ML20155A008

Rev 0 to Program for Independent Design & Const Assessment

ML20155A008
Person / Time
Site:	Limerick
Issue date:	05/27/1988
From:	Daniels H, Fleming E, Wille D STONE & WEBSTER ENGINEERING CORP.
To:
Shared Package
ML20155A004	List: ML20155A001 ML20155A008
References
PROC-880527, NUDOCS 8806090207
Download: ML20155A008 (30)

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J.O.No. 18138.00 PROGRAM FOR THE INDEPENDENT DESIGN AND CONSTRUCTION ASSESSMENT OF LIMERICK - UNIT 2 e

Stone & Webster Engineering Corporation Revision 0 May 27, 1988 e

l Assistant Program Manager 2 D/ J. Wille-I Assistant Program Manager

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E. IT. Flemin Program Manager h H. E. Daniels, Jr.

8806090207 880601 PDR ADOCK 05000353 P DCD ,,2 j

PROGRAM FOR THE INDEPENDENT DESIGN AND CONSTRUCTION ASSESSMENT LIMERICK - UNIT 2 Philadelphia Electric Company (PECo)

1. SYSTEM SELECTION AND SCOPE The purpose of the Independent Design and Construction Assessment (IDCA) is to review the adequacy of the design and construction process for Lim-erick Unit 2 by examining the Containment Heat Removal (CHR) mode of op-eration of the Residual Heat Removal (RHR) System, associated structures, and interfaces. In so doing, the IDCA team will review the RHR function of injecting water into the reactor vessel under a postulated accident condition, without containment spray, and returning water to the RHR pump from the suppression pool. The selected system operations include cool-ing of the RHR heat exchanger by the RHR Service Water System with heat rejection to the cooling tower or the spray pond.

This sample is a combination of systems acting together in a specific saf3ty mode and was selected to provide the broadest possible review of design and construction activities while focusing the IDCA team's activi-ties on a limited amount of plant equipment and structures. This system will provide an in-depth assessment of the architect engineer (A/L) de-sign process since the following activities were accomplished within the A/E scope of services:

• Interface with the NSSS design process, including postulated accident conditions.

• System design for a common system.

• Service water pump specification and procurement.

• Pipe sizing, layout, and procurement.

• Pipe stress analysis and support design, including ASME III, Class 1, 2, and 3 piping.

• Electrical power to pumps and valves and procurement of motor operated salves (MOV) and pump motors.

• Control logic interface with NSSS equipment.

• Control system logic for operation of A/E procured valves and pumps.

• Routing of power and control cables, including electrical sepa-ration criteria.

• Structural elements to supp'>rt system components.

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• Environmental qualification of equipment, including seismic requirements.

• Supporting systems for proper operation of the CHR function, including compartment cooling and pump / motor cooling systems.

• Design interface with subcontractors and component suppliers.

The IDCA will be performed by two teams of experienced personnel, one to conduct the Independent Design Assessment (IDA) and the other to conduct the Independent Construction Assessment (ICA).

2. INDEPENDENT DESIGN ASSESSMENT (IDA) OVERALL APPROACH The CHR mode will form the basis of the assessment. The design will be reviewed to determine if the following attributes are met:

• The design is consistent with and supports the FSAR commit-ments, including system function, compliance to documents com-mitted to in the FSAR and compliance with good design practices.

• The design is in compliance with NSSS requirements and criteria.

• Technically adequate calculations are available to support the design.

• Diagrams, specifications, drawings, and vendor documents are technically complete and consistent with each other.

• Inter- and intradiscipline interfaces are adequate.

The adequacy of design changes and the resolution to industry issues, NRC bulletins, notices, circulars, etc, will be evaluated. Emphasis will concentrate on design changes to the system under review. However, de-sign changes to other systems will be evaluated, where required to obtain a reasonable sample for review. The adequacy of disposition.c to noncon-formances/ deficiencies and design changes also will be evaluated.

To facilitate the review of the system design and to eva)uate engineering activities, a site walkdown will be conducted as part of the Independent Construction Assessment (ICA).

To evaluate certain types of design activities, it is anticipated that review of other systems / components (other than those related to the CHR mode) will be necessary. Types of activities where this may be necessary are:

• Hazards (pipe rupture, jet impingement, etc)

• Stress reconciliation (piping) 1852-18138-HC3 2 Rev. O, 05/27/88 2

• Structural load verification

• Electrical separation

• Raceway support design

• Procurement-and upgrade of commercial grade equipment and parts

3. IDA APPROACH BY DISCIPLINE 3.1 Mechanical Systems 3.1.1 System and Component Design The scope of the assessment will involve a design review of systems and components that are required to satisfy the safety and opera-tional requirements of the CHR mode. This review will be primarily based on review of design documents, as.well as discussions with project personnel and field walkdown activities. Design' changes and resolution of industry issues will be evaluated.

This design review will be performed in various steps using formal assessment plans, which will describe the approach to be followed for the review:

• The compliance of the Final Safety Analysis Report (FSAR) with the project position on applicable Standard Review Plans and Regulatory Guides, and the coraliance of the system design with commitments in the FSAR, will be verified.

• The system design will be reviewed to verify consistency with the NSSS interface requirements.

• The flow diagrams will be reviewed to ensure process adequacy 1

and compliance with applicable codes and standards and project procedures.

• The applicable calculations will be reviewed to verify consis-tency of the system design with the system design bases and criteria.

• Selected equipment specifications vill be reviewed to verify i consistency with other support documents; comprehensiveness; adequacy of technical, inspection, and construction require-ments; and compliance of the equipment test performance, when applicable, with the sp2cification requirements.

• The compliance of the suppression pool design with Regulatory Guide 1.82 will be reviewed.

• Preoperational testing and turnover of the Unit 2 portion of the RHR service water will be reviewed.

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• Piping drawings will be reviewed for consistency with the flow diagrams and machine location drawings for operability, maintainability, and inspectability.

• Vendor documents will be reviewed for completeness and for con-sistency with the specification requirements.

• The interfaces between other engineering disciplines will be reviewed to verify consistency and compatibility of design requirements.

• The hazards program will be evaluated as discussed under Sec-tion 3.2, and a selected flooding analysis will be reviewed for adequacy.

• The adequacy of the project responses to industry issues and the actions taken to implement the related design changes will be reviewed.

• The systems' design changes will be reviewed for technical adequacy.

• The actions related to nonconformances and deficiencies will bc reviewed.

A site walkdown will be performed as part of the ICA to facilitate evaluation of certain attributes such as system interaction, imple-mentation of piping and component layout, and to verify adequacy of shielding and separation where applicable.

3.1.2 Materials The scope of this assessment will include the evaluation of techni-cal adequacy of the materials and fabrication requirements invoked on the CHR mode systems. The evaluation will be based on review of the material and fabrication requirements for pressure boundary ma-terials and for related coating applications, including coating of the suppression pool. The review will be based primarily on the review of desiga documents and discussions with project personnel in the materials and other applicable disciplines, and team members.

The assessment will commence with a review of the applicable sec-tions of the FSAR and a review of applicable design specifications, drawings, and procedures used to implement the FSAR requirements.

The materials and fabrication Regulatory Guide positions and Branch Technical Positions committed to in the FSAR will be reviewed and a de te rmina tion made if these posi ions were adequately addressed in appropriate design specifications, drawings and procedures.

Design specifications for major components and materials and select-ed drawings associated with the CHR mode will be reviewed. Based on the results of this review the invoked technical requirements for materials and fabrication will be evaluated to assure that the FSAR commitments have been interpreted correctly and consistently.

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Selected A/E and vendor fabrication procedures utilized on this sys-tem will be reviewed to assure that these requirements have been adequately implemented during the fabrication / installation and erec-tion phases. Implementation will be evaluated during inspections as part of the ICA.

Selected design changes and nonconformances/ deficiencies written agai st the above specifications and drawings will be reviewed to assure that the requirements remain consistent and technically ade-quate and agree with established FSAR requirements.

The implementation of selected industry issues in the materials en-gineering area will be evaluated to verify the adequacy of project resolution.

3.2 Mechanical Components The scope of this technical assessment consists of an evaluation of the design process for the analysis of the CHR mode piping, the seismic qual-ification of equipment and valves, and the design of pipe supports.

This portion of the review will assess the following areas:

• Design is consistent with the FSAR commitments.

• Calculations supporting the design are complete and technically adequate.

• Specifications are complete and consistent with each other.

• Drawings used in the design are clear and complete.

• Inter- and intradiscipline interfaces are complete.

• Design changes and nonconformance dispositions are consistent with the design requirements.

• Design complies with NSSS requirements.

• Pipe stress reconciliation.

Regulatory Guides and the Standard Review Plans committed to in the FSAR will be reviewed. The FSAR will then be checked for compliance. Project technical memorandums and design calculations will be reviewed to ensure that FSAR commitments are included in the design process.

Selected NSSS equipment specifications and drawings will be reviewed for requirements which impact the stress analysis. Related stress calcula-tions will then be selected and NSSS requirements evaluated.

Calculations supporting the design of the CHR mode systems will be chosen based on one or more of the following criteria:

• The piping terminates at an equipment nozzle.

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• The piping spans two structures.

• The piping contains an expansion joint.

• The piping terminates at a penetration. l l

• The analysis represents two similar lines. l l

Information used as input to the calculations will be reviewed for com-pleteness and the documentation of input information. Each calculation will be checked for technical adequacy, compliance with project commit- l ments and the transmittal of results. Resolution of as-built differences I will be reviewed. Calculations supporting the analysis of large bore and field-designed small bore piping will be included.

A sample of the system pipe supports will be selected for review. The selection will consist of various types of restraint designs so that a broad spectrum of pipe supports may be evaluated. Typical designs will include, if possible, anchors (six-way), dynamic snubbers, frame type rigid restraints, struts, and spring hangers. Supports selected will include integral welded attachments to the run pipe, base plates with concrete anchor bolts, attachments to embedded plates and attachments to structural steel members. The pipe supports will be reviewed with empha-sis on the following:

• The pipe support design meets the stress analysis functional intent.

• The pipe support is in compliance with the pipe support design specification.

• The mathematical procedures and methods are correct and applicable.

• Justification of assumptions and/or special methods used in the calculation are clearly stated and applicable.

• The construction drawings show all pertinent details of the design calculations (proper members and orientation, weld types and sizes, etc.), and construction and inspection requirements are complete.

Piping location drawings (isometrics) will be selected and reviewed for completeness, clarity, and consistency with the design requirements.

Specifications will be reviewed for consistency with project procedures, FSAR commitments, and ASME code requirements. Technical requirements for the design process will be checked against the specification (s) to ensure that all such requirements are addressed.

Selected industry issues will be evaluated and project implementation checked by the review of relevant calculations and procedures.

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Interface requirements between various engineering and design groups will be reviewed to ensure that all information is current, complete, and technically accurate. Nozzle loads, pipe support reactions, system oper-ating conditions, drawings, amplified response data, and penetration loads will be evaluated.

Transmittals of pipe support results will be reviewed to verify that they are complete and in proper users f o rma t . The loads at the structural /

concrete interface locations and the weld technique sheets specified on the construction drawings are particularly subject to this review.

Selected design changes and nonconformances/ deficiencies written against the specifications, drawings, or equipment will be reviewed for technical adequacy and clarity of solutions.

A review of the hazards program related to high energy line break and internal missile generation will be conducted to assure the soundness of the program. Licensing and regulatory commitments will be assessed for consistency with current project practice. Calculations and other rele-vant documents will be reviewed as necessary. These reviews are intended to assure the following:

• The adequacy of criteria and instructions.

• The adequacy of engineering judgments applied during the execu-tion of the hazards review program.

• The adequacy of pipe rupture analysis, restraint design, and shield design as implemented in conj unction with the hazards program.

It is anticipated that two areas--one inside the containment, a second outside the containment--will be reviewed to assess the adequacy of the hazards program's current conclusions. Of the two areas chosen, at least one area should identify the necessity for protection of essential sys-tems or equipment as determined by a failure modes and effects analysis.

This will assure the integrity of the pipe rupture design basis as ap-plied in the selected areas. An area which is regarded as completed by the hazards program also will be reviewed. This is intended to assess the integrity of the program's final documentation.

3.3 Electrical l

l The basic scope in reviewing the electrical design of the CHR mode sys-l tems involves three areas: (1) system equipment that are electrically I driven, (2) power sources from the Class IE busses supplying electrical power to that equipment, and (3) cable and raceway systems carrying the electrical power from the Class 1E busses to the electrically driven sys-tem equipment.

Equipment for review will be selected from each of these three areas.

The selection of specific items of electrically driven system equipment will be predetermined from the list of key equipment. Electric power source equipment supplying power to the electrically driven equipment 1852-18138-HC3 7 Rev. O, 05/27/88 l

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will be selected. In addition, the electrical distribution system and equipment supporting these power sources will be included to verify elec-trical power distribution system adequacy. The selection of cables and raceways will include those carrying the electrical power from the elec-trical power sources to the selected electrically driven equipment.

The objective will be to determine if the design documents that apply to selected equipment meet the design basis, are technically adequate and are consistent with associated documents.

In each of these three areas, engineering and design documents will be compared against FSAR design basis requirements and commitments. The engineering and design documents include design criteria, diagrams, draw-ings, specifications, calculations, and design change documents.

Drawings and diagrams will be reviewed considering design criteria such as electrical independence, cables / raceways, grounding, and environmental conditions. The electrical power distribution system documents will be reviewed for consistency with the main one-line diagrams. Overall design configuration, equipment, and impact on or from nearby equipment will be considered. Specifications will be reviewed for adequate electrical and en"ironmental condition requirements. Calculations supporting the system equipment and the electrical distribution system's capability of provid-ing the required quality of power will be reviewed for adequacy and con-sistency with the design. These calculations will include equipment sizing, voltage profile, short-circuit capacity, and cable sizing. Ven-dor drawings will be reviewed for consistency with specifications, draw-ings, and diagrams.

The electrical equipment included in this review is Class IE and is sub-ject to the requirements of RG 1.89 for environmental and seismic quali-fication of equipment, and RG 1.75 for physical independence of redundant systems. These special needs will be included in this review to verify that the Class 1E equipment meet environmental, seismic, and separation requirements.

For equipment qualification, it will be determined if the Class IE equip-ment meet specification requirements (including environmental and seis-mic), are traceable to the qualification documentation, and are installed in a manner consistent with the engineering and equipment qualification documentation. The equipment sampled generally will be the same as that used in the above review. If necessary, equipment from other systems will be selected.

For separation, the Class 1E equipment, including cables and raceways, will be reviewed for confo rma nce to the separation criteria of RG 1.75 and committed to in the FSAR.

l Selected industry issues and problems will be verified for adequacy of project responses and application to and consistency with engineering and design documents within the electrical discipline scope.

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Electrical interfaces for the A/E and NSSS systems will be reviewed for compatibility and consistency of engineering and design requirements, where applicable.

Recent change documents will be selected and reviewed for adequacy.

These change documents will be selected mainly from those associated with the Class 1E electrical distribution systems.

A site walkdown as part of the ICA will be performed to evaluate certain attributes such as compliance with the requirements of:

• Electrical and physical separation.

• Grounding criteria.

• Equipment qualification requirements including equipment loca-tion, position, proximity to nonsafety-related equipment and pipes carrying high-energy fluids, mounting methods, and the consistency of the installed equipment with specifications.

To assess the adequacy of the Class 1E ac power system and de system, specific loads from the CHR systems will be reviewed back to the diesel generator and battery, including diesel generator sequencing and loading, 1E voltage drops, and de battery capacity.

3.4 Instrument and Controls The basic scope of the review of the CHR mode systems will encompass three major areas:

• System design including instrument and control (I&C) redundan-cy, and licensing document compliance.

• Environmental qualification adequacy.

• Field verification of as-built design and configuration rela-tive to licensing requirements (performed by the ICA).

Automatic control logic, operator controls, and hardware will be evaluat-ed for the ability of the system to meet the commitments of the FSAR.

The review will encompass locally mounted sensors, controlling devices, panel-mounted instruments and controls, and auxiliary devices such as relays.

Logic diagrams, loop diagrams, instrument schematics, elementary dia-grams, and specifications will be reviewed for compliance with licensing requirements as detailed in the FSAR and other applicable criteria, and for consistency with interfacing documents such as P& ids and wiring dia-grams. The adequacy of control and interfacing with NSSS control system logics will be assessed.

Piping system interfaces for purposes of the I&C review will be deter-mined during team preparation.

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Equipment for review will be selected from key equipment lists. Selec-tions will be based on environment, input from other disciplines, .ind generic functionality. Equipment characteristics will be verified for consistency with supporting calculations (or other documentation) and the adequacy of the calculations evaluated.

Field and panel-mounted equipment will be evaluated for capability of controlling and monitoring the process function. Safety-related instru-mentation will be checked for compatibility of setpoints with the antici-pated process operating conditions.

Availability and independence of power available to redundant subsystems, including proper separation, will be checked from initiating device to source of power.

Sample safety-related equipment will be reviewed for compliance with ap-propriate environmental and seismic qualification requirements. The va-lidity of the requirements will be reviewed by appropriate disciplines.

Nonsafety-related equipment will be examined for necessity for seismic qualification of structure and mounting provisions.

Grounding of enclosures, shields, and signal wires will be examined for compliance with applicable standards, vendor requirements, and project procedures. Separation, isolation, and routing cf low-level signal and control wires for control and instrumentation cabinets and panels will be reviewed during the A/E inspection and evaluated during the ICA field walkdown (such as adequate separation of wire bundles inside control boards and minimum clearrnce between modules).

A sample of design changes and nonconformances/ deficiencies resolution will be reviewed to evaluate the technical adequacy of the problem solu-tions and dispositions, respectively.

3.5 Civil / Structural The structural engineering and design assessment will evaluate the tech-nical adequacy of the design, including design changes, for structures associated and related to the ClfR mode systems. In addition, it will evaluate compliance with governing documents such as design criteria, FSAR, applicable codes, and other licensing commitments.

The categories or general attributes listed under Section 2, IDA Overall l Approach, will be used as the basis for the structural review. Prior to i initiating an examination of the building designs, a review of design

basis documents used by the civil / structural groups will be performed.

l The FSAR, structural design criteria, and selected key specifications and procedures will be reviewed for:

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• Consistency between the FSAR and key design basis documents.

• Consistency between design basis documents.

• Reviewer familiarizing with project commitments and require-i ments (both regulatory and project unique).

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Upon completion of the basic review of the design basis documents, a com-prehensive design evaluation of the structures or structural elements including materials and installation in the buildings will be initiated.

It is anticipated that the review will consist of, but not be restricted to, the following items. The sampling of these items will be based on different types of documents and degree of importance for supporting the CHR mode.

• Determine consistency between the FSAR and other documents such as Regulatory Guides, design criteria, procedures, and d rawings .

• Evaluate calculations for the structural analysis and design of the buildings and/or structural elements within the buildings including items such as structural concrete, structural steel, floors, walls, base plates and anchor bolts for equipment and pipe supports, and containment and other peney e nions. This will include appropriate dynamic analysis.

• Structural interface with other disciplines with respect to design data (loads, pressure, temperature, etc) transmittals for structural analysis.

• Consistency and adequacy checks between specifications such as structural steel, concrete testing services, and shield doors including associated A/E and vendor's drawings and other design documents.

• Implementation of structural load verification for structural members.

• Analysis and design of raceway supports.

• Technical adequacy of design changes.

• Evaluation of the resolution of selected industry issues appli-cable to the project.

A site walkdown will be performed as part of the ICA to evaluate certain attributes such as masonry walls requirements and edequacy of seismic l shakespace between buildings and between buildings and adjacent structur-l al elements.

l l 4. INDEPENDENT CONSTRUCTION ASSESSMENT (ICA) OVERALL APPROACH l The assessment will be conducted in conjunction with a technical assess-i ment of the CHR mode systems design and will cover the associated Unit 2 systems, components, and structures. The systems, components, and struc-tures will be examined to determine whether:

• The as-constructed condition reflects the design as shown on drawings and specifications.

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• As-built documentation used for design verification purposes (e.g., as-built piping drawings / isometrics) accurately reflect the as-built conditions.

The assessment will encompass review of specific areas, equipment, and components such as:

• Mechanical (piping) construction

• Wt1 ding and nondestructive examination

• Electrical and instrumentation construction

• Civil / structural construction

• Quality assurance and quality control

• Procurement activities The specific areas, equipment and components examined will be based on an appropriate sample selected from drawings, equipment lists, valve lists, and other current design documents. The samples selected will be coordi-nated with the design assessment team. Simil.a rly , the results of the examinations, particularly deficiencies, will be provided to the IDA for evaluation of possible design implications.

The review will include as appropriate, but is not limited to, verifica-tion of:

• Installation and construction of essential equipment / system characteristics

• As-built configuration utilized in design verification

• Adequacy of welded and mechanical joints

• Location, orientation, and configuration

• Cable routing and terrrination

• Separation and clearances The primary focus will be on hardware installation and construction qual-ity. Hardware will be inspected to determine if it meets the installa-tion requirements in design documents. When deficiencies are identified, related program controls will be reviewed to determine if the controls are adequate. When appropriate, the assessment will be expanded horizon-tally beyond the sample system boundaries as necessary to establish the limits of the concerns.

Additionally, basic programs such as those for procurement, qualifica-tion / certification, noncon fo rmance s and corrective actions will be re-viewed to determine if they meet regulatory requirements and PECo commitments.

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5. ICA APPROACH BY DISCIPLINE 5.1 Mechanical Construction A sample of heat exchangers, pumps, pipe, strainers, pipe supports, and other equipment associated with the CHR function will be inspected for conformance to design drawings, specifications, and site procedure re-quirements. Similarly, coatings, insulation and other material which could interact with the CHR function will be inspected. Items to be ver-ified include material traceability, identification, location, orienta-tion, bolting, dimensions, supports, in place storage and maintenance, and design change control.

5.2 Welding / Nondestructive Examination The welding and NDE programs will be reviewed to determine if they comply with regulatory requirements, industry standards, and PECo commitments.

This review will include parameters relative to weld rod control, weld procedures, welder qualification, NDE procedure qualifications, and NDE personnel qualifications. An appropriate sample of CHR mode system welds will be visually examined. Material traceability, welder and examiner personnel qualification, and NDE records including radiographs for the welds will be reviewed.

5.3 Electrical and Instrumentation Construction A sample of electrical components associated with CHR mode systems begin-ning with the emergency diesel generators through each applicable level of electrical distribution (e.g, 4 kV ac, 480 V ac, 120 V ac, 125 V de, 48/24 V de) will be examined. The components plus the cable, cable ter-minations, and raceway will be included. Also, certain critical instru-mentation will be included. Acceplance criteria will be taken from project apecifications, drawings and procedures, as well as from recog-nized industry practices. Such things as receipt inspections, storage, handling and installation, cable pulling, maintenance, testing, design change control, and documentation will be reviewed as necessary for both inprocess and previously installed items.

5.4 Civil / Structural Construction A sample of structural installations (structural concrete / grout, soil placements, embedments, erected structural steel, and masonry construc-tion) used to support or house the CHR mode systems will be examined for fulfillment of procurement and erection specification requirements. Com-pleted and/or in-process work, design change control, and inspection ac-tivities will be reviewed to assure compliance to specifications, drawings, and industry codes and standards.

5.5 Quality Assurance and Quality Control The Quality Assurance (QA) Program applicabla to the construction of CHR mode of RHR system operation will be reviewed to ensure consistency with SAR commitments. A sample of documentation will be reviewed and person-nel interviews conducted to ensure comprehensible and technically correct 1852-18138-HC3 13 Rev. O, 05/27/88 a

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inspection procedures, adequacy of inspector training and qualification, and freedom of inspectors from harassment. Nonconformance and design change mechanisms will be checked to assure their adequate description in procedures with resultant changes appropriately approved, effectively transmitted to the field, and accomplished. Corrective action systems including the audit program will be reviewed for proper tracking and closcout, trending, and upper management involvement. Finally, the con-struction completion process for CHR will be checked for accuracy of sys-tem tests, transition to the operational mode, and appropriate transfer of design control from the construction to the operating organization.

5.6 Procurement / Receipt / Storage Program definition will be evaluated with specific emphasis on fulfill-ment of PECo commitments to regulatory guidance, industry codes, and standards. The effective integration of procurement, receipt, and stor-age activities will also be verified. A sample of CHR mode system hard-ware in receipt and storage areas as well as those items installed in the plant will be assessed for adequate source control, handling /identifica-tion / traceability from fabrication through installation, upgrading of commercial grade parts, and compliance to preventive maintenance requirements.

6. ASSESSMENT TEMi The team will function under the direction of the SWEC Quality Assurance Department with reporting authority to the SWEC Vice President, Director of Quality Assurance. Should PECo personnel be assigned for the assess-ment, they will report to SWEC supervision for the duration of this as-signment. The SWEC team member, will be experienced technical personnel.

Team members are identified on Attachment 1.

7. TEAM PREPARATION

• Review applicable FSAR sections, NSSS documents, and related project procedures and technical criteria to become familiar with system function, design basis requirements, and project-specific consider-ations. Identify and assemble key documents necessary for the aadit (e.g., P& ids, Design Criteria, etc).

• Determine status of design documents (Example: Determine what pipe stress analysis problems have been stress reconciled).

• Discuss and establish means to evaluate interface between disciplines.

• Refine scope and approach to indicate discipline-specific scope and approach, specific interfacing systems, and structures to be evaluated.

• Refine scope to account for results of previous evaluations of Lim-erick Units 1 and 2.

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• Prepare discipline task sheets as necessary to address general prep-aration requirements, refined scope, and any additional requests by team members.

• Dtvelop IDA assessment plans specific to the discipline and areas to be reviewed. The review plans are to reflect the scope of the audit and the means for evaluating discipline interface and identify the detailed attributes that are to be pursued during the review.

• Orient the team members with the Limerick 2 organization and pro-grams and the concept and scope of the assessment.

• Review recent NRC inspection reports, applicable construction and inspection procedures, and general installation specifications and any reported assessments.

• Review scoping information (system diagrams, equipment lists, iden-tification of system boundaries, components, structures, etc) and the specific applicable installation instructions to determine hard-ware requirements.

• Develop ICA detailed review plans. Criteria shall be based on in-stallation requirements, experience of the team members and an anal-ysis of CAT inspection findings at other nuclear plants.

8. PERFORMANCE OF ASSESSMENT To facilitate the review of the system and evaluate engineering activi-ties, a site walkdown will be conducted in conjunction with the ICA.

Incomplete installation will be noted and controls on remaining work evaluated for impact on assessment results.

The team members will annotate the review plans to specifically and com-pletely identify the documents / designs reviewed or hardware inspected and to document, in detail, the review for each attribute. Any support docu-mentation and notes will be included as an attachment to the review plans. Review plans shall be utilized as a guideline to ensure all nec-essary activities are reviewed and as the principal method of collecting the results.

Engineering or design concerns will be forwarded to the design assessment team for investigation, reporting, and followup as appropriate. The con-struction assessment team will investigate, report, and follow up QA/

Construction concerns received from the design assessment team.

During the performance of the assassment, the team is to inform the pro-ject (A/E or PECo) of potential concerns or requests to provide needed information using an Action Item form. The project engineering staff will be expected to promptly respond to each Action Item providing the information requested or a response to the potential concern. A status log is to be maintained to track and account for all Action Items. (See Attachment 2 for guidance in preparing Action Items.)

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If the additional information received from the A/E is sufficient to re-solve the action item, it will be considered resolved. All action items will be retained and become part of the final IDCA Report. If the action item is not resolved by the additional information, it will be trans-ferred into an Observation Report. (See Attachment 3 for guidance in preparing Observation Reports.) Observation Reports can be written di-rectly or can be a summary of unresolved Action Items.

9. EVALUATION OF RESULTS The observations from the assessment will be summarized and grouped to dete rmine the overall significance and impact, when viewed as a compos-ite, that these observations have on the adequacy and implementation of the design and construction process.

The observations will be assigned categorized by type. These categories will be selected as representing specific activities or functions and will provide a framework for judging the adequacy of the design and con-struction process. Listed below are examples of observation types which will form the basis for the categorization.

1. Design Deficiencies

2. Design Process or Method Inadequate

3. Inadequate Interface Control

4. SAR Related Deficiencies

5. Inadequate Design Corrective / Preventive Actions

6. Design Change Deficiencies

7. Document Control Deficiencies

8. Personnel Qu:lification/ Training Deficiencies

9. Test Requirements or Implementation Deficiencies

10. Records Retention Deficiencies

11. Corrective Action Deficiencies

12. Electrical and Instrumentation Construction Deficiencies

13. Mechanical Construction Deficiencies

14. Welding and Nondastructive Testing Deficiencies

15. Civil and Structural Construction Deficiencies

16. Material Traceability, Storage, and Maintenance Deficiencies

17. Quality Assurance Deficiencies To facilitate the evaluation, the data base for these observations will also include the following type of information:

• Responsible Discipline

• Document Type

• Cause

• Extent of Condition

• Corrective Action

• Preventive Action After the observations have been categorized and grouped by discipline, they will be reviewed and analyzed. The rationale for eliminating any observations (e.g., minor, editorial, etc) from further consideration will be documented. The remaining observations will be used to evaluate the adequacy of the overall Limerick 2 design and construction process.

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10. REPORTING l 1

At the conclusion of the assessment, an IDCA report will be prepared to I address the following: 1

1. Introduction

2. Purpose

3. Scope

4. Summary of Results and Overall Conclusions S. Assessment Observations '

6. Summary by ' scipline (both IDA and ICA)

Each team member is specifically responsible for analyzing any assessment observations and preparing the summary section for the discipline.

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Page 1 of 4 ATTACHMENT 1 LEAD PERSONNEL FOR IDCA TEAM The IDCA personnel have been organized into two teams for the IDA and ICA efforts, respectively. The IDA and ICA organization charts included in this section identify the principal participants and their respective functions. This attachment provides a brief summary of the key personnel and their related experience. '

Program Manager Mr. H. E. Daniels has recent management experience at the Clinton Power Station. As a Stone & Webster employee, Mr. Daniels was loaned to Illi-nois Power Company from March 1984 through July 1986 and functioned as their Project Manager during the final stage of construction, startup, and operations. During this period, the Clinton Proj ect successfully completed an NRC Construction Assessment Team (CAT) inspection and an Independent Design P.eview (conducted by Bechtel Power Corporation on the Clinton Power Station architect / engineer Sargent & Lundy).

IDA Team Assistant Program Manager - Mr. D. J. Wille is a registered Professional Engineer with over 25 years of engineering, design, and management expe-rience in the nuclear power industry. Mr. Wille recently was assigned to the construction assessment programs at both Braidwood Nuclear Power Plant and Comanche Peak Steam Electric Station, providing an engineering review of the approach, results, and final reports. In the fall of 1987, he was Task Leader for an independent review of nuclear and mechanical calculations for the Watts Bar Nuclear Power Plant and Sequoyah Nuclear Plant. He was also the Lead Engineer for design verification of modifi-cations and changes to the diesel generator system for the Clinton Power Station.

Mechanical Systems Lead - Mr. G. E. Hirst is a registered Professional Engineer with over 15 years of engineering experience, including 12 years on the River Bend Station project. Mr. Hirst also has participated in the independent review of component reclassifications in support of the equipment qualification program for the Fermi 2 Power Plant.

Mechanical Components Lead - Mr. N. S. Motiwala is a registered Profes-sional Engineer with over 20 years of engineering experience, including 10 years on BWR plants at River Bend Station and Nine Mile Point Nuclear Station. While assigned as Lead Engineer to the River Bend project, the NRC conducted an integrated design inspection, and Mr. Motiwala inter-faced with the NRC audit team in the engineering mechanics area.

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Electrical Lead - Mr. E. F. Heneberry is a registered Professional Engi-l neer with over 20 years of engineering experience, including 15 years on nuclear power plant projects. In addition, Mr. Heneberry has been the Lead Electrical Engineer on the independent design verification reviews l for design adequacy for the Fermi 2 Power Plant and Diablo Canyon Nuclear i

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Page 2 of 4 Power Plant. At Diablo Canyon, an onsite inspection was performed to verify selected equipment and systems. He also provided electrical re-view and assistance to the client's Readiness Review Program for engi-neering, design, and construction of the Vogtle Station.

Instrument and Controls Lead - Mr. J. C. Bisti has over 20 years of engi-neering experience, including a total of 10 years with increasing respon-sibilities on the River Bend and Nine Mile projects. While assigned as Proj ect Engineer to the River Bend project, the NRC conducted an inte-grated design inspection for the engineering effort. Mr. Bisti repre-sented the project at all status and final review meetings with the NRC and reviewed all written responses by the project to issues raised during the inspection.

Civil / Structural Lead - Mr. B. E. Ebbeson is a registered Professional Engineer with over 15 years of engineering experience, including 11 yea m on several nuclear projects with increasing responsibilities. Mr. Ebba-son is currently the Lead Engineer responsible for the independent and detailed technical review of all civil / structural calculations for the Browns Ferry Plant for Tennessee Valley Authority. He also participated in reverification of the final design in the civil / structural area for a nuclear power plant for the Washington Public Power Supply System.

Coordinator - Mr. J. R. Kirby is a Certified Lead Auditor and has over 15 years of experience in the engineering industry. For the past 5 years, Mr. Kirby has been responsible for quality assurance audits of engineering and design activities for various Stone & Webster nuclear power plant projects. In particular, he has been an Audit Coordinator for the pipe stress / pipe support requalification effort performed by Stone & Webster for the Comanche Peak Steam Electric Staticn.

ICA Team Assistant Program Manager - Mr. E. B. Fleming has been at Stone & Webster for over 15 years. For the last 8 years, Mr. Fleming has managed the quality assurance audit program and conducted assessments for various utilities. He managed an audit at Millstone Nuclear Pcwer Station -

Unit 3 to provide a further evaluation of INPO construction assessment findings; managed the construction portion of a Stone & Webster "vertical r slice" audit of the RCIC system at Nine Mile Point - Unit 2 conducted l under NRC overview to obviate the need for an NRC IDVP; and was a member I of the Niagara Mohawk Power Corporation / Stone & Webster team providing response and corrective action for the Nine Mile Point CAT inspection.

l Coordinator - Mr. R. B. Avrich has 19 years of experience at Stone &

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Webster in quality assurance, shop inspection, and auditing. Mr. Avrich l is a Certified Lead Auditor and is certified in NDE processes as well.

l Welding and Nondestructive Examination Lead - Mr. B. C. Jersild has over 20 years of experience in quality assurance and nondestructive examina-l tion. Mr. Jersild has Level III certifications in liquid penetrant, mag-netic particle, and radiographic testing and is a Certified Lead Auditor.

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Page 3 of 4 He is a member of the ASME B&PV Committee on radiography. At Nine Mile Point - Unit 2, he was responsible for preservice (ASME XI) inspection activities.

Mechanical /HVAC Lead - Mr. W. W. Orr has 13 years of experience in nucle-ar quality assurance. His experience includes inspection and supervision of inspection activities related to the assembly and installation of pumps, motors, and HVAC and the development and supervision of construc-tion surveillance programs. Mr. Orr was on the Stone & Webster response team for a CAT inspection at Millstone 3.

Civil / Structural Lead - Mr. J. C. Thompson has over 25 years of experi-ence in civil / structural engineering and quality assurance. He has been assigned as Superintendent of Quality Control at four nuclear power sta-tions under construction. He managed teams for design verification walk-down reinspections at Davis-Besse Nuclear Power Station, reinspection of installed and previously accepted work at Braidwood, and independent overview of the Construction Completion Program at Midland Nuclear Power Station. These assignments were subject to high NRC visibility.

Electrical / Instruments and Controls Lead - Mr. F. N. Morrissey has over 22 years of experience at Stone & Webster. During this period, Mr.

Morrissey has served as a Design and a Construction Engineer, Construc-tion Supervisor, and Assistant Project Engineer, all with responsibili-ties in the electrical area on eight nuclear and fossil power plants. He also served as QA Program Manager for Beaver Valley Power Sta-tion - Unit 2, where he was responsible for coordinating NRC inspection responses.

Piping / Piping Supports Lead - Mr. J. Crossland has over 20 years of nuclear construction inspection experience. Currently as Inspection Supervisor, he has worked on nine nuclear power plants including a period on the construction completion team at Midland. His inspection exper-ience has been concentrated in piping, piping supports, and associated welding.

Procurement / Receipt / Storage - Mr. R. J. Scannell has over 12 years of quality assurance experience. This experience includes inspection and testing in the civil / structural area, auditing of construction quality p rog rams , and program reviews and surveillances for the TVA restart ef-fort at Sequoyah. During the latter years of construction of Mill-stone 3, Mr. Scannell served as the QA Project Manager, in which capacity he was a member of the CAT Response Team.

QA/QC Lead - Mr. F. J. Qualter has 28 years of experience in the quality assurance and reliability field in the nuclear shipbuilding, computer, and construction industries. Mr. Qualter has developed and implemented quality assurance programs and procedures in each of these industries.

He is currently assigned as Assistant Manager of Procurement Quality As-surance. He has developed audit programs and conducted audits both of construction and manufacturing quality programs. He also has performed assessments of various utility and governmental programs.

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Page 4 of 4 IDCA TEAM HEMBERS Title No. of People IDCA Program Oversight Committee 4 J. E. Huston, Chairman Program Manager 1 H. E. Danie'Is, Jr.

Coordination / Administration 2 W. Baranowski Clerical 2 -

Subtotal 9 IDCA - Design Review Asst. Program Manager 1 D. J. Wille Mechanical Systems 3 G. E. Hirst Mechanical Components 3 N. S. Motiwala Electrical 2 E. F. Heneberry Instrument & Controls 3 J. C. Bisti Civil / Structural 2 B. E. Ebbeson Coordinator 1 J. R. Kirby Clerical 1 -

Subtotal 16 IDCA - Construction Review Asst. Program Manager 1 E. B. Fleming Welding and NDE 2 B. C. Jersild Mechanical /HVAC 1 W. W. Orr Civil / Structural 1 J. C. Thompson Electrical /I&C 2 F. N. Morrissey Piping / Pipe Supportr: 3 J. Crossland Work Controls 1 R. J. Scannell QA/QC 1 F. J. Quilter Coordination 1 R. B. Avrich Clerical _1 Subtotal 14 i

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Page 1 of 1 ATTACl&fENT 2 PREPARATION OF ACTION ITEMS An Action Item can be generated to identify potential concerns or to request information. It is difficult to define precise criteria to apply in determining if an Action Item should be generated. Three considera-tions are: significance of individual discrepancies, number of discrep-ancies, and the urgency of needed information by the assessment team member.

An Action Item is to be written when one or more of the following needs exists:

1. Need to identify a technical concern.

2. Need to identify a potential technical concern and there is no information readily available to substantiate or alleviate the concern.

3. Need to identify a significant program aspect or practice that is, or appears to be, incorrect or inadequate.

4. When it is deemed necessary for the project to investigate to determine cause and extent of discrepancies.

5. When it is deemed appropri tc to evaluate the Project's pro-posed actions to correct discrepancies and prevent recurrence.

It is generally not necessary to generate an Action Item if a minor dis-crepancy is observed and the discrepancy appears to be isolated or ran-dom. An Action Item could be used, however, if deemed necessary to track correction of the discrepancy. Several minor discrepancies, however, could generate an Action Item.

NOTES

1. Review plans must indicate all discrepancies observed regardless of significance or number and even if an Action Item was not gener-ated. The Assistant Program Manager will make tne final decision for when an Action Item is written. The decision will be based on the above written guidance, as well as objectivity to the issue in question at that time.

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2. Generation of, and obtaining a response to, an Action Item does not necessarily negate the need for an Observation Report.

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Page 1 of 3 AT1ACHMENT 3 APPROACH TO PREPARING AN OBSERVATIO(REPORT INTRODUCTION The main purpose of the assessment is to identify and resolve both indi-vidual and any "systematic" or "generic" problems. This requires obser-vation reports (OR) to be written in a manner such that overall assessments are presented, problems are identified, and their root causes can be addressed.

To maintain credibility and impact, ors must be valid and demonstrate good judgment. It is difficult to define precise criteria to apply in determining if an OR is necessary or warranted. However, two main con-siderations are significance of individual deficiencies and number of deficiencies.

General Examples:

1. If a minor deficiency is observed in a document and was not observed in other documents of that type, an OR probably is not warranted.

The deficiency could be corrected during the assessment or marked for future correction at next revision.

2. If a large number of minor deficiencies are observed in several doc-uments, an OR is probably warranted.

3. A single deficiency of relative significance if observed in only one document may warrant an OR, even if apparently isolated, in order to assure the deficiency is corrected. (Action to prevent recurrence may not be necessary, however, if deficiency is of isolated nature.)

Specific Examples:

1. Logic Diagrams and Logic Descriptions are reviewed. They are found to be clear, complete, consistent with P& ids, elementaries, and technically adequate. Some of the Logic Descriptions contain a few minor "typos." Should an OR be written? Probably not.

2. Several mechanical calculations are reviewed. Calculations are clear and complete, appropriate methods are used, are technically adequate. In one calculation, an input value was incorrect, appar-ently due to a transposition error. Results would not be affected.

Another calculation was not marked with the QA Category, but was independently reviewed. Should an OR be written? Probably not.

3. St ructural calculations are reviewed. Calculations are found to be adequate except that in one calculation an input value is incorrect.

The results are not affected. The incorrect values appear to result from failure of another discipline to provide revised in fo rma tion.

Time did not permit further investigation. Should an OR be written?

Probably.

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NOTE: Assessment plans musr. Indicate all deficiencies observed regardless of significance or number. For any deficiency not included in an OR, it must be evident why an OR was not written, e.g., minar, isolated, or corrected during the assessment.

If it is decided that an OR is probably warranted, it is prepared in ac-cordance with the next section.

OBSERVATION REPORT PREPARATION An OR is usually presented in two basic parts: the "Description of Condition (s)" and the "Details." In nearly all cases, it is the "De-scription of Condition (s)" that should be addressed by audited organiza-tions in their response to the observation. Therefore, assessment results must be evaluated, logically grouped, reevaluated, and a conclu-sion or summary presented. The details or supporting evidence then follows.

Preparation ei an observation is more of a thought process than a mechan-ical exercis . The following is an attempt to describe that process.

1. List all the deficiencies.

2. Determine if there is a commonality among some or all of the items listed. Can the items be logically grouped or placed in categories?

Possible groupings ar.4 categories:

• By element (procedures, control, review or approval, documen-tation, design consistency, technical adequacy).

• "Probable cause." For example: lack of thorough review, mis-understanding of requirements, etc.

• Consequence. For example: various distribution problems could result in personnel working with out-of-date information.

• Other

3. Prepare a rough draft OR (handwritten) using the outline below.

4. Read the draft as objectively as possible. Is it logical? Can an overall conclusion be reached? Should this conclusion be stated in the description of condition (s)? Is the English, spelling, etc, correct?

OBSERVATION REPORT OUTLINE Description of Condition Categories need not necessarily be presented in the order shown below.

In fact, it would be unusual for an OR to contain ali categories.

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1. Describe the basic failure af the system or activity if applicable or describe the overall conclusion, c.g., "the design change system does not provide complete control'of design changes".

2. Summarize the deficient elements (cr subelements). Sitice most peo-ple will not be fmniliar with element definitions, include a brief definition or examples, e.g., "... calculations are incompletely documented (c'ethods and sources of inpu' not identified, ... etc)."

3. When there is strong supporting evidence, state what the observed deficiencies indicate. That is, what is the "probable cause."

Sometimes the cause is implied and need not be stated.

Example: "... the improper application of the analysis method indi-cates a lack of guidance to the preparer ..."

4. Indicate the consequences of the deficiencies. (As stated above,;

this may be implied or obvious and need not necessarily be stated. 1 Improper application of method could, obviously, affect technical adequacy).

Example: "Failure to distribute results of revised calculations could lead to ..."

5. The reviewer may (in some cases) provide guidance on the boundaries for determination of '.he extent of conditions.

6. If any observations are recurrences of earlier findings on the ac- ,

tivity being assessed, this fact should be emphasized in the OR.

1 Details (Supporting Evidence)

1. Details should be grouped and sequenced to be consistent with the Summary where practicable.

2. Some type of qu:.atitative comparison should be provided where appro-priate, e.g., fifteen <if the twenty selected from the list were not included in ...".

3. Provide detail, e<planatioa, background, etc. Do not force people to "read between the lines." Take care to provide information. not .

just more words. .

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l l ATTACIUiENT 4 PROTOCOL GOVERNING CONDUCT OF

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INDEPENDENT DESIGN AND CONSTRUCTIONi ASSESSMENT (IDCA) LIMERICK UNIT 2

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In the conduct of the IDCA by Stone & Webster Engineering Corporation g

j (SWEi;), the following protocol shall be adhered to:

1. SWEC may request documentation material, meet with and inter-view individvals, conduct telephrine conversations, or visit the Site, PECo, Bechtel, General Electric, or other contractor's 1 offices to obtain information without prior notificat!on of the NRC or other outside organizations. Communications and trans-mittals of information shall,,however, be dornmented and such documentation shall be maintair.ed in a locatien accessible for NRC examination. Communications between the SWEC and PECo, solely with respect to financ U i" and administrative aspects of the IDyi contract, are outsik the scope of this protocol.

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2. Observations, reports, evaluations and all exchange of corre-spondence, including draf ts, , between SWEC and PEco (including its contractors and subcontractors) will be submitted to the NRC at the same time as they are submittedi'.o PEco. In addi-tion, SWEC shall maintain IDCA filles in such condition as to be ,

prepared for NRC examinati(r at any time throt.ghout the ascess-ment, including backup Ateumpination in suyport of observa-tions, evaluation of proposed resolutions, recommendations, trend analysis, etc.

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3. If SkTC wishes to discuss' with' PECo subnantive matters related to information obtained,i to provide an interim report to PECo, or'to discuss its findings or conclusions with PEco in advance N completing its report, or if PEco desires such communica-etion, such discussions . shall be accomplished in meetings that s

are open to NRC participation. In this regard, PEco sball pro-vide a minimtua of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> advance notice to the NRC of any such meeting. Transcripts or written minutes of all such meet-ings should be prepared by the organization requesting the meeting and provided to the NRC in a timely manner.

4. Once an Action Item (AI) is issued by SWEC, the AI will be as-signed c number and will remain a part of the IDCA report, re- .

gardiess of its final resolution. An AI which is satisfac-torily resolved throu h additional review or analysia by the A/E will be considered resolved. An Observation Report (OR) will be initieted for each AI which is not satis ?actorily re!.olved . Copies of all Ah 411 ba forwarded to PECo and the NRC, if requested.

5. Following the issuance of an OR, PECo and Bechtel ,or other ra=ponsible PECo contractor) may discuss the observa. tion with SWEC to obtain further clarification and addition:.1 information to allow a full understanding of the observation and its basis.

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s i In these instances , the NRC will be notified 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in ad-vance of telephone calls and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in advance of nieetings. ' ',

Such communications or meetings shall be documented. Copies of such dveumentation shall be maintained accessible- for NRC and PECo examin'ation.

6. Following the issuance of an OR, should it be necessary for PECo and Bechtel (or other t'esponsible PECo contractor) to dis-cuss possible or proposed resolutions or actions with SWEC, the NRC will be notified 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of telephone calls and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in advance of scheduled meetings to allow the op-portunity for . participation. Such communications or meetings shall be documented. Copies of documentation.shall be provided to the NRC and PECo in a timely manner, including copies of the Observation Reports discussed.

7. To support the NRC independence criteria, each member of the IDCA team will be . required to execute an IDCA agreement and an IDCA questionnaire. Copies of ;hese agreements and question-

, naires are attached. Also, any full-time ' PECo employees as-signed to the IDCA team will be under the direction of SWEC and will be required to taecute these documents in order to ensure objective conclusions and prevent compromising the pur-poses of this assessment.

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LIMERICK IDCA PERT 0NNEL QUESTIONAIRE After first being duly sworn hereby de-poses and says: (print or type name) j 1. I have no previous involvement with the Limerick Project, except as noted on the reverse side, t

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/ 2. I have not previously been hired by PECo, Bechtel, General Electric or a Limerick 2 site contractor to perform similar audits, except as noted on the reverse side.

3. I have not been previously employed by PECo, Bechtel, General Elec-tric, or a Limerick 2 site contractor, e.: cept as noted on the re-verse side.

4. I do not own or control stock of PECo, Bechtel, General Electric or a Lim 2 rick 2 site contractor, except as noted on the reverse side.

5. No member of my present household is employed by PECo, Bechtel, Gen-eral Electric, or a Limerick 2 site contractor, except as noted on the reverse side.

6. None of my relatives is employed by PECo, Bechtel, General Electric or a Limerick 2 site contractor, except as noted on the reverse side.

7. g I havi not bee . offered future employment by PECo, Bechtel, General Electric or a Limerick site contractor, except as noted on the re-verse side.

I hereby gaffirm that the above is true and correct to the best of my knowledge r

~I (signature) (date) l Subscribed and sworn to before me on this day of , 1988.

My commission exaires:

Notary Public 1

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AGREEMENT CONCERNING INDEPENDENT DESIGN CONSTRUCTION ASSESSFENT OF LIFERICK 2 I (print or type name) hereby agree that:

1. I will notify the Program Manager if during the term of this project I, or any member of my immediate family (parents, spouse, children and grandchildren) acquire any financial in-terest in Philadelphia Electric, Bechtel, General Electric or any site contractor at the Limerick-2 Power Station.

2. If I identify what I believe to be a potential discrepancy hav-ing the potential for a significant safety impact, I will imme-diately notify the Assistant Program Manrger for further evaluation.

3. I will treat all information revealed to me in the course of my work on this project as confidential and will not disclose it to others not involved in the project except as directed by the Assistant Program Manager.

(Signature) (Date) 1826-18138-HC3 Rev. O, 05/27/88