ML20141G449

Forwards Comments on IE Draft Insp Rept of Facility Design Adequacy Review Program Plan.Appropriate Couple Between Comanche Peak Project & IE Effort Deemed Principal Interest

ML20141G449
Person / Time
Site:	Comanche Peak
Issue date:	01/06/1986
From:	Calvo J, Calvro J NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:	Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML20141G446	List: ML20141G441 ML20141G449
References
NUDOCS 8601100267
Download: ML20141G449 (4)

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1. " *%'o, UNITED STATES j -g NUCLEAR REGULATORY COMMISSION 5 l- WASHINGTON, D. C. 20555

%*****/ JAN 0 6 886 MEMORANDUM FOR: Vincent S. Noonan, Director Comanche Peak Project FROM: Jose A. Calvo, Manager Systems / Operational Group Comanche Peak Project

SUBJECT:

COMMENTS ON THE IE DRAFT INSPECTION REPORT OF THE CPRT DESIGN ADEQUACY REVIEW PROGRAM PLAN The enclosed comments reflect our review of the draft report as it relates to

-the design adequacy review scope of the CPRT program plan. As indicated in our comments our principal interest is to maintain appropriate coupling

'between our effort and that of IE.

[tr d2, b Jose A. Calvo, Manager Systems / Operational Group Comanche Peak Project cc: L. Shao C. Tramell A. Vietti-Cook 8601100267 e60107 PDR A ADOCM 05000445 PDR

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• ENCLOSURE IE- DRAFT INSPECTION REPORT - COPMENTS C0pmENT'

1. Cover letter, page 1, second paragraph -

It is stated that " TERA's verbal responses during the inspection have been compared with formal responses to-the same comments in TUGC0 letter CPRT-113 dated November 22, 1985, and any discrepancies have been highlighted in the enclosed inspection report."

This letter should state that the inspection team review of the TUGCO's November 22, 1985 submittal was limited to the applicant's responses on the staff's specific design adequacy review comments. Responses to programmatic comments have not yet been reviewed by the staff. Therefore, this letter should not' imply acceptance of all responses to staff-comments transmitted to the' applicant on 8/9/85 and 9/30/85.

2. Cover letter, page 1, third paragraph - It is stated that "NRC scope related.

comments are addressed in the existing DAP review check lists or will be

• included in the checklists to be developed-as a result of the Phase 3 scope validation process."

This statement appears in conflict with our effort to determine review scope on the basis of independent homogeneous design activities. Check lists are to be developed with design attributes that detemine the quality of the individual design activities identified in an approved scope. The checklists reviewed by IE include only technical attributes, and not attributes of homogeneity.

3. Cover letter, page 2, second paragraph -

It is stated that " TERA was unable to

provide, to the team, Gibbs and Hill documentation covering design considerations, approach and methodology and design control procedures."

Following the IE inspection TERA has obtained G & H documentation covering design control procedures and some engineering guidelines covering design considerations, approach and methodology for some disciplines.

This documentation was audited by the CP project during a recent audit at TERA.

4. Cover letter page 2,

' fourth paragraph - It is stated that "In general, the checklists list the criteria and commitments for which the implementation will be verified in the review, but do not indicate the design considerations which must be accounteo for verifying that the commitments were met."

We believe that for the purpose of determining an acceptable review scope, identification of design criteria and commitments is adequate to satisfy that element of homogeneous design activities. Design considerations in the implementation phase will determine the quality of the individual design activities performed by G & H. ,

5. Introduction and Summary, It is stated that "The scope of the Section 1.2, page 1, and DAP will be reviewed and approved by Remaining Sections of Report the Office of Nuclear Reactor Regulation, with input from IE."

It will greatly assist our effort in this evaluation of the review scope, if a statement can be made in this inspection report regarding the adequacy of the design criteria and commitments reviewed by the IE team, for the identified design activities, as related to each discipline.

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6. Introduction and Summary Section 1.3, page 2. -

It is stated that "the inspection team generally agreed with TERA conclusions that certain checklists adequately covered HDAS."

It is unclear whether the conclusions that certain checklists adequately covered HDAS, is based on design activities with only a single occupant. It appears inconsistent that such conclusions can be reached for design activities with more than a single occupant, since the elements of homogeneity have not yet fully been addressed for the design activities.

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