ML20209F978
| ML20209F978 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/15/1985 |
| From: | Terao D NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | Shao L NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20209F938 | List: |
| References | |
| FOIA-86-657 NUDOCS 8507250282 | |
| Download: ML20209F978 (3) | |
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UNITED STAIES E
NUCLEAR REGULATOR COMMISSION h
E WASHINGTON, D. C. 20555 k.....,/
aanes NOTE T0: Larry Shao, Engineering Group Leader Comanche Peak Project, DL FROM:
David Terao, Mechanical Engineer Comanche Peak Project, DL
SUBJECT:
COMMENTS ON CPRT PROGRAM PLAN Based on my revier (
the CPRT Program Plan (Revision 2) dated June 28, 1985 in the area relatd to design adequacy, I have the following comments.
- 1) My previous coments provided to you in my note dated July 8,1985 commenting on the applicant's June 13-14, 1985 slide presentation is also applicable to the CPRT Program Plan.
- 2) The interfaces between the CPRT and NRC should be clearly established with respect to the staff's responsibilities in reviewing the implementation of the CPRT Program Plan.
For example, in Appendix C Action Plan Item Number X, " Mechanical Systems and Components Discipline," the staff should clearly establish the staff's division'of responsibility for the review of systems, components, and other multi-discipline considerations (i.e., flooding, fire protection, missile protection, environmental and seismic qualification).
3)
In the Program Plan (page 13 of 22), the methodology described for the evaluation of design adequacy issues is broadly written as follows..." identification of all deviations; and evaluation of the deviations for safety significance, leading to an identification of deficiencies." The identification of the deviations and the evaluation of their safety-significance are the critical areas where close staff interaction will be needed.
Previously, in the staff review of the applicant's motions for sumary dispositions on design issues, the staff raised many questions in these particular areas which have been left unresolved.
Now, with the CPRT Program Plan intending to evaluate the same design issues, it follows that the same questions previously raised by the staff will still need to be answered by the CPRT.
4)
In Appendix C Action Plan Item Number IX Attachment 2 (page 8 of 13),
the Stone & Webster Engineering Corporation's (SWEC) actions to address the piping and pipe support concerns are discussed. However, it is not clear what SWEC will be doing in the pipe support design The program plan states that SWEC will " qualify" piping drea.
supports but it is not clear whether SWEC will reanalyze the support designs using new calculations or reevaluate the acceptability of existing pipe support calculations, m
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5)
In Appendix C Action Plan Item Number IX Attachment.2 (page 10 of 13), it is stated that the SWEC procedures " automatically" resolve the issues concerning frictional forces, local stress, skewed fillet welds, and rotational restraint of axial supports. The SWEC procedures should be reviewed by the staff to determine exactly how their procedures resolve the issues.
- 6) The Design Adequacy Program Plan (Appendix A) references the SIT report. However, the current design concerns were developed from events which occurred subsequent to the issuance of the SIT report (i.e.,ASLB's 12/28/83 Design Decision and staff's comments on the motions for sumary disposition).
The staff's concerns are documented in transcripts of meeting held with the applicant subsequent to the issuance of the SIT report. The applicant's review of the SIT report-will not be adequate to identify the staff',s concerns. Similarly, with respect to the Cygna IAP, all the Cyg~na concerns were not included in their final reports for Phases 1, 2 and 3.
Many of Cygna's concerns were presented in letters issued subsequent to the IAP reports and in transcripts of meetings held between Cygna, the staff, and applicants.
Furthermore, Cygna has not yet issued its Phase 4 IAP report and it is not clear what the relation of Cygna's Phase 4 effort is with respect to the CPRT effort.
- 7) During the Cygna hearings, the " independence" of Cygna as a third party reviewer became an important issue, and the staff established a
" protocol" for a third-party, independent review. The CPRT effort has now evolved into a third-party review but there appears to be no established " independence" between the CPRT and the utility. This point is exemplified by the selection of John Beck on the CPRT Senior Review Team. To what extent can the staff rely on the objectivity of the CPRT effort if their independence is not assured?
8)
From a hearing standpoint, the CPRT cannot testify as an independent third-party (as Cygna had previously done on the ASLB design issues.
Obviously, the CPRT can only testify on behalf of the applicants.
Thus, from a hearing standpoint, the CPRT effort is not a third-party effort but rather is a CPSES project effurt.
Previously, the applicant's motions for summary disposition (which included tests, studies, and analyses submitted to the ASLB to resolve the design issues) raised many questions by the staff and intervenors which were left unresolved.
It would likely be unacceptable to the ASLB for the CPRT to evaluate these ASLB issues without input and feedback from the staff and intervenors.
In resolving the ASLB issues, clearly the hearing would be one-sided if the CPRT alone presented its findings.
Thus, the staff and intervenors must be provided with the details of the resolutions of the ASLB design issues and given the opportunity to coment on these resolutions prior to resumption of the hearings.
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- 9) In Attachment 2 of Appendix A, a flow chart shows the CPRT design evaluation" the acceptability of hardwarejne'fs IIch?isT; ion /licensiyd'" 4
,d-adequacy evaluation methodology.
Under "gorrective ac1 g
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commitments. Many of the pipe support design issues require an evaluation at a level of engineering detail more exacting than that established in licensing comitroents. Thus, it is not clear what criteria will be used to determine the acceptability of hardware for those specific design issues where licensing commitments are too broad to address them.
David Terao, Mechanical Engineer Comanche Peak Project Division of Licensing cc:
R. Bosnak
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