses were chosen on the following basis:

Obtain a sample from all buildings Obtain a sacple from all elevations Obtain a sample from a diversity of' systems Obtain samplss from lines most important to safety i

1 (risk of radiation release).

t This sampling strategy is based on the fact' chat each piping analysis is a lengthy and comples,under.-

taking that requires avamin= tion end verification' of, a large body of data.

In addition, consistent with the overall plan, if discrepancias are found, addition-al verification will be required.

5.4.2.2 Methodology-The methodology for the verification is based on the following' points:

A field verification of installation of the sample lines will be performed.

Models. will be developed from field verified drawings.

The methods used for the analysis will in general

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parallel those used for the Hosgri analysis of the piping.

The applicable Hosgr1 criteria are included in Actar hment III.

The analysis will consider deadweight, pressure and seismic loads.

The verification analyses will be done using ADLPIPE, a differene computer program than was used for the Hosgri analysis.

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5.4.-2.3 Acceptance Criteria Upon completion of the independent analysis of c'a h

10 piping runs, the results will be compared with the design analysis.

The following procedure will be employed.

Field tolerances are defined in PGandE's 79-14 program.

For both the verificacion and design analysis, select all poines in the line that are stressed to 70% of allowable stress or more.

These are che i

reference location.

I If fewer th 5 such points are found, select i

the 5 most highly stressed poines as reference locations.

Compare design and verification stresses at the reference locations.

If the stresses differ by more than 15% or exceed allowable stress additional l

verificacion is required.

Y Compare all supporr loads to the design analysis results.

Compare all equipment nozzle loads to the design analysis results.

Compara all valve'acceleracions to ch'e design anal-ysis results.

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" Additional verification is required if differences greater.than 15% result in the last 3 steps or if allowable values are exceeded.

5.4.3 Pipe Supports 5.4.3.1 Sample Twenty pipe supports have been chosen from those

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associated with the.10 pir.ing verification analyses.

These supports were chosen from different locations and represent a cross section of the differene types of supports:

snubbers,' rigid restraints and spring hangers.

5.4.3.2 Methodology For the twenty supports, chosen:

. '. A field.verificacion will be performed.

Calculace the first mode frequency.

Calculace the stresses in the pipe supports,

based upm loads calculated from the 10 piping analyses.

For the remainder of the supports included in the 10 piping analyses:

Compara che loads calculaced from the independent analyses with those in the qualification analyses as discussed previously.

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26-5.4.3.3 Acceptance Criteria The' original design of pipe supports required each supporr to have a mini:mam natural frequency of 20 Hz considering the stiffness of the supporr and the mass of the supported pipe.

For the twency supports chosen:

The field verificacion will compara as built to design utilizing PGandE's 79-14 colerances.

The first mode frequency must equal or be greater than 20 Hz.

Compare che design and verificacion stresses on the pipe supports, based upon loads calculated from the piping analyses.

Critical section stresses

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that differ by more chan 15% will require additional verificacion accion~.

For the ramahder of the supports included)in the 10 piping analyses Compare loads calcuIaced from the independent anal-yses with the design loads.

Loads differing by 15% or over allowable will require' additional ver-ificati.au.

5.4.4 SMALI. BORE PIPING 5.4.4.1 Samole The small bore piping at Diablo Canyon Unic 1 has been supported using scandard criteria for the spacing of e-.

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This is a standard ap-Ioach in the industry.

A sample of 3 runs of approx-imacely 150 feet each of small bora piping has been chosen for review.

This sample of piping will include 20 supports or more.

In view of the face that a rela-cively simple scandard machodology was employed in the design, che sample chosen is expected to permic a satisfactory verification of the design.

5.4.4.2 Methodology The verification of the small bore piping will consist of two parts:

Field verificacion of the sample to establish that the pipe installations conforms to che design crtcaria.

Independene review'of the des ~ign criteria to establish that the cricaria satisfy the applicabIe scress limics and provide conservative support design loads using Hosgri seismic inputs.

The Hosgri small bore piping criteria is included in Attachment II.

5.4.4.3 Acceptance Critaria Acceptability of the field installation will be based upon the PGandE colorances developed for the I&E 79-14 Bullecin review.

Instances of violacion of the criteria will require additional verificacion.

Review of the design criteria wilI. cons ~1 der the

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If chese cricaria are not met, additional verifi-

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5.4.5 Eguipment Analysis

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For purposes of the present discussion, the general category of equipment qualified.by analysis includes the

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following classes:

Haac exchangers Tanks

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. Pumps Valves Carcain electrical panels and cabinets 5.4.5.1 Samole The equipment sample is identified in Table 1.

The samples have been chosen using the same guidelines as with the other samples.

An attemoc was made to choose equipment most important to public safety and-from a diversity of locations.

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Hand calculacions are used where possible, other-wise scandard computer machods for dynamic analysis are employed.

Scandard, benchmarked computer codes are u.d for this work, ANSYS for example.

A com-pucer code different from chac used by PGandE will be used in the independent calculacion.

The verificacion analysis considers scresses in the i

equipment itself as well as the supporting structure including the anchorage.

The Hosgri loading combi-nacions and structural cricaria for both the Mechanical-Equipment and supportsare included in Accachment 1.

In general, che different types of equipment are governed by different codes and scandards.

These governing cri-ceria are listed for each type of equipment and supports in the Hosgri recore. Field colerances will be 15%.

The results from the verification analysis will be compared to che design analysis.

Stresses from govetning l

locations will be required to be within 15% and below allowable.

If this level of agreement is not obtained.

additional verificacion will be required.

5.4.6

, Equipment qualified oy Tesc 5.4.6.1 Sample Certain cypes of electrical equipmene are sore conveniently qualified'by cast chan analysis.

Electrical equipment qualified by cast within the present scope has been segregated into 7, groups in the original desigd quali-ficacion.

This segregacion was based upon the location of the equipment in che plant and was done to persic one case spectra to envelop the floor spectra applicable

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to each group.

The cast qualification applied to each group will be reviewed.

5.4.6.2-Methodology The review will consist of two steps:

. i Verify that the equipment in each group is l

located such that the applicable floor spectra of each item of equipment does in fact fall within the envelope of the design spectra.

Verify that the case response spectra, specifically response spectra associated with the motion of the cast table, does in fact envelop the design spectra for each of the 7 groups of equipment.

Verify that the seismic test procedure meets the required IEEE 344-1975.

5.4.6.3 Acceptance Criteria i,

The governing criteria applicable to electrical equip-ment qualified.by test, as specified in the Hosgri 1

report is the IEEE 344 standard 1975 edition.

The seismic test proedure will be reviewed to verify than the requirements of the standard were met.

Se-condly, the test spectra will be required to envelop the design spectra.

5.4.7 Conduit Suonorts l

~

l 5.4.7.1 Sample The applicability of design spectra used in the qualifi-cation of conduit suuports was reviewed as part of :he 1

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n.

preliminary study of the PGandE design interface with URS/Blume.

As reported in the November 12, 1981 pre-14=h m study, a substantial portion of the sample was' qualified with either inapplicable spectra or acceleration values.

PGandE undertook a program to requalify all conduit support designs.

The present verification effort will involve 20 dif-farent conduit supports.

5.4.7.2 Methodology The methods to be employed for the verification of the conduit supports are:

Verify that the sample supports were installed according to the design, loading, location, di-mansions, etc.

Using the PGandE design methodology, independently calculate stresses for the sample supports.

Review the technical basis of the conduit. design methodology employed by PGandE incoporating the requirements of TEEE 344-1975.

5.4.7.3 Acceptance Criteria Acceptability of the field installation will be based

'on the PGandE colerances in drawings 050029 and 050030.

Review of the design methodology will consider the effectiveness of the resulting design to r'esist loads from the total dynamic effects of an earthquake, i.e.,

longitudinal and transverse socian, differential stiff-ness etc., as well as the applicability of the methodol-ogy throughout the plant. ~fhe seismic stress allow-ables in the AISC and AISI manuals are the governing e

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Criteria.

HVAC 'upports 5.4.8 S

5.4.8.1 Sample Two sections of HVAC _ducri. ha:ts been selected for independent verification.

One section is located in an area of high corsional accelerations in the building, and the other is attached to a floor with high peak horizontal response spectra.

5.4.8.2 Methodology The methodology for the. verification is based on the following points:

I A field. vez;Lfication of installations will be 1

j performed.

Independent analysis of the duct supports 5.4.'8.3 Acceptance Criteria Acceptability of the field installation will be based on a colerance of 15% in Mmansions.

Additional verification will be required for stress differences greater chan 15% or above allowables at governing locations.

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.m-33-6.0 Field verificacion In order to ensure that the building, piping, equipment and' components are built and installed in the manner for which they were qualified, an independent field verificacion will be made.

7.0 Hosgri Spectra The spectra used in the verification program will be che docketed Hosgri Spectra with two exceptions.

Turbine Building spectra included in che March 1980 Blume Turbine Building Report but not abailable in the Hosgri Report will be used (E0I 1029).

Tha revised annulus spectra (curves dated 10/30/81-Equipment Loads) will be used in place of the Hosgri angulua spectra.

4 l

Seismic inputs into che qualificacion calculacions for all che samples will be checked against the above spectra.

In addition che verificacion program will identify the lacase and most current seismic data developed by Blume.

8.0 Seismic Service Related Activities of NSSS Vendors The seismic design chain will be mapped to show all NSSS vendors who supplied service for Diablo Canyon.

The iner-face between PGandE and the NSSS vendor will be checked for cransmiccal of Hosgri spectra.

On a sampling basis NSSS vendor calculacions will be checked to verify chac-che applicable seismic input spectra were actually used for qualificacion calculacions. _

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e 9.0 Program Approach The review ceam(s) shall establish review plans,. checkliscs, schedule (s), and prioricies for accomplishing the Design Verification Program.

10.0 Reporting Procedures R.F. Reedy, Inc. QA Reports will be sent simultaneously to the NRC and R.L. Cloud Associaces.

R.L. Cloud Associates' semi-monthly, interm and final report will be sent simultaneously to che NRC and PGandE.

Deficiencias identified in the QA reviews will be nocad on sequencially numbered, "QA Findings and Observations" forms..

i Deficiencies identified by means of the independent calculacions will be noted on sequentially. numbered, " Error end. Open Ices (EOI)" forms.

These will be accached to che R. L. ' Cloud Asso-ciates semi-monthly reports.

11.0 Conclusion The Design Verificacion Program presented in this report is designed to be responsive to each point of the request for informacion listed in Accachment 1 to che NRC order suspending license, CLI-81-30, for DCNPP-1, dated November 19, 1981.

This verificacion program is designed to establish the correct-ness of the seismic design.

It will detect errors in the seismic design process that arise in the generation of daca, in the transmission of data, or in the use of data.

Tais will be accomplished by an in-depch review of Quality Assurance, independent sample calculations,~and -field. verification of as-build condicions.

A sampling approach employing engineering judgement will be employed which is designed to expand the S

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l-scope of the program upon dacccion.of an error.

1 ha Semi-monthly reports will be subniitted as requescad.

A final report will be prepared and submitted upon complacion of the program.

Tha significance of errors found will be evaluated.

If any errors are found to be significanc, reconunendations will be made.

This will include a descrip-tion of the errors correction, if required: implicacion to safecy, if any: the cause of the error with a scacement as co whether it is generic or not and a justificacion.

Errors decermined to be insignificane will be explained.

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e Table I I

EQUIPMENT Item PGandE or Contractor Analysis Anco & PGandE CCW Hz -

Manufacturer & PGandE CCW Pump Manufacturer & PGandE Aux SW Pump Manufacturer & PGandE Turbine Driven Aux FW Pump Anco & PGandE Diesel-Engina Starting Air Receiver Tank.

PGandE Diesel-Engina Oil Priming Tank.

PGanglE Boric Acid. Tank Wyle & PGandE Main Annmciator Cabinent Hot Shutdown Ramnca Manufuturer & PGandE Control Panel HVAC Supply Fan S-31 EDS Nuclear EDS Nuclear HVAC Damper 7A 7 Groups of Electrical.

Wyle Equipment by Test e

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Table I (continued)

EQUIPMENT 1

Valves Independent calculacions will be performed for:

FCV--41 EDS Nuclear Analysis FCV--95 EDS Nuclear Analysis Acceleration values will be checked for all che values in-cluded on the 10 piping analysis:

l Westinghouse analyzed' Valves

(

9001A 8804A 8700 9002A 8805A 8010A 8821A 88053 8010B 8921A 8394A 8d10C 8922A 8394B 9003A 8473 l

PGandE analyzed Valves l

FCV355 FCV37 4 valves listed 6 PGandE FCV430 LCV113 specificacion 8729 FCV431 LCV115 es e emp l

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TABLE II PIPING SAMPLE RLCA Piping i

Analysis Piping Basign Review No.

Blda.

System Isometric i

RLCA 100 Aux.

Contaimaant 446540 Rev.9-l Spray i;

RLCA 101 Aux.

Safety 446546 Rev.8 Injection RLCA 102 Aux.

Chemical Volume 446544 Rev. 11 Control 446542 Rev. 10 RLCA 103 Aux.

Residual Heat 446541 Rev. 7 Removal RLCA 104 Turbina Component Cool-449314 Rev. 3 Auz.

ing Wacar 449315 Rev. 3 449316 Rev. 3 RLCA 105 Cont.

Rasccor Coolant 437991 Rev. 16 System 445884 Rev. 8 RLCA 106 Conc.

Component Cool-446491 Rev. 10 ing Wacar RLCA 107 Aux.

Containmenc 446540 Rev. 9 Spray 446542 Rev. 10 RLCA 103 Aux.

Auxiliary 445878 Rev. 14 Feedwater RLCA 109 Aux.

Auxiliary 447119 Rev. 12 Feedwater e

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TABLE III QUALITY ASSURANCE PROGRAM REVIEWS CRITERIA ORGANIZATIONS APPENDIX B PG&E EDS EES HLA ANCO.

WILE,, URS/BLUME I. ORGANIZATION X

X X

II. PRCGRAM I

X X

III. DESIGN CCNTROL X

X X

X NA NA X

IV. PROCUREMENT I

NA NA X

DOC CONTROL V. INSTR. PROCED.

X X

X DRAWINGS VI. DOC. CONTROL I

I I

X X

VII. CONTROL OF I

NA NA X

NA NA I

PURCH. MAR'L SERVICES VIII. IDEN & CONTROL NA NA NA NA NA NA NA 0F MAT'LS, PTS, COMP II. CONT.0F SPEC.

NA NA NA NA NA NA NA' PROCESS I. INSPECTION NA NA NA NA NA NA NA XI. TEST CONTROL NA NA NA I

I X

NA III. CONTROL OF NA NA NA I

I I

NA M & TE XIII. HAND, SHIP NA NA NA NA.

NA NA NA

& STORE XIV. INSP, TEST &

NA NA NA NA NA NA NA OPER XV. NONCONF. MAT'L NA NA NA NA NA NA NA PTS, COMP XVI. CORRECTIVE I

X X

ACTION IVII. QA RECORDS X

X X

(7III. AUDITS X

X X

NA - Not Applicable

~

X - Applicable

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.a m _ z ATTACHMENT I Tabla 7-1 Hosgri Seismic Evaluacion--Loading Combinations and Structural' Criteria--h chanical Equipment i

Table 7-2 Hosgri Seismic Evaluation--Loading Combinacious and Structural Criteria--hchanical Equipmanc Supports 5

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aarles thg seerte of gccespl$stlag its desige Agac$1en.

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(4) morale needs shall laclude all piplag leads treasoitted to the cespennet durlag the isosgrt earthquate.

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(6) Velves, helas stranger then the ptsached piplag and havlag g preven history epithout ear gross failures of pressure bounderleg. casi gefely trengelt piplag leads without comproelslagtheirpressurerelaleloglategrity. Teoreferg piplag lategrity essere6 j!

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(1) See Chapters 5 and 6 for reacter caeltet systes supports, ij

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i ll (2) riate and Shell Type supports: ple(p and shell type cappeasel qupports are supports such e,

g es v.ssei airti sad uie, aich ere fonricos.4 tres piece eed shell elemete 94 er, j li seneally subjected to a blastel 64r,4s flejd.

e f,.,

ll (3) Llacar Type supporti A llaest type compeeest support is 4eflop( eg gcting under ll essentially a ginele e y *at of direct Stress. Eucli pleopptg may tigg be'6ubjec494 l

lo shear stresses. Isamples of tuch 61ructural elements ergi $9estes and cespresgles si,uu..e-s e.d Caiu s 3,cl,4 t.

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i and is produced only by machemical leeds.

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.and cisiesntrations, and le loroduced only by mechenteel leads, t

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9 ATTACHMENT II Hosgri Section 8.1 Spacing Critaris for Piping Seismic Restraints 9

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8.1 SPACING CRITERIA FOR PIPING SEISMIC RESTRAINTS

{~

s For certain pipe sizes (described below) spacing criteria were developed

~

for restraints to ensure that piping would be in the rigid region of the response % i.r..

i 8.1.1 PIPING GREATER THAN TWO INCHES IM DIAMETER AND (;P TO AND INCLUDI!!G l

SIX INCHES IN DIAMETER I

Spacing criteria for piping seismic restraints were developed by sinpitfied dynamic analysir on a simple span, simply supported beam. The beam's first mode is away freer the frequeny where the spectrum peak vaTue exists. The results. from this simpitfied approac.4 have been previously compared with detailed dynamic piping anaTysis and proven to be coasarvative(l). This t '.

simplified approach does not represent the exact solution to the 3-0 multi-de.a af-freedoar piping systes since the effect of the torsionaT moments v

and higher modes of vibration are neglected. Therefore, these design l

criteria were applied only. to piping systems in the rigid mgion of the j

response spectra. A piping. system was considered, rigid if the first mode of vibration was Tess. than 0.066 seconds.- (

A system restrained by these spacing critaria consists of spans of pipe suppcirted by two mutually perpendicular restraints normal to the pipe; a) at ait concentrated masses (e.g. valves), b) at all extended masses, c) at a maximust spacing orr straight runs of piping defined by the formulas.

gtvert below, and d) at elbows and. tees For eTbows and tees, the maximum l

axia1Ty measured distance was 75% of the straight-run distance calculated by the fornistas given below. The maximust distance between two seiscric~

guides may be determined from the following equation:

"2 (TEI5 L = 0.862 l

l (s ptember 19m 8-2 Amendmen: 53

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. = = =::

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Where:

Maximum" seismic span' (maximum distance between two seismic guides L

=

for straight nms) ft period (0.066 see)

T'

=

E'

= modulus of elasticity of' piping material, psi miment of inertia, in.'

I.=

~

ifp '=' weight of pipe per foot,.lb idw = weight of water per foot,1b (if applicable)

D

,,~ ~ 's' equation was used in a Company computer program PIPROP12 to generate Thi maximum: allowable pipe spans for various sizes of pipes containing water or air. The results from this calculation are susmarized in Table 8-1.

The values in this table wara-used. for the Diablo Canyon piping' designs.

The above design criteria were limited to cold piping systeam because the resulting restraints may not allow themai flexibility of hot piping. Also, these. spacing criteria normally were limited to pipes with diameters between two and. six. inches, because their use results in a large maiber of res-traints. For piping larger than 6 in in diameter, in the flexible regioi of the spectra,'it is sure economical to restrain the piping according to response spectrus modal superposition analysis described in Section 8.2.

I 8.1.Z PIPING TWO INCHE5' IN DIAMETER AND LESS For both cold and hot piping, two. inches in diameter or less, criteria for placing seismic restraints were also developed by the Company. These criteria deal primarily with two types of restraints:

1 1.

A bilatersi restraint holds the supported pipe in the planes r.onnal to its longitudinal axis. The pipe is allowed to move axially and to expand radfally within specified clearances.

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2. ' An axial restraint holds' the supported pipe axially and bilaterally.

The pipe is allowed to expand radially within specified clearances.

These restraints are supplemented as necessary by unilateral restraints-for-one direction only-to provide seismic mstraint while allowing for thennal expansion.-

Maximum spacing between successive bilateral supports is according to Table 8-2.

If concentrated loads (velves, flanges, etc.) are not directly sup-ported. the anximum allowable span is reduced by the length of piping equivalent 'to 'the weight of.the concentrated load. Piping mas longer than i

one span length, and less than 100 ft long, are allowed only one axial l

restraint.

Spacing cHteria were developed for seismic restraints on ' piping with off-sets. For example, Figure 8-1 illustrates the maximum allowable pipe length without axial restraint--es a function of pipe size and offset. Other cHteria cover spacing of bilateral restraints, as.well as minimum and maximuur pipe spans at comers.

8.1.3 RUIN FOR HQ58RI CONDITIONS

~

The spacing crf teHa fbe piping restraints, as described in Subsections l

8.1.T and 8.T.2, have been reviewed with the working HosgM acceleration respoese spectra (see Chapter 5) as 1.nput. 25 damping and maximum floor eccentricities (distance freer the building center of mass) were used in developing the spectra fbr the myfew. The results of this study indicate the fbliowfng:

1. Pipe stresses are within allowable limits.

I 2.

The simplified model described in Section 8.1.1 was run using the final Hosgri spectra for all Class I portions of the power plant. The result-ing load coefficients were found to be as shown in Table 8-10. A repre-l sentative case model was developed and run with the final HosgH spectra.

56 The loads and stressus found with this modal were less than the 1 cads and stresses developed by the simolified model. Thus, the c.cnsertatism of the simplified model was verified.

(November 1977) 8-4 Amendment 56

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e*

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ATTACHMENT III Hosgri Seccion 8.2 Response Spaccrum Modal Superposicion Analysis Hosgri Section 8.3 Analysis of Piping Six Inches and Greacar Attached cc Reactor Coolanc I. cop Piping 9

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t 8.2 RESPONSE SPECTQP MODAL SUPERPCSITION ANALYSES For the seismic design of Class I piping systems not covered by restraint..

spacing criteria, response spectrta modal superposition analysis us used with computer programs PIPOYN and PIPESD(2). Analysis of piping six inches and greater attached to the reactor coolant piping is discussed in t

Section 8.3.

4 j

PIP 0YN us written specifically for piping systems consisting of straight j

,, ipe and elbows. Input to the program consists of descriptions of the p

loads--horizontal and vertical acceleration spectra--and of the physical model. This andel has lusped asses and one-dimensional elements

all physical properties of the real member can be concentrated,on its al.astic.

axis The analysis is an eigenvalue of the reduced structure (consisting only of translational degrees of freedom). Results of the program are SRSS (square root of the sus of the squares) values of displacements, member end moments, effective stresses, 'stop forces and stop soments.

i PIPE 3D is much more comprehensive thart PIPDYN. It is designed to perfors linear elastic analysis of three-dimensional piping systema sIubjected to static, thermal,' and dynamic (earthquake) loadings. The results for a dynamic load case consist of vefues of displacements, support reactions.

and ammber forces and stresses. The dynamic load. casa can be coneined with static load cases te present., combined stress results. The methods for combining modal responses and combining stresses in this analysis are described below 1

The ass participation in each mode due to orthogonal components of motion l

(two horizontgl.and one vertical) was computed individually, and then added (one horizontal plus vertical) by absolute sunsation at the modal 60 level. All modal responses 1. ore combined by Square-Root-of-the Sun-of-the-i Squares to obtain the total response for all modes considered.

l L'

l (March 1978) 8-5 Amendment 6a l

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_J The total response was calculated twice: once with florth-South Horizontal and Vertical Spectra, and second with East-West Horizontal and Vertical Spectra. The' resultant total response used for design is the :naximum of 60

~

the twai calculations. This approach of cabined horizontal and vertical seisaric response may be illustrated as follows:

Let F be a responsa quantity of interest, be it a displacement or a member g

force at some point in the structure. Let Fij be the maximum response in the jth mode due to ith component of excitation. Consider n modes (i.e., j = 1,1... n) and 2 components (i.e.,1 = 1, 2 for horizontal and. vertical directions).

4 = ( j=$[

l F ij [ 1 )1/2 2

Then F 1

i=1 stresses resulting from the OE seismic analysis were cabined with deadload stresses, pressure stresses, and other htresses caused by other sustained loeds. The following equation in the ANSI B31.1 piping code was used:

C-a.n,,, + a.ni,, 1 1.2 S l

+

g g

h more:.

Internal pressure,.psig.

l P

=

l 00 = Qutside diameter of pipe, in.

t-

= Nominal wall thickness of component, in.

n

,, =,eseitant me.ent 1 min,. c,oss s.cti. due to susta,ned loads, in-1b.

~

M

= Resultant moment (in.-lb.) loading on cross secticn due to g

occasional loads such as thrusts frem ret tef/ safety valve loads, from pressure and flow transients, and (CE) design earthquakes.

For earthquake, usa only one hal,f pe earthquake moment range.

Effects of anchor displacement due to earthquake may be excluded.

Anendment 60 8-4 (March 1978) eI f '

4 t

a e-

4 =..-

--.~

=-

_z x..

_u u

\\

Basic atorial allowable stress at operating temperature from S

=

h allowable stress table of ANSI S21.1, psi.

For DOE stresses, the following formula was applied:

0.75 i M 0.75t M.

g

' I 1.8 S

, @n+

+

g g

h 14:ere:

for DE.'

M are DOE values corresponding to Mg C

Earthquake stresses due to the DOE were not calculated directly; instead the results from the OE piping analysis were doubled to repcesant the' 00E.

This approach was chosen because review of the design spectra showed that the DOE acceleration did not exceed twice the OE acceleration and in some cases was less than twice as large. Since pipe stress is linear with acceleration, this approach is conservative.

C

. Linear interpo(ation-was dsed to generate the spectra at the intermediate elevations. Each safssic analysis, deals with a section of pipe which lies between two or a re anchors. These anchors may represent equipment connec-tions, containment penetrations, or tuitsorts which restrict any transla-l tional 'and rotational avements of the pipe. Supports in the seismic l

analy' sis my be located at various elevations of the structure. Therefore, different response spectra at the carresponding support elevations are enveloped to obtain the final design spectra. In est cases, the highest elevation responsa spectra will govern and the low elevation spectra are ignored. In situations where the piping systems run between two buildings',

all support ei'entions are considered. Ffgure 8-2 illustrates the combination of spectra.

One hal,f percent damping was used throughout for CE and 00E analysis. l es e ans.

3-7 I

_ e_.

_r.., J n e

9.

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The fmme supports and snubbers in the seismic analyses are modeled as infinitely stiff elements. This modeling method is slightly'less conserva-tive than the actual situation. Since the support:: are designed with the first soda of frequency above '20 Hz. the slight deviations in support modeling do not significantly affect the results of the seimic analyses.

4 All piping designed by the response spectrtmi modal superposition analysis was found to exhibit acceptable pipe stresses under DE and DOE conditions.

piping systems seismically qualified by response spectra modal superposi-i tion methods for the OE/ DOE were reanalyzed using the Hosgri spectra, described in Chapter 5.

For, Class A,8 and C piping (as defined in FSAR Section 3.2), other than the ' reactor coolant loop, the specific differences in other criteria were as follows:

1.

The damping wes 25 for pipes equal to or less than 12 inches in diameter

' and 31'fbr 1tnes greater than 12 inches in diameter. ' As discussed in Chapter 5. these values are in accordance with Regulatory Guide 1.67.

2..

The Hosgrt earthquake loads or stresses were combi,ned with nomal operating loads or stresses--pressure plus desdtoad. The allowable j

l combined str' esses were currently accepted values for faulted condi-l for Class B and C piping (per ASME Code Case 1606-1) and tions-E.4 Sh fbr class A piping (unchanged from the FSAR, Table 5.2-13).

3.8 Sh i

3.

The allowable stress on all seimic supports was 1.2. S, based on ASME y

j 5ection III NF criteria. Table 8-9 lists the maximum allowable stressas for various loading combinations on hangers.

t i

~

l The results of the evaluation are shown in Table 8 3.

This table comparts h

the highest seismically induced stress and the maximum alloweble seimic stress for each piping component in each section. The allowable seimic stresses were obtained by subtracting the dead weight and longitudinal I

pressure stresses fmm the total 2.4 th allowable.

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(November 1977) 8-8 Ac.endment 58 l

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The table is organized on the basis of the major systems included and ifnes

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are given in numerical order within each system. Modifications were made-where seimic stresses exceeded allowable stresses, but some Ifnes which were not over allowable stresses have also been affected. Some Ifnes in the table are not represented by specific stress values but have the note "See 8.1.1."

This indicates that these lines were qualified by the seismic restraint spacing criteria described in Sections 8.1.1 and 8.1.3.

A few 3

ifnes in the tabte have the note "N.AE This stands for "Not Required *,

l and means that these lines are extremely short, embedded Jn,c.nogtetq4or otherwise obviousTy adequately supported to assure low seismic stres'ses.

)

. Lines in this category have been re. reviewed to verify this conclusion.

i Piping in the reactor coolant loop is discussed further in section 8.3

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t-8.3 ANALYSIS OF PIPING SIX INCHES AND GREAT B ATTACHED TO R UCTOR COOLANT

(-

LOOP PIPING Piping models were constructed for the WESTDYN computer program. This special purpose program is designed for the static and dynamic analysis of j

redundant piping systems with arbitrary loads. and boundary conditions The' lumpedeass models represented ordered sets of data that numeHeally descHbed the physical systema to the WESTOYM program.

The spatial geometry of the piping models was based on the piping isometHc i

drawings..The node point coordinates and the incremental lengths of the elements were calculated from these drawings..

. ~....

The luping of a distributed mass of a piping segnant was. accomplished by the fellowingr t,,

It For straight pipe between rigid restraints separated by length L. one.

half the totai masa was located 1/4 L from each rigid restraint.

j i

2.' For pipe segments witAvelves, flanges, anstifelds, etc..,tte piping mass was located along the centerline of the pipe at the location of j

the component.

3 For components, valves, flanges, manifolds, etc.. the total mass was located at the center of gravity of the component.

l Each piping model was coupled to a model of the appropMate reactor coolant toop which included the mass and stiffness characteHstics of the steam I

generator, reactor coolant pump, reactor vessel and core internals. The remaining reaci:or coolant loops were modeled as a 6x6 stiffness matHx applied at the reactor vessel centerline. The influence of the auxiliary piping supports on the piping model was considered by applying each support in the form of a 6x6 matrix representing the stiffness and directionality in the plant coordinate systam. Support types and directionality were obtained fram the appitcable support datati drawings. In geners1 support GO

('.

Amendnent 60 8-10 (March 1978)

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spring rates used in the analyses were calculated frem the support detail drawings.. Srubber spring rates were assumed to be the average of the W

manufacturer supplied tension and conversion values. t.oads acting on supports were computed by multiplying the support stiffness atrix, by the displacement vector at. the support point.

A sketch of a typt, cal piping model is shown in Figure 8-3.

The reactor coolant loop model to which the piping model was coupled is shown in Figure 8-4.

Analysis of the auxiliary piping as performed for the Hosgri earthquake horizontal floor response spectra discussed in Chapter 5 of this re. port.

l The analysis as performed using the three. dimensional lumped ass model described above and the response spectrum method also discussed in Chapter.

L.,

i

~.

The horizontal response spectrum used in the analyses was the envelope of i

l floor response spectra curves for the interior contairement at elevation

+

l 1 M.ft. and if applicable, the her contai,nnnt at the elevatio.n of the y

containment. penetration of the specific. piping under consideration. The interior containment 140 ft. elevation represents the highest elevation for attachment of the piping supports or components and also eximum horizontal l

l seisuic ancitation. -

The vertical response spectrum used in the analyses was the envelope of 60 floor response spectra curves. for the interior containment at elevation 140 ft. and, dere applicable, the exterior containment at the elevation of the containment penetration of the specific piping under consf deration and also, where applicable, the containment annulus structure (envelope of curves dependent upon, actual location of support attachment to the annulus structure). The interior containment 140 ft. elevation represents tne highest elevation for attachment of the piping supports or components and also eximum vertical seismic excitation.

t

'41 thin each mode, the results due to the vertical sacek were added absolutely to the results of tne horizontal snock directions. The modal l

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contributions were then added by the-SRSS. method.

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(Marca 1978) 8 11 Amencment 60

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Two seismic cases were consid' red; north-south plus vertical. asid east-west

{.

e plus iertical. The. worst combined response was used in the evaluation of the systas.

The following loading combination was considered:

I m

N M t'~1 3.6Sy y.

Where:

3, '

fongitudinal pressure stress as defined by Paragraph 102.3.2

=

of the ANSI 831.1 code,1973.

. S g

an assumed maxfinar stress of 1500 psi due to deadweight. -

=

moment.

gg = stres' due to the Hosgri earthquake inertial moment as S

s C.

deffned by Paragraph 104.8.2. equation 12, of the referenced r-code.

s h

piping anterial allowable stress at eximian tamperature from Appendix A of the refierenced code.

Summary results. are given in Table 8-3 and compare the calculated stresses resulting freur the Hosgrt earthquake to the allomble seismic stresses.

The allowable seismic stresses were obtained by subtracting the daadweight and longitudinal pressure stresses from the total 3.6 S allowable.

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Amendment 66 8-12 (August 1978)

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NUCLEAR REGULATORY COT,if.ilSSION

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MAR 5 1982 Mr. Halcolm H. Furbush Joel Reynolds, Esq.

.i Vice President - General Counsel John R. Phillips, Esq.

Pacific Gas and Electric Company Center for Law in the Public Interest Post Office Box 7442 10951 West Pico Boulevard San Francisco, California 94120 Third Floor Los Angeles, California 90064 The Honorable Edmund G. Brown, Jr.

Governor of California Sacramento, California 95814 Gentlemen:

The Cor.cission, in its ' meeting on March 4,1982, accepted the staff reccamen-dation that the Diablo Canyon Seismic Design Verification Program - Phase I be performed by a contractor (such as Teledyne) with (1) little previous involvement with Pacific Gas and Electric Company and (2) a large experienced staff in nuclear power plant design and quality assurance. The Commission also directed the staff and advised all other parties to the Diablo Canyon proceeding to reach agreement within one week on one or more of such organiza-tions acceptable to all parties.

As discussed by Mr. William Olmstead on Friday, March 5,1982, the purpose of I

this letter is to request that you prepare such a list of proposed contractors.

The list will form the basis for discussion, in conjunction with similar lists prepared by the other parties, at a meeting of the parties on Wednesday, March 10, 1982 at 9:00 a.m. in Room 422 of the Phillips Building in Bethesda, Maryland.

l Sincerely, I

3 'w.

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

H. Brown D. Fleischaker A

B. Norton e

e em meme Oh

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a.

Mr. Malcolm H. Furbush Vice President - General Counsel Pacific Gas and Electric Company Post Office. Box 7442 San Francisco, California 94120

Dear Mr. Furbush:

The Commission, in its meeting on March 4,1982, accepted the staff recommen-dation that the Diablo Canyon Seismic Design Verification Program - Phase I be performed by a contractor (such as Teledyne) with (1) If ttle previous involvement with Pacific Gas and Electric Company and (2) a large experienced staff in nuclear power plant design and quality assurance. The Commission also directed the staff and advised all other parties to the Diablo Canyon proceeding to reach agreement within one week on one or more of such organiza '

tions acceptable to all parties.

As discussed by Mr. William Omstead with your Mr. Bruce Norton on Friday, March 5,1982, the purpose of this letter is to request that you prepare such d list of proposed contractors. The list will form the basis for discussion, in conjunction with similiar lists prepared by the other parties, at a meeting of the parties on Wednesday, March 10,1982 at 9:00 a.m. in Room 422 of the Phillips Building in Bethesda, Maryland.

Sincerely, Harold R. Denton, Director Director of Licensing cc:

H. Brown D. Fleischaker 4

m e me t

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OISTRikTION:

Docket File RDeYoung LB#3 File EJordan HDenton RTedesco ECase BBuckley MAR 5 1982 Ryo11mer FMiraglia DEisenhut-JLee RPurple IE W01mstead REngelken

!!r. Halcolm H. Furbush JoeYMolds. Esq.

,' ice President - General Counsel.

John R. Phillips, Esq.

.f acific has and Electrjs Ggeginyg,,

Center for Law in the.Public Interest F att Office Box 7442 10951 West Pico Boulevara San Francisco, California 94120 Thiro,rloor Los Ant,eles, California 90064 The sionorable Eanuno G. Drown, Jr.

covernor of California Stcra.mento, California 95814

/

Gentlemen:

The cc::.tission, in its coeting on March 4,1962, accepted the staff recoir..en-dation tnat the Diablo Canyon se,istaic Design Verifwation Program - Phase !

be perfor.aec by a contractor (such as Teledyne) with (1) little previous involvement witn Pacific Gas and Electric Company and (2) a large experienced staff in nuclear power plant eesign anc quality assurance. The Comission J

also directed the staff anFaavised all other parties to the Diablo Canyon proceeding to reach agreei;mnt within one week en one or more of such organiza-tions acceptable to all parties.

/s discussed by !!r. ',1111am Ohsteaa on Friday, tiarch 5,11[u2, the J.urpose of this letter is to request tr.at you prepare such a list of proposed contractors.

The list will fort.:

the basis for ciscussion, in conjur.ction with simil er lists

reparac of tne cther parties, at a Maeting of the parties on. Wertnesccy, i.4ren 1;,

ir L.s V:w a.o. in i,vcn...,n of 1.i.e Phillips Lu11cing ir. Bethesca,..arylanc.

Sincerely, ORIGINAL SIdlC 37 R. L. TICISCO narcic c. Dentun, sircetar j g, Utructor of Licensing., a h,.,. :.,

j

.s cc:

li. Drown

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D. Fleischaker h

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1 cument Control:

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i R. F. REEDY, INCORPORATED

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236 N. Santa Cruz Avenue

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Los Gatos. California 95030 * (408) 354-9110

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tf' March 8, 1982 GA b..' T O' W'. /

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Robert L. Cloud and Associates, Inc.

125 University Avenue O

g Berkeley, CA 94710 a,

Subject:

Report of R. F. Reedy, Inc.

TA Review of Pacific Gas and Electric Company

Dear Mr. Cloud:

Attached is a copy o,f our Quality Assurance Audit and Review report of Pacific Gas and Electric Ccmpany (PG&E).

We have reviewed the Quality Assurance Program as it related to seismic safety-related design performed prior to June, 1978.

The details of our review are contained in this final report.

I am transmitting a copy of this report to Mr. Rarold Denton of the NRC.

V ly yo s

/

F.f (dy, P.E.g /

j Rog Re R.

. 2EEDY, INC.

V RFR:cc Encl.

cc:

Mr. Harold Denton

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REGLLATw11 1hECn;. ATIC., vISTaloililuk $ s 3 tem sAIDJ)

ACCESSION NUR A203160309 OuC.DATt: 82/03/08 NOTARIZED: NC DOCKET m FACIL 50-275 Diablo Canyon Nuclear Power Plant, Unit'.1.,' Pacific Ga. 05000275 50-323 Dianto Canyon Nucleae power Plant, unit.R, Pacific Ga.'05000323 AUTH.AAhE AUTHOP AFFILIATION REEDY,k.F.

R.F. Needy, Inc.

4ECIP.NA"E HECIr!LNT AFFILIATION CLOUD,R.L.

Robert L. Cloud Associates, Inc.

a nie sent,p%a,,

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p.43-te

SUBJECT:

Forwards "ca Heview 4 n

safety-related cesiun svcs performeo t'or PG/.E refor to Juna 1976.

OTNTRIBUTIONCCOC: R0013 CCHIES RECETVE0 LTR.. EACL /.

SIZE [.[.b.f'...

I TITLC: PGAll/F3A9 A; CTS and avlatec Corresponoence NOTES J Hanchett icy POR Occuments.

7f/

<{

"'"* 45.000279 J hanchett icy POR Occuments.

. 05040323 RECIPIENT COPIES RECIPIENT CCPIES 10 CODE / NAP'E LT f R ENCL 10 CCOE/hAPE LTTR ENCL A/O LICErS.'A 1

0 LIC RW e3 HC 1

0 Ltc SR 83 LA 1

0 BUCKLEY,R.

01 1

1 INTERAAL: ELV 1

0 IE 06 1

1 IE/0Ep/EP06 35 1

1

!k/DEP/EPLA 36 3

3

!4P A 1

0 NRR/0E/CEB 11 1

1 NRR/DC/EGB 13 3

3 NRR/0E/GR 28 2

2 NRR/DE/HGE8 30 d

2 NRR/0F' NEB 18 1

1 NRH/0E/*TED 17 1

1 NRR/0E/QA0 21 1

1 NRR/0E/ SAC 24 1

1 NRR/0E/SEO 25 1

1 NRH/0HFS/HFE040 1

1 NR8/0HFS/LOS 32 1

1 hRH/0HFS/0LB 34 1

1 NRR/0HF3/PTR920 1

1 hRH/DSI/AEG 2u 1

1 NMR/OS!/ASB 27 1

'1 NRd/OSI/CDb 10 1

1 NR3/OSI/CS8 09 1

1 t

hRn/OSI/ETSR 12 1

1 NRR/OSI/ICSB 16 t

1 NRs/OSI/P3h 19 1

1 NR4/OSI/ RAS 22 1

1 NWn/OSI/RSo 23 1

1 NR9/OST/LGO 33 1

1 HEG FILE 04 1

1 RGN5 1

1 E r f E N P. AL : ACds at to 16 aNL(AMOTS ONLf) 1 1

FEMA = REP CIV 39 1

1 LPOR 03 2

2 f.9C P6H 04 1

1 NS!C 05 1

1 f,713 1

1 1

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QUALITY ASSURANCE REVIEW AND AUDIT REPORT PEASE I By:

R. F. REEDY, INC.

On SAFETY-RELATED ACTIVITIES PERFORMED BY PACIFIC GAS AND ELECTRIC PRIOR TO JUNE, 1978 s

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v PGt.E - March 8, 1992 1/99 203160313-GIO303

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.s QUALITY ASSURANCE PROGRAM REVIEW REPORT PHASE I SAFETY RELATED ACTIVITIES PERFORMED BY PACIFIC GAS AND ELECTRIC PRIOR TO, JUNE 1, 1978 Introduction Scope:

On February 23, 1982 R. F. Reedy, Inc. completed the Quality Assurance Review and Audit of Pacific Gas and Electric (PG&E) safety related activities concerning the Diablo Canyon Nuclear Project.

The purpose of this review and audit was to assess the adequacy of PG&E Quality Assurance Program prior to June, 1978 with particular emphasis on activities that could affect seismic related design.

The base.line for this review and audit were the requirements of 10CFR50, Appendix B.

PG&E Activities:

PG&E had the responsibilities of Architect-Eng'ineer and Construction Manager for the Diablo Canyon Project.

PG&E was supported in their design ac,tivities by contracted design consultants.

Evaluation Criteria:

___..m This Quality Assurance Review and Audit of PG&E addressed the requirements of 10CFR50, Appendix B with selected parts of ANSI N45.2.ll being considered for guidance.

Follow-up items were introduced that evolved from earlier R. F. Reedy, Inc. audits of PG&E design consultants.

?.fothed of Review and Audit!

The review and audit was conducted in three steps:

1.

Introductory meetings; 2.

Quality Assurance Manual and Procedure

review, and, 3. Audit of program implementation.

Steps 2

and 3 were performed to detailed checklista, and a general questionaire was used for Step 1.

The introductory meetings were held at p0&E on Dec. 17 and 18, 1981.

The discipline groups visited were Quality PG4E - March 8, 199 2/89 t 4 WMdem de-ees a eW 4#we A-e3

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t One concern is if the latest Hosgri seismic data was inputted-f or design analysis.

3.

The design verification program was not formalized and was inconsistently implemented and documented.

This included major gaps in design overviews of the design approach for mechanical and other equipment.

,I Findings programmatic Deficiencies:

1.

Quality Assurance,as defined in the QA' Manual was essentially an audit rols.

The Quality Assurance group was not assigned a

pri=ary role in deter =ining QA requirements.

2.

PG&E had no procedure for assuring the completeness of the QA program to address the requirements of 10CFR50, Appendix B.

I 3.

There were no provisions. for document c strol of correspondance and design documents.

4.

During Phase I, there were no controlled procedures for design control, design interfaces and design responst-bilities.

PRE-9 and PRE-10 on these subjects were released in 1979 and see to be audited during Phase I,I.

5.

PG&E did not require design consultants to imple' cent Quality Assurance requirements.

6.

Corrective action provisions were not addressed except with respect to audit deficiencies and deficiencies at the site.

7.

Indoctrination and training were not addressed in the QA Manual or procedures.

8.

The QA Manual contained no provisions for PGaE management review of the QA program for status and adequacy.

!=plementation Deficiencies:

1.

P0&E mana6ement did not review and assess the effectiveness of the Quality Assurance Program.

PG&E - March 9, 1992 4/39 i

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o WYLE was not contractually-required to have a Quality.tesuranca Program until Dec. 1, 1979.

o ANCO was not contractually required to have a i-Quality Assurance Program until May 1978.

4.

PG&E design verification on in-house activities and suppliers was unstructured and applied inconsistently.

i We consider that design verification consists of the following three elements:

~

1)

Design overview for design approach, methods, design input selection, and assumptions.

+

2)

Detailed checking of design steps and completed design documents.

3)

Verification of approved "As Built" condition against approved design.

Activities for element 3 were not initiated until 1979 and ~ are to be reviewed during Phase II.

Documentation showed detailed checks to be performed on PG&E work with design overviews being performed on a' selective basis.

Most of what PG&E refers to as Design Reviews consists of element 2.

o Comprehensive overvi'ews and det iled checks were performed by EDS on Class I electrical design, some EVAC, and structural items.

Design overviews were not evident for mechanical decignn.

4 o

PG&E did not require design contractors to perform design reviews of their own work.

o For the majority of cases

reviewed, design verification criteria were not defined and were dependent on the discretion of "ae reviewing engineer.

i o

Documentation of design verifications was inconsis-tent and at times incomplete.

i 5.

There was no effective document control system established.

o Design interfaces intornally and e.tternally were PG&E - Mn:ch 3, 1992 6/09 e

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APPENDIX A t

l AUDIT ATTENDANCE LIST i

i 1

1 4

t PG&E - March 8, 1982 8/89

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l ATTENDANCE LIST I

FOR INTRODUCTION MEETINGS ti 12/17/81 12/18/81 l

i W. S. Gibbons R. F. Reedy, Inc.

x x

j P. J. IIerbert R. F. Reedy, Inc.

x x

l R. F. Reedy R. F. Reedy, Inc.

x x

f P. Chen R. L. Cloud & Assoc.

x x

E. Dennison R. L. Cloud & Assoc.

x 1

C. Ralston PG&E x

W. Raymond PG&E i :"

x i ~-

J.

Rocca PGEE x

C, Eldridge PGEE x

J,. McCracken PGEE x

x I. '

I' l

H. Bettinger PG&E x

P. hollack PG&E x

J. McCann PG&E x

I t

A. Immas PG&E x

f g

M. Cunley PG&E x

f E. Kahler PG&E x

l G. II. Aster PGEE x

I J.

It. IIerrera PG&E x

I i

~

i PGEE - March 8, 1982 f1 9/89 I

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ATTENDANCE LIST EXIT INTERVIEW AT PG&E Name Company Name Company W. S. Gibbons R.

F. Reedy, Inc.

J. R. IIerrera PG&E R.

F. Reedy R.

F.

Reedy, Inc.

D.

A'. Brand PG&E i

P. J. IIerbert.

R. F.

Reedy, Inc.

J. J. McCunn PG&E T. G. deUriarte PG&E J. V. Rocca PG&E J. W. Colwell PG&E E. Denison R. L. Cloud & Assoc.

Dan Brand PG&E J. B. Hoch PGEE R. M.

I.averty PG&E G. II. Moore PG&E j'

J.

E.'Ilerbst PG&E M., R. Tresler PG&E it

[-

t P.

Zerebinski PG&E G. H. Aster PG&E

(

., 7 E.' R. Kahler PG&E E. P. Wollak PG&E F

i H.l S.

Breed PG&E j:

r i

D.

I.. Polley PGLE

,F: {

^

W. A.

Raymond PG&E I-f.

i C.

E.

Ralston PG&E q

g' ~

It. V.

!!c t tiliger PG&E

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APPENDIX B PROGRAM REVIEW CHECKLIST I

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l PG&E - March 3, 1982 12/89 i

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F. REEDY, INC.

PROGRAM REVIEW CHECKLIST l

e ORGANIZATION: PG&E Co.

ADDRESS:

77 Beale' Street San Francisco, CA 94106 QA PROGRAM

REFERENCE:

QA Manual, January 1970

Q'A Manual, Rev. 3, April 15, 1974 l

. REVIEW CONDUCTED BY: W., S. Gibbons Y DATE: 1/30/82 REVIEWED BY:

.DATE:

Z

/ V E

// ' ATE:

DATE:

1

Through Manual Change No. 36 (4/24/78) :

l Volume I Policy l

Volume II - Quality Assurance Precedures NO. OF PAGES:

22 l

^

PG&E - March 8, 1982 13/89 l

l I

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P PROGRAM REVIEW CHECKLIST January 30, 1982

[.,

l

)ROJECT: Diablo Canyon

Subject:

I Orqanization (Arzt El Page 1 of 3 f]

PROGRAM AND ITEH REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS REFERENCES 1.

'Itc applicant shall be responsible OAM Authoriza-X'

' Applicability of ()AM in Unit 1 is not j.

for the estahlistment and execution tion clear in that OAM lav. O arx13 Authoriza-of the quality assurance program, tion Statesnent addresses Unit 2 only.

'the applicant nay delegate to FS.\\n Osapter 17 (17.0 Quality Assurance) i others, such as contractors, agents,

p. 17.0-1 states QAM would also be used or consultants, the work of estab-for Unit 1 to th( extent possible. FSAR

[

lishing asyl executing the quality Aneixtnent 14,17,}.1, July 1974, states assurance projran, or any part

" IGE... Units 1 and 2, established a l

thereof, Ixit shall retain responsi-quality assuranca'iprograin for design, bility therefor.

construction anditartup of the plaat

.'I which controls Ifp&E's activities arvi the activities of' suppliers and contrac-8 torn."

l '.

f

[ff 2.

'the authbrity and duties of per-OAM 2.0 (Rev.0)

X Project Engineer is also Olief Hecinnical sons arxl[ organizations perfonning Engineer... " coordinates engineerity

'p' ;

activitihs affectiry the safety-activities within the Engineering arvi Con-related functions of structures, struction Departinents...". Coordination j

systems, arx1 coiponents shall be is not clear in absence of controlling clearly estahlinhed arxl delineated i

procedures until PRE-9, Design Respmsi-in writing. 'these activities bilities and Interfaces (issued 6/10/79) j.'

inclixte hoth the gerfonning func-and PRE-10, Design Control (issued tions of attaining quality cbjec-6/111/79) - (note, these dates exceol

.l :,

.tives and the quality assurance June 1978.)

(M

~l functions. 'the quality assurance functions are those of (a) assuring Ii I

tlkit an tippropriate qiiality assur-anx'e projrain is established and i

ef tectively executed and (b) veri-fyles, stich au by checking, atxlit-l i

l inn, anxl instection, that activi-PG&E - March 8, 1982 g

3 1

Lies affectis.y the safety-related 14/89

.l functhins have luen correctly I

Ierfonial.

4

1 i

.f B

PROGRAM REVIEW CHECKLIST January 30, 1982 i

)ROJECT: Diablo Canyon Subjects :I Omanization

'Arp, BC Page 3 of 3

i r

PROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEN COHHENTS I

90.

REFERENCES l1 4.

...the irglividual(s) assigned the 2.0 X.

After 6/9/72 QAM revision.

responsibility for assuring effec-tive execution of any portion of the

1.

(puslity assurance program at any location where activities subject' to this Apperxlix are 1xming performed I

shall have direct access to such f~

-! lI l

levels ofgrunagement as may be y

.; j necessary to perfonn this function.

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PROGRAM REVIEW CHECK 1.IST January 30, 1982 Page 2 of 3 i

2ROJECT: Diablo Canyon Subjects' TT Prroram (App B)

I PROGRAH AND

.i REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS ITEH NO REFERFNCES 3.

'line quality assurance program PRE-12 X.

Addresses classificaticin of structures, shall provide control over activi-systems and cniponents.

'l I

ties affectiiv3 the quality of the identifial sLmetures, systems, and i

ccuponents, to an extent consistent t

with their inportance to safety.

y,

~!

4.

Activities affecting quality X

Construction is contracted.

shall Le accaiplisixxl under suitably 1

controlled conditions. Conditions 1

incliule the use of appropriate equiguents suitable enviromental

{~

oonditioris for acccuplishing the activity, such as adequate clean-ness; ar I assurance diat all pre-rapiisitps for the given activity f.

,I have been satisfied.

I !

5.

'lle prcyram shall take into OAM 3.3.6 X

(x)

Construction is contracted.

. [

acccaint the need for special con-OnM addresses requirments.

trols, processes, test equl[nent, a

1 tools, arvi skills to attain the

'l rapiire I qikil*ity, arid die neal for 4

verification of quality by inspec-f f

tion aryl test.

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a PROGRAM REVIEW CHECKLIST January 30, 1982

, "'8 if 2ROJECT: Diablo Canyon

Subject:

III [esign Control (Aru. B)

Page 1 of 5 3

PROGRAM AND l

REQUIFEMENT PROCEDtJRE YES NO N/A REVIEW COMMENTS ITEM i.' l No.

REFERENCES

.p

.j 1.

Measures chall be establisted to 041 3.2.1 X

.e i!

assure that opf1f'ni,le regulatory 1l

-l recpaironeswapixl ti.e design basis, PRE-4 X

Specifications.

l{

as acrip&l in Para. 50.2 and as ll V(ut/A@ in the license applica-OMI 3.2.2.1 tion, for those structures, systems PM:-3 X

Dravings.

i and caiponents to dich this Appeixlix applies are correctly OMI 1.4 X

Procedures to be in other Vohanes.

.~

translatal into specifications, drawiivjs, proculures, and instruc-tions.

1 ','-

l ' ' l, 2.

'these nea'stires shall incitxle provi-OMI Rev. 0 sions to assure that appropriate and Rev. 3, 2

~

(piality htarxbrds are specified and 3.2.1 X

Engineering responsible for; Y' I ]f incituted' in design doctments and i'

that devkations fran such standards Pm:-2 I

v I

are controlled.

(7/17/70)

fj 3.3.2 X

Mennrandum of Design Criteria.

.J l

includes Quality Assurance Requirernants.

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OMI 3.2.2.3 PIWl-3

.' i i l :. {l Nonconfor-nonces and

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Corrective l /*,

?;i 1

Action X

Addresses design changes.

Plot-3 (issued 2/1/78) - addresses dapar-tures fran approved requirements....

11 i

design.

1 PG&E - March 8, 1982 i

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PROGRAN REVIEW CHECKLIST January 30, 1982

+

ii 2ROJECT: Diablo Canyon Subjects' III Design Contml (Ap). B)

Page 3 of 5

j PROGRAN AND REQUIREMENT PROCEDURE YES NO N/A REVIEW CONNENTS ITEM No.

REFERENCES i1 5.

'these neasures shall include the GN4 3.2.3 X

Requires procedures,tuit procedure

~:,

establistment of procedures among PRE-9 not issued until. 6/18/79.

participating design organizations See III, 4., above.

for the review, approval, release, distritmtion, aryl revision of docu-I t.-

nents involvirvj design interfaces.

6.

'the design control neasures shall 0213.2.2.2 X

Inadequately aMrnsa,vvi.

provide for verifying or checking tle ackrluacy of design, such as by PRE-2 the perfonnance of design reviews, (3.2.5) 11 ly the u;;c of alternative or sinpli-Design Devel-

q fied calculational methods, or by opent X

.Only checking of calculations.

i}

the perfonrunce of a suitable test-

?

l ing pra ram. '1he verifying or PRE-3

j i

checking process shall be performed Drawing Pre-i i3 ly 1 xlividuals or groups other than

paration, tiose who perfonted the original Review and.

M d

design, int win nay be fran the sanu Approval X

3.5.2 - Responsible Engineer may mive

-}

organization.

checking at his discretion.

i i

Plu;-6, i?

lj Calprehensive i!(

X "Suoervising Engineers are responsible

j Denign Review for selecting structures, systons arv1 corponents Wiich require cuipre-hensive design reviews..." rather than

'. j li for all Class I itens.

N

'f7 PG&E - March 8, 1982 a

22/89

)

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g PROGRAM REVIEW CHECKLIST January 30, 1982

.l 2ROJECr: Diablo Canyon

Subject:

III Desicm Control (Am. B)

Page 5 of 5

PRC4 RAM AND I

j REQUIREMENT PRCCEDURE YES NO N/A REVIEW COMMENTS l$'

I N 0

REEERENCES 1

7.

Design changes, including field OMI 3.2.2.3 X

only requires referral to Responsible clarvjes, shall tu subject to design Engineer and Supervising Engineer for control neasures comensurate with review and written approval.

d ose applied to tie original

s design and le atproved by Llm organ-PIU:-2 izatico that performxi tie original Denign Devel-

),

design unless the applicant desig-opent X

Does not address subject.

nates another responsible organiza-tion.

PRI:-3

j_.

j Drawing Prep-

aration, Review and Approval X

Miresses for IC&E drawih is.

f l

Plu:-4

[

Specification Pnparation, Review and j;

Approval X

Mlresses for spec changes.

~ f.

.61

+

PRI-l-10 Design Control X

Issued 6/18/79.

i' 7

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PG&E - March 8, 1982 24/89 i

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PROGRAM REVIEW CHECKLIST January 30, 1982 i

?ROJECT: Diablo Canyon Subject; V Instructions, Procedures..and Drawings (Arc. til *

Page 1 of 1 PROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COHHENTS ITEH NO.

REf'ERENCES 1.

Activities affecting quality shall OAM 1.4 and be prescritul by documented instruc-OAM 3.1.1 X

Ibguiranent for procedures prescribed tions, procodores, or drawings of a and are contained in Supraemental type appropriate to the circtanstan-Voltanes.

ces arx1 shall be accorplished in acconlance uith these instructions, i I ll procalures, or drawirvJs.

2.

Instructions, procedures, or draw-OAM and PIM-1 inyJs shall include appropriate or Otulity Assur qualitative acceptance criteria for ance Program

,i detennini,ng that inportant activi-Control X

%ese do not aMress this requirement,

'n !.

i(( f, '

j ties have been satisfactorily however, it is included in the speci-i accmpliplet.

fic procedures.

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PitOGRI.M REVIEW CHECKLIST p.y

, 1982

!VIIControlofPurchasedMaterial,

)ROJECT: Diablo Canyon

Subject:

. Fanirunent, and Mrvices (Arp.11)

Page 1 of 3 PROGRAM AND

~ REQUIREMENT PROCEDURE YES*

NO N/A REVIEW COHHENTS I "

REl'ERENCES l.

naasures shall be established to OAM 3.2.1 X

Addresses equipnent suppliers and field j '. ?

assure that purchased material, OAM 3.2.4 contractors. Does not address deuicpi

)

erluiginent, anl services, whether GAM 3.2.5 consultants.

"{

turclased directly or through con-tractors aryl subcontractors, conforn PRP-1

,i to the procurenent documents.

Suppliers Pre-

!j Survey and' ~

!l

j Award Quality

M

'l Evaluation (PI;P-1 Rev.3, I.) [

9/15/78, re-vised to in-r-

i clude services 7

~'

in supplier

j definition)

PRP-4 Suppli-

1 ers.' /Contrac-3l q

tors' Ouality Assurance Pro-4 grams.

t PHP-5 Qualified nidders List PitE:-7

, b

i i

Sugplier Bid Iteview and Award PitE-8 IM4 Preparation anct Itelease

'l a

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i Pit 0 CRAM REVIEW CHECKLIST January 30, 1982 VII Control of Purchased Material, 3ROJECT: Diablo Canyon

Subject:

Fanirmmt, and Services (Am. B)

Page 3 of 1

f PROGRAM AND l

)

4' REQUIREMENT PROCEDURE YES NO N/A REVIEW COHHENTS ITEH

.I Wo.

REFERENCES jl 4.

'Ibe effectiveness of the cxmtrcl ONt 3.2.5 of (piality by contractors shall be ONt 3.6

.M

')

assesual by the applicant or desi -

ONi 3.6.2 X

Covered by IC&E Surveillance and audits.

9 nee at intervals consistent with -

States: " Audits will Le apolied to PGEE's the ingortance, cmplexity, and own organization, as well as consultants,

.i

<piantity of the product or services.

contractors, and suppliers."

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s PROGRAM REVIEW CHECKLIST h

l January 30, 1982

g p 2ROJ ECT: Diablo Canyon Stibject : I XVI Corrective Action (App. B)

Page 2 of 2 i'

PROGRAH AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COHHENTS I "

NO.

REFERENCES I

e' 3.

'line identification of tle signifi-OAM 3.6.3 X

'See itesns 1. and 2., alxwe.. " Audit cant corvlitions adverse to quality, reports forwarded to apprcpriate tic cause of the condition, and the nanagement officers."

corrective action taken shall be doctaiented arvl reported to appropri-ate levels of nanagatent.

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PROGRAM REVIEW CHECKl.IST January 30, 1982

?ROJECT: Diablo Canyon

Subject:

XVII Guality AssurancetRecords (Ann. B)

Page 2 of 2 PROGRAM AND a

l ITM REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS NOo REFERENCES

. s j

4.

Records stall be identifiable and See 1., above.

N retrievable. Consistent with appli-

, {,.

i2.j. -

3 cable regulatory requirenents, thu

~

applicant shall establish require-l nents concerning record retention, such as duration, location, and j

I assig xxl responsibility.

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APPENDIX C PART A GENERAL REQUIRE.E rrS AND MANAGEMENT CONTROL.

CF QUALITY ASSU ENCE I.

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1 AUDIT CHECKLIST 1

l Company Pacific Gas & Electric Company PMBe 1 of 19 l

Applicable QAM Rev. O thru Rev. 3 Amil tor WSG Date February 2-23, 1982 8*

Statement

' Audit Instruction

. Comment lI I

Such persons and organiza-(a) Determine project organ- (a) Historical copies of organ-tions performing quality as-ization and specific person-ization charts wern not surance functions shall re-nel in effect for time per-retained as QA records.

port to a mangement level lod (pre-June 78) by review Reviewed the charts that were y

such that this required auth-of objective evidence.

made available (earliest was yt;;

ority and organizational 1/13/70) and other documents jp, d

freedom, including sufficient to verify existence of proj(ct

f

independence from cost and organizational structure.

j schedule when opposed to Responsible engineers were safety considerations, are identified in discipline provided (10CFR50, App. B).

group lists issued as memoranda j

It may be possible to establish

4 2.112

...Hesponsibility for execu-the precise organization in G4 tion and implementation of effect at a given time, but

'i the Quality Assurance Program this would require a detailed

]

}

8 is assigned to both the Vice review of memoranda and was l

President-Engineering and not done for this audit.

N1 E Vice President-General Con-d r

.] [.

((

struction...The Vice President (b) Verify for quality en-(b)

Until March 1982 Quality

-Engineering has primary gineering and quality assur-Engineering, which had respon-J 11 responsibility for design...

ance that the job functions sibility for total quality l

(and) is also responsible for and relationships described program, was part of engineer-

i p

j development and coordination include sufficient indepen-ing and reported to same

't of tile Quality Assurance Pro-dence from cost and schedul( Engineering'Vice-President.

' d,

j!

gram.

considerations when opposi-During this time Quality

'i 9 l{

tion to safety considera-Engineering was not independent

. i..

j 2.1.2 Has authority to stop work if

t. ions may arise.

of Engineering.

Reorganizatlan

'{

(alp 8 technical and regulatory in March 1972 created Quality

't o

+-

requirements are'not being Assurance Department reporting 11 observed.

to the Executive Vice-President ji 8

.1 -

PG&E - March 8, 1982 I

37/89 e

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'J i t.It' e

i AUDIT CHECKLIST i

Page 3 of 19 Company Pacific Gas & Electric Company l

4 Appticable QAM Rev. O thru Rev. 3 Aud tor,WSG i Date ebruary 2-23, 1982 i

APP

0*

OA" statement

-Audit Instruction

d,Commen t

}

Crit.

Ref.

i

'l...

2.1.3.1 Each Department Chief is re-l(a) Determine how this was (a) Was to be performed by

[

sponsible for...Developme:it accomplished.

Responsible Engineer via of quality assurance requ$re-Procedure PHE-2 which required monts for all vital compop-a Memorandum of Design Criteria ents... Review and approva} of These Memoranda were not ade-quality assurance programs quately developed; however, developed by others.

for procured equipment apprc-l priate QA requirementu were

i L

invoked; for subcontracted -

q,,.- f design servicas they were not.

's y

2.1.3.4 Project Engineers Coordina ~ (a) Determine how this was (a)

In the absence of con-8 tion of all engineering acti, accomplished.

trolling procedures coordina-c-

7.

vities with other departments' tion was at the discretion of A

the Project Engineer.

The q

Project Engineer distributed

.{p g

all correspondence as he 2;

deemed necennary.

In addition, hit 0'

i i..

j j Responsible / System Engineers E l' -

I.'

were responsible for inter-4!

faces with other affected disciplines.

Memoranda were i:4 reviewed that did list which 4

engineer.and discipline were

i

. to be involved, but these memoranda were not in a con-

. l

,j i

ii trolled system.

J a

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PG&E - March 83,'1982' 39/09. '

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]

Appticable QAM Rev. O through Rev. 3 Auditor WSG

Date February 2-23, 1982 Statement Audit Instruction h

Comment App. B.

QAM l2 Crit.

Ref.

7 3.2.5.2 On-site surveillance is per-Review for evidence of on-tiot applicable for Phase I.

formed by the Station Con-site surveillance by.the i

d

=

i; struction Department.

Inspection Section.

,l 5i 3.2.5.3 The surveillance ~representa-Review reports of surveil-Not applicable for Phase I.

'p-

i

!j tive confirms on a continuing lance'by Inspection Section, s

l basis that the supplier's or

=

contractor's sytem is adequato il to assure that quality work will be accomplished.

'. ?

4

-.i I '-

II 3.1.1 -

The Quality Assurance Program (a)How did program assure (a) No formal method (matrix,

.j>

ld a

requires that written pro-procedures were developed etc.) was used to assure com-j) cedures be used in all key for all key activities.

prehensiveness of procedures

,i).

activities... periodic audits' to 10CFR50, Appendix B require-i ll

... provide objec'tive assur-ments.

Audits were relied 8

I nnce of both the adequacy of upon to assure adequacy of the procedures and compliance procedures.

Audit reports were I.

with them.

reviewed that did include

~.!

evaluation of a given procedure l;.I

~:

for adequacy.

It was stated that in 1974-1976 an audit had been performed for compar-l ison of the program to Appen-2:

t 'I

! I dix B requirenients.

This audit was not reviewed

,j because there are clear pro-

i cedural gaps in the program

j i

all the way through this Phase One review.'

9.7e i

.i 11 PG&E.- March 8,.1982

. tj J

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AUDIT CHECKLIST

i Page 7 of 19 U

Company Pacific Gas & Electric Company

!l Applicable GAM Rev. O thru Rev. 3 Auditor WSG Date February 2-23, 1982 h

l*

i i;

App. B.

QAM Statement Audit Instruction Comment j

Crit.

Ref.

I

s

+

1 II 3.6.2

[

,l cont.

'(d) ' Prior to PRE-9 and PRE- '(d)

No formal procedures 1

10, what procedures applied existed, i -

8 to interface control and

)

design control?

i it (e)

Could not verify, as PHM-1 The Director, QA, will main-(e) Verify distribution to 4.0 tain a list of those holding identified Project person-records are not available QA manuals.

nel, earlier than 1979.

1

.g.

a 1

1.2

...These items are classified (For information)

']

as Design Class 1.

The Pro-

)

i gram will be applied to any lj

,,C lj particular component, system jl or structure in a manner and to the extent appropriate to l

its importance in preventing tit l,

!l 5

t!

or mitigating the consequence.

I.(.

s of a ' nuclear accident.

i i i 3.2.1+

...The Project Engineer is (a) Determine how these (a)

Program was applied via l1 PHE-12 responsible for identifying items were classified and i Classification of components,

.., j

' structures, systems and com-designated, and how the Systems and Structures issued

' {y ;

ponents covered by the Qual-extent of application of by Project Engineer.

Veri-

- -f i i ji ity Assurance Program.

the Program was determined,, fled by review of April 13, f\\J[

reviewed, and verifled.

1972.

(DCPE-1), Project

.' j

-{

Engineer Instruction No. 1.

( i l

Distribution shown was

'f, l}!

acceptable.

Listing did not

'j address service contractors.

'J-

'l PG&E - March 8, 1 9112

)

43/89 1

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l AUDIT CHECKLIST q'l Company Pacific Gas & Electric Company Page 9 of 19 i

Tj Applicable QAM Rev. O thru Rev. 3 Auditor WSG Date February 2-23, 1982, l'

a Statement

' Audit Instruction Comment.

^

~~

~

y App. B.

QAM

i Crit.

Ref.

1

i J

II 3.3.2

}

3.6.2

,i,

2.1.2 Report on its adequacy and management review,.but (p.6) the extent to which it is review of ~ their minutes..shota:d cont.

heing carried out (Director, that they were only.for' OE,0A).

operational considerations t

ji for the Humbolt and Diablo projects.

P

I (b) Review evidence of (b)

These and other comunit-

./

l review by General office of tees only reviewed opera-

.U Nuclear Plant Review and tional considerations, not j

Audit Committee.

design and construction.

.Y i

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li AUDIT CHECKLIST l! ;-

)

Company Pacific Gas & Electric Company Page llofl9

((

i' lDate February 2-23, 1982 i j'-

U Applicable QAM Rev. O thru Rev. 3 Auditor WSG G

[,,

~~

0*

Statement Audit Instruction Comment I

IV 1.2.4.3 The Responsible Engineer re-(a) Verify that the Respon-(a) No objective evidence 4

ceives a copy of the purchase sible Engineer documented.

for quality-related require-I;;

order after issuance and is his approval of the techni-ments.

,; [

required to confirm that the cal 'und : qual-ity-rela ted technical and quality control-regiairements of purchase q]

requirements are correct.

orders'for subcontracted i:

j; design and consulting ser-1 vices.

t p

1 (b) Was Quality Assurance (b) Only for equipment pur-

-l

~

Engineering involved in the chase orders.

OE/QA was not

,,,i d

review of purchase orders brought into involvement in

't fi.

8 to ensure inclusion of appli -design consultants contractn y

cable quality assurance re-until late 1977.

I h

quirements?

8 il r

b 3.l.2 The procedures developed to (a) Verify that such a (a) No means was available.

control documents include...

means of determining the

,. :. p.

a monas by which persons status of documents was lg(~

p involved in the work can available.

' i, l verify that a copy of a docu-l ment which they hold is an (b)

PRE-1, Rev.

O, Project (b)

It was stated that they

,I Up-to-date and complete copy.

Bngineer function referenced could not reach agreement on

+{

'i PRE-5, Correspondence Con-procedure.

p

+

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trol, from 6/30/70 until

h 9/2/75.

Why was PRE-5 never i "-

n

~fI Lasued?

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H 47/89 1

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AUDIT CHECKLIST Company Pacific Gas & Electric Company Page 13 of 19 Appticable QAM Rev. O thru Rev. 3 Auditor WSG lDate February 2-23, 1982 App. B.

GAM Statement Audit Instruction Ctement Crit.

Re f.

l 8

VII

3. 2. 5..

The PG&E surveillance repre-(a) What criteria does the (a)

Not appli.able for Phase sentative... brings major PGEE surveillance repre-I review.

problems to the attention of sentative usc to determine the supplier's or contractor' awhen problema are major and management and the Responsibl ashould be brought to the Engineer, and in these cases attention of the Responsible

[

it is required that the cor-Engineer?

rective action be approved

{

by the Responsible Engineer.

(b)

Verify that corrective (b)

Not applicable for Phase t

action was approved by the I

review.

! ' I Responsible Engineer.

,l,l

[, y; [.

l (c) was Quality Assurance (c)

Not applicable for Phase Engineering involved in I

review.

t l!

subcontractor surveillance?

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PGEE - March 8, 1982 l

~

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Y AUDIT CHECKLIST ~

l1 I

Company Pacific Gas & Electric Company Page 150f 19 I Auditer l

Applicable QAn Rev. O thru Rev. 3 inniG Sate February 2-23, 1982 j..,

I1 App. B.

GAM Statement j

' Audit Instruction Cemeent.

I~r Crit.

Ref.

1 d

j' VII Documentary evidence that yerify that the designs, an< See Part B Checklist.

material and equipment conform hlyses, tests, and qualifi-i to the procurement require--!

cations subcontracted by j : ',-

i}

ments shall be available ath PG&E were actually per-8 i;

the nuclear power plant...

Yormed, received, and re-jj prior to installation or use kiewedbyrespcsiblePG&E

J i

j of such material and equipment personnel to verify con-

.-}

j; This documentary evidence lformance to the specified pg 4.

shall be retain.cd at the procurement requirements.

[@Q nuclear power plant...and ll fy the specific requirements, ly l

Jj shall be sufficient to identi-M ij such as codes, standards, or

, c1

);

specifications, set by the q

purchased material and equip-j; ment. (10CFR50, App. B) ii it t The effectiveness of the con-Verify that, design subcon-Initiated in late.1977.

Was j'y

!4 trol of quality by contractors tractors' and consultants' not fully effective until Q

shall be assetsed by the appli-quality assurance programs 1979.

l-cant or designee at intervals were surveyed and audited consistent with the impor-at intervals consistent witi

[

thace, complexity, and quality importance, complexiti, and p

4, af the product or services, qualit'y of service.

h (10CFR50, App. B) j d

l

.- l. ?.

n

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'1 D

PG&E - March 8, 1982 s

d I

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AuBIT CHECKLIST 4

}

Company Pacific Gas & Electric Company l

Page 17 of 19

l i

Appt icable QAM Hev. O thru Rev. 3 Auditor MSG

! Date February 2-23, 1982 H

Statement Audit Instruction Comment 5.I App. B.

GAM n

Crit.

Ref.

\\c I

'L q!.

(a)

Audit schedules reviewed l i. 1,

,'(1969 - 1978) xvIII 3.6.14 rhe Director, Quality Engineer i(a)' Review audit schedules

]!

PnM-2 ing, is responsible for making :for planning.

and were compro-pl planned periodic audits of hensive.

ilesign, procurement, supplier l Q, '

/

and contractor quality control (b)

Verify that all aspect (b)

Quality Assurance / Quality construction, start-up, rec-of the quality assurance Engineering were not audited.

4 e

ards, training programs, and program were audited, in-Reviewed audit reports from h

personnel and procedure certi-cluding Quality Assurance April 1970 through March 1978.

]

b fication functions as they Engineering.

Audit scope and coverage was d

relate to t.he Quality Assur-acceptable.

}j[

ance Program... Members of audit teams will not have (c)

Verify that audits (c)

Some audits did cover i

8

<lirect responsibility in the evaluated adequacy of pro-adequacy of procedural subject area of being audited.

cedures.

area being audited.

However, I;

[l '

audits did not assure total 2.1.

... Engineers assigned to the program adequacy of 10CPR50, Ou'ality Enginscring Section Appendix B requirements.

will be experienced in plant yy J,'

lesign. and construction and (d) Verify that auditorn (d)

OA auditors were indepen-

'r, i j

familiar with the quality re-were independent of the area dent.

Reviewed engineers f'

.guirements of the project....

being audited (especially temporarily assigned to audits

'. )

eersonnel assigned to the for engineers assigned to and concluded they were suffi-i, Obality Engineering Section auditing).

ciently independent of specil*ic will be experienced engineers activity being audited.

l {j specially chosen for their u

I knowledge and judgement.

In -

d sofar as possible, audits will

./

t>e conducted by individuals f

who have had no close connec-Lions with the function t,cin's PGEE - March 8, 1982

'I

.sudiLed.

53/89 I.

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AUDIT CHECKLIST i

'l 8

1 Company Pacific Gas & Electric Company j

Page 19 o!19 i

t Applicable QAM Rev. O thru Rev. 3 Auditor 'WSG Date February 2-23, 1982 2

'1 1

i App. B.

QAM Statement Audit Instruction Comment

- j Crit.

Ref.

y e

s XVIII 3.6.1+

j

]

l*RM-2 7

2,1,2

]

cont.

(g) Verify that follow-up (g)

Review of audit reports 3

action.'and timing including shows that corrective action 3

reaudit of deficient areas, by the audited group was was taken where necessary.

ineffective.

The same subject areas are repeatedly audited with the same findings re-

.;j curring.

Audits of Design j,

i Reviews (PRE-6) performed I,*

j from May 1972 through Feb-5 j

ruary 1978 show that correctivo 8

action was ineffective.

The 4

same results apply to the I.

Construction Drawing Index.

l i

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APPENDIX C PART B DESIGN CONTROL I

I l

I PG&E - March 3, 1992 56/99 1

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Aue1T CHECKLIST I

PART B I

i f

Company Pacific Cas axi Electric Ctnnany Page 1 of 34 t,

k Date Feb. 3-16, 1982 applicable onn Rev. O thru Rev. 3 Auditor R.

F. Reedy & R.

F. Petrokas 4

)

App. B.

CAM Statement Audit Instruction Consent trit.

Ref.

k:

i s1II 1

3.2.1 the ILpartmysit of Engineering is (For Infonnation) e j

respmsible for the preparation of

.bsims and specifications...,*lhis respussibility incitales tle specifi-catim of quality assuraice require-j ents...1he nuality Assurance Pro gan requires writtm procetkires J idi assure that the regulatory re-

..l;i

.pinwonts awl the design bases are

{

properly incorporated in tie speci-ficatims, drawings, awl the other i

.ksi m doctnents prepared by tie flyartnent of Engineering. A systan or desi y reviews is provided to t

verify that desigps acet require-j s

q 1 xnts in all respects....Respmsi-

).

ide Engineers develop desty criter-ia...Uhere desim cminitutsits are iak in the PSAR or otler filings

'6 '

~

i lefore the Atanic Fnergy Ccurnissicn,

'il j.

'tley are incorporated into tie desim... 0uestims in this area are

'[.

[.

3 referred for resolutim to tle l

Safety hudysis Report Group.

3.2.2.1 LIslin tie desip criteria, the i

i desi p inputs, and cmcentual desip 3

as a starting point, desl y draw-

~

ings ase prepared,

,{

l PG&E - Marcli 8, 1982 I i 3.-2.2.2 Stiecifications md rutrchase orders SUH9 are reviewed 1sy tic' Safety Analysis Report' Grotp to ccnfinn that tie regularcry reoutrments are properly incan iorated.

l 3 4

.L -:. = ===::==

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l AUDIT CHECKt.IST PART B i

Page 3

I 14 l

Company pacific Gas & Electric Company-1 Applicable GAM Rev. O thru Rev. 3 Audi tor R. F.

Reedy & R.

P. Petrokas Date Feb. 3-16, 1982 App. 8.

GAM Statement Audit Instruction Comment j

Crit.

Ref.

i,'

3 i

PRE-3*

Para. 2.2-Responsiblo Engin.

For the items selected in Prepared for piping II"V

I 3.

cers are responsible for:1)-

1., above, verify written systems.

This requirement providing written design cri-design criteria were pro-is not applicable to other teria in accordance with vided to the Design Drafting items whicli are' designed i

pile-2, " Design Development,"

Department.

by the vendors.

I',

j to the Design-Draf ting Depart-ment for the Develogwaent of i

l Project drawings...

4,0 7

PRE-4 j

The complete file of specifi-Verify that the specifica-Reviewed for selected

' i Revs.

4*

cations with all approved tion file for the items items.

Found no 3

1. 2 changes is located in the chosen in 1.,

above, is discrepancies.

Some l

Engineering Department Cen-complete.

piping desig.n criteria in tral Files.

PSAR.

l b. 2. 2'. -

Design reviews are conducted (a) Verify that Design Re-(a) and (b) IU&E's program.

'h 5.

]

by comgiotent persons other views were performed, and addW the above tlwee elemnits than those who performed the by individuals other than as follows:

original design... Comprehen-those who performed the

^

i sive reviews of Design Class I original design.

For element 3. "As Built" veri-y I

structures and systems as-fication, review work was initt-siire that the necessary design (b) How were the necessary ated in 12 ami will N within [ l steps have been taken.

design steps determined and the scope N Hiase II.

j f

documented?. Verify that Element 2. Detailed checks weru MfE the necessary steps were performed on IG&E designed itans.

[.

s Verification should incliule 3 ele-

taken, such as piping system and con--

! i 1

n uits:

sultant's design reports.

1. Overview of design appmach; l

iretints, input selection and assisap.

Element 1. Ikusign. overview acti-k i

tions.

PG&E - Narch 8; 1982 vities were perfonned by HlS on

'O ni tw ass I

2. Ibtaileil check of design steps 59/89 azul conplule design.

l electrical designs ami sanu HVC i

a sMud Mgns, bb

1. Verification of aggroval design sign overview was docunented fan-against "As llullt" comit tion.

wechanical systum designs, h

.w

gy j.. -

6

,1 l

l f

d.

[

s AUDIT CHECKLIST ->

3 j

pART B Company Pacific Gas & Electric Company I

f9' 5 O f 14 m

b

Rev* 0 thru Rev* 3 I'

I i

Applicable OAM Auditor R. F. Reedy & R. P. Petrokas l:

Data <Feb. 3 16, 1982

9j i

' Statement Aud{t Instruction Comment j

App. B.

GAM

. Crit.

Re f.

l i f g

.c<

PHE-6 para. 3.1 - Comprehensive fe'-

(c) Verify required design (c) Reviews performed on 3

Rev. O views of Design Class I struc-reviews for items chosen in consultant work and piping l

h

(?)

tures and systems shall be _

1., above, have been per-systeins as discussed in j

li cont.

7/17/70 conducted to assure that the formed.

(a) and (b).

l.

design is complete and ade-quate, and confirm the.t the i

design bases have been pro-j, perly incorporated in the de-sign.

Para. 3.2 - The Responsible (d). Check reports for the (d) Reports were available Engineer or Lead Engineer will items chosen.in I.,above.

but in cases they were tiotify the Supervising Engin-uncontroll.gd or "E

'i i

cer when the design is com-NOTE: Final Hosgri-Criteriit

[

plete enough for a review to established 11ay.,9, 197e.

l be conducted.

The Supervis-

,;j ing Engineer will then desig-nate an engineer to conduct the review.

The design review j

will be conducted by a quali-l fled engineer who has'had no l

r si ;ni fica n t involvement in jj t

y the design under review.

The

/

, reviewing engineer will pre-i

+

~

i!

pare a report of his work.

e V

1 l

- l 4~ '

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AUDIT CHECKLIST

~

iPart B q

ompany Pacific Cas and Electric Canpaly i

Page 7 of 14

'1

~

applicable QAn Rev.' O thns Rev. 3 AuditorR. F. Reedy & R. F. Petrukas Date[Feb. 3-16, 1982 1:

App. B.

GAn Statement l

Audit Instruction Comment crit.

Ref.

I p

III (a) Design changes were J

6.

3.2.2.3 lbsim chang.es, including clunges (p) Verify that desip changes prcposed by suppliers aid ccntra'c-were approved by the Responsible approved for all itens.

d.,

tors, are refened to the Responsi-thgineer and his Supervising limever, for sgorts approvals p

ble Engineer arui his Stpervising' gineerc of the design change calculations were not traceable j; j Engineer for review and writtm,

h) Verify that Desip Reviews approval.

to the drawing (drawings not j,-

+

re perfonned to decennine the signed-off).

pact of design changes cn the (b) Design changes,were reviewed N

c,riginal designs.

for impact.

f' llomuver, no review sign-offu

,c.

e a

PIE 11

/

Lc) Verify that changes were were evident for support

'i)

/

.t I

reviewed for inpact and change drawings.

(oFSAR.

(c) There was no evidence of impact reviews.

(OCN's introduced in phase II contant

[

I this activity.)

7 s'

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AUDIT CHECKLIST fase9of 14

oapmY Pacific Gas md Electric Capany applicable QAM I:ev, O thru Rev. 3 Auditor R. F. Reedy & R. P. petrokas Date pep -316,19112 Statement Audit Instruction Coms.ent App. B.

QAM trit.

Ref.

I III 8.

3.2.4.1 lha Responsible Engineer devel<ps (a) llow does the Responsible En-(a) For! purchased (quipnent and tic recinical requirenents and coor-gineer coordinate Lie interface piping systens the dhiates the woric done.by InterfacJng ing engineers for vor.k on sneci.- specifications were circulated a

digineers m the specification, ficaticus?

via routing slips. There was no i:>

l Draft specificatiots are revicued by evidence of interface reviews for

+

all engineers engaged in the (k sign (b) Mere final snecificaticus piping support specifications.

ji Jose work mip)it be affected by tie reviewed with all the interfacing (b) Final specifications m:re ajulpumt, and by other eng ecers as engineers dio made coments on circulated except. for piping:

j appropriate, e.g., material applica-the draft specificatimst supports as ident.iried in (a) above.

thns and qualicy assurance,,,,'Ihe final specificaticns are reviewed (c) Verify that the final speci.

(c) All specifications were and signed off by the Rpspcnsible ficatiois were reviewed snd approved as requiral except for

,p.

thgineer, and the Ibpartnent Odefs approved by the Ecsoonsible supports as noted above.

i

~

4 Engineer aid the Departnent l

Otiefs, l

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AUDIT CHEtKLIST PAllT B

't..

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~

Pacific Cas and Electric Ocupany Page 11 of 14.

tompany

}'

Applicable OAM Rev. O tluu Rev. 3 Auditor II. F. Reedy & R. F. Petroka3 Da te Feb. 3-16, 1982 APP D-GA" Audit Instruction Comment Statement trit.

Ref.

I. '

III 3.2.2.2 there a design is so.imovative or Does the ryising Digineer Not applicablu - designs of 10.

has so many inter-related require-decennine a desi p is "so concern were not imoyative" or has 'hvai innovative.

nents that independent review by related reauiranents"? y inter-frulividtial engineers wotild not Nhat assure a cmprehensive view, a criteria are used in the deter-

'l review necting is held with cal-minatim and how is it docuien-cemed engineers and the Responsi.-

ted?

ble Digineers. Situatims reouir-ing this review are identified by a i:.

the Supervisin, Bigineers and it is j).

their respmsi sility to call aid e

cmloct such npetings,

i 8

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PGGE - March 8, 1982 i"

67/89 i

)

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.i

I AUDIT CHECKl.IST p33g g lacific Gas & Electric Cisnpany i

Company

?

Auditor H. F. Reedy & R. P. petrokas.

Date Feb. 3 -16, 1982 Applicable QAM Rev. O thna Rev. 3 App. B.

GAM Audit Instruction

. Comment Statement Crit.

Ref.

11tE-13, Para. 2.1 (Rev. 1) The Supervisor, Verify existence of Constm4 tion 3

13.

Revs.

Records and Reproduction, of Design Drawing List.

1&2

-Drafting Ibpartment is responsible for pregnring and distritmting a) Check that. Construction Drawing a) The current list has leen copies of the Construction Drawing List was kept up to date, updated, inst old lists are List.

not kept.

b) Verify that Constrpet. ion Draw-b) Evidenco indicates the E

!l Para. 3.2 (Rev. 2) The Construction ing Index supplanents were is-List was rqularly

}

Drawing 1.ist will be reissued sued perialically.

tilstrituted.

j monthly.

H;)

c) Verify that applicable drawingt c) Equipnent. drawings for Para 3.2.1 - Supplanents to update for.itens chosen in I., above, checked itanu were verified uy the Construction Drawing Index will tippear on the Construction Drawing to be enteral correct.ly. One t

be issual periodically, Ixst at

, l.ist.

support drawing was alment 7

1 cast every two weeks.

fran Itst (taipport 48/17R)

!jn i

i l

And anotine support luul

', t.

incorrect revision 2:

2ntry.

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APPENDIX C PART C FOLLOW-UP FROM SUPPLIER AUDITS g.-

L

[

F i

i PG&E - March 3, 1982 71/39

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l AUDIT CHECKLIST

\\

88'

I I

7 Company WYLE/pG&E Design Control Interface Applicable QAM pG&E Auditor P.

J.

Herbert Date Feb. 2-17, 1982

.i APP B-OAM Audit Instruction Comment statement Crit.

Ref.

3.1. 2 Document Control Procedures are used to assure 1. Verify that PG&E used a Not Acceptablo. PG&E did that the latest apyfroved Ul

<i i

procedure to assure that not establish their drawings, specifications, WYLE was issued and used Document Control Procedure procedures, purchase orders, the correct IlOSGRI data in PRE-5 and it was never l '. Y and other documents are in establishing their Test' issued.

the hands of personnel carry-Plan Report No. 26286.

ing out the work.

2.

Determine if PG&E can Not Acceptablo.

PG&E could

}

verify what IIOSGRI data not provide documentary J

was used by WYLE to develop evidence to establish the Test Plan Report exactly what liOSGill da ta No. 26286.

was given to WYLE.

The

I, ;,

Responsible Engineer stated

})?a that WYLE made copies of i

' ' ' [J

- Nr 3

~

selected ilOSGRI Data during 21 l

meetings with pG&E.

No documentation exists to 2

establish exactly what

'I IlOSGRI Data WYl.E recolved

?

in this manner.

l; (a) On Nov. 25, 1981 PG&B requested by letter that WYLE "... document the Spectra fi you used to develop the RRH f-Plots... contained in your I:

report No. 262116...and Ad-dondum...."

WYl.E responded on Dec. 15, 10111 and pro-j.-)

'd vided attachments but did I. "4 PG&E - March 8, 1982 not establish dates in their

)

72/89 1ptter for the attachments.

. j.

(b) In an internal pG&E memo l'

O. Steinhardt to.I.

Ilerbs t

(

i.

i 1p

,;,' L i

i AUDIT CHECKl.IST Page 3 Of 7 1

Company wyt.E/PG&E Design Control Interface

,h i

ii Applicable QAM PG&E Auditor P. J. Herbert

,Date Feb.

2-17, 1982 Statement

' Audit Instruction Coseent i

Ap. B.

lV '

g_

8 n:

r 3.2.2.2 Supplier Contractor Designs i

!.~ :

}

Specifications require nup-herifywhetherWYLEpre-

'WYLE prepared and submitted 2

l pliers and contractors ;

pared detailed test plans test plan (Report No. 26286) sutwni t de tailed... test plans '

and test procedures and and Addendum to this test 1a etc., as the work progresses. submitted them to PG&E na plan -- both were sulmitted the work progresses.

to PG&E for review and approval.

3 1

N WYLE prepared test procedure

.N No. 3642 and revisions A, B, i.;

-l and C to this procedure. The

.t l

4 original procedure No.'3642 I;

q

'l and Revistor. A were submitted to PG&E and were approved ll by PG&E.

No records were I,

'd available to verify whether I!

I

i g

~

Revisions H and C were sub-I{

mitted to PG&E for review i

L

j and approval.

The Hosponsible id Engineer stated that he was in residence at WYI.E when

.;h l }3 Revs. B & C were prepared

r. : D 4

during testing and he ver-bally agreed to the evisions

'I

'I but did not sign off as j

j approving them.

.N i

i :

i l::

11

'; ; {

'.,I PGEE - March 8, 1981 f,~

l.!

i I

74/89 l11 [

i l;

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[

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,J

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,F AUDIT CHECKI.IST

' Company WYl.E/PG&E Design Control Interface i

Page 7 of 7 Applicable QAM PG&E Auditor P. J. Ilerbert pate Feb.

2-17, 1982

+

. App. B.

QAM Statement

' Audit Instruction j

Comment Crit.

Ref.

t

of the 4160 Switch gear and.

l-fesign drawings were checked.

l

?

No evidence were on file

?

verifying field incorporation of the design modi'fication.

t Verify in PG&E purchase Contract #5-67-77 was voided.

l' s.'

records that Contract f

~

5-67-77 was not activated with WYLE.

i

'i l;

O s

L-l 4:-

i

'., j i

n l

f-1 j

i

j PG&E - March 8, 1982 78/89 j

g 1

J

I L.*

I e

AUDIT CIECKLIST Company At00/1G&E Design Contxol Interface Page 1 of 5 I

Date February 2-17, 1982 Applicable QAM IG&E Auditor P.J. lierbert h

AP *

^"

Audit Instruction Comment Statement t.

e.

r-L

,s 3.1.2 Document Control Procedures are a.

Verify that IC&E used a pro-a.

Not Acceptable. IC&E's

-,{

used to assure that the latest carbre to assure that AN00 ws' prnreaire was not in effect afproved drawings, specifications, inawi and used the correct for the control of information procedures,. purchase orders, and i m RI Data in establishing their EC&E gave to AN00.

other A - aits are in the hands of Test Plan.

l personnel, carrying out the work.

{';

b.

Determine if IC&E can verify b.

Not Acceptable. No docu-5 that HOSGRI Data was used by mentary evidence was made AN00 to develop the Test Plan.

available to the audit

.O teasa frcia Wiich a determination

f o

could be made as to uliat 110SGRI i;

Data or other data was given

. i'[

to MOD by IC&E for use in P'

developing Test P'ian(s).

j i

i s

't ;.t i

F

p:{. i

!-.' li F'I.

r 8l < l.

r s

. 4

! T e PGEE - Nar'h 8, 1982 c

,,l g 79/89 1i I

.i}j 5,}' -

9

_ v

g I

4 i

J AUDIT CHECK!.!ST 1

I company Arn)/ME Design Control Interface Page 3 of 5

Applicable QAM g,G&E Audito'D.J. Herbert Date February 2-17, 1982 i

APP

8*

i statement Audit Instruction I

comment Crit.

Ref.

I s$

t Aev'ar+ahle, I

3.2.2.2.

%ese documents are reviewed by Verify that the Responsible de Responsible Engineer and/or Engineer or another engineer otler engineers and returned to revie d ANCO's Test Plan, and See Table 1.

.~

the supplier with conments and/or Test Prrvv' aire and Test Reports approval.

and returned them to ANCO cither Note.

iblo Engineer PG&E

.i approved or with coments.

could n46 verify diat he or another enginee$adreviewed5of11AN00 Test Plans subnitted.

4.

t j

Nodeta'fledtestloroceduresapproved I ',

j by the Responsible Engineer or another d

i engineer.

i i

.I h e Responsible Engineer provided

'N t

documentary evidence Witch verifleil l,

h.

l that he had revh. sed the draft ANO)

Test Reports and girovided AN00 with comnents or approval.

%e Rasponsiblo Engineer cranld not verify that the Final Test Report l'

had been revised by ANCO to include i

M E review cm m mts. %eir is no l.'

i l*jj[

evidence of IG.E teview anvl/or app'xival of Final Test Itegrerts.

'N

[

I '.

1 PG&E - March 8, 1982 I

81/89

,s i :.

t

m g

' (

b e

t d..

Page 3 of 5 t

?

February 2-17, 1982 l'

TABLE 1 Initial TEST PLAN' TEST PROCEDURES PG&E ANCO PG&E ANCO PG&E Prelim.

Final Data Sutwa.

Appr.

Sulun.

Appr.

Test Rpt.

Report i

l :'

,l 1.

Diesel Generator 4

1 11-8-77 3

2 7 5-78 2

& Acc.

t l

.i 2.

Ilorick Acid Tank 4

1 12-1-77 3

2 7 5-78 2

3.

1.1 quid IIoldup Tank 4

1 12-1-77 3

2 7-14-78 2

ll.

~

,.o 4.

Comp. Cooling 4

1 11-8-77 3

2 7/78 2

Water Ilt. Ex.

e s. :i 0*

""I' ~

4 1

12-1-77 3

2 7-13-78 2

k y t r r

Tank s

G.

I.imitorque Oper.

4 2-3-78 2

3 2

7-14-78 2

f Valve

/

7.

Itqtork Oper. Valve 4

'2-3-78 2

3 2

7-14-78 2

l 8.

Air Oper. Va1vo 4

2-3-78 2

3 2

7-14'-78 2

e-

9.

S j_l ns 4

11-30-77 1-10-78 3

2 7/'[8 2

}

2")

10 45 Pipe Ilangers 4

2-3-78 2

3 2

7/78 2

11.

Diesel Gen. Air 4

2-3-78 2

3 2

7/78 2

Tank I

I i it

~3 1 - ANCO Submittal was not dated or signed

) ;i.

,i 3 - No record of PG&E review and approval

,.)

3 - No record of preparation or transmittal by ANCO ;

2.

4 - No. record of PG&E initial data transmittal i

i,3 i

or data uscago by ANCO

q l 5

t'(

PGEE - March 8, 1982

.? I 7 9 3 /189

-l l *

i i

t

j

b i

'l 3 v.

PART C

~'

AutIT CHECKLIST l

Company gy;&E P898 1 of 5 1

l r

q j

Applicable QAM Amitter R.

F. Petrokas Date February 9, 1982 i

N 8*

Statement Audit Instruction Comment i

III Items for pG&E Audit - from

1) Review contents of PG&E

1) The files were not t

j RFP's EDS Audit File.

File 146.29, plus others as checked but evidence from e

applicable for evidence of elsewhere showed that M

interface instructions, control of design inputs, control of design criteria, criteria, etc., was done l,'

control of design inputs, by letters.

No written etc.

procedures.

Interface e'

)

instruction from EDS

]

governed document distribution j l!

across PGEE/EDS interface.

{

See EDS Interface Control 4!

Instru' tion, Rev.

O, 8/31/77.

I

i

2) Review level of control

2) Control was by trans-i:

established for PGEE docu-mittal letter prior to July a

ment " Guidelines for Design 1978.

If -

l of Pipe Supports & Re-straints." This was basic I;

criteria document for both

?

EDS & EES work.

{

jli

3) Review design file for

3) Couldn't find Rev. 3 of l ;;

l support #58S-37A (EDS cal-EDS calculations in the

]'.

culation package #002). EDS package.

Found two versionn

],

reen== ended stiffening of of PG&E Baseplate Detail

~

l support to meet design al-Drawing No. 049264 (Sht.

lowables.

Was support 95A/958) both labeled as I'

changed in field? (Rev. 3 Rev. IC.

Neither detali of calculation package matches Toledyne drawing.

l should be in file as current (Doc. No. 4121-0028) Rev. 2 revision.)

stamped "Idsued for Con-fj

'I i

struction".

~;

PGEE - March 8, 1982 84/39 it

?

.i n

m-

5 j

,i 3,t i

I L[

AtmIT CeIECER.IST 1 -

p Company NEE Fase 3 of 5

, C l-Applicable QAM Auditor R. F. Petrokas iate February 9, 1982 j

statement

-Audit Instruction Comment iI 11 Iri i te.s for imE Audt t - fro. 1=> Revie. iG&E fue for evi-li) Rev. O of a s interfaces a

~

ltFP's EES (Cygna) Audit File. dence of scope of work defini-dated 8/20/79.

F. truer meno to tion and interface controls.

fils on interfaces uns dated June 28 1978 (File 14G.56).

l, 4

i lb) Was IRIS ever responsible Ib) Apparently so. 10&E letter of for piping analysis?

February 23, 1978 transmits draw-ings and criteria.to he iH.-

istter fmn 10&E dated ~ October 31, t'

1977 traced ta'a 'muduv of iso-

}

i'

}.

setric drawings to be used for Hoegri m-evaluation.

. i

)

2) thw* control over EU&E

2) IEgi received R.sv. 2 via letter l1 dncament Gaaidelines for Pipe dated Jealy 12, 1978 and Rev. 3 via

' j 1.I Supports and Restraints". Why letter dated Decadner 27, 1978. EES

,;j)

I g

did EES use Revision 4 & H1S received Rev. I via letter'of' (g

i only have Revision I? What sms Octoher 27, 1977.

l1[ I' l-in Revisions 2, 3, and 4 that would pertain to HYi scope? What uns in Rev. 2 (not received Isy

}

j E'S) that womald effeet EES scope?

{ - ).

i

~

3) 10&li: letters transmitted lists 3) Yes. IGSE letters dateli

'i i

l of hangers to be analyzod, and 10/31/77,8/21/78,8/19/77, i

4 therefore estabusimmt scope of 8/24/77 and 8/2s/77.

.~

work.

m file had the folhar-

4 k

ing letters: 10/19/77, 9/26/77.

ij 9/7/77, 9/l/77. 8/16/77 (2 Itrs),

jG g-I 7/25/77, 7/13/77, 7/12/77

5 l 7/6/77, 7/1/77, and 3/1/77. Is

- tj

[

there evidence o,f ollwer letterrs t

in 10&E file not twelval IT 4{i g

PG&E - March 8, 1982 EM 1

06/89 j

o

.~

j s.

3 Aue1T CHECKLIST b

Page 5 *I 5

l f.

Coopmy Itag i

t f

Applicable Qan Auditor R. F. Petrv*ms

Date February 9, 1983 u

APP

8*

"A"

-Audit Instruction Comment statement trit.

Ref.

}

q

III,

6) EES re w hi a changq to d) Design modification anggestal cre t.

design of hanger #98-134R.

by EES uns fourni in IG&E's pararara i

Oeck for evidence of receipt of Oxald not verify actual cienge uns infonnation at IC&E and imple-sade in file fann date in hanger

~

mentation of reconnendation file. Rev. nimber on several (EES calculation file #137).

drawings in file was attuck over and no new rev. nurbers were

. fI assigned.

ii

)

j

,t

.l.

.. g g

I

.?

a I

a J-I.

l

}-

8 i;

ld E

PG$E - March 8, 1982 b

88/89 y

i

' i

> o, s

._........ _.7 4;,'L' 8

i L

I l

PART C 9

AUDIT CHECKLIST Company CONSULTANTS /pG&E Page 1 of.1 1

Applicable QAM l'G L E Auditor R.

F. REEDY Date February 17, 1982 I

i App. B.

CAM Statement Audit Instruction

, Comment 1

Crit.

Ref.

0

+

jf.

Ilow were HLA Reports used Per E. R. Wollak --

et in the design process for effect of report minimal each structure?

since:

Intake structure.

[

~

Water Storage Tanks and li

?

Salt Water Piping are all on bed rock.

e' ;.

What did EES, EDS, and Original approved design.

Blume use for analysis --

"As-Built" or Approved j

Design?

2-

); ',

llow can it be verified Only by examining the 3

that each piece of equip-files for each piece of j

ment was analysed to the equipment.

b < <

i final llosgri?

.i l

t I.

l-n...

t a.

I j

t b

i PG&E - March 8, 1982 l

89/89 f;

e

m -

.A,-.

a i

MAR 6 i932 i

The rionorable uun Albosta buited States House or Representatives

' ashington, D.C.

20616 vedr Collyress;.ian Albosta:

luis is in response to your letter of February 2, IM, to Chair:..cn pe.lic.;1ae re,,'arcinij t;te innependent aucii. of the ciculo (.anfon :;uclear r cuer riant e

( C..r'P) of tou Paci tic Gds and c.lectric Cui.ipuny (road).

The incepeaoent auuit resul ted fro: cite discovery of an errar in tne 5,.;is ic i usi',a of equip.aent oriu pipin, in the cuntaisii..ent an au t is ut tae UG:.r, uni t 1.

lue design error was cetecteo in late Septewcer 121 oy Puac. cnd was repurteu by PuoE to tne nuC. Basec upon an inspuction perfornesi by our Region V frice ano tne discovery of additional design errors, t:1e Cotviission issucu an cruer on uoveauer 19, lWI, unich suspenceu the UC;wi Unit 1 operatint, license tnet authorized fuel lodoini,) and low po.4er operations (i.e., operationt, oelow 5, of full power level). The Coonission cruer also requirec Puc.t tv conduct an independent design review for all seisr.ic service-relateu concructs that ucre in eticct pricr to June 197J (t.nclosure 1).

In acuitica, t::e sirector Of Cne htIC if ff1Ce of i.4Cle&T dedblor degnldCIOn (b.nl) isbued on aoVeUCer b, lx1, a letter to ebut. requestiny that furtt er incepein. cat vesisn revie n, Cuahucted prior to tne isSuuhCe of an upbrdt1n., licease.mshGriJins i,Nrem vi uC..Pr Unit I acve % or rull pcuer (inclusore s.

In.i subuittel datets ueccocer 4, Ival, FL..

previcec its propusea glaa rur ;.v seis..ilc cesign vert rication progran in re!, goose to c...: cc.. :Is:,1.,o cru., i t.c nu.i n,,

t..e tecnnical qualificacians of tne ur anizations anc in.1v1ctals ;u es.;act s

tr.e Indepencent eu=ign revie.s (z.nclusure al.

1..e i s:,ua ut ini.csence.ce of cne proposce or:;ani tativo;,.ae.,

i.n.1,ii.ml. :.c

,mrfur.. tae desi;,n veri fica 6iva pro ro... nas a.u....

,3 r res.or i.:.,:. r u s u.

a ru oreing this prograi.;. In uur rtsponse ca.. lectar t ru.i t ua.,rna. ea

.s hi,. li aus 9.i.imger. L;iai rs ioa i'al I..uinu se t rurdi ti.e s,,u.i ric. icc uur., ci w.il1 uu cc.nsidereu to oep.r.;i:ie cne incesen,Je..ci. eni. Lee.nical,ali t ic..t n...;

u tea. t r ani;.a cious ae.n iniit viouels ( Lne l u:,ures 4 ano 2 re s

.et. ci vu l ;. -

.,ince tee 1se.ue of Indepencence is of sac.i is.gortancs, un

....G i,Ici.su

..100

..as buen concuct.eu er the circiatstances surrsunala cne u velu,;c.it,s,;

s o

r li.. l. ory re, sort pra, cret. ay tne pro,,ascu mer,wcot au..l ar est ;.,

..,2 c

ou./ ;.#., ri ar t.; 3.. :i ct.a t in t.e evo r s, w i... e

.1

1. n e c i.

reso l'.ue Ia o La '. il" J I' n :ta ts.ent und

.d lCs t

r *. i u i d '. l R i t e. o; I 3.. I'.: ~.

o

.o

/ resiectively).

3 1

Ll 3p rxio

_gsssgg g.

r

___m h..,:.

+

.ge 1

N

-Z-e

]

Regarcing the costs for tne indepenuent auuit, I can only provide /cu with su:u very preli..iinary estinates. I 'do not expect tnet tiie pro rait c.in ne cc:.;,31eteu s

before the end of t'ay of this year and it coulo extend rauch longer. Tne inuependent j

review organization contracted by PuaE has so far spent approxii..ately 10,uou professional can-hours on the project. I expect titat a si..iilar efinrt has i

been devoted by P66E. In acuition, other parties to tile Diablu Canyon proccedings dre spending tine and resources in their pdrticipation. In Su!.blary, I co not tnink tilat tt:e total verification program can be cucpleted witti less than j

20 to 30 wan-years of effort oy the utility und its contractors.

elith respect to the potential and expected benotits of the incependent cesinti

~

verification program, we expect tuat certain chan es to the cesit,n anu as-ouilt structures, systems anc cos;ponents of tt;e uicolo Canyon Unic 1 i.ill ce requireu and will be i.iade.

however, regarcless of the magnituae of such enanges, a for greater benefit will be tnat the heelth ano saruty or trie p%)1c bus been dssured.

Lot ite capnasize tilat the responsiDillt.f for any review lie',. i th Gas

.;.d..

While ct:e Co.rijssio;i iias orcereu Pue.t as che licensee that an ine:e encenc s

review De conductec, the results of such a review wili uniy be asi inpt;t to our review. At this time the hRC has ceuicaceu a sta itica.it effort to tou n

seismic verification program. A decision to perait PUaE to proceco witn fuel loaaing will not be mace until all the actions contained in tiie Cor.uission's hovember 19,19u1 Oroer are. fully satistieu.

i Sincerely, Willie; J. vircks, ucsucive.:1 rec r.o r for operations Lnclosures:

1.

Cocaission oruer, oto.11/19/b1 2.

i.iet ltr. co PLor., uto. 11/19/81 a.

N.c response or 12/4/a1 to Cer..;isslan vruer 4.

L:r. rru. Cwnt;resst.en vin ell a Oi. tin.;er, ctu. Il/is/bl s

to Gheiruan vallucino Cnoir.:an vallauino response tu vingell a ottinJr 1.r.

.2.

i utu. 2/1/Os.

'~

Co.viission :.,teceuent, uta, c/lu/:u.

u.

~/.

i.. I tr. Is.%

t.,ucice or Violatio U, a:c. -/11/ -

~

n I

~ ~N

?

SEE PREVIOUS CONCURRENCE.

W

.. L:

/t r

....D..L..:..L 8..#. 3..*....

l..D..L..:..L..B..#. 3..*......

...D..L..:..A..D..)...O..E.L..D.... 9.... M......L..:. D...I. R...

ED0 #

i e,,ico

.em-a.Sc.h.aru.as;A....s.o.i. ras.u.e Rue.ee.s... t...

. 0cE.4.s.my t.....a s.eas.o.. o;.........

.n....nai.r.cas.

...26.1.8.2..... 2L.'.LS.2.... 31..M.M....... l..k}.a2.... 3u3.32...

am t.ac roau sia c a.coi sacu c24o OFFICIAL R F.CORO CCPY

.ss: :.m -u m

2

. _ r.--

.\\

s 4 P.cgardin the costs for the inuepenuent audit, I can only provide you uith soue very prel. inary estimates.

I do not expect tnat the progran can ue coupleted oefore the. d of riay of this year and it could extend inuch longer. The indepencent review organi tion contractea by Pd&E has so far spent approxjuately 10,000 t

professional aa -hours on the project. I expect that a similar effort has been oevoteu by ' oE. In adoition, other parties to the uiablo Canyon proceecings are spencing time o resources in their participation. In suraiery, I do not tnink that the tal verification program can be completen witu less tr.an 20 to 30 uan-years o effort by the utility anc its contractors.

s i

hith respect to the pot tial and expectea benefits of tne incependent design verificatiori prograu, we pect that certain changes to tne desiso and as built structures, systens and con. onents of the ujoulo Canyon Unit I will be requiree and will be i:1 ace. Ifouever,

>9ardless of the i;4gnitude of sucn changes a far greater

benerit will be tn t tue health and safety of the public nas been assureo.

I Let he eupudsize thdt tHe respOnSi-lity for any review lies witn the imL.

While the Cocuission nas croered Pue. as tna licensee that an inuepenuent review ue conducted the results of su 'I a review will only be on input to our review. At this time the uRC has c uicatao a s19nificalit effort to the seismic verification progract. A cecisio to permit Pbei:. to proceed with fuel loading will not be wade until all the ac ions contained in the Cor4aission's t.ove.nber 19, l' ul Order are fully satisfie \\

J L

4 n

Sin.cerein

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j Williau J. uirctis, c.xecutive uf recur for operations s

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dnclosures.

l.

Comission urcer, dtd. 11/13/61 i

2.

.i R ltr. co Fuat, dtd. 11/19/61 J.

Pasi. responsu uf 12/4/ii) to Co..nissten breer i

to Chairriart Palladinu.

II/la/bl 4.

Ltr. tru. Congressuen din., ell

.2 Utt1n.,er, utd.

5.

Ch41 mani Pallauitto respchse u DingulI a ut.inser itr.

e dtc. 2/1/L.

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Co..oission : cateuent, utu. 2/10/n4 7.

1.w I tr. to NJ. butice of v iuluion),

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DISTRIBUTION: SEE flEXT PAGE.

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Regarding the costs for the independent audit, I can only provide you vith sone very prelininary esticates. I do not expect that the prograia can be complecca before the end of !!ay of this year and it could extend nuch longer. The inaepencent review organization contracted by PGt.C has so far spent approxier,ately 10,Luv professional man-hours on the project. I expect that a sin 11ar effort has been devoted by PL&E. In adu1 tion, other parties to the Diablo Canyon proceedings are spending time and resources in their participation. In sun.1ary, I co not think that tne total verification progran can be cos.ipleted with less tuan 20 to 30 man-years of effort by the utility and its contractors.

,4f th respect to the potential anc expectec benefits of the independent design verification prograa, we expect that certain changes to the design and as-ouflt structures, systems and components of tne Diaulo Canyon Ltnit I will be requirec and Will De IJadd. howeVer, far greater benefit Will be the auded assurance that the plent nas been properly desijned anc ouilt, thereoy furtner ensuring

aat the operation of the plant.will pose nu undue rist to the public.

incerely, a

i QC ;. ~ ~; n utilia;.1 d. uircks, Executive utrector for operations Diclosures:

1.

Caission Urder, atd.11/1' /31

)

2.

Mit ltr. to PGG, oto. 11/10/81 3.

PuE response of ic/4/51 to Comissico t,re.er 4.

Ltr. frm. Congressrtn ain.. ell t.

Jttinger, etc. Il/Is/t.1 to t.rairt.an Palladt.io 5.

Chainwan Palladino responsa to Din:, ell 5 Ottin.er ltr.

dtd. 2/1/30 e.

Coc cission Statement, cre. 2/10/2

~/.

I.2L ltr. to vud. (..ctice of v talation), uta, e/)l/ i F

SEE PREVIOUS CONCURRENCE.

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IN RESPONSE REFER

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TO M820304A

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UNITEO STATES

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NUCLEAR REGULATORY COMMISSION 3 a..

l wasnoworow.o.c.aoses ACTION - Denton #RA 24.

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i Cys:. Dircks

/h March 8,.1982 Cornell Rehm opescs op twa -

GCunningham secastany g

DeYoung D

Engelken. RV Stello MEMORANDOM FOR:

William J. Dircks, Executive Director for Operations I

FROM:

Samuel J. Chilk, Secretar

SUBJECT:

STAFF REQUIREMENTS - DISCCSSgON AND POSSIBLE VOTE ON STAFF RECStetENDATIONS ON DIABLO CANYON PROGRAM PLAN'~AND INDEPENDENCE OF AUDIT, 10:00 A.M.,

t THURSDAY, MARCH 4, 1982, COMMISSIONERS' l

CONFERENCE ROOM, DC OFFICE (OPEN TO PUBLIC ATTENDANCE)

The commission was briefed on staff's conclusions and recommendations resulting from their review of the adequacy of the proposed seismic verification program and the qualifications and independence of the proposed contractors.

(Staff recommendations 1

are contained in SECY-82-89).

The comunission:

a.

by a vote of 4-1, with Conunissioner Ahearne in the

[

minority, disapproved a motion by Commissioner l'

Ahearne (1) to reject the proposal of PG4E to retain Cloud Associates as the independent auditor i.

to perform the proposed seismic design verification l

programs and (2) to accept a proposal from PG&E, if submitted, to retain Teledyne Engineering Services in that capacity; I

b.

'by a vote of 4-0, with Commissioner Roberts abstaining approved Commissioner Bradford's motion directing i

the staff (1) to make a concerted effort for one week to obtain an agreement among the parties (PG&E, State of California, Joint Intervenors) for j

a proposed independent auditor or a list of auditors from which NRC would make a selection; (2) if this is not accomplished within the time period prescribed, i

i the staff should proceed as otherwise directed; l

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2 c.

unanimously approved the following additions to the recommendations contained in SECY-82-89:

"The contractor's role should include the following items, to be defined in the program plan and implementing procedures:

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(7) scope and technical approach should be enlarged to include analysis of NSS vendors design; consideration of statistics in the sampling plan; and, inclusion of a sample of structural.

elements (see staff Conclusions chart presented at the Commission meeting).

d.

by a vote of 4-1, with Commissioner Roberts dissenting approved the recommendations of the staff as contained in SECY-82-89 as amended by b and c above (one week ef fort to obtain agreement among the parties on an auditor or a list of auditors; modifications to the program plan).

The Commission instructed the staff that:

if the efforts to agree on a jointly approved contractor were successful, the staff could' proceed with that selection; if the parties agreed on a short list, the staff could pick a company (such as Teledyne);

if efforts above were unsuccessful, the staff i

should proceed with the recommendations contained in SECY-82-89 as revised and voted upon by the Commission.

(NRR) (SECY SUSPENSE:

3/12/82) cc:

Chairman Palladino Commissioner Gilinsky Commissioner Bradford l

Commissioner Ahearne Commissioner Roberts Commission Staff Offices ACRS ASLBP ASLAP PDR (Advance)

DCS-016 (Phillips)

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ML20212A076

Contents

Text

Dear Mr. Denton:

Subject:

Dear Mr. Heer,

Subject:

Dear Mr. Manentis:

Subject:

Dear Mr. Maneatis:

Response

Response

Subject:

SUBJECT:

Enclosures:

Dear Mr. Denton,

SUBJECT:

**e

=

Dear Mr. Furbush:

Subject:

Dear Mr. Cloud:

SUBJECT:

REFERENCE:

Subject:

Subject:

Subject:

Subject:

Subject:

Subject:

SUBJECT:

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ML20212A076

Text

Dear Mr. Denton:

Subject:

Dear Mr. Heer,

Subject:

Dear Mr. Manentis:

Subject:

Dear Mr. Maneatis:

Response

Response

Subject:

SUBJECT:

Enclosures:

Dear Mr. Denton,

SUBJECT:

**e

=

Dear Mr. Furbush:

Subject:

Dear Mr. Cloud:

SUBJECT:

REFERENCE:

Subject:

Subject:

Subject:

Subject:

Subject:

Subject:

SUBJECT:

Navigation menu

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