ML20098E932

Confirms Util Position Re State of Il 840905 Comments on Independent Design Review Program Plan for Facility

ML20098E932
Person / Time
Site:	Clinton
Issue date:	09/27/1984
From:	Geier J ILLINOIS POWER CO.
To:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8410020137
Download: ML20098E932 (6)

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ILLINDIS POWER COMPANY IP 500 SOUTH 27TH STREET, DECATUR, ILLINOIS 62525 September 27, 1984 Mr. James L. Milhoan Section Chief,. Licensing Section Quality Assurance Branch Office of Inspections and Enforcement Mail Stop EWS - 305A U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Milhoan:

Re: . Illinois Power Company Clinton Power Station Independent Design Review By letter dated September 5, 1984, Mr. Samelson, Assistant Illinois Attorney General, submitted to the NRC Illinois' comments on the Independent Design Review (IDR) Program Plan for the Clinton Power Station (CPS) and, on the same day, transmitted those comments to our Illinois Power Company's (IPC) counsel with the suggestion that a response from IPC could be helpful. On September 12,-1984 Mr. Edwin Reis, Assistant Chief Hearing Counsel, responded to Mr. Samelson stating that Illinois' comments raise almost wholly technical matters and he had forwarded Illinois' comments to the Office of Nuclear Reactor Regulation.

The NRC and IPC essentially responded to Illinois' comments at the meeting held on August 31, 1984. The responses which follow are intended to confirm in writing IPC's position:

1. The IDR Program Plan states that the purpose of the IDR is to provide additional assurance that the design of the CPS meets licensing requirements (p. 1), and Task 2 specifically refers to " licensing commitments and safety-related design requirements" (p. 11). Identification of commitments in the FSAR is specifically mentioned in Task 1 (page 9) and elsewhere. These provisions, among others in the IDR, make clear that Bechtel will review the design of the CPS for compliance with the pertinent regulations and the FSAR. The review of the design process, including internal procedures, is described under Task 3 (pp. 14-18) and elsewhere. Thus, additional statements do not seem to be needed to assure that the reviewer will reach mee.ningful conclusions about these matters.

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Mr. Milhoan Page Two 9/27/84

2. IPC believes that the scope of the vertical review has been adequately described in the Program Plan and in Bechtel's responselof August 17, 1984 to the NRC's Comment #1.

Specifically:

a. The areas of design to be reviewed have been specifically described. The portions of the HVAC associated with the three systems in the_ vertical review are part of Bechtel's scope; we see no reason to add a

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separate, entire HVAC system to the IDR.

b. A list of the design' subcontractors, with a brief summary of their work scope, is being provided to Bechtel. As mentioned on August 31, Bechtel will review the interface between Sargent & Lundy and any design subcontractors involved in the systems encompassed in the' vertical review, and has_the flexibility to review any design subcontractors it determines are important to the accomplishment of the objectives of the IDR. IP sees no reason to have the Program Plan dictate how Bechtel exercises this flexibility, particularly in view c: the limited design work performed by subcontractors.

c. As mentioned by the NRC at the August 31, 1984 meeting, "Important-to-safety" is a generic problem and is not relevant to the proper scope of the IDR.

3. IPC does not see any reason to expand the data base for the horizontal review. Specifically:

a. The situation at Zimmer and Clinton are not comparable.

At Zimmer, where all construction had stopped, the concern was with the quality cf construction and the findings were directed at that question. The IDR here is concerned with design and as such the Zimmer findings simply are not pertinent,

b. Although we have not seen the EBASCO findings at Marble Hill, it is our understanding they were not prepared pursuant to a program plan reviewed and approved by the NRC nor one implemented under the surveillance of_the NRC. The Clinton IDR is the subject.of such NRC scrutiny. As a result, the two are not comparable and including the EBASCO findings in the review would not be fruitful.

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Mr...Milhoan g Page^Three.-

g 9/27/84 m c.;;As we hAve previously explained, the results of the IPC reviews of the twenty topics referred to in Section

> III.D. :(page -7) - of Attachment 1- of IPC's letter to : the NRC.of May 31, :1984 .are available to the NRC and to Bechtel. These items are not Clinton or S&L specific.

~To-the' extent that Bechtel deems it' appropriate in the

. conduct'of(the IDR, it will review those topics and take

-IPC's results into account. IPC seems no reason why Bechtel should not be allowed to utilize its independent

. judgment in this regard.

4. No' advantage has been.shown, and none is apparent, from havingLthe horizontal review and vertical review conducted by separate reviewers. In fact, IPC believes-that such:

. separate reviews.would not only be inefficient but would result injan inferior product since the individual reviewers would not.have the benefit of the comprehensive knowledge

. gained'in-a single overall review.

15 . . No problem has been detected, nor was any.shown to exist,

.with:the qualification and training of design pe'sonnel. r

-Bechtel will, of. course, exercise independent judgment in k the' course of'its review to determine whether these subjects, and/or other subjects, should:be investigated in lightDofLany deficiencies found in the. design or design -

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process'or of Bechtel's identification offroot causes.

6. The appropriate scope of the field _as-built review as part .

of an IDR has been defined in Task 2-E-(page 13) and Bechtel's response of August 17,-1984- to the NRC's Comment

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!#10. .IPC-sees no reason to add specificity to this description.

' 7. The present Protocol satisfies the NRC requirements for an

-IDR. To the extent that, as suggested'by_. Illinois, "the IDR

.isito belused as;a means for removing any issuesifrom litigation in the hearing ~ process," such possibility is being considered in the continuing discussions among:the.

parties.. Any: agreements reached among'the parties will be

-appropriately implemented; but the possibility.of such-agreements-is not relevant to the proper' content of the

-Protocol..LAs to Item number 8 of'the Conference Notes of July 12, 1984 , clarification was provided in the IPC letter to Bechtel of; September 12, 1984.

8. The term " safety-significant condition" is-defined in the

' Glossary (page ii) -of the Program Plan and is approximately equivalent.to a reportable item under the NRC regulations.

' As indicated .in Table 2 (page 19) , all valid Observations

'(whether or not " safety significant") are processed 4

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Mr. Milhoan

- Page'Fouri 9/27/84-

~, =similarly, i.e.,fa report isfissued for.each individual Observation, a response is made, and the corrective action, liffany, is1 reviewed. The principal impact of a.

classification as " safety-significant".is' prompt-

, ....: notification.toEIPC and there is another tier of review

within(Bechtel (Level-2 Committee).

- 9. : Illin'ois'. suggestions of additional: independent audits are not~ relevant to the review or implementation of the Clinton

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IDR..

, , We are. pleased that Illinois found the meeting of August 31,.

- :1984 to' b'e informative and . helpful.

.Please-le't;us'know if we can~be of further assistance in o

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responding to Illinois' comments.

.--, - Sincerely-yours, ILLINOIS POWER COMPANY.

. D..Geier.

Assistant-to Vice President

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, - cc:1 See1 attached distribution list.

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Clinton Power Station Independent Design Review Standard Distribution List Director of Nuclear Reactor Regulation Richard J. Goddard, Esq. l Attn: Mr. A..Schwencer, Chief Office of the Legal Director j Licensing Branch No. 2 U.S. Nuclear Regulatory Commission

' Division of Licensing Washington, D. C. 20555 U.S. Nuclear Regulatory Commission I Washington, D. C. 20555 Don Etchison l Director, Illinois Department of l James G. Keppler Nuclear Safety Regional Administrator 1035 Outer Park Drive Region III Springfield, Illinois 62704 U.S. Nuclear Regulatory Conmission 799 Roosevelt Road Allen Samelson, Esq.

Glen Ellyn, Illinois 60137 Assistant Attorney General Environmental Control Division Byron Siegel . Southern Region Clinton Licensing Project Manager 500 South Second Street Mail Code 416_ Springfield, Illinois 62706 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Jean Foy Spokesperson, Prairie Alliance Fred Christianson 511 W. Nevada

. Mail Code V-690 Urbana, Illinois 61801 NRC Resident Office Clinton Power Station Richard Hubbard R.R. #3, Box 228 MHB Technical Associates Clinton,- Illinois 61727 1723 Hamilton Avenue Suite K Janes L. Milhoan San Jose, California 95125 Section Chief, Licensing Section Quality Assurance Branch Gordon L. Parkinson Office of Inspection and Enforcement Bechtel Power Corporation-Mail Stop EWS -~305A Fifth Beal Street U.S.-Nuclear Regulatory Commission P. O. Box 3965 Washington, D. C. 20555 San Francisco, California 94119 Richard C. Knop Roger Heider Section Chief Sargent & Lundy Engineers Projects Section 1-C 55 E. Monroe Street U.S. Nuclear Regulatory Commission Chicago, Illinois - 60603 799 Roosevelt Road Glen Ellyn, Illinois 60137

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bc:.__'W.'C.'Gerstner - B-13 D..P. Hall - V-275 W. Connell -'V-923

.H. R. Victor - V-928 J. D. Geier - A-17 F.- A. Spangenberg - V-928 D. W. Wilson - V-920 S. A._Zabel - Schiff, Hardin & Waite C..D. Fox - Schiff, Hardin & Waite M.-Axelrad - Newman & Holtzinger

-]R. Brodsky ' Basic Energy Technology CPS Central File - T-31

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