ML20106F392
| ML20106F392 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 10/26/1984 |
| From: | Samelson A ILLINOIS, STATE OF |
| To: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8410300224 | |
| Download: ML20106F392 (4) | |
Text
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gp N EIL F. HARTIGAN ATTORNEY GENERAL STATE oF ILLINolS SPRINGFIELD 627o 6 October 26, 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 J
Re:
Clinton Power Station Independent Design Review-IDR Progress Meeting of October 16, 1984
Dear.Mr. Milhoan:
I am writing in response to your request for the State of Illinois' comments on the first progress report of Bechtel Power Corporation (BPC) in the above-referenced matter.
Because our comments were presented on the record at the October.16, 1984 meeting,.I will not repeat or summarize them in:their entirety.
However, I would reiterate three particular areas of concern to the State of Illinois.
Firstly, we request an opportunity to inspect the primary documentation generated during the course of the IDR.
This would include' check lists, commitment lists, review sheets, and all other working files of BPC in the conduct of
-the IDR.
Without access to this documentation, we believe the IDR' reports are essentially inscrutable.
Secondly, it is unclear whether substantive discussions between BPC and Sargent & Lundy or Illinois Power Company will be held during " working meetings" that may occur after an observation.has been reported.
We believe that any such discussions should be. subject to the prior notice and opportunity-to-attend requirements of the IDR protocol.
Thirdly, we are especially concerned about Sargent &
Lundy's~ role in the IDR.
Recent Observation Reports confirm our initial' impression that it is Sargent & Lundy, rather than l O
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4-D l
Mr. Milhoan October 26, 1984 f
the independent. reviewer, who is conducting important aspects of the IDR program.
See, for example, observation report no.
10,-dated October 12, 1984:
"SkL should provide an explanation of why these discrepancies occurred, and an assessment.of their safety significance.
S&L should. identify similar applications of using interruptable control power.in the control circuits of other safety related systems and. verify that the design commitments are implemented in the design to ensure design adequacy.";
and observation report no. 11, dated October 12, 1984:
"S&L should provide an ' explanation of why these discrepancies occurred, and an assessment of their safety significance.
S&L should review other layout drawings and evaluate the implication on other systems and areas if similar discrepancies occur elsewhere."
We would be interested in learning whether, in the judgment of NRC,"the IDR is being conduated with the requisite independence and freedom from outside influence", on the scope of the l
reviewer's work, in the processing of observations, the determination of their safety. significance, the need for more intensive review, and in the evaluation for underlying, root causes or broader implications.
(See IDR Program Plan, Rev. 1, page 3,' par. 2 and page 6, par. 1.)
The State of. Illinois would also request copies of the
-following documents which have been referenced in recent IDR
- correspondence:
(1) the Sargent & Lundy analysis of the four
. independent reviews of SkL design activities, as specified in correspondence dated October 11, 1984 from D.P. Hall to James
. L. Milhoan (U-0750);
(2) the " point papers" developed by Illinois Power
' Company in response to the twenty engineering design areas identified by Stone & Webster; reference D.P. Hall to James L.
Milhoan dated September 28,1984 (U-0741); and (3) each of the reviews of Sargent & Lundy design factivities which are being provided to BPC in the conduct of
- the IDR.
, _. -. - _. _ -. -...~.
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a Mr. Milhoan October 26, 1984 The State of Illinois appreciates the opportunity to attend the IDR progress report meetings and to present our comments.
I look forward to receiving a copy of the transcript of the October 16, 1984 meeting.
Very truly yours, Allen Samelson Assistant Attorney General Environmental Control Division AS:dm cc:
Attached distribution list
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L40-84 (10-23)-L 8G.150b Clinton Power Station Independent. Design Review Standard Distribution List (ce w/o Enclosures)-
Director of Nuclear Reactor Regulation Richard J. Goddard, Esq.
- Attn: _ Mr. A. Schwencer, Chief Office of the Legal Director.
Licensing Branch.No.'2 U. S. Nuclear Regulatory Cc==ission Division'of Licensing Washington, D.C.
20555 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Don Etchison Director, Illinois Department of James.G. Keppler Nuclear Safety Regional Administrator 1035 Outer Park Drive Region III Springfield, Illinois 62704 U. S. Nuclear Regulatory Commission 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 4.16 Springfield, Illinois 62706
'U.'SP Nuclear Regulatory Commission p.
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 James.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 Fifty Beal Street
-U. S. Nuclear Regulatory Commission P. 0.: 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 East Monroe Street U. S.. Nuclear Regulatory Commission
' Chicago, Illinois 60603 799 Roosevelt Road Glen Ellyn, Illinois '60137 Maurice' Jbcelrad
'Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington,:D.C.
20036
., -