ML20244D199
| ML20244D199 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/12/1984 |
| From: | Hudson H AFFILIATION NOT ASSIGNED |
| To: | Gilinsky V NRC COMMISSION (OCM) |
| Shared Package | |
| ML20105C097 | List: |
| References | |
| FOIA-84-519, FOIA-84-520 NUDOCS 8502090324 | |
| Download: ML20244D199 (27) | |
Text
, m. o
, w/aA W sets . .
Hon. Victor Gilinsiy,' Commissioner
~
To:
United States Nuclear Regulatory Commission !
1717 H Street I Washington, D.C. 20555 1.
From: darold Hudson - Former Rullman Power Products Quality Assurance Inspector, Quality Control Inspector, Qua3it:.
- Assurance Program Internal Auditor and Lead Auditor.
Date: 1-12-84 subject: Report #3 - Quality Assurance Discrepancies Associatet i With Pullman Power Products Internal Audit #101 At i' The Diablo Canyon Nuclear Plant.
e i s'., \ v Pullman Power Products ' Internal Audit #101, performed on l
/ 1-18-82, identified significant conditions adverse to quality !
which were not promptly corrected and resulted in corrective action which was not adequate.
- 1. Pullman Power Products' Internal Audit #101, Audit Action Re, quest #1 findings have not had adequate correci-ive action implemented.
A. Five NDE Procedures were identified on I.A. #101 :s ,
not having evidence that the special processes were l controlled and accomplished using qualified procedures or that qualification records were maintained to document and assure quality of material and work. ;
There are no Procedure Qualification Records docu- l menting Procedure Qualification Tests for these five NDZ procedures. The five NDE procedures are: 1
- 1. ESD 234 - UT Inspection Groove Welds AWS-D1.069, ASME Section VIII and Section V. Used to exenine full penetration groove welds on Pipe Rupture Rectraints prior to July 1979.
- 3. ESD 246 - Magnetic Particle Procedure / Dry /Continu-cas Coil - B31.7. UsefunkownP 3,
, c. .
.m j 4. ESD 247 - Magnetic Particle Procedure / Dry / Contin-
! uous Coil - B31.1. Used to examine crack repair welds on Feedwater Nozzles to Unit # 1 Steam Gen-erators.
l 5. ESD 270 - Liquid Penetrant Examination Procedure.
l Use unkown.
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B. Two Ultrasonic. Material Thickness Measuring Procedures were identified as not having evidence that the special processes were controlled and accomplished l using qualified procedures or that qualification ",
records were maintained to document and assure.
quality of material and work. There are no Pro-cedure Qualification Records documenting Procedurc Qualification Tests. These procedures are:
- 1. ESD 236 - UT Thickness Measurement of Boundary ,l, Valves, a See P.P.P. Unscheduled Internal Audit #34 and H. Hudson's Report #2 to NRC Commissioner V.
Gilinsky, dated 1-2-84.
ESD 244 - UT Thickness Gauge Procedure. This 2.
procedure widely used by Pullman.
It was determined in' I. A. #101 by Pullman QA/QC !
Manager H. Karner that these two ultrasonic proced-ures were not nondestructive testing procedures but l de were used to measure material thickness and therefore did not require " Procedure Qualification Records" <
(Procedure Qualification Tests). This was not a valid determination. All special processes, not just welding, heat treating and nondestructive test-ing, are to be controlled and accomplished using qualified procedures (Procedure Qualification Tests). i The determination that ESD 236 and ESD 244 were not l nondestructive testing procedures does not exclude j the procedures from qualification requirements for special processes. It is alleged that QA/QC Manager H. Karner's determination that ESD 236 and ESD 244 did not require Procedure Qualification Records covers up a serious breach in the Quality Assurance ,
requirements for special processes as required by !
100FR50 App. B IX and XVII and PG&E C.S. #8711 Section 4.3,23 and 4.3.29.
No corrective action has been initiated by P.P.P.
concerning use of ESD 236 and ESD 244 without Procedure Qualification Records.
C.\.ESD 234, ESD 246 and ESD 247 NDE Procedures had Irocedure Qualification Tests performed as corrective action to I.A. #101, A.A.R. #1 (see attached PQR's).
These PQR's are after the fact qualifications of these proc ed ur es . The actual use of these procedures were not controlled and accomplished using qualified proc ed ure s.
It should be noted that the PQR's for these procedures ,
do not have approval signatures of either P.P.P. or PG&E Management authorities. The only signatures
3 on the PQR's is that of the individuals conducting the qualification ~ tests. ~It'isTalleged that these PQR's have not been approved by the appropriate I management authorities.
2 ESD 270 did not have a Procedure Qualification Test performed as part of the corrective action to I.A.
- 101, A.A.R. #1. QA/QC Manager H. Karner determined
, that ESD 270 used similar penetrant materials and examination methods as ESD 210 - Liquid Penetrant Procedure ( ANSI - B31.7) and that ESD 210 had Pro-cedure Qualification Records which demonstrated the ability to detect the specified discontinuities.
QA/QC Manager H. Karner directed that ESD 270 be revised to incorporate the PQR's of BSD 210 as the corrective action to be taken.(see I.A. #101, A.A.R.
- 1 Corrective Action Taken). The use of ESD 210 PQR's does not provide a proven demonstration of ESD 270's ability to identify discontinuities. ESD 210 and ESD 270 must have some differences or there would be: no need for two procedures. It is alleged c that QA/QC Manager. H. Karner's directive to use ESD 9b )I 210 PQR's for ESD 270 does not provide proper or adequate corrective action to the Audit finding and that ESD 270's lack of proper PQR is still a condition adverse to quality.
No investigation was performed to determine where ESL 270 was used.
- 3. ESD 241 did not have a Procedure Qualification Test 015 performed as corrective action to the Audit finding.
A Procedure Qualification Record was suppose to be prepared per A.A.R. #1 Corrective Action Taken but {
this corrective action was never implemented and j A.A.R. #1 was closed out and approved by the QA/QC ;
Manager without the PQR being generated. I l
The bases for this action was a memo prepared by {
Internal Auditor J. Gyyler, dated 1-13-83 (see i attachment to A.A.R. #1) that stated: "There is a t pending DR involving ISD 241 This is a special procedure createdxto supplement PG&E and manufacturers -
examinations. PPP has accomplished this per instruct-ions from PG&E. It is evident that a nonconformance l does not exist and a DR is not necessary. A written ,
response indicating this will be considered basis l i
for closing this portion of AAR". QA/QC Manager l pg H. Karner indicated on AAR #1 that this memo by I. A. l; J. Guyler would be uses to close out that portion of AAR #1.
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4 Internal Auditor J. Guyler's statement that "it is eirfd'ent~that'a~nohabnformance does not exist and a DR'is not necessary" is'not a valid statement, It is alleged that I.A. J.
Guyler and QA/QC Manager H. Karner have covered up serious breaches in'the Quality' Assurance-Program and are-in noncondormanc'e to 100FR50 ,
App, B IVI and PG&E 0;S. #8711 Section 4. 3.28 {
requirements that all conditions adverse to i quality are to promptly identified, reported and corrected. I It should be noted that during a conference {
to formulated a revised response to AAR#1- t on 9-14-82, attended by QA/QC' Manager H. Karner, {
NDE Leadman P. . Dawson and I. A. H. Hudson, it - .
was agreed that a Discrepancy Report would be ;
sent to PG&E identifying that there was no i l
PQR forbthe procedure and that the UT examinatic of the Yoke Rods was performed prior to ESD 241 being issued by M.W. Kellogg (Pullman) and approved for implementation by PG&E (see attached Interoffice Correspondence of 9-15-82 to I.A. #101, AAR#1 File). QA/QC Manager H.
Karner later reneged on this agreement when he approved I.A. J. Guyler's memo and approved the closing of AAR#1. QA/QC Manager H. Karner has covered up significant QA discrepancies in the 9 '
use of ESD 241 by refusing to forward the 1 f
proposed DR to PG&E.
The proposed Discrepancy Report, dated 11-3-82, f prepared by H. Hudson, identified the followinc i discrepancies (see proposed DR attached to I.A. l
- 101): {
A. ESD 241 did not have a PQR as required by C.S. #8711 Section 4,3.23 and 4.3.29 j B. The UT examinations of the, Yoke Rods were performed prior to ESD 241 being issuedThe by M.W. Kellogg and approved by PG&E.
examinations were.;perf ormed between 12-17-7:
12-20-73. ESD 241 was issued on 12-26-73 l and approved for construction by PG&E on 2-12-74.
C. The PG&E Field Change Order directing M.W. Kellogg to perform the work required inspection per the Dresser Instruction and a PG&E Memo by J. Sale. The Sale Memo specified the part of the Dresser Instructic l to be used was paragraph 12, "BoLis-and i i
Studs (Greater than 2 inch Diameter Up to 4 inch
' Diameter)"7 Dress"#SP;52-166, paragraph ~12.1 states "all bolts and studs'shall.be examined 1 ot7 P6aor" x{
-- prior to threading". The yoke rods UT examined j by M.W.'Kellogg were threaded. The examination .i of these threaded yoke rods is a nonconformance j to the requirements of the Dress ^er Instruction, j
- Du, The " Report of Ultrasonic Examination" used to
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document the description of equipment, procedure used, and the results of':the examination was not a form referenced in ESD 241.18. It did not include certain required information.
- 1. It did not include the surface or surfaces from which the test shall be performed as l required by ESD 241 and the Dresser Instructic
- 2. It did not include a description of the .
calibration block (size, material and basic calibration reflectors) and calibration method as required by ESD 241 and the Dresser Instruction.
3., The equipment calibration frequenciesreference onathe " Report of Ultrasonic Examination" were not as required by ESD 241 and the Dresser Instruction. It should have been noted that i ESD 241 and the Dresser Instruction procedure l gq9 N'/ requirements for equipment for calibration frequency were for production runs and not g
for individual rod examination. The two procedures did not meet the needs of the type examination being performed.
E. The " Ultrasonic Examination Report", Appendix !.,
Form F-66, referenced in ESD 241 was not used tc record the required information of ESD 241.15.3.
F. There were differences between ESD 241 and the Dresser Instruction concerning information used to determine the reference point for sensitivity and criteria used to report questionable items.
G. PG&E Memo by J. Sale stated that "in addition to the UT inspection, a back up inspection should be performed with the dye penetrant technique to check the yoke lod ends for indications of crack-ing that might e;*. tend into thethreaded' area of the yoke ends".
- 1. The Ultrasohic Status Reports indicate that no dye penetrant inspections were performed.
t . _ - _ _ _ _ _ _ _ _
2 ESD 241.17;l did not stipu3 ate the same requiremerit- as the PG&E Tem 6. ~
ESD 241.1N1~
stated '" Liquid Penetrant o'r Magentic Particle !
will be used on rods which areasuspected of containing discontinuities which may extend into threaded areas or to support areas where UT-tests indicate discontinuities with lengths in excess of'1" long".
No Corrective Action wasttaken on the audit findings for ESD 241. The proposed DR concerning ESD 241 QA l discrepancies was not approved by the QA/QC Manager and was not forwarded to PG&E for: disposition. This is a nonconformance to 100FR50 App. B XVI and PG&E C.S.
- 8711 Section 4.3.28 Corrective Action.
I
- 4. Only two of the seven procedures identified on I. A. #
101 not to have PQR's were identified to PG&E on Discrepancy Reports for thsir disposition. C.S. #
8711.Section 4.3.28 and,C.S. # 8833XR Section 3.4.1210 require Contractor to assure that all conditions adverse to quality are promptly identified, reported, and corrected. P.P.P. did not report al19the conditions p' c adverse to quality identified in I.A. #101 to PG&E.
x This is a nonconformance to the C.S. requirements.
- 5. ESD 246 and ESD 247 were identified to PG&E on DR #4662 (see attached) as having no Procedure Qualification Records. DR #4662 identified that ESD 247 had been used to MT examine the inside diameterof Feedwater Nozzle welds to Steam Generators 1-land 1-4 during the repair c: cracked welds. PG&E accepted as issall work examinec ty ESD 247. Because DR #4662 did not identify any locations where ESD 246 had be used no reference was made to accepting any work performed by ESD 246.
During the Internal Audit investigation into the use of ESD 246 and ESD 247 I was ordered by QA/QC Manager H.
h- Karner to cease the investigation once it was known ss l5% where ESD 247 had been used. I was not allowed to fuSA aM"#- continue the Audit investigation to determine where ESD 246 was used. This resulted in DR #4662 having limi" information concerning the discrepancies being reported.
There are two questionable Quality Assurance issues relat-to the useof ESD 247.
l A. ESB 247 specifies that it is a Magnetic Particle '
Procedure / Dry / Continuous Coil for B31.1 Code. C.S
- 8711 Section 2.2.1 specifies thtt portions of the f i
feedwater piping from the steam generators to the isolation valves are to be designed, fsbricated, and ;
erected per ASME Section I. The MT Examination Records attached to DR #4662 (see attached) indicate i
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1
7 the~ Acceptance 4tandards to be-ASME.Section-I.- This raises the question can a 331.1 Code MT procedure be used to examine ASME Section I piping and obtain results which are reliable. '
B. The MT Examination Records attached"to DR# 4662 are dated 10-19-77 and 10-20-77 and the MT's were
, performed by D.R. Geske. The M.W. Kellogg (Pullman)
Personnel Testing Record for D.R. Geske (seeattached) indicated he was certified a Level II MT on 8-23-76 with a composite grade of 98%. But the Testing Record under Examination Grades in Percent does not record any scores for the General, Specific,
/ Practical Examinations. It is not understood by this (3$ % writer how a composit grade of 98% could be obtained when there are no recorded percental scores for the General, Specific, and Practical Examination. Both the SNT-TC-1A and M.W. Kellogg ESD 235 (NDE Personnel Qualification. and Certification Procedure) require General, Specific add Practical examinations to qualify for Level II MT. The Personnel Testing Record for D.R. Geske'does not provide the necessary information to verify that Geske was properly qualifie as a Level II MT Technican.
(64 The NRC should investigate these issues to assure that there are no QA discrepancies associated with the use of ESD 247 and the examinations of the Feedwater Nozzles to Steam Generators.
ESD 246 and ESD 247 had Procedure Qualification Tests performed on 11-9-82. The Corrective Action Response to I.A. #101, AAR#1, by M. MacCrae (see attached) states "As both ESD 246 and ESD 247 have been withdrawn from use. and the equipment listed in both procedures is no longer available for use, the equipment used for yg these PQR's was the Magnaflux Model P-90 for the coil technique onlyn. The Procedure Qualification Test was performed using different equipment than specified in the original procedures. The Response does indicate that P-90 puts out lesseamperage than the equipment listed in ESD 246 and ESD 247 and that acceptable results were obtained. But a questioners raised. Is.it acceptab3e to qualify MT procedures after the fact using different
)R GOO equipment than listed in the procedures? This is an item of concern that the NRC should investigate.
- 6. The most important issue to raised by this report and ARR#1 findings is can NDE procedures be qualified after they have been used? 100FR50 App. B IX and PG&E C.S. #
8711.4.23 and C.S. #8833XR.3.4.128 require special processes to be controlled andraccomplished using qualifie:
procedures. The seven procedures identified in I.A. #101 were used without being qualified by Procedure Qualificati test and are nonconformances to the above requirements.
L- - - - - - - - - . - - - _ - - . - - --- . - - - - - - _ - - - - - - -)
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This is a major breakdown in the PPP Quality l Assurance Program;- in--my-opinion,- the-use of. j unqualified procedures puts the work examined into a questionable. status. The NRC should investigate this. issue to assure that thereare .
no conditions existing which would adversely affect qualitynand. tend'to cause failures or (
malfunctions'in thefwork examined by these l oi, procedures.
e>rnA C' # # #"" 2. The Internal Audit #101, AAR#1 findings were not promptly '
corrected as required by 100FR50 App.B XVI and PG&E C.S.
- 8711.4.3. 28 and C.S. #8833XR.3.4.1210 requirements. It is alleged that QA/QC Manager J. Karner deliberately procrastinated on these findings to avoid identifying these y discrepancies to PG&E and Pullman Corporate Management 2.29 and because he was unable to formulate a proper corrective !
action. It is alleged that Pullman Corporate Director l
/ f Quality Assurance, A. Eck, failed to expedite c) 23 L corrective action once he was made aware that the on'. site
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\ QA/QC Manager was not providing a prompt response to l
l l AAR#1 finding.
Internal Audit #101 was performed on 1-18-82. AAR#1 findings were not formalized until 3-22-82 due to additional investigation requested by the QA/QC Manager.
AAR#1 findings were acknowledged by QA/00 Manager H. ,
Karner on 3-23-82. Corrective Action Taxen response Before was 2Y' due on 4-5-82 and was received and approved.
the follow up audit to assure activities complied with approved corrective action, QA/QC Manager H. Karner requested AAR#1 back so that a revised response could Thebe prepared due"to addition finding being identified.
additional finding was that ESD 241 had been used. It 1YI had been decided under the original response that this procedure had never been used. AKR#1 would not be returned to my possession for a follow up audit until yp 45 0 3-22-83. Prompt corrective: action was not implemented for the findings of AAR#1 as required by 10CFR 50 App. 3 XVI and PG&E C.S. #8711 and #8833XR.
I would spend the next year tryingsto get QA/QC Manager l H. Karner to provide a revised corrective action response so that AAR#1 findings could be closed out. Following is a narrative of action takenbby me to try to get a revised corrective action response from the QA/QC Manager.
A. On 5-18-82 I send a PPP Message (see attached) to the QA/QC Manager requesting he provide an immediate revised response and return it ti me.
B, Cn numerous occasions I verbally request the QA/QC Manager for a revised corrective action response.
1 L
9 1 C. On 6-14-82 an-Interoffice Correspondence (see attached: '
A was sendqto-A.~Ech TJorporate Strector.Tof-Quality 4 Assurance , stating that an AAR"(NDE procedures .
without PQR's)' directed to the QA/QC Manager, 3dlich
- per ESD 263 was .to le responded to in 10 c'alendar days', was:taking weeks'for a response...
y$- 27'q ( D. On 7-6-82 an~ Unscheduled Internal Audit # 31'(see !
attached) was performed and addressed to A. Eck, j Corporate Director of QA. The Unscheduled audit was performed to identify to Management personnel a ,ll deficiency in the implementation of corrective action '
to Internal Audit Reports. The Audit finding was that the QA/QC Manager was not promptly implementing corrective action to Internal Audit Report findings.
1, A response from A. Eck, dated .7-16-82 (see attachec did not address thetissue of Corrective Action not being implemented in a timely manner. Instead, A. Eck reprimande,d me for incorrect application of ESD 263. U I. A. #31 was not responded to by jph ggo the Director of QA. Mp WP,5&WA)TE-Y .VMED: -
l n-It appeared :that the Director of QA was more concerned with the so called inproper application of ESD 263 (Internal Audit Procedure) than with getting corrective action implemented to an Internal Audit finding that NDE procedures did not have Procedure Qualification Records. It should be noted thatLA. Eck's reprimand directed me to assign resolution of no formal PQR's for NDE procedures to the responsibe NDE Supervisor.
- 2. On 7-22-82, QA/QC Manager H. Karner conducted a meeting with me at which time A.Eck's reprimand was discussed and Mr. Karner laid out ground rules for future Internal Audits. It should be noted that no mention was made as to when a revised corrective action response would be forth coming.
(see attached).
On 7-28-82 I send an Interoffice Correspondence (see E. l attached) to QA/QC Manager H. Karner asking what l Corrective Action is being takentto resolve audit
- .[# f " et$ findings for AAf$1. Also I asked Mr. Karner if he wanted me to readdress AAR#1 to the NDE Supervisor per A. Eck's directions. Mr. Karner verbal response was no that he would provide a resolution to AAR#1 findings. At this time I recommended that the AAR#1 findings be identified in a Discrepancy Report to
')( "500 TG&E for review. In addition, I stated that sub-sequent investigation of ESD 236 - UT Thickness Measurement of Boundary Valves may be required to he.ve a PQR.
F. On 9-15-82'I prepared an' Interoffice correspondence to 'I.I ~#IO17D#1 Tile aYid 'to thb~QA/QU : Man'hg' hr dnoutI6Httng a'.c'on'ference . held to formulate .a revised responsecto"AAR#1.t(see atta'ched). The1fo11owing v action waar. agreed on.by the:QA/QC Manager, NDE Supervisor and the Internal Auditore.
- 1. ESD 234 would have a Procedure Qualific& tion Test performed.
- 2. ESD 241 would be reported on a DR to PG&E I identfying that there was no PQR ahd that the UT examinations were performed prior to ESD 241 being issued by Kellogg and approved by PG&E.
- 3. ESD 246 and ESD 247 would have additional invest-igation performed before a decision as to correct-ive action would be made.
G. On 10-13-82 an Interoffice Correspondence (see. attache was send to the QA/QC Manager requesting a " Revised Written Response to AAR#1, I.A. #101". It was stated in this IOC that PG&E C.S. #8711 and #8833XR required all conditions adverse to quality to be promptly corrected.
H. On 11-3-82 a proposed Discrepancy Report concerning ESD 241 was prepared by me in compliance to the 9-14-82 conference to formulate a revised response to AAR#1 (see attached)
- 1. This proposed DRtwas reviewed by QA/QC Manager H. Karner andche wrote comments concerning the DR (see attached).
- 2. The proposed DR was reviewed by M. MacCrae and he wrote comments concerning the DR (see attached)
- 3. On 11-22-63 I send an Interoffice Correspondence to QA/QC Manager (see attached) responding to Karner's and MacCrae's comments of the proposed DR.
It should be noted that subsequently QA/QC Manager zjzit, E. Karner would' refuse +to submit the DR to PG&E identifying ESD 241 discrepancies. .
k.____________--------
I. On 1-12-83"w PPP-Message (see -attached),was -send to QA/QC Manager H. Karner requesting he provide j At this revised corrective action to A'AR#1. -
time the QA/QC Managerdwas informed he was in nonconformance to 100FR50 App' B XVI and PG&E C.S.
- 8711 Section 4.3.28 and #8833XR SectTon 3.4.1210.
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J.
On 1-21-83 and Interoffice Correspondence (see ,
attached) was send to.the QA/QC Manager indicating }
that Corporate Audit #7177-1-83., AAR#10 had identified '
that the required number of Internal Audits for 1982 ,
gw had not been closed out and that a revised corrective action response was needed for AAR#1.
gg It should be noted that QA/QC Manager 'H. Karner did not l provide any responses to any of the many correspondences i re uesting a revised correctiirecaction. It is alleged that !
D?-- QA QC Manager H. Karner deliberately procrastinated in !
providing a revised correctlye action;to AAR#1 to avoid identifying thesse discrepancies to PG&E add Pullman Corporate l Management and because he was unable to formulate a proper ;
corrective action. It is alleged that QA/QC Managen H.
l Karner deliberately violated 100FR50 App!B XVI and EG&E C.S.
l
- 8711 Section ments 4.3.28 and that conditions #8833XR adverse Sectionbe to quality 3.4.1210 recnire-promptly
~
identifie 9 / reported and corrected. It is alleged that Pullman Corporate l g/1 ,. ; v( Director of Quality Assurance, A. Eck, failed to expedite (
corrective action once he was made aware that the onsite QA/QC Manager was not providing a prompt response to AAR#1 findings.
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- 3. On 1-28-83 QA/QC Manager H. Karner and myself had a violent verbal confrontation concerning AAR#1 and another11ssue.
- 1@m gpmow During review of Rupture Restraint Docun ntation for invest-i igation of Unscheduled Internal Audit # 35 I identified three full penetration welds that had NDE by MT instead of the C.S.
required UT process. While preparing to report these dis-crepancies, Mr. Karner confronted me at my desk and vanted to know what I was doing. I informed him that I had j identified Rupture Restraint NDE discrepancies. Mr. Karner l then asked me if I had been directed by him to identify these l
- problems. I stated Mr.
that he had not directed me to identify Karner at this point began to scream and i N,\ the problems.
shout at me that I was no longer the Internal Auditor-(I had I
been replaced but given permission tc conclude two audits in progress , one of which' was U.I. A. #35) and .that .I was only to do what he told me. In effect, Karner was telling me'that I as a QA/QC Inspector could no longer identify discrepant i conditions unless specifica11y' order to:do so by him. Mr. l Karner screamed at me that if I did this again he would get ,
l
'393( rid of me.
f l
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Karner then accused me:of g6Agg to unscheduled audits to gst krohnd~1risrapprover oYnthe Hudit~~checklistr ~He accused me'of being' adverse'to quality. At this point I screamed at'his'that he'had beenL. sitting on AAR#1 of g< I.A..#101 fir a yea'r ahd -that he was. violating 100FR50 App 4B XVI and two PG&E Contract requirefients by not i
(
J promptly correcting problems adversetto quality. QA/
QC Manager Karner~ at this pbint stated that it was OK
%, _h for him to violate the Code and Contracts. He repeated i
I this statement twice. .Mr. Karner also stated that:. one of the reasons why.i didn't have all the required 1982 audits done was be'ause c I investigated items not on.a checklist or irrelvazit.1I responded to this by' saying one reason was th't'.he a had been'si'tting on an audit ;
(AAR#1, I.A. #101) for'a year. !
I should point out'thattthis timb we were toe to toe, I face to face; screaming'at each iother, y
Mr. Karner again repeated that I was only to do what I
l he told me to do'which I interpa ted to mean that I l could not identify Quality AssuFancefdiscre;ancies ,
I unlessspecifically-ordered-tofoso.
This confrontation was witnessed:.by numerous persons in the QA/QC Office. .:
This confrontation produced twoi;significant conditions i
adverse to quality, p
- 1. As A QA/QC Inspector Iwas ordered by the QA/QC Manager not to identify QA discrepancies unless y% specifically order to do so :by the QA/QC Manager.
If I did I would be gotten rid of. This was an attempt to intimidate me from identifying I
discrepant conditions. This violates 10CFR50 App.
B I requirement that persons performing quality j
._S/
/
Y g( assurance functions shall have sufficient authority and organization freedom to identify quality problems
- 2. The QA/QC Manager stated hep'did not have to comply with 100FR50 App. B and 0.S4 requirements to promptly correct conditionsr adverse to quality.
This is a base violation ofiQuality Assurancea requirements. 6QA/QC Manager H. Karner has demonstrat wg this disregard for this QA' requirement in his lack M
of corrective action for I.4. #101, AAR#1 audit sawt to tv , findings, in.a' timely manne ,
h Internal Audit #101 identified.signI .icant Quality Assurance discrepancies in the qualificationof NDS ;and UT thickness meas- i uring procedures. ' Subsequently, sigdifi t QA discrep,ancies took place in the implementingo 'f correc$1ve action to the audit findings. The issues identified in this report and I.A. # 101 should be investigated'by the NRC to asst re that quality assurance has not-been compromised at the Diablo Cdnyon Nuclear Plant.
CWO - A
% - END OF TAfE 4l .
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4 ,h,',l',h. NUCLEAR REGULATORY COMMISSION /2( [C/P g% l ,t 8? I HLGlon v l f)
," jE 1990 N. CAlliOHNIA DOtn C VAllD SUIT C 202, n At. NUT CHCCK PL AZA
,,,,e WALNUT CHC C K, CAltrOHNI A D.1%G f June 1, 1979 -
Odciet Hos. 50-275 50-323 l
i I
Pacific Gas and Electric Company 77 Beale Street ,
San Francisco, California 94106 .
{
i Attention: Mr. Philip A. Crane, Jr.
Assistant General Counsel Gentlemen: i
Subject:
flRC Inspection at Diablo Canyon Units 1 and 2 T. W. Hutson of this office on April 30 - May 3,1979 authorized by flRC Construction Permit flos. CPPR-39 and CPPR-69, and to the discussion staff of our at the conclusion findings of the inspection.held by Mr. Kirsch with members of your <
Areas inspection examined report. during this inspection are described in the enclosed Within these areas, the inspection consisted of selective examinations of procedures and representative records, in- i terviews with personnel, and observations by the inspectors .
t activities were not conducted in full compliance with 1 as set forth in the Notice of Violation, enclosed herewith as Appendix A !
These items of noncompliance have been categorized into a level as de- .
n scribed in our correspondence to all NRC licensees dated December 31, 1974.
of the NRC's " Rules of Practice," Part 2, Title 10 Code Regulations.
s within thirty (30) days of your receipt of this notice, a writtenS :
4 have been taken by you and the results achieved; statement! o
- 2) corrective steps which will be will full compliance taken to avoid further violations; a(nd (3) the date when be achieved.
'l 1
i specific items of noncompliance, please e' include a d t
actions you have or plan to take to separate and/or preclude n the asso'
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.;1fic Gas and Electric Company June 1, 1979 of non-safety related cables with redundant safety-related cables in order that "no single failure results in loss of the protection' function,"
in accordance with 10 CFR 50, Appendix A, Criterion 21. -
J In accordance with Section 2.790 of the NRC's " Rules of Practice," 1
-Part 2, Title 10, Code of Federal Regulations, a copy of this letter and f the enclosed inspection report will be placed in the NRC's Public !
Document Room. If this report contains any information that you believe l to be proprietary, it is necessary that you submit a written application i to this office, within 30 days of the date of this letter, requesting i that such information be withheld from public disclosure. The application !
must include a full statement of the reasons why it is claimed that the l information is proprietary. The application should be prepared so that j
any proprietary information identified is contained in an enclosure to s the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. -
1 Should you have any questions concerning this inspection, we will be glad to discuss them with you.
j Sincerely, l M uc3m G. S. Sp ncer, Chief Reactor Construction and I Engineering Support Branch l
Enclosures:
A. Notice of Violation l' B. IE Inspection Report Nos. 50-275/79-12 50-323/79-07 l
cc w/o enclosure B: !
W. A. Raymond, PG&E L J. D. Worthington, PG&E R. D. Ramsay, PG&E (Avila Beach) i cc w/ enclosures R. D. Etzler, PG&E (Avila Beach)
J. B. Iloch, PG&E ;
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APPENDIX A Pacific Gas and Electric Company
-77 Beale Street
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San Francisco, California 94106 Docket Nos. 50-275 and 50-323 Construction Permit Nos. CPPR-39 and CPPR-69 Notice of Viclation i
Based on the results of an NRC inspection conducted during the period of April 30 - May 3,1979, it appears that certain of your activities were not conducted in full compliance with conditions of Construction Permits Nos. CPPR-39 and CPPR-69 as indicated below.
A. 10 CFR 50, Appendix B, Criterion V, as' impicmented by Section 17.1.5 of the FSAR and the PG&E Quality Assurance Manual Section V, states in part that, " Activities affecting quality shall be pre-scribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Paragraph 10 of Drawing 049237, Revision 4 (Piping and Mechanical Hanger and Snubber Supplementary Installation Instrt.-tions) specifies a maximum attachment weight of 25 pounds when a tubing support is attached to a large bore hanger.
Contrary to the above, a tubing support (2-FT-640) that weighed 28 pounds was attached to Unit 2 large bore support 49-12V.
This is an infraction applicable to Unit 2.
B. 10 CFR 50, Appendix B, Criterion V, as implemented by Section 17.1.5 of the FSAR and the PG&E Quality Assurance Manual Section V, states in part that " Activities affecting quality shall be ...
accomplished in accordance with . . . instructions, procedures or drawings."
Foley procedure QCP-9 (Quality Control Procedure for Installation of Raceways, Junction and Terminal Boxes for Wire Pull) Paragraph 4.2.5 (implementing PG&E Drawing 050029, conduit note 60) states that "Where non-class 1 conduit shares supports with more than one class 1 raceway, vital or protection channel, an intermediate class 1 support shall be provided."
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O scific Gas and Electric Company docket Hos. 50-275 and 50-323 APPENDIX A (Con't.)
Foley procedure QCP-9 further requires in Paragraph 4.l.8 im -
plementing PG3E Drawing 050030, note 3) that where raceways (, other than those identified as class 1, " cross a class 1 raceway, a class 1 support shall be constructed on each side of the inter-section."
Contrary to the above requirements, the following conditions were identified on May 1,1979 in the K-100 area of Unit 1:
1.
Non-vital conduits KHT-52 and 53 were both attached to support K-115-6-47 (a vital bus F support) and an unnumbered vital bus H support class of detail I support number 397 without having an intermediate provided.
2.
Non-vital conduits K-9424, K-9430 and K-9652 were installed above and crossing vital conduit without having a class I support provided on each side of the intersection.
This is an infraction applicable to Unit 1.
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U. S. NUCLEAR RECULAToRY Co>cilsSION OFFICE of INSPECTION AND ENFORCEMENT 50-275/79-12 w no,50-323/79-07 '
get no,50-275, 50-323 Liecnse No. CPPR-39, CPPR-69 safeguards croup
,; Pacific Gas and Electric Company 77 Beale Street f I
San Francisco, California 94106 '
.:c t u ty Nan,e : Diablo Canyon Units 1 and 2
,cpection at: Diablo Canyon Site, San Luis Obispo County, California
.spection conducted: April 30 - May 3, 1979 nspectors: . M) wp, / , j p y(/
D. F . Kir'sch, Reactor inspector i
Date signed l K __ %w \ R9 T. W. Hutson, Reactor Inspector _ 0 Datc Signed
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Date Signed proved By: _- # t f
R. T. Dodds, Chief, Engineering Section, Reactor Dat'e signed Construction and Engineering Support Branch Inspection during period of April 30 - May 3,1979 (Report Nos. j 50-275/79-12 and 50-323/79-07)
Areas Inspected: Routine, unannounced inspection by regional based I
inspectors of construction activities including: licensee action on previous inspection findings; licensee action on IE Bulletins and Circulars; physical protection of safety-related equipment; allegations of improper raceway support installation; Unit 2 volume control tank overpressure corrective actions; NDE examiner, QC inspector, and welder performance qualifications; welding materia 1 control; and steam generator preservice examination results. The inspection involved 46 inspector-hours by two NRC inspectors. '
Results: Of the eight areas inspected, no items of noncompliance or I l
l deviations were identified in six areas, one item of noncompliance was identified in each of the areas of pipe supports (infraction - tubing support installed on another support exceeded the maximum specified l
weight limit - Paragraph 4.a) and electrical raceway supports (infraction - l failure to install conduit as required by procedures and drawings - !
Paragraph electrical 7.b.(4))
raceway and one supports unresolved (Paragraph item was identified in the arg ( g g 7.b.(3))
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DETAILS i
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- 1. Persons Contacted
- a. Pacific Gas and Electric Company (PG&E) .
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- li. R. Tressler, Assistant Superintendent - General Construction i R. D. Etzler, Project Superintendent I
- ll. N. llorem, Startup Engineer )
- D. A. Rockwell, Resident Electrical Engineer !
- V. L. Killpack, Resident liechanical Engineer
- R. K. Rhodes, Instrumentation Supervisor
- fl. E. Leppke, QA Supervisor
- S. J. Foat, QC Engineer J. R. Bratton, QC Engineer W. lianegold, Hanger Engineer C. Craff, Pipe Support Supervisor F. J. Cucco, Instrumentation Engineer 1
- 0. G. Crass, Tubing Installation and Valve liaintenance Coordinator F. M. Russell, Acting P,esident Civil Engineer V. Snart, Electrical Field Engin.eer R. Whited, Electrical Field Engineer G. Hegli, QA Engineer R. Johnson, Civil Field Engineer
- b. Pullman-Kellogg (Kellogg)
D. Geske, QA/QC Manager R. A. Richardson, Receiving Inspector K. W. Melin, Rod Room QA Inspector
- Denotes those attending the exit interview.
- 2. General .
The licensee anticipates readiness for operating license issuance and fuel load for Unit 1 on or about July 6,1979.
- 3. Punch List L The licensee's punch list of incomplete work contained 235 items at the time of inspection and efforts were underway to complete the work.
The licensee stated that, to assure readiness for licensing and fuel load, an instruction would be written detailing (a) individuals responsibic for document reviews to assure completion of and/or identification of incomplete work, (b) documents required to be reviewed and (c) appropriate interface requirement: necessary for General Construction, Operations Division, and Engineering.
8 9 Licensee Action on previously identified Followup Items l l
- a. (0 pen) Unres_olved item - Unistrut Welded to Support 49-12V
~(323/79-05-03)
During the inspection conducted on March 26-29, 1979,: the inspector noted that a secticn of unistrut associated with !
instrument tubing support 2-FT-640 was welded to the bottom of hanger 49-12V in Unit 2. Paragraph 10 af Drawing 049237, Revision 4 (Piping and Mechanical Pipe Hanger and Snubber Supplementary Installation Instructions) gives three criteria ,
for determining the acceptability of attaching a tubing I support to a large bore hanger. These criteria specify a maximum 25 pound attachment weight. Subsequent to installation and inspector identified concerns, calculations by PG&E showed that the weight of support 2-FT-640, attached to 49-12V, was 28 pounds. The tubing support installation contractor, H. P. Foley, installs supports in accordance with Drawing 049238, Change 5, Instrument Tubing Supports. This drawing did not contain the three acceptance criteria in Paragraph 10 of Drawing 049237. Drawing 049237 had not been issued to i H. P. Foley. This appears contrary to the requirements of i 10 CFR 50, Appendix B, Criterion V, which states in part that, l
" Activities affecting quality shall be prescribed by documented l instructions, procedures, or drawings, of a type appropriate l to the circumstances and shall be accomplished 'in accordance i with these instructions, procedures, or drawings." ,
i This is an apparent item of noncompliance. )
- b. [0p_en) Isolation of Mutually Redundant Circuits (275/79-07-02)
In order to determine if non-safety related wiring crossed protection set or vitality boundaries, the inspector examined the licensee's circuit schedule and a number of mechanical panels housing class 1 instruments in the Unit 1 containment and made the following observations.
(1) Common non-vital heater circuits cross the following circuits with less than 5-ipch air separation.
(a) Steam Generator 1-3 level circuits in protection set 1 (PliL46) and protection set 3 (PNL54): Heater circuit No. PJ7116 (b) Steam Generator 1-4 steam flow circuits in protection set 1 (PNL47) and protection set 2 (PNL51): Heater circuit No. PJ7107 (c) Steam Generator 1-4 level circuits in protection set 2 (PNL51) and protection set 4 (PNL59): Heater circuit lio. PJ7107 l
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I Pressurizer level circuits in protection set 1
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(d)
(PNL22), protection set 3 (PitL20) and protection set 2 (PiiL89): Heater circuit 11o. PJ7104 ;
.. l (c) Reactor Coolant System loop 1-2 flow circuits in {
protection set 1 (PNL22), protection set 3-(PNL20) j
~_ and protection set 2 (PNL89): Heater circuit flo. j PJ7104
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(f) Steam Generator 1-2 level circuits in protection set 1 (PNL45) and protection set 3 (PriL53).: Heater ;
circuit No. PN7114 !
(2) In addition, wires at the heater end in panel 57 had been-removed from the heater element and were hanging free. J The wire ends had been taped with electrician tape and I were visible inside the tape. )
i This item is open pending evaluation of additional information l to be submitted by the licensee. l
- 5. Licensee Action on Bulletins and Cir.culars i i
Bulletin 78-04 NAMC0 Stem Mounted Limit Switches j l
The inspector examined the Unit 1 installation of five environ- I mentally qualified NAMCO Snaplock switches, EA 180 series, model No. EA-180-ll302 on valves 8149A, 8149B, 8149C, LCV 459 and LCV 460. 1 At present 14 of 18 switches in Unit I had been replaced with the l exception of installation of the LOCA seal connections to the limit j switches. The LOCA seals had been ordered from the Conax Company, '
Drawing lio. 25Kl915, Revision A, Part No. 02 and certified as meeting the applicable environmental qualifications. The inspector has no further questions on this item.
- 6. Physical Protection of Safety-Related Equipment During a tour of the Auxiliary Scauater System (ASW) pump and gate operator area, located in the intake structure, it was observed that a large screen wash water line was suspended above the Unit 1 and 2 ASW suction gate operating motors. The line did not appear to be supported by seismically qualified supports. In addition, the redundant gate operators for each unit had no physical barriers installed.
The licensee noted that this problem had been previously identified in Plant Design Comment No. 16. The followup of this item has been remanded to the cognizance of the Resident Inspector, who was following the licensee's resolutiori of plant design comments. In addition, this question was addressed to the Project Engineer who stated that this observation would be examined and that licensee actions deemed necessary or already taken to assure adequate physical protection of safety-related equipment would be identified.
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_4 7, A_lleSations of Igrop_cr Raceway Support Installation
- a. Allegations as understood by the !!RC Allegations of improper Unit i raceway support installations were received by the Resident inspector who, in turn,' referred Specifically, the them to the regional office for resolution.
allegations were:
(1) Support rio. K-115-4-100 had no side brace support to the wall; FE/FW-2-249 had holes in unistrut welds; and FE/FW-1-260 welds were not to detail.
(2) Support flos. C-104-3-7 and 3-8 had a unistru't beam on I piece S-6 which was not to detail.
(3) Support flos. K-100-7-ll5 and 116 had concrete anchor bolts installed which were not separated from adjacent concrete anchor bolts by the required distance.
(4) Conduit flos. K-9424, 9430 and 9652 in K-100 area, run above vital conduit and did not have class 1 supports installed.
- b. t!RC Construction Branch Findings (1) The allegation was substantiated, however, support !!os.
K-115-4-100, FE/FW-2-249 and FE/FW-1-260 had been pre-viously identified by the licensee as discrepant and entered onto work package C-93:E-84 for repair by the PG&E cleanup creu. ,
(2) The allegation was substantiated; however, examination indicated that support flos. C-104-3-7 and 3-8 were con-structed in a manner which exceeded design detail require-ments. The design details called for a P-3300 unistrut .
beam attached to piece 56. A P-1000 beam was attached to the S6 members for both supports. The P-1000 beam is a heavier, more substantial member than P-3300.
(3 The allegation was substantiated. The inspector examined the concrete anchor bolt installations for supports K-100-7--115, 116 and about 100 other supports located in various areas of Unit 1. In addition to the supports identified by the alleger, it appeared that supports flos.
l K-100-7-100, K-100-7-165 and K-100-7-ll8 (in K-85 area of Unit 1) had anchor bolts which did not meet the specified anchor bolt spacing requirements of Foley procedure QCP-
- 9. All of the ider.tified supports had been inspected and accepted by Foley in the conduct of the raceway support inspection / inventory program and none of the Support Inspection Work Sheets, for the above supports, identified anchor bolt spacings as a discrepancy.
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'Foley procedure QCP-9, Paragraph 4.4.1, requires' that "cen:er-to-center anchor spacing shall not be less than 12 nominal diameters of the largest anchor bolt ' pniess directed by PGSE design documents." The supports noted above utilized 1/2 inch diameter concrete anchor bolts t;hich were spaced between 2-1/2 and 3 inches from adjacent anchor bolts.
The licensee's Resident Electrical Engineer' believed that Foley had been provided with additional PG&E direction, i based upon an inspection of all anchor bolt installations l by Engineering Department in 1975 and the results of a PGSE study performed to establish anchor bolt installation acceptance criteria. This is an unresolved item pending examination of the additional PG&E directions supplied to the contractor. (275/D-12-01)
(4) The allegation was substantiated. An examination of numerous raceway and support installations on May 1,1979 in the K-100 area of Unit 1 identified the following discrepancies:
(a) lion-vital conduits K-9424, r,-9430 and K-9652 were installed above and crossing vital conduits without having a class 1 support provided on each side of the intersection. ,
(b) Non-vital corduits KHT-52 and 53 were both suspended from support K-ll5-6-47 (a vital bus F support) and an unnumbered vital bus H support of detail number 397, without having an intermediate class 1 support provided.
Foley procedure QCP-9 (Quality Control Procedure for Installation of Raceways, Junctions and Terminal Boxes for Wire Pull), Paragraph 4.2.5 (implementing PG&E Drawing 050029, conduit note 60) states that "Where non-class 1 conduit shares supports with>more than one class 1 raceway, vital or protection channel, an intermediate class 1 support shall be provided."
Foley procedure QCP-9, Paragraph 4.1.8 (implementing PG&E Drawing 050030, note 3) states that where raceways, other than those identified as class 1, " cross a class 1 raceway, a class 1 support shall be constructed on each side of
, the intersection."
This is an apparent item of noncompliance. (275/79 02)
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/ 8. Uni t 2 Voygo_ntrol T:o k The hydrostatic test cr. cords, visual examination and liq'uid penetrant test records for the Unit 2 Volume Control Tank were reviewed by the inspector for compliance with the requirements of ASME Section XI, through Summer 1975 Addendum.
The visual and liquid penetrant examinations disclosed surface defects such as slag left on welds during fabrication, excessive weld reinforcement and a misalignment Ifon-of the shell to head which exceeded allowable code limits.
conformance report DC2-79-QC-P0054 was written to document the deficiencies noted and all data taken had been turned over to Westinghouse engineering for evaluation and disposition. The resolution of this item will be followed through the normal review of itCR's.
tio items of noncompliance or deviations were identified.
- 9. Nondestructive Examiner and QC Inspector Qualification l
l The. inspector reviewed one Level II NDE examiner's qualifications and five Level II QC inspectors' qualifications for conformance to l the requirements of Si1T-TCI A, Kellogg Procedures ESD-235 (iton- 1 l destructive Examination Personnel Qualification and Certification {
Procedure) and ESD-237 (Quality Assurance Inspector Training l
l Program). )
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tio items of noncompliance or deviations were identified.
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- 10. Welding Material Control j 1
The filler material withdrawal and issue operations and material l l
storage in the Kellogg rod room were examined for compliance with i Procedure ESD 202 (Weld Material Distribution and Control). The holding ovens were properly marked with the contents and the '
temperature gauges had been calibrated. All portable rod warmers had been checked for operation and temperature at the required i frequency. The rod room was clean and neat with all cans of moisture sensitive weld rod undamaged and hermetically sealed. The rod withdrawal slips for May 2,1979 were randomly reviewed and ,
appeared to be properly completed. The receiving inspection reports and certified material test reports fo'r the following heats of weld rod being issued were reviewed.
Heat flumber Rod Type and Size 07L150 E7018 - 3/16" 412E-0271 E7018 - 5/32" 422E-1681 E7018 - 1/8" 29963 E308 1/8" 48116 CR308 - 3/32" 482584 ER308 - 1/8" Ito items of noncompliance or deviations were noted.
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l d- EEld.er_hrfetngnceQualification !
Ten welde'r; performing welding on May 2,' 1979 were checked for 4 proper qualifications using the welders qualification matrix issued for the period May 1 through May 31, 1979. These ten welders appeared qualified by use of the matrix. To verify the accuracy of l
- the matrix, the inspector compared two welders performance qualifi- j cation records with the matrix. The review showed that the limit ;
of thickness stated for a specific welding procedure had been j rounded up to the nearest quarter inch over the 2T (T-thickness of l
test plate) limit required by Section IX of the ASME code. For j l
example, a 2T limit of 0.636 inches had been rounded up to 0.750 ;
l inches in numerous cases. The inspector also found that a procedure qualification record for a welder, symbol BR, was missing from his l qualification folder. This item is open and will be examined 'i during a future inspection. (275/79-12-03) j
- 12. Steam Generator preservice Examination In the course of liquid penetrant preservice examinations, the licensee reported that indications of crazing were identified on l the outer diameter of Unit i Steam Generators 1 and 2 cold leg ring dams. The indications appeared in the clad area at the edge of the weld material and not in the weld material. Steam Generator 1 had an indication about 3/8 inches long and Steam Generator 2 had a number of large indications. The licensee was still in the process of investigation to determine the exact nature and depth of the indications on Steam Generator 2. l Westinghouse Electric Corporation, the NSSS suppl ~ier, had initiated j a Field Discrepancy Report and submitted this to their Tampa office i for resolution. Westinghouse personnel noted that all previous studies determined that the indications had never gone into base metal. This item will be examined further during a future in-spection. (275/79-12-04)
- 13. Unresolved Items i Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. One unresolved item was identified during this inspection and is discussed in Paragraph 7.b.(3).
- 14. Exit Interview The inspectors met with licensee representatives (denoted in Para-graph 1) on May 3, 1979 and summarized the inspection purpose, scope and findings. The licensee was informed of those matters considered as items of noncompliance and unresolved.
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Docket Nos. 50-275 50-323 Pacific Gas and Electric Company l 77 Beale Street San Francisco, California 94106 .
Attention: Mr. Philip A. Crane Assistant General Counsel Gentlemen:
Subject:
NRC Inspection at Diablo Canyon Units 1 and 2 .
i This refers to the i',spection conducted 'by Messrs. D. F. Kirsch and '
T. W. Hutson of this office on June 4-7 and 20,1979 of activities authorized by HRC Construction Permit Nos. CPPR-39 and CPPR-69, and to the discussions of our findings held with Mr. R. D, Etzler and Mr. J. R. Stevenson and other members of your staff at the ,
l conclusion of each inspection period.
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.
No items of noncompliance with NRC requirements were identified within the scope of this inspection.
In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public -
Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application I to this office, within 20 days of the date of this letter, requesting that such information" be withheld from public disclosure. The application must include a full statement of the reasons why it is m
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Pacific Gas and Electric Company .
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should be prepared so that any proprietary information identified l is contained in an enclosure to the application, since the application I without the enclosure will also be placed in the Public Document l Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be j glad to discuss them with you. , !
Sincerely, d ' fi ./
G. S. Spencer, Chief Reactor Construction and Engineering Support Branch
Enclosure:
IE Inspection Report Nos. 50-275/79-13 and 50-323/79-03 cc w/o enclosure:
W. A. Raymond, PGLE J. D. Worthington, PG&E R. D. Rainsay, PG&E (Avila Beach) cc w/ enclosure t/t. D. Etzler, PG&E (Diablo Canyon)
J. B. Hoch, Project Engineer, PG&E e
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