ML20080N888

Forwards Response to Items 1a & 1b,per NRC 840109 Request Re Independent Assessment Program Performed by Vendor.Response to Supplemental Info Supplied by

ML20080N888
Person / Time
Site:	Comanche Peak
Issue date:	02/16/1984
From:	Williams N CYGNA ENERGY SERVICES
To:	Burwell S, Schmidt H NRC, WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
83090.004, NUDOCS 8402220373
Download: ML20080N888 (5)

Text

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101 Cakfornia Street. Suite 1000, San Francisco CA 94111-5894 415:397-5600 DoqtET r(e. 50 IFVS February 16,1984 83090.004 Mr. S. Burwell Licensing Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20014 Mr. H. Schmidt c/o Westinghouse 4901 Fairmont Avenue Bethesda, Maryland 20814

Subject:

Request for Supplemental Information

Reference:

(1) NRC letter to R.J. Gary, " Independent Assessment Program (IAP)

Performed by Cygna," dated January 9,1984 (2) Cygna letter No. 83090.003 to S. Burwell and H. Schmidt, " Request for Supplemental Information," dated December 29,1983 Centlemen:

Please find enclosed our responses to items la and Ib requested by Reference (1). The remaining supplemental information requested by the NRC was supplied by Reference (2).

If you require additional information, please do not hesitate to contact either Ted Wittig or me.

Very truly yours, Y

Nancy H. Williams Project Manager NHW:pm

Enclosures:

Attachment A, Supplemental Information ec: See attachment 8402220373 840216 PDR ADOCK 05000445 A PDR San Francisco Boston San Diego Chicago Richla..d I L . .

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SitvlCE S Mr. S. Burwell February 16,1984 Mr. H. Schmidt Attachment Request for Supplemental Information Nicholas S. Reynolds, Esq. Mr. John T. Coilins Bishop, Liberman, Cook, Purcell & Reynolds U.S. NRC, Region IV 1200 Seventeenth Street, N.W. 611 Ryan Plaza Drive Washington, D.C. 20036 Suite 1000 Arlington, Texas 7601i Robert Wooldridge, Esq.

Worsham, Forsythe & Sampels Mr. Lanny Alan Sinkin 2001 Bryan Tower i14 W. 7th, Suite 220 Dollos, Texas 75201 Austin, Texas 78701 Mr. Hcmer C. Schmidt B. R. Clements Manager - Nuclear Services Vice President Nuclear Texas Utilities Generating Company Texas Utilities Generating Company 2001 Bryan Tower Skyway Tower Dallos, Texas 75201 400 North Olive Street L.B. 8I Mr. H. R. Rock Dallos, Texas 75201 Gibbs & Hill, Inc.

393 Seventh Avenue Peter B. Bloch, Esq.

New York, New York 10001 Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. A. T. Parker Washington, D.C. 20555 Westinghouse Electric Corporation P.O. Box 355 Dr. Walter H. Jordan Pittsburgh, Pennsylvania 15230 881 W. Outer Drive Ook Ridge, Tennessee 37830 Reneo Hicks Assistant Attorney General Dr. Kenneth A. McCollom Environmental Protection Division Dean, Division of Engineering Architecture and P.O. Box 12548, Capitol Station Technology Austin, Texas 7871I Oklahoma State University Stillwater, Oklahoma 74074 Mrs. Juanita Ellis, President Citizens Association for Sound Energy Stuart A. Treby, Esq.

1426 South Polk Office of the Executive Legal Director Dallas, Texas 75224 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. James E. Cummins Resident inspector / Comanche Peak Nuclear Mr. J. B. George Power Station Texas Utilities Generating Company c/o U.S. Nuclear Regulatory Commission Comanche Peak Steam Electric Station P.O. Box 38 Highway FM 201 Glen Rose, Texas 76043 Glen Rose, Texas 76043 Mr. David H. Wade Texas Utilities Generating Company

- 2001 Bryan Tower Dollas, Texas 75201

QUESTION A Question: Provide a more literal or exact description of the Cygna project conclusions presented on Pages 1.6 - 1.8.

Response: The Independent Assessment Program for CPSES ochieved four important objectives. The Program was able to :

e assess the adequacy of Texas Utilities' design control program; e ossess the adequacy of the design of an important safety related system; e to verify a selected as-built configuration; and e to verify implementation of selected elements of the design control program.

With respect to the first objective, we have concluded that:

e Texas Utilities' design control activities, as defined in their design control program documentation, satisfy the project commitments and standard practice; and e The design control activities of Gibbs & Hill satisfy the commitments of contract documents and the CPSES SAR.

The second objective has been met with the following conclusions:

e The review provided assurance that the design control process has been odequately implemented in the areas of criteria, procedures, interface control, and documentation.

e Selected elements of one safety related system has been adequately designed to perform its intended safety function in accordance with the project commitments, applicable code requirements and industry standards.

The third objective has been met with the following conclusions:

e An as-built walkdown of a completed system provided assurance that proper controls were in place to ensure construction was completed in accordance with the drawing, specifications and associated change notices.

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The fourth objective has been met with the following conclusions:

o Texas Utilities and Gibbs & Hill have adequately implemented control of design analyses (G&H only), design changes and interfaces in accordance with the design control commitments os delineated in their respective design program documentation.

This scope of work afforded Cygna on opportunity to examine, in detail, the CPSES design process on safety-related systems located inside the safeguards building and fuel building. It provided on in-depth look into activities related to mechanical (piping, pipe supports, equipment qualification), structural (cable tray supports) and electrical engineering disciplines.

This independent assessment program not only followed the flow of information from the preliminary design stage to the as-built condition, but it also assessed the occurocy and completeness of various elements of the design process. The results of our design control and technical reviews, integrated with the previous reviews of CPSES, provides sufficient evidence for Cygno to conclude that the overall design activities on CPSES are adequate and have been properly implemented.

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significance of design documents and hardware reviewed by Cygna rela-l tive to the systems and components evaluated and relative to the impact of design on safety.

Response: Cygna is confident in the results and conclusions stated in the Independent Assessment Program (IAP) report for the Comanche Peak project. This confidence is based on the following facts:

1) The review was performed in accordance with on opproved program plan, which included scope and methodology.

2) The review covered procedures and documents that guide the design process.

3) The review was exhaustive, in that it was multidisciplined, included a walkdown and involved a detailed review of design calculations.

Our philosophy in performing this LAP was defined in the objectives and methodology sections of the opproved Program Plan. That philosooh ir, based on a conviction tha the design adequacy of a defined work scope con be assessed by a team of experienced individuals working in accordance with formal review procedures. Cygna's procedures are fully described in the Program Plan and LAP final report. They are structured to ensure that individual and generic items having a potential impact on plant safety are identified and tracked to resolution. In each case, resolution meant verifying that a process was in place or being imple-mented which satisfactorily assured plant safety, it is also' important to note that the IAP covered design control procedures and general technical documents. Cygna reviewed all of these general guidance documents as related to the defined scope of work.

Based on the review methodology, the results of the broad review, and the detailed review of selected design elements of the Comanche Peak design, Cygno reached the conclusions stated in the IAP report.

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