ML20209F931

Comments on 850613-14 Slide Presentations on Applicant Plan Re Comanche Peak Response Team Design Adequacy Program.Nrc Needs to Be Assured That New Team Fully Aware of Unique Design Problems

ML20209F931
Person / Time
Site:	Comanche Peak
Issue date:	07/08/1985
From:	Terao D NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:	Shao L NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML20209F938	List: ML20209F931 ML20209F978 ML20209G009 ML20210S689 ML20210S767 ML20210S785 ML20210S804
References
FOIA-86-657 NUDOCS 8507170254
Download: ML20209F931 (2)

Text

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\...+/ JUL 8 96 4 NOTE T0: L. Shao, Engineering Group Leader Comanche Peak Project, DL FROM: D. Terao, Mechanical Engineer Comanche Peak Project, DL

SUBJECT:

COMMENTS ON JUNE 13-14, 1985 PRESENTATION TO NRC BY TUGC0 Based on my review of the June 13-14, 1985 slide presentation on the portion of thethe applicant's following plancomments.

general relating to the CPRT Design Adequacy Program, I have

1) The program scope and methodology, as presented, sounds thorough and comprehensive (although confusing) containing the a comitments to satisfy many of the design concerns.ppropriate verbiage and provides a framework for the actual effort to be done.However, the plan It is within theonly implementation be determined by of the the staff.

program in which the acceptability of the program must From past experience, written plans by the applicant overall also appeared to be thorough and comprehensive but their weak implementation appears to have been a major source of many of the persistent problems still existing at CPSES. Irrespective of the completeness and acceptability of the program plan, the staff must assure itself that the applicant's new team performing the tasks is competent and fully aware of the unique type of design problems at issue at CPSES. This team's ability to identify and adequately address these potential deficiencies is of paramount importance for an acceptable resolution of the design adequacy concerns.

2) It has taken the staff, CYGNA, and applicants months (perhaps years) to fully understand what the specific design concerns are and how to identify them as well as similar andrrelated issues. With so many new players on the CPSES scene, how does the staff gain confidence that these new players truly understand what it is they are looking for without their having to comit the same blunders through oversightedness as had occurred in the past(e.g.,CYGNA). Although the applicant has apparently retained its veteran team (i.e., Finneran, Iotti) for consultation purposes, the staff is unaware of whether the applicants agree or disagree with the issues raised by the staff, the ASLB, and the intervenor. If they do not agree, then we need to know with which issues there is a disagreement and discuss this before the applicant's effort is too far along.

3) Many of the design issues raised in the Walsh/Doyle allegations exist in a level of detail not clearly addressed by the broad scope of the program plan. The staff should be concerned about how the applicant will address each of the specific design concerns raised as a result of the ASLB hearings. Otherwise, the broad sweeping program presented by the applicants may only scratch the surface of the design issues or, worst, allow these issues to be neglected completely. Should this occur, it could result in a repeat of the previous hearings on the design adequacy in which the ASLB issued its adverse findings because it was not provided with ,

adeouate answers to specific design concerns.

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4) Following the ASLB design decision, the summary disposition motions were intended to address these specific types of design issues. The staff and applicants expended much time and effort trying to identify where specific 2

concerns remained unaddressed. -However, with sumary disposition motions i on hold, and with the program plan now intending to address these design concerns, it is confusing and unclear how the staff is to proceed in our 4

review and evaluation of these design issues; especially, since the design issues have been thrown in the same pot with everything else (i.e,. QA/QC, TRT allegation findings, CYGNA, etc).

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5) It is not clear to what extent the participation by the ASLB and intervenor will be permitted in the review of the program plan and its implementation.

6) It should be evident to the staff by now that a favorable finding in our

• review of the program plan alone will not address many of ASLB's design concerns.

Nor can the ASLB's concerns be resolved simply by stating in a 1

final report that certain aspects of the effort found no safety concerns.

The emphasis by the applicant should be placed on clearly explaining and

documenting the decisions made and the basis for those decisions. The applicant should develop technically logical and comprehensive review and -

acceptance criteria and document decisions made regarding engineering 3 judgment and Code interpretations as well as the basis for those decisions.

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! 7) Stone & Webster Engineering Corporation (SWEC) pipe supports tend to be simple (short and stout) and standard designs based on our review of pipe supports at Millstone-3 and Beaver Valley-2. The SWEC " proven standards" for pipe support analysis may not be sufficient to address many of the pipe support design concerns raised at CPSES.

i It is not clear how SWEC will

! review their standards "to ensure they encompass features and issues related to piping and supports at CPSES." This is a crucial step and one in which

close interaction with the staff is necessary.

^ TLC-David Terao, Mechanical Engineer Comanche Peak Project

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