ML20154L615

Renews Request for Info to Complete Review of Comanche Peak Review Team Program Plan.Objects to Issuance of Sser Until Review Complete.Insp Checklists & Info Re Region IV Audits of Implementation of Review Team Not Received

ML20154L615
Person / Time
Site:	Comanche Peak
Issue date:	03/10/1986
From:	Garde B TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	Chandler L, Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM), NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
CON-#186-413 OL, NUDOCS 8603120096
Download: ML20154L615 (2)

Text

_.

TRIAL LAWYERS FOR PUBLIC JUSTICE. P.C.

COUN5ELLOR$ AT LAW SulTE 6tl 2000 P STREET, NORTHWIST ANTHONY L rot 5 MAN WASHINGTON, D.C. 20036 (202)463-8600 IntcuTu DRtcroR ARTHUR BRYANT STAH AHORNEY March 10, 1986 situc cARot DRtCTOR. tNVIRONMENTAL WHISTLIBLOWid PRO ltCT mRuu run GTICL MANElR

"'"cYt$n'Y 5t 68- NI N Mr. Vince Noonan Director . .

Technical Review Team U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Lawrence J. Chandler Special Litigation Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sir:

We are in receipt of your March 5, 1986 letter to the Board regarding the expected issuance of the Staff's

! Supplemental Safety Evaluation Report (SSER) evaluating the CPRT Program Plan by the end of March 1986.

As you know CASE has not provided comments to Revision Three of the CPRT, and do not believe we can t competently do so without accesa to other information which

has been available to the staff. Specifically we have not

received any of the attribute inspection checklists, nor virtually any information on t'1e Region IV audits of the implementation of the CPRT.

Our concern, as has been expressed to the staff on numerous occasions, is that the staff's approval of the plan will have the effect of grandfathering in all of the work done according to Revisions 0, 1, and 2 without regard to critical deficiencies in the earlier phases, or the inadequacies of the current program.

CASE was informed sometime ago that the CPRT approval will be of " scope" only, not implomontation. It seems to us that this is a distinction without a practical difference because the approval of the plan will validate the procedures which have allegedly been followed, and by default all of the inspection and rework done to those

l i

l 1

i We renew our request to the staff to immediately i'

provide us with all of the information necessary to complete an adequate review of the CPRT. Until that review is finished we object to the issuance of the CPRT SSER.

! Sincerely, l Billie. Garde s j Representative of CASE l BG kc j cca Service List l l 1

i l I

j l l

I l

1 l

e i

l l

1

!