ML20213F451
| ML20213F451 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/07/1986 |
| From: | Eggeling W ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#486-1470 OL, NUDOCS 8611140212 | |
| Download: ML20213F451 (6) | |
Text
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/'l? O ImLauldliillaummeerg F1 L E D:
NOV.
,6
'J W C UNITED STATES OF AMERICA 86 WJV 12 P12:37 NUCLEAR REGULATORY COMMISSION
((G,F.
before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
)
50-446-OL COMPANY, et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
RESPONSE TO BOARD 10/3/86 QUESTIONS (CPRT SCOPE)
In the October 3, 1986, Memorandum from the ASLB two questions were posed by the Board regarding the scope of CPRT.
These are as follows:
- 1) 'Ftrst, stil the CFRI revied :uality contrcl cr quality assurance issues generates in austts, reste.s, diagases, e,aluations, censultant re: orts and in-boase au21ts cr other internal re;crts?"
- ) "Sec003, to what extent utll CPRT exastte tre aaeauacy of sana;esent response to tssues so generated?'
Board Memo at 2 and 3.
Applicants' respond to the Board's questions as follows1:
Question No. 1 Yes, to the extent that, following implementation of the activities described below, such issues may be determined by l
l the CPRT to have any continuing importance with respect to Originally due by the end of October, this filing is timely 1
pursuant to authority granted by the Chairman of the Licensing Board panel; by phone, October 31, 1986.
8611140212 861107 h05 PDR ADOCK 05000445 G
-9 5
developing the requisite assurance that CPSES has been adequately designed and constructed:
A.
Specific CPRT Action Plans were formulated to evaluate certain aspects of the TUGCo QA program which are also addressed by the Board's question number 1.
These action plans include:
VII.a.2 Non-conformance and Corrective Action System VII.a.4 Audit Program and Auditor Qualification VII.a.5 Periodic Review of the QA Program B.
The CPRT program commits to " responding to and resolving the open TRT, ASLB, SSER, CAT, SIT, RIV, [NRC Region IV] and IAP
[CYGNA) issues."
(Program Plan at 2.)
The open issues contained in these documents are called " External Source" issues in the Program Plan.
This list of documents is further supplemented in Appendices A and B of the Program Plan to include the NRC Special Review Team (SRT), letters, the MAC Report and the Lobbin Report.
See Program Plan Appendix A at 6 and Appendix B'at 4 '.
All these to come within the range described by the Board's documents seem question.
While the documents listed in the CPRT Program Plan as sources of open " External Source" issues may not be an exhaustive list of all possible sources of potential issues, it is believed that they contain sufficient depth and breadth of potential open issues to serve as the basis for formulation of the CPRT Program f
/
The NRC Staff has endorsed CPRT's approach for thus scope.
capturing and resolving " External Source" issues as may be evidenced by their statement in SSER No. 13 at 5-1 which states, "The staff evaluates the Cosancne Peak Res:ense Teas KPRI)
Progras Plan an: fin:s tnat it ;revides an overall structt,re for ad:ressing all existing ccastruction ar.3 design issues and any future such 1stues that say te 1:entified free future evaluations. The staf f concludes that the construction and design a:ecuacy prograss provice an accepta le process f r resolving all current and any future external source issues."
C.
Finally, the hardware ramifications of a potentially inadequate QA/QC program are being assessed through the implementation of Action Plan VII.c " Construction Reinspection and Document Review Plan."
One of the functions of this program is to capture hardware deficiencies regardless of the extent to which assessment of an identified External Source issue might have led CPRT to them.
To the extent Action Plan VII.c concludes
.there are such deficiencies, their analysis and correction may envelope additional concerns such as appear to be hypothesized by the Board's question.
This cannot be determined until the Action Plan's implementation has been completed, howev,er.
Question No. 2:
The CPRT Program looks at the " adequacy of management response to issues so generated" to the extent that the specific
" issue" is the subject of a CPRT Action Plan and the response to that issue, by whomever, is pertinent to the investigation and closure of a specific Action Plan.
Except insofar as it is r
e captured thus, CPRT has no separate goal to investigate or assess historical management efficiency or effectiveness.
CONCLUSION Applicants are currently completing their Response to the Board Concerns (Memorandum of 6/26/86) regarding the CPRT, which they expect to be able to publish within the next few days.
This filing will discuss matters which should be considered with the topics raised by the Board's 10/3 questions, along with and in relationship to other similar concerns regarding the design of the CPRT Program.
We suggest the Board consider the above answers with the benefit of the more comprehensive treatment that should be in this next filing.
Respectfully submitted, C.L Thomas G.
Digq[, J R.K.
Gad III Fg William S.
Eggelin Kathryn A.
Selleck ROPE.S & GRAY 225 Franklin Street Boston, MA 02110 (617) 423-6100
_ 4 -
r e
D0LPEiU UM CERTIFICATE OF SERVICE
'86 NOV 12 R2:38 I, William S.
Eggeling, one of the attorneys for the Applicants herein, hereby certify that on November 7, 1986, ImdkElsgivice,lof E t.L -
the within document by mailing copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Mr. James E.
Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S.
Nuclear Regulatory P.O.
Box 38 Commission Glen Rose, Texas 76043 Washington, D.C.
20555 Dr. Walter H.
Jordan Nancy Williams Administrative Judge Cygna Energy Services, Inc.
881 W.
Outer Drive 101 California Street, Suite 1000 Oak Ridge, Tennessee 37830 San Francisco, California 94111 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission 7735 Old Georgetown Road Room 10117 Bethesda, Maryland 20814 O
Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.
Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Joseph Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W.
2000 P Street, N.W.,
Suite 611 Suite 840 Washington, D.C.
20036 Washington, D.C.
20036 Dr. Kenneth A. McCollom Mr. Lanny A.
Sinkin Administrative Judge Christic Institute 1107 West Knapp 1324 North Capitol Street Stillwater, Oklahoma 74075 Washington, D.C.
20002 Ms. Billie Pirner Garde Mr. Robert D. Martin Midwest Office Regional Administrator, 3424 N. Marcos Lane Region IV Appleton, WI 54911 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B.
Johnson Geary S.
Mizuno, Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O.
Box X, Building 3500 U.S.
Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 William S.
Egg fng/
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