ML20195G094

Requests Listed Addl Info Re Comanche Peak Response Team Program Plan to Develop More Comprehensive Plan Identifying All Activities Required to Support Licensing,Per 870407 Mgt Meeting & Util Commitment to Submit Rev 4

ML20195G094
Person / Time
Site:	Comanche Peak
Issue date:	05/12/1987
From:	Charemagne Grimes NRC OFFICE OF SPECIAL PROJECTS
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8705180186
Download: ML20195G094 (5)

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UNITED STATES iy P b pt _.

8" o NUCLEAR REGULATORY COMMISSION 2 W ASHINGTON. D. C. 20566 May 12, 1987

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Docket Nos. 50-445 and 50-446 Mr. William G. Counsil Executive Vice President Texas Utilities Electric Company Skyway Tower, L.B. 81 400 North Olive Street Dallas, Texas 75201

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION IN CONJUNCTION WITH PROGRAM PLAN UPDATE Durina our last manaaement meetino on April 7,1987, representatives from Texas Utilities Electric Company (TUEC) described your intention to prepare and submit Revision 4 to the Comanche Peak Response Team (CPRT) Proaram Plan.

That revision would update the Plan to reflect the results of your investiaation thus far into the desian adequacy and quality of construction, TUEC manacement decisions for corrective actions, and other chances to proarams that make up or are related to the Plan which have evolved since the staff's evaluation in Supplement 13 to NUREG-0797 (SSER 13).

Althouah the staff recoanizes the need to update the Plan at this time so that it will more accurately reflect evolvino results and other related activities (i.e. a "livina" proaram), we have identified the need for you to develop a more comprehensive plan that identifies all of the activities required to sup-port licensino, and the relationships between those activities. Toward that end, we have identified certain information and explanations, outlined below, that the staff needs to clearly understand the present and future course of your efforts. I am aware that this request is beina made late in the process.

However, I believe this course of action is necessary to facilitate the iden-tification and resolution of issues without further delay. Your response to the questions should distinauish between what we consider to be three distinct phases of your activities: (1) investication, (2) corrective actions and (3) verification or overview.

You should provide the followina infomation and clarifications:

1. Provide a concise description of the present scope, purpose, and objectives of the Desian Adequacy Proaram (DAP) and the Quality of Construction and QA/QC Adequacy Proaram (QOC).

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Mr. William G. Counsil 2. Provide a concise description of the scope, purpose, and objectives of the Correction Action Proorams (CAPS), the Desian Basis Consolidation Prooram (0BCP), and any other major onaoina proarams necessary for the licensina of Comanche Peak.

3. Where the purposes of the proarams described in your response to Items 1 and 2 above are similar, clearly describe the differences and interrelationships between these proarams. Include in your respcase a diaaram showina the functional and timino relationships between each of the procrams. For clarity, it may be necessary to provide a series of diaarams showina the proarams in increasina levels of detail. With respect to the relationship between DBCP and DAP, specifically(address the the interface phases: 1) investiaation, between these (2) corrective proarams actions, and (3)inveri- each of fication or overview.

4. Clarify the present role of the "safety sianificance evaluations" and the identification of "critical desian parameters" with '

respect to your redesian and construction verification efforts.

Explain the oraanizational controls you apply to ensure that i these screenina processes do not overly constrain the scope of the corrective actions required.

5. Identify the documentation that will be produceo for each of the activities described in your response to items 1 and 2. Specify whether the documents will be submitted on the docket or filed at the site. It should be recoanized that we will docket any information, not otherwise so submitted, that the staff relies on

• for conclusions in its safety evaluations.

6. Identify the as-built verifications and/or walkdowns that have  :

been or will be conducted for each proaram. Indicate which of ,

those verifications will be relied on fur the "final" desian. 1 Inasmuch as future desian chanaes may be undertaken for a variety l of reasons, you should define "final" desian with respect to the  !

CPRT efforts.  !

7. Explain how the TUEC Technical Audit Procram SWEC Enaineerino Functional Evaluations, SWEC Enaineerina Assurance Proaram, TERA evaluations, CYGNA Independent Asstssment Proaram, and vendor /

contractor QA/QC procrams relate to the overall QA/QC proaram for Comanche Peak. Identify which of these verification methods will apply to each proaram. It appears that the evolution of these verification methods have resulted in a QA/QC proaram that is different from that currently described in the FSAR and possibly different from that evaluated in SSER 13. Therefore, you should:  !

(1) describe the present QA/QC proaram for Comanche Peak, (2) iden-tify differences between the present proaram, the proaram described ,

in the FSAR, and the proaram evaluated in SSER 13, and (3) indicate l the schedule by which you will update the FSAR to reflect the QA/QC l proaram for future reference. In addition, explain how QA/QC has l been applied to the CPRT activities over time, particularly for work performed prior to Revision 3 of the Plan.

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Mr. William G. Counsil 8. In SSER 13, the staff noted that the desian activities and, by implication, the quality proarams of certain "proven" vendors may be exempt from a desian adequacy evaluation; for example, the vendor for the nuclear steam supply system. Please identify other vendors that you believe would fall into this cateaory, in that you feel that ,

thei. desian and QA/QC proarams had substantial credibility prior t to Revision 3.

9. Please explain what the role and purpose of the Senior Review Team (SRT) will be in the future. We believe that this role should be explained particularly with reaard to the transition from the CPRT ,

to TUEC responsibility for implementina the Plan.

10. With respect to the CYGNA Independent Assessment Proaram, the staff notes that ricent Phase IV activities appear to have value as an adjunct to the l Technical Audit Proaram. Please indicate the extent to which the CYGNA l uvaluation will or can apply to any of the proarams described in your response to Items 1 and 2.

11. Durino the April 7,1987 meetino, you provided listinas of "licensina open items' other than those included as part of CPRT and related ,

activities. We request that you provide the status of the resolution of those issues. The status should include identification of those issues that will require plant modifications, interfaces with CPRT activities (i.e., dependencies), and projections for future FSAR amendments.

We intend to use all of the information you provide to develop a comprehensive review and inspection proaram for Comanche Peak licensino activities. Further, we intend to review this information to determine whether to request that you make chanaes or additions to your planned activities. Once we approve this broader Plan, we will require that any chances to this Plan be submitted i to the staff before they are implemented to ensure the most efficient use of our i respective resources. Should you have any questions reaardina this request,  !

please contact me. i I

1 C. .

! Christopher I. G imes, Director Comanche Peak Project Division Office of Special Projects

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May 12, 1987 Mr. William G. Counsil 8. In SSER 13, the staff noted that the desian activities and, by implication, the quality proarams of certain "proven" vendors may be exempt from a desian adequacy evaluation; for example, the vendor for the nuclear steam supply system. Please identify other vendors that you believe would fall into this cateaory, in that you feel that their desian and QA/QC proarams had substantial credibility prior to Revision 3.

9. Please explain what the role and purpose of the Senior Review Team (SRT) will be in the future. We believe that this role should be explained particularly with reaard to the transition from the CPRT to TUEC responsibility for implementino the Plan.

10. With respect to the CYGNA Independent Assessment Proaram, the staff notes that recent Phase IV activities appear to have value as an adjunct to the Technical Audit Proaram. Please indicate the extent to which the CYGNA evaluation will or can apply to any of the proarams described in your response to Items 1 and 2.

11. Durina the April 7,1987 meetina, you provided listinas of "licensina open items" other than those included as part of CPRT and related activities. We request that you provide the status of the resolution of those issues. The status should include identification of those issues that will require plant modifications, interfaces with CPRT activities (i.e., dependencies), and projections for future FSAR amendments.

We intend to use all of the information you provide to develop a comprehensive review and inspection proaram for Comanche Pesk licensina activities. Further, we intend to review this infortation to determine whether to request that you make chanaes or additions to your planned activities. Once we approve this broader Plan, we will require that any chances to this Plan be submitted to the staff before they are implemented to ensure the most efficient use of our respective resources. Should you have any questions reaardina this request, i please contact me. '

l (original signed by) l Christopher I. Grimes, Director Comanche Peak Project Division Office of Special Projects 1

cc: See next pace Distribution:

DCS P. McKee OGC OSP Readina HSchierlina l CPPD Readina JAxelrad CGrimes JKeppler 4

S:e previous concurrence sheet

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Mr. William G. Counsil l

8. In SSER 13, the staff noted that the design activities and, by implication, the quality proarams of certain "proven" vendors may be exempt from a desian adequacy evaluation; for example, the vendor for the nuclear steam supply system. Please identify other vendors that you believe would fall into this cateaory. in that you feel that their desian and QA/QC proarams have substantial credibility prior

to Revision 3.

9. Please explain what the role and purpose of the Senior Review Team (SRT) will be in the future. We believe that this role should be explained particularly with reaard to the transition from the CPRT to TUEC responsibility for implementina the Plan.

10. With respect to the CYGNA Independent Assessment Proaram, the staff notes that recent Phase IV activities appear to have value as an adjunct to the Technical Audit Proaram. Please indicate the extent to which the CYGNA evaluation will or can apply to any of the procrams described in your

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response to Items 1 and 2.

11. Durina the April 7,1987 meetina, you provided listinas of "licensina l open items" other than those included as part of CPRT and related activities. We request that you provide the status of the resolution of those issues. The status should include identification of those issues that will require plant modifications, interfaces with CPRT activities (i.e., dependencies), and projections for future FSAR amendments.

We intend to use all of the information you provide to develop a comprehensive review and inspection procram for Comanche Peak licensino activities. Further, we intend to review this information to determine whether to request that you 4 make chances or additions to your planned activities. Once we approve this broader Plan, we will require that any chances to this Plan be submitted to the l staff before they are implemented to ensure the most efficient use of our respective resources. Should you have any questions reaardina this request, please contact me.

i Christopher I. Grimes, Director .

i Cemanche Peak Project Division  !

Office of Special Projects 4

cc: See next pace ,

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OSP Readina HSchierlino PC)R CPPD Readina JAxelrad Dou6-r F 4 L 6 CGrimes JKeppler

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