ML20081C827

Suppl to Applicant 840203 Plan to Respond to Memorandum & Order Re QA for Design,Discussing ASLB 840224 Comments on Walsh/Doyle Issues Re Compliance W/Criteria I & Xvi. Certificate of Svc Encl.Related Correspondence

ML20081C827
Person / Time
Site:	Comanche Peak
Issue date:	03/13/1984
From:	Reynolds N BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
NUDOCS 8403150032
Download: ML20081C827 (12)

Text

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,,-? March 13, 1984 UNITED STATES'OF AMERICA NUCLEAR REGULATORY COMMISSION '84 U$ 4 NO .38 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD c r- C

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In the Matter of )

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TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 COMPANY, et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units.1 and 2) ) Operating Licenses)

SUPPLEMENT TO APPLICANTS' PLAN TO RESPOND TO MEMORANDUM AND ORDER (OUALITY ASSURANCE FOR DESIGN)

I. BACKGROUND On February 3, 1984, Applicants filed their Plan to provide the Board with information necesssary to satisfy its concerns regarding quality assurance for design. In that document, Applicants outlined an extensive program that entails the performance of several tests and analyses, the preparation of detailed testimony and documentary evidence, and the performance of an independent and reliable review of these efforts. The several issues that Applicants are addressing in the Plan envelop all significant issues raised by the intervenor and the concerns raised by the Board. Applicants also committed to retain the services of an independent expert to review the basic engineering principles being addressed in the Plan. Finally, Applicants have commissioned Cygna Energy Services to conduct an independent design review of the piping and pipe support systems on a segment l 8403150032 840313 PDR ADOCK 05000445 Q pop f-

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of the component cooling water system and all four main steam lines from the steam generators to the main steam isolation valves.

All of the work involving the specific issues to be addressed has commenced, and much of it is nearing completion.

Further, Cygna has initiated its independent design review and is well along in those efforts.

On February 24, 1984, at the close of the'last hearing session, the Board commented on Applicants' Plan (Tr. 10,337-39).

The Board first observed that the independent design review included in the Plan "apparently will be limited to the Walsh/Doyle aspects of the systems that will be examined" (Tr.

10,338). The Board also noted "that it would be helpful in the current plan if the independent design review organization, which Applicants propose to be Cygna, were to examine the question of compliance with Criterion XVI ana Criterion I [of Appandix B3 in the context of Applicants' response to the Walsh/Doyle concerns, in particular how the Applicants worked internally to determine whether there were discrepancies related to those concerns, whether those discrepancies were promptly resolved, what records were kept about those concerns, and generally the adequacy of the system under Appendix B with respect to the Walsh/Doyle concerns" (Tr. 10,338-39).

II. SUPPLEMENT TO APPLICANTS' PLAN In developing their Plan, Applicants had attempted to be responsive to the Board's request in its December 28, 1983 Memorandum and order for a Plan to af fect the Board's level of confidence in the design process for Comanche Peak. In particular, the Board suggested the need for an independent design review of [o]ne or more segments of important safety '-

systems," but also stated that "[1] esser measures might, possibly, succeed in affecting this Board's views . . . ."1/ In ,

our attempt to be responsive to the Board's request, Applicants proposed that the Plan which has been undertaken include detailed evaluations of the principal technical issues, and also the independent design reviews of the pipe support and piping systems for the component cooling water system and four main steam lines in the main steam system. The intent here was not to limit the independent reviews to Walsh/Doyle concerns (i.e., pipe support design), but also to include the design and design process for piping for the two systems being reviewed by Cygna. See Applicants' Plan at p. 8.

In any event, Applicants have reflected carefully and deliberately on the Board's comments discussed above. We appreciate the clarification made by the Board. As we understand ,

that clarification, the Board perceives two differences between the Plan and the suggestions made by the Board in its December 28 1/ Memorandum and Order (Quality Assurance for Design), December 28, 1983, at 73.

Memorandum and Order. These differences are that the independent design review work under the Plan will be limited to the Walsh/Doyle issues and that the question of compliance with Criteria I and XVI will not be addressed.

A. Programmatic and Implementation .

Reviews of Criteria I and XVI In order to be responsive to the Board's comments on February 24, 1984, Applicants have supplemented their Plan to address those comments. Specifically, Applicants have first requested Cygna to conduct full programmatic and implementation "3 views of Criteria I and XVI at Comanche Peak. This review will not be limited to the pending questions on pipe support design.

Rather, the review will address these criteria as they relate to the overall design activities at Comanche Peak, including pipe support design. With regard to criterion I, this review will a include, but not be limited to, the following attributes:

(1) responsibility for design activities and design reviews (independent design review):

(2) interface within the organization; (3) interface external to the organization:

(4) audit / surveillance independence:

(5) responsibility for corrective action responses:

(6) control of design process (design input / analysis):

(7) design verification performance / documentation; (8) design changes:

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(9) transmittal of design information and (10) organizational independence.

With regard to Criterion XVI, this review will include, but not be limited to, the following attributes:

(1) mechanisms to identify design deficiencies; (2) tracking of design deficiencies (3) methods for correcting / treating design deficiencies; (4) processing of reports required by 10 C.F.R. $50.55(e) and Part 21; j (5) auditing of' design activities; (G) surveillance programs: and (7) corrective action systems employed:

Through these full programmatic and implementation-reviews of Criteria I and XVI, Cygna will assess whether an appropriate design quality assurance program has been in place and e f fectively executed at Comanche Peak, including whether an effective and prompt method existed and functioned to identify and resolve design deficiences, and whether, in the case of significant conditions adverse to quality, a corrective action system existed and functioned to effect appropriate corrective actions.

B. Programmatic and Implementation Reviews of Elements of ANSI N45.2-11 As a next step, Applicants will request that Cygna conduct a j review to supplement its Independent Assessment Program by conducting full programmatic and implementation reviews of two additional elements of ANSI N45.2-ll (Design Input Document l

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Control and Design Verification Control). This will provide a basis for the supplementation of Exhibit 1.1 (Review Matrix) in the IAP such that every element in ANSI N45.2-ll for the implemention of Criterion III (Design Control) of Appendix B will have been fully reviewed for Comanche Peak by the CAT Report or ,

1 the IAP.

C. Multi-discipline Independent Design Review Finally, although the design reviews in the Plan were not limited to Walsh/Doyle 13 sues, in further response to the Board's comments on February 24, Applicants have requested that Cygna conduct a multi-discipline independent design review of the component cooling water system. Cygna has determined that this system is acceptable for such a design review. The specific portion of the system to be reviewed will be selected by Cygna.

This process of having Cygna establish the scope of the review is necessary to ensure the independence of the review.

As noted, the review will be a multi-aiscipline review. It will include reviews of mechanical equipment, electrical equipment, instrumentation and controls, and other related ,

1 structures, systems and components. Cygna also will conduct a field walkdown of the system within the selected review scope.

As modified with this major addition, Applicants' Plan now includes not only independent design reviews of the pipe supports i

L and piping of all four main steam lines from the steam generators to the main steam isolation valves, and a segment of the l

l component cooling water system (with a focus on, but not limited l

s to, the Walsh/Doyle concerns)r but also an expanded independent design review of all disciplines for the component cooling water system. We believe that this represents a responsible and comprehensive response to the Board's December 28 Memorandum and Order, and to the Board's clarification provided on February 24, calling for a plan to af fect its confidence in the design process for. Comanche Peak.

D. Procedures Governing Independent Design Reviews Cygna will employ the same methodology and retain the same independence, reliability and protocol that it utilized for the Independant Assessment Program, as reflected in the hearing record in February 1984. Cygna also has been made aware of the Board's suggestions in its December 28 Memorandum and Order (at 73-74) on independence, reliability, sampling, scope and the l ike .- Further, Cygna has been provided with copies of the comments on Applicants' Plan filed by the NRC Staff and the

~1ntervenor so that cygna may take due account of those comments.

III. SCHEDULE ,

Applicants acknowledged in thei: ' Plan (at p. 8) that the schedule set forth in the Plan is ambitious. We wish to reconfirm here our statament earli,er that while we intend to' process the activities called for in the,. Plan expeditiously, we

! are above: ail dedicated to full and careful development of all of L

the elements in the Plan. We intend to assure that no i

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participant in the Plan, including Cygna, is subjected to undue pressure to complete activities in accordance with a prescribed schedule where the quality of the result may be impaired.

We intend to present the results of these efforts in phases, commencing with the results of the efforts to address the various issues raised in the Plan (at pp. 5-7). We continue to be hopeful that these issues can be addressed in hearings commencing in April, but also recognize that a more realistic schedule might call for these issues to be addresced in hearings in mid- to late-May. We envisage that the Cygna review of the piping and pipe support systems for the component cooling water system and the main steam lines, and the Cygna reviews of Criteria I and XVI and of the two elements of ANSI N45.2-11, also can be addressed at that time or shortly thereafter.

We trust that the Board, when it establishes the schedule for hearings on these issues, will direct that all parties (including the Staff) be prepared to peccccd in accordance with that schedule. We believe that upon presentation of this information in the hearings, the Board' a concerns will be satisfied and the Board will have reasonable assurance that the design quality assurance program for Comanche Peak is and has been adequate.. Specifically, we believe that this will provide evidence of record sufficient to demonstrate that the quality assurance program functioned adequately with respect to the Walsh/Doyle allegations _and overall pipe support design.

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l Applicants' original Plan was designed to convince the Board that its impression with regard to the adequacy of the quality assurance program for the Walsh/Doyle allegations was not justified. Applicants believed that if the Board was so satisfied, then its expression of a lack of confidence in the design quality for the balance of the plant was also not justified. We expressed this view to the Board during the last hearing, and the Board concurred that if the evidence produced by Applicants' Plan demonstrates the adequacy of the design quality assurance program for the Walsh/Doyle allegations, then the Plan will be adequate to satisfy the Board's specific concerns on Walsh/Doyle issues and to erase the Board's concerns for the plant overall (Tr. 10,339-40).

Thus, we assume that if Applicants can successfully sustain their burden of proof on these issues, then there will be no need to hold the record open for litigation of the multi-discipline independent design review of the component cooling water system now being commissioned by Applicants. At that juncture, evidence of that review would be merely cumulative and-therefore unnecessary. See FED.R.EVID. 403. It follows that hearings to present that evidence would be unwarranted. Accordingly, we are hopeful that the Board will provide guidance, at an appropriate time following the presentation of evidence on all but the t

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5 multi-discipline independent design review, concerning whether the record need be held open for receipt of evidence on that review.

Respect ul submitted, Nichola( S ./ teynolds Counsel ifo# kpplicants l

BISHOP, LII RMAN, COOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9818 March 13, 1984 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE A'iOMIC SAFETY AND LICENSING BOARD In the Matter of )

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TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 and COMPANY, _et _al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Supplement to Applicants' Plan To Respond To Memorandum And Order (Quality Assurance For Design)," in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class, postage prepaid, this 13th day of March, 1984:

Peter B. Bloch, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. William L. Clements Dr. Walter H. Jordan Docketing & Service Branch 881 West Outer Drive U.S. Nuclear Regulatory Oak Ridge, Tennessee 34830 Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom Dean, Division of Engineering Architecture and Technology Stuart A. Treby, Esq.

Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S. Nuclear Regulatory Mr. John Collins Commission Regional Administrator, Washington, D.C. 20555 Region IV U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Panel 611 Ryan Plaza Drive U.S. Nuclear Regulatory Suite 1000 Commission Arlington, Texas 76011 Washington, D.C. 20555

2-Renea Hicks, Esq. Mrs. Juanita Ellis Assistant-Attorney General President, CASE Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O. Box 12548 Capitol Station Austin, Texas 78711 Lanny A. Sinkin 114 W. 7th Street Suite 220 Austin, Texas 78701 5

William A. Horin' '

cc: Homer C. Schmidt Robert Wooldridge, Esq.

David R. Pigott, Esq.

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