ML20210D374

Forwards Staff Evaluation of Comanche Peak Response Team Plan Providing Detailed Comments/Concerns on Section 3.0, Main Rept (Sections I to Viii & Attachments 1-5),Item 1

ML20210D374
Person / Time
Site:	Comanche Peak
Issue date:	08/16/1985
From:	Knox J NRC
To:	Landers D, Noonan V, Shao L NRC
Shared Package
ML20209E570	List: IA-86-657, Advises of Meetings Scheduled for 850701,10,17 & 31 in Bethesda,Md to Discuss Util Program Plan.Nrc Response Will Be Sent to Util by 850807 ML20209E567 ML20209F940 ML20209F945 ML20209G005 ML20209J318 ML20210A660 ML20210A729 ML20210A774 ML20210B207 ML20210B978 ML20210C077 ML20210C318 ML20210C513 ML20210C590 ML20210C696 ML20210D123 ML20210D374 ML20210D403 ML20210D459 ML20210D880 ML20210E104 ML20210R211 ML20210S437 ML20211H073
References
FOIA-86-657 NUDOCS 8702100073
Download: ML20210D374 (2)

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ROUTING AND TRANSMITTAL SUP Aug. 16, 1985 Initials cate 70

goggreem number, .

a V. idoonan '

I* I Nhan D. Landers /R. Hookway

2. C. Hauahnev D. Jeng

. 3. H. Livemore

. S. HoM

4. J. Calvo

, E. Marinos '

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s. E. Tomlinson

. Action File Note and Retum Approval For Clearance Per Conversation As Requested For Correction Prepare Reply Circulate For Your Information See Me Comment lavestigate Signature Coordination Justify REMARKS .

Staff Evaluation of CPRT Plan , Detailed Coments/Concems Section 3.0, Main Report (Sections I to VIII and Attachments 1-5), Item 1. ~

w To clarify this item, the attached text has been proposeo.

7-s DO NoT use this form as a RECORD of approvals, concurrences, disposals, clearances, and similar actions FROM:'(Name, org. symbol, Agency / Post) Room No.--Bldg.

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g. John Knox etion. No.

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492-4568 ti) 1 i sost-to2

'orrlONAL FORM 41 (Rev. 7-76)

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COMMENTS / CONCERNS

1. .A deficiency is the major mechanism used to increase sample size.

Appendix A. Attachment 5, addresses Scope Expansion for the Design Adequacy Program (DAP) by stating that it may be necessary to expand the scope' to investigate trends, deviations, or root causes. Scope expansion is a requirement only when (a) deficiencies (safety significant concern) exist, (b) one or more deviations exist that would be deficiencies if occurring elsewhe're or (c) design activities are affected by identified root causes. Based on the above, it appears that an increase in sample size is initiated because a safety significant concern (deficiency) is anticipated not because licensing connitments were not met. The concern is' that this approach, for increasing sample size, may not provide an acceptable level of assurance that all areas of noncompliance with

!- licensing commitments have been identified and acceptably resolved.

Furthermore, this approach does not appear to be in compliance with the commitment in the letter of transmittal that:

l "It should be made unequivocally clear that we consider satisfaction of our FSAR commitments as the first guiding principle in execution of the CPRT program."

Augment the Plan to identify areas which:

(1) will meet licensing connitments, (2) will not meet licensing commitments, or

! (3) acceptance criteria are not detenninable at this time.

Where licensing connitments cannot be met, define the proposed acceptance criteria and describe the tasks for obtaining NRC staff approval. For these areas for which criteria cannot be established at this time, augment the Plan to include tasks which are aimed at quickly providing the necessary input to make appropriate judgments and to assist in establishing criteria.

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