ML20098H254

Comments on 840831 Meeting in Bethesda,Md Re Independent Design Review.Areas of safety-related Design Should Be Identified & Encompassed in Vertical Review.Info Requested on Scheduling & Listed NRC Reviews.Svs List Encl

ML20098H254
Person / Time
Site:	Clinton
Issue date:	09/05/1984
From:	Samelson A ILLINOIS, STATE OF
To:	Goddard R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
OL, NUDOCS 8409120265
Download: ML20098H254 (5)

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N EIL F. HARTIGAN ATT o R N EY GENERAL STATE oF ILLINolS SPRINGFIELD 627o 6 September 5, 1984 Mr. Richard J. Goddard Office of Executive Legal Director U.S. Nuclear Regulatory Commission Uashington, D.C. 20555 Re: Illinois Power Co.

Clinton Power Station Docket No. 50-461 OL

Dear Mr. Goddard:

I am writing to summarize Illinois' comments on the L Independent Design Review (IDR), that were presented during the August 31, 1984 meeting in Bethesda in the above-referenced matter. Our major concerns with respect to the IDR are as follows:

(1) The IDR Program Plan should expressly. provide , , '

that it is designed to permit-the seviewer tu ceacicaeaniT(ful conclusions as to whether compliance with and adherence to the regulations, Final Safety Analysis Report, and internal procedures have been achieved by Illinois Power Company (IPC)

. and its contractors in the de~ sign of the Clinton Power Station (CPS).

(2) Illinois believes that an adequate data base must be provided for the vertical review in light of the stated l

objective of the IDR Program Plan (page 6, Rev. 1, July 19,

( 1984) to allow the reviewer to " reach meaningful conclusions

. regarding the. overall adequacy of the Clinton (Power Station) ,.

design". Specifically, (a) All areas of safety-related design _should be _

identified and encompassed in the vertical review. In  !

particular, the HVAC system should be included in the vertical review; j.

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l Mr. Goddard September 5, 1984 (b) all subcontractors.and design groups involved in safety-related design should be identified I and encompassed in the vertical review; and

_(c) the IDR Program Plan should be expanded to include a review of selected. structures, systems, and equipment that.are considered "important-to-safety",

but not safety-related. Thus, the reviewer shouli

~ identify all subcontractors involved in the design of important-to-safety areas so that the IDR will include La~ review of all pertinent design disciplines considered important-to-safety-(as required by GDC-1 of Appendix A).

-(3) The data base for the horizontal review should be.

expanded .to include the following relevant audits of-Sargent &

Lundy :- (1) NRC findings at the Zimmer. station, (2) EBASCO findings at the Marble Hill station and' (3) Stone and Webster .

findings-at the Clinton station.

l (4) fie horizontal review.should be conducted by a

. separate revie wr in order to avoid any downplaying of the results obtained in the vertical review.

-(5) The' qualification and training of design personne1~should be directly reviewed an'd addressed in the IDR.

'(6) The field as-built _ review should be sufficiently specific to -enable ,the reviewer to reach a' meaningful conclusion as to whether_the systems reviewed were constructed in _ accordance with- applicable design drawings.

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, (7) Protocol - If the IDR is to be used as a means for removing"any. issues from~1itigation in the hearing process,

-Illinois believes . reciprocal rights (and duties) should be

. accorded the State and IPC11n the conduct of the IDR.

Accordingly, the State . requests direct notification of all meetings between the reviewer'and IPC', its contractors or

! subcontractors, rather than the~ indirect notification as F provided'in paragraph 3 of the Protocol. No " status / progress" reoorts:should be presented to IPC or'its contractors or '

l. -subcontractors without advance notice to all parties and

. written' documentation should be made of all such reports. (See item no. (8), Conference Notes of July 12, 1984 " Kickoff meeting" at Sargent & Lundy ' Offices.) Additionally,~all

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correspondence subject' to paragraph 2 of the protocol should be sentfdirectly to the State.  :

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'4r. Goddard September 5, 1984 (8) The use of the term " safety significant l condition" should be clarified.

e:: plain what role " safety significant Specifically,"Bechtel findings will play should in formulating the general conclusions of the IDR regarding "the overall adequacy of the Clinton design". Illinois believes the use of this term is inappropriate because it is not defined in ,

the regulations and has no correlation with the pertinent {

regulatory requirements. i (9) For the reasons outlined in the State's proposal of March 5,1984, Illinois believes an independent audit should also be conducted of as-built construction conditions, IPC's construction Quality Assurance program, and IPC's operations QA/QC program at the CPS. .

Finally, we were pleased to learn that the NRC is planning to assign a Construction Assessment Team to the Clinton station and that a review of IPC's " recovery program" will 1xa conducted. It would appear that the , timing of these '

programs- is critical given (1) the status of near completion of

. the construction schedule and (2) the proposed schedule for completing discovery and commencing hearings in the licensing process. I would appreciate your best efforts in forwarding information on the scheduling as wgli as the scope and depth of these two NRC reviews at the earliest practicable date.

Illinois appreciated the opportunity to advise the NRC staff of our views on the IDR and found the meeting' informative and helpful. I look forward to receiving the staff s written responses to.the above comments.

Ve truly yours, 4 (4 All~en Samelson Assistant Attorney General Environmental Control Division AS:dm cc: See attached service list

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SERVICE LIST Director of' Nuclear Reactor Regulation Attn: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of. Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 James G. Keppler-Rep,ional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road ,

Glen Ellyn,' Illinois 60137

-Byron Siegel Clinton Licensing Project Manager Mail Code 416 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Fred Christianson-

, Mail Code V-690 NRC Resident Office Clinton Power Station R.R. #3, Box 228 Clinton, Illinois 61727 james L. Milhoan U Section Chief, Licensing Section Quality Assurance Branch Office of Insuection and Enforcement Mail-Stop ~EWS'- 305A U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i Richard C. Knop;  !-

Section Chief Proj ects Section 1-C l' U.S. Nuclear Regulatory Commission '

799 Roosevelt Road Glen Ellyn, Illinois 60137 Don Etchinson -

Director,' Illinois Department of Nuclear Safety 1035 Outer _ Park Drive Suringfield, Illinois- 62704

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l Service List.(cont'd.)

Jean'Foy Spokesperson, Prairie Alliance 511 T1. Nevada

' Urbana,_ Illinois 61801 Richard-Hubbard MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125

. . Gordon L. Parkinson

'Bechtel Power Corporation p Fifty Beal Street P.O. Box 3965 -

San Francisco, California 94119 Roger Heider Sargent & Lund:e Engineers 55 East Monroe Street j

,' Chicago, Illinois 60603 Sheldon Zabel i Charles D. Fox IV Schiff, Hardin'& Waite 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 Maurice Axelrod

. Newman and'Holtzinger, P.C.  ;

1025 Connecticut, N.W.  ?

Washin,e, ton , D.C. 20036 e

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