ML20210P833

Forwards Comments on Facility Design Adequacy,Program Scope Validation Process & Review Checklists.Design & Const Problems Identified for Cable Tray & Conduit Supports Which Are non-ASME Related

ML20210P833
Person / Time
Site:	Comanche Peak
Issue date:	01/09/1986
From:	Shao L NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:	Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
Shared Package
ML20198G216	List: ML20198G214 ML20210P747 ML20210P797 ML20210P833
References
FOIA-86-38 NUDOCS 8605130518
Download: ML20210P833 (2)

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NUCLEAR nEGULATOnY COMMisslON y WASHING TON, D. C. 20',$'i JAN 9 1986 MEMORANDUM FOR: V. Noonan, Project Director Comanche Peak Project FROM: L. C. Shao, Engineering Group Leader Comanche Peak Project

SUBJECT:

COMMENTS ON IE INSPECTION OF CPSES DESIGN ADEQUACY PROGRAM SCOPE VALIDATION PROCESS AND REVIEW CHECKLISTS

Reference:

J. M. Taylor draft letter to W. G. Counsil, undated We have reviewed the referenced IE inspection report and consider that it effectively addresses the scope of the Comanche Peak Response Team's Design Adequacy Program. The report clearly documents the inspection team s activities and findings. Our coninents on the inspection report -

are provided for your consideration in Enclosure 1 to this memorandum.

It is suggested that these coments either be incorporated in the IE inspection report or be used as guidance for future IE inspections of DAP implementation.

Please do not hesitate to call me at 37908 if you wish to further discuss our coninents. -.

[ d L. C. Shao, Engineering Group Leacer Comanche Peak Project

Enclosure:

As stated cc: B.Jrimes W. Norkin R. Shewmaker B. Saffell i C. Hofmayer R. Masterson D. Jeng S. Hou D. Terao V. Ferrarini J. Calvo L. Chandler l g 51 g 8 860423 g A.g4-$g GARDE 86-38 PDR

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, C0tmENTS ON IE INSPECTION REPORT ON COMANCHE PEAK DESIGN ADEQUACY PROGRAA

1. We agree that the experience of the staff perfonning the Design Adequacy Program is a key element in the strength and validity of the conclusions drawn from this program. Therefore, we concur with the IE team's intent to followup during implementation inspections the appropriateness of the balance between reviewer experience and the prescriptiveness of review checklists.

2. TERA oversite of the cable tray and conduit support effort should be strengthened. We don't perceive the current oversite program as suffi-ciently active or timely. This is illustrated by the number of deviations identified by the staff in a recent audit. We expect the CPRT, through an active oversite program using experienced people, to identify deviations and effectively dispose of them.

3. NRC-IE may want to consider the following comment during future audits.

TERA has established HDAs and developed checklists for the evaluation of each area. As the supporting documentation is developed, checklist revision is likely. If checklist revision should occur during the imple-mentation phase, TERA should have a procedure or process for evaluating the effect of checklist revisions on completed evaluations.

4 Since the IE audit, TERA has documented their method for establishing the homogeneity of design activity groups (DAP-21). We suggest that future IE audits address implementation of this procedure. In this regard, documen-tation packages should be developed for each homogeneous design activity (HDA). Design evaluation documentation should include the design activity definition, the basis for homogeneity, the checklists and its basis, design y evaluation with results and conclusions.

5. Appendix 3, Mechanical Components: With respect to active valves, there did not appear to be a commitment to establish the root cause and review the generic implications concerning the apparent misinterpretation of certain Gibbs & Hill specifications, e.g. a review of the G&H QA program to determine how specification discrepancies are addressed and followed up.

6. Appendix 8, Item 18, Piping / Supports: The TRT has recently found a violation with the ese of later code addenda for piping design use, 1 (Category 51, Allegation AP-43). l

7. Design and construction problems have been identified for cable tray and conduit supports which are non-ASME related. Therefore, emphasis should be placed on similar types of safety-related supports that are non-ASME related.

8. Appendix 7 - Question 1: The NRC coment says that the design process should be looked at as part of the design review scope. Neither the TERA ,

response nor the team evaluation addresses this concern. l

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