ML20209G005

From kanterella
Jump to navigation Jump to search
Responds to Request for Comments on Comanche Peak Response Team Program Plan.Plan Contains Most Elements Required for Adequate Implementation of Action Plans for Review of Design & Const.Detailed Comments Encl
ML20209G005
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/31/1985
From: Taylor J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Noonan V
NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML20209E570 List:
References
FOIA-86-657 NUDOCS 8508080104
Download: ML20209G005 (4)
v • d • e


Text

..

r *1s

  • p aee fV M
  • ' / m\* ' UNITED STATES

% [\ g NUCLEAR REGULATORY COMMISSION

-3 s WASHINGTON, D. C. 20666

-e f

( q a.. pr MEMORANDUM FOR: -Vincent S. Noonan, Director

  • Comanche Peak Project

.FROM: James M. Taylor, Director Office of Inspection and Enforcement

'SU8 JECT: COMANCHEPEAKRESPONSETEAM(CPRT)PROGRAMPLAN This responds to your request for comments on the subject program plan. The review by IE and its consultants addresses the adequacy of the broad aspects of the program plan and its implementation for the purpose of assurin design and construction of the Comanche Peak Steam Electric Station (g that CPSES) meets FSAR commitments. Detailed coments on the action plans for the mechani-cal, electrical, and IAC disciplines were previously provided to you. .

'IE's coments on the program plan, which should be addressed by the applicant prior to NRC's approval of the plan, are enclosed. In particular, we wish to note that:

The " third-party" charter of the CPRT is not well served by the proposed relationship between the dPSES and the CPRT. Insufficient protocol exists to verify independent:e of organizational decisions.

Neither the CPRT nor the senior review team has sufficient strength to implement the objective of the program plan. Key experience and discipline-specific technical expertise appear to be missing.

- The specific criteria against which plant acceptability will be evaluated need to be clarified. This review should identify and provide disposition for any, plant deviation from FSAR comitment.

Pending resolution of these coments, IE concludes that the program plan

, contains most of the elements required for adequate implementation of the i action plans for review of design and construction. Since these elements are

somewhat general, however, NRC overview at various stages of the CPRT review j process is necessary to evaluate the course of the review and interpose timely
corrections.

8-James M. Taylor, Director Office of Inspection and nforcement

Enclosure:

IE Comments , F60 ~ #H g601(09'01oy Yh l'*

1r* #]  !(

r n ,

IE Com ENTS ON COMANCHE PEAK RESPONSE TEAM (CPRT) PROGRAM PLAN

'1. Relationship Between CPRT and CPSES Pro.iect Personnel

a.Section III, "CPRT Program Plan Principles" (page 12) states that "CPSES project personnel under the guidance of the Review Team Leader will perform most of the preparatory tasks and will participate in the -

implementation of action plans." It is important that performance of these tasks by the project not compromise the independence and I objectivity of the review team. For example, a significant part of the action plans is definition of design criteria for which implemen-

. tation will be assessed. The review team should exercise independent judgement in identifying all pertinent design criteria, and not merely review implementation of the criteria identified by the project.-

, NRR/IE evaluation of the Cygna Phase 4 review found that Cygna's lack of independence in scope selection limited the effectiveness of its review.

b. The Program Plan does not address a protocol or other means for struc-turing contacts between the reviewing organizations and the project in order to assure a verifiable trail of review organization decisions.
2. Breadth and Depth of Reviews Appendix A, page 10 states'that the " scope determination process will ensure that all design processes, organizations and activities employed with respect to safety-related designs at CPSES have been reviewed..."

The scope determination process involves four phases.

a. In Phase 1 consideration is given to the breadth and depth of previous design assessments conducted at CPSES. The basis for taking credit for previous design reviews, if CPRT efforts are commensurate 1y reduced, should be described. For example, subsequent to the NRR/IE review of Cygna Phase 4, we understood that credit would not be taken for areas reviewed and found adequate by Cygna in the mechanical systems, electrical and IAC disciplines.

f b. Phase 2 involved a comparison of safety-significant system design characteristics applicable to AFW and electric power systems against other safety systems to determine if the AFW and electric power systems l provide a representative sample of CPSES safety systems. Appendix A, i Attachment 5, page 38 is intended to demonstrate this comparison; it i merely lists system characteristics but does not show system comparisons.

l For example, containment spray has heat exchangers and sumps; the AFW system does not. Previous IDIs and IDVPs have shown problems in sump

, design related to NPSH calculations. The Phase 2 program description i

should identify how key design areas, such as this, are being covered.

i i

t l-

c. Phase 3 is intended to " establish the minimum depth necessary for extrapolation of the results to the entirety of the 80P design process related to safety related systems, components and structures..

The depth will be documented through the development of detailed checklists..." Phase 2 and 3 are closely related, and in that regard the CPRT should provide a rationale for making judgments as to whether the breadth and depth of the review are representative of the entire-CPSES design process.

3. Qualification of Personnel

,a. Texas Utilities' June 28, 1985 letter indicates that emphasis has been i placed on specific technical expertise of the review teams and team leaders. However, the plan does not provide details, such as resumes, which the NRC needs to evaluate this. Based on IDI and IDVP experience, we believe that these personnel should have direct commercial nuclear design experience of a degree and kind such that the reviewer could have performed the original design of the area being reviewed. Team leaders should have this experience at the supervisory level. .

. b. Texas Utilities' June 28, 1985 letter does not adequately address the issue of discipline-specific technical expertise for the members of the Senior Review Team. This is important with respect to the role this team plays when compared to the technical qualifications of the working level review team leaders and members. In-deptie technical

, experience in each discipline must be present somewhere in the review organization.

4. Program Plan Implementation IE's experience has shown that implementation of the Program Plan for design areas is best assessed by visits to the reviewing organization, A-E,'and site.

as appropriate, to review:

a. the review checklists j b. implementation of the checklists; 1.e., the in-process inspection i c. the final report vs. source documents
d. implementation of corrective actions l CPRT should develop schedules for its reviews, so that NRC surveillance as
indicated above can be provided. The schedule should include a " cutoff date"

? i for the review to ensure that the review sample is representative of typical

( work performed at CPSES and does not contain final " polishing" of systems l design.

I

( 5. Design Criteria j -

a. The applicant should clarify what is intended in the " review of design

, criteria for consistency and completeness." For example, does it i evaluate whether design criteria in internal procedures and other

, design documents are consistent with FSAR commitments?

l t

2 L

0

b. Action plans X and XI state that the compliance of the design with FSAR and other commitments on the criteria list will be deemed acceptable if no safety-significant deviation exists between the as-installed and tested design and the requirements identified on the current criteria list. Other action plans (e.g., VIII for civil / structural) require that there also be no adverse trends of deviations for the design to be

, considered to be in compliance with commitments. Given these statements we are concerned that action will not be taken in all cases where the design differs from the commitment. The applicant should note that all design criteria contained in FSAR commitments are considered to be safety significant by the NRC and that deviations from such commitments must b either be corrected or submitted to the NRC for its review and approval as amendments to the FSAR. In addition, there should be an audit trail for any non-FSAR design criteria changes which are made as a result of CPRT efforts. An individual discrepancy may not, in and of itself, be significant. However, in the aggregate, such minor discrepancies may reveal trends which do have safety significance.

4 0

3-

-

Retrieved from "https://kanterella.com/w/index.php?title=ML20209G005&oldid=3316877"