ML20214X329
| ML20214X329 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/26/1985 |
| From: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20214X308 | List: |
| References | |
| FOIA-86-272, FOIA-86-454 NUDOCS 8612110068 | |
| Download: ML20214X329 (4) | |
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dN4 UNITE 3 STATES -
p NUCLEAR REdULATORY COMM18813N y f-i REoloN iv 4..6
, PARKWAY CENTRAL PLAZA BUILDING
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811 RYAN PLAZA DRIVE. SUITE 1000 -
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ARuNeToN. TEXAS 7eo11 s
JUN 2 61985
' MEMORANDUM FOR:.V.~.S.:Noonan, Director, Comanche Peak Project R.'P. Denise, Director, Division of Reactor Safety-and
~FROM:
Projects-
SUBJECT:
COMENTS ON THE COMANCHELPEAK ' STEAM ELECTRIC STATION '
.g COMANCHE PEAK RESPONSE TEAM (CPRT) PROGRAM PLAN AND SELF-INITIATED' ACTION
- Attached are comments-by Region IV personnel regarding the CPRT Program Plan and Self-Initiated Action.
Overall, Region IV finds the CPRT Action Plan to be a satisfactory approach for the resolution of presently outstanding CPSES issues;
'at this time, we_have'not made a comprehensive evaluation-that all identified issues are encompassed by the plan.
Region-IV. recommends that the plan be approved.in principle,.with. full recognition that the plan and its detailed
~ implementation is dynamic, and will be revised to reflect present staff -
comments, inclusion of items not known when the plan was prepared, additional external sources, and (perhaps) new items identified as a result of plan-implementation.
This recognition also implies an NRC approval of changes to 2
y the plan; a mechanism to do so needs to be established.
It is important that the NRC. expedite.the review, comment, and approval of the
' applicant's plan. Mo'st of the plan is already being implemented and some portions are already completed.
The inspection of the implementation of an unapproved plan is not a desirable situation.
We also observe that it is not realistic to fully assess the adequacy-of the U
CPRT Action Plan without~ examination of the detailed implementing procedures.
The CPRT Action Plan is written in broad terms, and this is a major contributor g
to many of the concerns expressed by the NRC persepnel/ contractors reviewing the i
i
. action plan.
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R. P. Denise, Director L
Division of Reactor Safety and Projects cc:
R. Martin, RIV J.-Taylor, IE R. Heishman, IE H. Denton, NRR O. Eisenhut, NRR 8612110068 861204 PDR FOIA
,.p OARDE86-272 PDR i
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Comments on the Comanche Peak Response Team and Issuance of-Specific Action Plans
~Overall Program' Comments i
1.
tThere:needs to be-an NRC management decision ~with regard to the applicability of 10 CFR Appendix B toithe'CPRT Program.
Region IV
. inspectors are indicating that the'CPRTLis not considering Appendix-B to be applicable.
I 2.
'The plan needs to address the mechanisms to be implemented to assure l
proper applicant reporting as required by.10 CFR 55(e).
From-the design aspect of the plan, the described approach of redesigning for expediency certain difficult-to-resolve issues:does not appear.to
= provide the final analysis required by 10'CFR 55(e).
Additional' effort may be req'uired.
3.
The plan needs to provide for a periodi.c briefing on schedule, status of
-implementation / completion, an~d a summary of findings for applicant management, NRC, ASLB, etc.
4.~
The difference.between " deficiency" and " deviation" needs to be better-defined, particularly.with respect to the statistical treatment of data in each category.
A focus' on deficiencies, as the applicant defines them, appears to be too narrow to achieve the desired confidence level.
The plan is oriented.toward the identification of all safety significant
' deficiencies; however, the plan should also provide the basis for assuring that the plant has been constructed in accordance with the FSAR and application.
There needs to be an address of the following items:
To what degree can the design margins be degraded, a.
b.
Does the redesign of difficult-to-resolve design issues preclude the identification of design deficiencies, c.
When are cumulative construction / design deviations considered to be deficiencies.
5.
In the initial Region IV discussions with regard to the Quality of Construction and QA/QC Adequacy Prograin Plan, there appeared to be only a limited use of NDE in confirming weld quality.
Although Region IV would agree that there have been limited problems related to the NDE inspection program, the basis for limiting the use of NDE in the self-initiated sample reinspection of all the construction activity processes should be' addressed.
Plan Specific Comments 1.
While the plan may ignore coatings, the applicant needs to address the handing of the coatings issues.
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The MAC,jlobbin, and Teledyne ' reports are not a'ddressed specifically in 2
0 the plan._ Perhaps the. substance of these reports is considered,_but each L
could provideLinsight to~ root cause of probless'and the effectivenesssof.-
the. corrective / preventive action program.
Action Plans ISAP VII.a.4 and "ISAP.VII.a.5 should address these reports.
There may'also be additional ~
problem areas which have not been addressed, such as the calibration
. problems identified-in the MAC report.
i l3;
-The plan should respond to allegations reviewed by the.TRT dealing with pipe hanger material control and weld rod material control:which the TRT could neither: substantiate nor refute (i.e., allegations made by Dillingham,
_Bo "X", Steiners, etc.).
- . 4.
Section:VII.a.4, " Audit Program ~and Auditor. Qualifications," addresses itself to 1978 and forward.- The basis for excluding audit activities prior to 1978 should be addressed.
5.
- Draft;SSER 7 supplements have been forwarded by A. Johnson.RIV to the
~
TRT, but have.not been issued.
The CPRT Program-Plan does not, therefore, address the new information identified in the draft SSER 7 supplements.
J
- 6e The term "use of butt splices on a limited basis" as specified by.
Section 8.1.5.2.4 of Amendment 44 to the CPSES FSAR needs to tne defined.
7.
The CPSES FSAR commits to RG 1.75, Revision 2/IEEE 384-1974 requirements.
.IEEE 384-1974, Section 5.6, " Control Switchboards," Subsection 5.6.2,
" Internal separation" requires qualification based on tests performed to determine flame retardant characteristics.
DSAP XI appears to exclude
'e qualification testing of SERVICE AIR metallic conduit.
ISAP I.6.2 make it an option to either perform an analysis or physical test.
8.
A concern expressed by Region IV personnel who participated in the TRT review of the preoperational test program is that Regulatory Guide (RG) 1.68, position C.2 and C.3 with regard to retests may not be properly interpreted in ISAP III.a.1 (i.e., cold retesting methods employed on the replacement SG and pressurizer level control should not be considered adequate).
The position that should be taken with regard to the intent of
.RG 1.68 is that components requiring preoperational testing that fail subsequent testing, or were not installed in the first place, shall be retested in a manner commensurate with the original preoperational test; and to the extent practical, the plant conditions during the tests should simulate actual operating conditions whether it is a preoperational test L
or retest.
Such testing may be performed during post core HFT.
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9.
Action Plan ISAP VII.a.4 is provided in response to an NRC Region IV enforcement' action.
From review of the response for adequacy, Region IV
' finds that the CPRT should assure that'the action plan ISAP VII.a.4,
" Audit Program and Auditor Qualification," focuses on the central issue of whether'the applicant's audit program adequately assesses the proper implementation of the design procurement, construction, inspection, corrective action programs.,The question of whether an adequate audit '
-program can be effectively implemented from the Dallas office versus the site should be addressed.
The performance of supplemental audits when problem areas are identified should also be addressed.
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