ML20210D880

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Forwards Addl Comments Re Draft Sser 13 Sent on 860514
ML20210D880
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/16/1986
From: Landers D
TELEDYNE ENGINEERING SERVICES
To: Noonan V
NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML20209E570 List:
References
FOIA-86-657 6410-60, NUDOCS 8702100184
Download: ML20210D880 (9)
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[f&f J MtY ENGINEERING SERVICES 130 SECOND AVENUE WALTH AM, MASSACHUSETTS 02254 (61 ?) 890-3350 TWX (7101324-7508 May 16, 1986 6410-60 Mr. V. Noonan, Project Director Comanche Peak Project United States Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Mail Stop P-234 Washington, DC, 20555

Reference:

TES Letter 6410-59, dated May 14, 1986

Subject:

Additional Comments, Draft SSER No. 13, May 1986

Dear Mr. Noonan,

Attached please find a copy of subject additional comments which were transmitted to you by Telefax today, May 16, 1986.

Very truly yours, TELEDYNE ENGINEERING SERVICES a

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1 n, Donald F. Landers Executive Vice Presiden DFL:mid attachment cc: JQC JAM 6410 file

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. W TELEDYPE ENGWEERNG SEMCES ADDITIONAL TES COMENTS - REVIEW 0F DRAFT SER-13, received 5/12/86 COMMENTS Page 1-4, Self Initiated Evaluation TES reccmmends that the paragraph remain as originally stated. The words "100% of the work" and " envelops all" are not those stated in the Program Plan, last paragraph on page 3 of 45. The interpretation - 100% and all -

is too liberal and not absolutely accurate. Compare this paragraph with that given on page 2-1, the second paragraph:

Page 1-5, Issue Specific Action Plans (ISAPs)

The first sentence states ... and some design issues...

The sentence should state: some design related issues.

Page 1-5, Discipline Specific Action Plans Editorial, first paragraph, third sentence, suggest that the third sentence be revised to read "Those DSAPs encompassing ... supports, include a significant...

Page 1-7, first paragraph, next to last sentence should state: ... consists I of a sample reinspection and/or documentation review.

Page 1-11, third paragraph - grammar Sentence reads: at this time ... fully enough resolved as yet ...

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Suggest revising the sentence to read: "Few of the issues have been evaluated sufficiently..."

e Page 1-17, first paragraph, second sentence Editorial - change to read: ... evaluations are appropriate mechanisms...

Page 2-3, third paragraph i

l Editorial - last sentence ... information such that a valid concern...

Same sentence ... to the ISAP governing the concern, should the word be

" covering"?

. . . ..?.

-, TN l ENGSEERNG SERVICES 1 Page 2-3, Section 2.2, Self Initiated Program The last line on the page states: common areas, supplemented by a review... ,

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Documentation reviews are not a supplementary action. It is an either or condition. See App. B, Page 9, third paragraph. 1 Page 2-4, first paragraph, second sentence should be revised to read: the population ... attributes gr documentation reviews of inaccessible or nonrecreatable attributes.

, Page 2-4, last paragraph, last full sentence should state: both l

ginspection... ,

l Additionally the sentence refers to Quality Instructions. Something is missing in context. The Quality Instructions (CPRT??) have not been l previously addressed.

Suggest rephrase ... Quality Instructions prepared and issued by the CPRT QA/QC review team or ??

Page 2-5, first paragraph, third sentence.

NOTE: It is not an assurance level. Suggest revise sentence to read:

This was selected by the CPRT...

l Page 2-5, second paragraph, last sentence explains that as a result of audits the staff determined sample augmentation. (Ref: App. B, page 9, third paragraph).

l l o This should be addressed in terms of the basis for augmentation as described in the Plan. Does it mean 60 times?

o If not defined in the Plan, and the staff requires this, it should be stated in Appendix 8 as a concern to be addressed. Perhaps it can be restated to clarify.

o Also, when CPRT inspection activity is addressed, the word n inspection should be used.

Page 2-6, First paragraph, second sentence states:

...according to the applicant.

This subject should be addressed in tenns of "according to the plan."

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.' ym N MICES Page 2-6, second paragraph, sentence beginning: If no additional deficiencies...

Should this be addressed as a new sample? New population?? e.g. the total population is not new.

Suggest delete the word new, where used.

Same paragraph, next sentence, suggest revise to read: ... is detected and a different root cause is not identified...

Page 2-7, Section 2.4, Staff Evaluation Suggest comparing and replace with wording from page 3-2, last sentence, first paragraph reads better. Or, consider using words of page 2-9 under 2.4.2.

Page 2-7, Section 2.4.1, Evaluation of QOC, etc.

It is suggested that explanation'of reviews by consultants, etc., is not meaningful. Also, page 2-8, the first full paragraph, suggest deletion / revision.

Page 2-9, Section 2.4.2, Evaluation of Self Initiated Programs The third sentence states: the audits did not address...

If what the audits did address is stated, why is it necessary to say what wasn't addressed.

! Suggest deletion of this sentence.

Page2-10,first(partial) paragraph What does it mean? Irrespective of human and administrative factors?

l Editorial - second paragraph: It was noted in the, delete the word the.

Page 2-10, third paragraph l The Closed External Source Issues should be identified as those that were l closed by sources external to the CPRT.

l Editorial - spelling, word affect should be effect.

l Page 2-11, Item (d) editorial, delete word both.

_ . .-. -.- xx ..

'. TTELEDGE ENGNEERNG SEFMCES Page 2-12, fourth paragraph Suggest that the word " dichotomous" should be expressed for a laynan's understanding, or in simple terms - explanation??

Page 2-14, first full paragraph The first sentence is confusing. Should this be stated: ... based on on-site audits.

Page 3-3, first paragraph states: ... pages 9 thru 14.

Since the DSAPs also resolve ESIs, this should be stated as pages 6 thru 14.

Page 3-5, the first paragraph states that the issues are classified.

It is the results (findings) of the CPRT's activity that are classified, not the issues. (Ref. App. E)

Page 3-5, bottom of page - sentence beginning: This process - continued on page 3-6.

Suggest revise the sentence to read: This process results in the establishment of matrices...

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Page 3-9, Section 3.4 Sentence beginning: For the tray / conduit...

Should read: For the cable tray / conduit...

Page 3-11, Section 3.4.2 Sentence beginning: As a result...

Suggest delete word special.

Page 3-12, sentence after item f Editorial - use plural verb are. Viz. details are...

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.' 1PTELEEME

-s- ENG3EERNG SERVICES Page 3-22, first paragraph, sentence beginning with Thus.

Syntax - suggest "can be demonstrated better"...

Page 3-25, Section 3.6, conclusion first paragraph Suggest revise to read: ... source issues related to design.

It is also suggested that this section offer its conclusion identifying the Design Adequacy Program, not the CPRT program plan..

Page 4-6, the second full paragraph It should be noted that the current plan allows SRT review and approval of corrective actions af ter implementation.

TES previously expressed a concern that the SRT should be involved in review of the ongoing process of recomendation and implementation of corrective action.

App. B, page B-5, staff comment on ISAP V.d ,

It is not clear why the sampling plan utilized by the ISAP did not yield an acceptable confidence level.

Shouldn't the ISAP adjust or modify its sampling plan or initiate a special sampling plan that does comply with Appendix 0 rather than perform the bounding analysis. Since an effective sampling plan can be implemented it appears that compliance with the program plan is the requisite, and it is suggested that the CPRT should not be granted an alternative.

App. B, page B-6, item (1)

It is not clear what the provisions for additional third party investigations should be. Why isn't third party design reverification acceptable?

App. 8, page B-8, staff comments on ISAP II.a How can the plan address the corrective action until the CPRT finds what the problem is (if any)? However, it is agreed that the ISAP should address corrective action for deficiencies.

App. B, page B-8, staff comments on ISAP II.e See coments as above.

WTELEDYME ENGNEERNG SERVICES App. C, page C-2, first paragraph The first sentence should be revised to read: This matter is... of discrepancies related to the self initiated construction program...

The sentence beginning: The major reason... should be revised to read:

... related to design optimization or resolution of deficiencies.

The next sentence should be revised to read: Therefore, new design documents and loads / stress values which form the basis for the safety significance evaluations would be available.

App. C, page C-2, item 2 Description The first sentence should be revised to read: ... using Code or regulatory criteria.

App. C, page C-3, item 3 description and staff comments Should be deleted. This is an old DFL comment, no longer valid.

App. C, page C-4, item 4 description and staff comments Delete - same as above.

App. C, page C-5, item 5 Delete - same as above.

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App. C, page C-10, item 1 Description Editorial: ... descrepancies (or deviations) for...

l Editorial: ... modifications may be made to piping and supports by SWEC...

App. C, page C-12 Staff comment The paragraph states that active valves should be considered in root cause/ generic implications evaluations.

Root cause/ generic implications evaluations are described in DSAP X on page 21, third paragraph. Since active valves are an issue to be resolved in this DSAP, is it apparent that the topic is covered?

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  • WTELEDYE

. ENGREERNG SERVICES App. C, page C-17, Staff coment Editorial - second sentence, delete word but.

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App. C, page C-18, Staff comment Editorial - spelling, word approach.

Iten 2 - Description Editorial - spelling, word pump.

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