ML20095E985

Forwards Bechtel Response to NRC Comments Re Rev 1 to Independent Design Review Program Plan.Concurs W/Bechtel Suggestion That Response Be Considered as Immediately Effective Amend to Plan

ML20095E985
Person / Time
Site:	Clinton
Issue date:	08/22/1984
From:	Hall D ILLINOIS POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
U-0729, U-729, NUDOCS 8408270135
Download: ML20095E985 (8)

Text

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U-0729 L40-84(08-22)-L '

0982-L llLLIN018 POWER COMPANY IP CLINTON POWER STATION, P.o. BOX 678, CLINToN. ILLINOIS 61727

.- August 22, 1984

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Docket'No. 50-461 Director o'f Nuclear Reactor Regulation.

Attention: Mr. A.' Schwencer, Chief Licensing Branch No. 2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station-Unit 1 Independent Design Review Program Plan

Dear Mr. Schwencer:

Your letter to me of August 6, 1984 provided the comments of the

~ NRC Staff on the Independent Design Review (IDR) Program Plan (Rev.1)

-for the Clinton Power Station prepared by Bechtel Power Corporation (Bechtel).

'We have received the attached Bechtel letter of August 17, 1984 (from Mr. G. L. Parkinson-to Mr. J. D. Geier) forwarding Bechtel's response to the NRC Statf's comments. We have reviewed Bechtel's response and believe that'it-both improves the Program Plan and provides a satisfactory resolution-to the NRC comments. Accordingly, we are concurring in Bechtel's suggestion that the response be considered as an immediately effective amendment to'the Program Plan, and the 1DR is proceeding in that fashion.

S ere yours,

. . all Vice President MA/Im Enclosure cc: See attached distribution list l

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PDR l

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h U-0729-L40-84(08-22)-L Clinton Power Station r

Independent Design Review Standard Distribution List Director of Nuclear Reactor Regulation Richard J. Goddard, Esq.

Attn: Mr. A. Schwencer, Chief Office of the Legal Director

. Licensing Branch No. 2 U. S. Nuclear Regulatory Commission Division of Licensing Washington, D.C. 20555 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Don Etchison Director, Illinois Department of James G. Keppler Nuclear Safety Regional Administrator 1035 Outer Park Drive Region III Springfield, Illinois 62704 .i U. S. Nuclear Regulatory Commission 799 Roosevelt Road Allen Samelson, Esq.

Glen Ellyn, Illinois 60137 Assistant Attorney General Environmental Control Division Byron Siegel Southern Region Clinton Licensing Project Manager 500 South Second Street ,

Mail Code 416 Springfield, Illinois 62706 l U. S. Nuclear Regulatory Commission l Washington, D.C. 20555 Jean Foy l Spokesperson, Prairie Alliance l 511 W. Nevada Fred Christianson Mail Code V-690 Urbana, Illinois 61801 NRC Resident Office Clinton Power Station Richard Hubbard R.R. #3, Box 228 MHB Technical Associates Clinton, Illinois 61727 1723 Hanilton Aver.ue Suite K James L. M11hoan San Jose, California 95125 Section Chief, Licensing Section Quality Assurance Branch Gorden L. Parkinson Office of Inspection and Enforcement Bechtel Power Corporation Mail Stop EWS - 305A Fifty Beal Street U. S. Nuclear Regulatory Commission P. O. Box 3965 Washington, D.C. 20555 San Francisco, California 94119 Richard C. Knop Roger Heider Section Chief Sargent & Lundy Engineers Projects Section 1-C 55 East Monroe Street U. S. Nuclear Regulatory Cottmission Chicago, Illinois 60603 739 Roosevelt Road Glen Ellyn, Illinois 60137

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Bechtel Powar Corporation l

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August 17, 1984

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Nr. J. D. Geler I111 pots Power Co 500 South 27th St. . -

Decatur. Illinata 42526 !j l

i sub,tect: C1tnton Independent Design Review

Illinois Power Company Job No.15478-003 frogram Plan - July 1984 (pe_v._ .1)

Enclosure (a): Responses to NRC comments, dated 8/16/84.

Reference (a): Letter from A. Schwencer to D.P. Hall. dated August 6.1984, sub, lect: Clinton Independent Design Review (IOR) Program Plan.

Reference (b): Program Plan, Independent Design Review of Clinton Power l Station, Unit 1, dated July 1984. (Rev.1)  :

i

Dear Mr. Ester:

As mquested we are providing Enclosure (a), as our resanse to the WRC letter of Aeference (a), which cessented on the Program Olan, Reference (b). I l

This response is intened to be fully responsive to the key elements of the 1 NAC comments (Reference (a). We believe that the Program Plan, as clartfted )

hy Reference (a), fully camplies with the NRC caements. 1 i

Unless you instruct us otherwise, we intend to attach the enclosed response to the Program Plan and consider it an issediately effective amentent to the )

Program Plan.

l EUG 17 ~

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J. D. Geier Page Two

! August 17, 1984 -

l Flease advise if we can be of further assistance.

. Very tmly yours, M,1-l'h E. . Pedinson .

Project Manager cci M. Axelred, w/att.

C. D. Fox, w/att.

J. Foy, w/att.

R. Goddard,w/att.

D. P. Hall, w/att. ,

R. C. Nelder, w/stt.

R. Mut6ard w/att.

J. L. N11hoan, w/att.

A. Sasselson, w/att.

II. t.. Siegel, w/ett.

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l August 17, Ig84 Responses to WRC Coments on Clinton 10R Plan

($y its neber of WRC cessents of 8/6/84) l ..

1. After consideration of the NRC concorps, it is agreed'that e l modification is appropriate to the proposed system selection and scope for sechanical design espects of the systems to be covered by the Clinton IDR. Accordingly, we now propose a full mvfew of the shutdown seWice water (SSW) systs and a limited review of the high pressure com sprey (HPCS) aystem fma the containment penetration to the reactor vessel, to cover desip areas described below. Thf a would be in addition to the review of the Class IE ec electrical distributton systm l alree $ proposed.

)

1ha SSW systs is a reasonably complex systa requiring several 1 different mode: of operatiens, has mdundanqy, and the full rsnge of  ;

single failure considerations. In addition, the conceptual and implesenting desip is done by 5 argent and Lundy (SEL). It has I

sipificant interfaces with General Electric such as hut loads and the safe shutdown control panel. However, it is essentially independent of j General Electr.fc design influence and is sufficiently complex to be representative of other systet.

I 1he proposed section of the HPCS syste selected provides for the .

enelysis and support of a pfping systs with a higher design ,

taperature, and the qualification of components in a harsh environent. The analysis and support design are both done by S&L for the NPC$ syste.

i Design for NEL8/MELB protection will be reviewed on a functional basis, across systems, and will not be limited by scope of the above systems.

The depth and bmedth of this review will be consistent with the exarple review plan provided with the NRC cossents. ,

)

(

!. We agree with the NRC that procedural violations and trends in even

' s(nor deficiencies in technical or pmcodural violations should be I identified and mcorded. This was always intended. Accordingly, the l

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August 17, Ig84 interpmtetton of observations will be that of including all ameningful def tsjengtes. However, we believe there is a minimus threshold below '

Thus which it cannot be justified to pursue insigniffcont deficiencies.

the individual revlever will identify and mcord deffclencies (other 4

than trivial ones), and will identify each deficiency which he determines should not he reviewed further because in hf s judgement is not signtNeant. These review mcords st11 he maintained and will be available for NRC inspection,

' l'

3. Ispissenting procedures will be a combination of existing EDPs and 10R-special procedures. Both types era combined into a single pm, lect }

procedures manual, whts is approved by the Project Manager and Project Quality Assurance Engineer. A listing of planned IDR-special procedures not based on EDP's procedures is as follows:

Il comunications 9l 1DR Proced m f1 IOR Procedure #2-Deview Process ,

d IDR Proce'ure f3 Processing of Obserystions IDR Precedure #4 Walkdoom l

We believe' the titles are sufficiently descriptive to indicata the intended scope.

4. The civil-structural aspects will be covered in the 10R as described during the refemeced June te meeting. (See Tmnscript pages $9-90).

This assures reviews which evaluate the safe load path from system ,

supports to the but1 ding foundation, where appropriate.

6. We agree that potential generic deficiencies should be pursued and the IDR will do this. However, we believe there should be some flexibility in the IDR as to how they are pursued and by whos. Accordingly,we propose that Bechtel be 51ven discretton as to whether such satters are investigated outside the systems of IDA scope, by tochtel or by others.

If by others, then techtel would have responsibility of reviewing the results and concurring with determinations made. Bechtel will do enough examination itself to deterstne if generic deftciencies exist, or will verify that the examination has been performed by others. The basis for deciding how and by when generic issues are to be pursued will be

' documented. , ,

AUG 1 y i

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August 17, 1984 -

6. It is intended that documents of the type unntioned by NRC will be included in the IDR. The listings in the program Plan are typical but not complete.

7. There is every intention of reviewing requirements as stated in the NRC cessents to reflect ANSI M45.2.11 and no intention to do otherwise.

i S. The 10R recognisees the situation described by IAE Notice 84-54 and is l prepamd to cover it in the review, including sissing calculations reflecting undocumented judgements. hse instances k.'11 be documented, and meaningful situations covered in the final report.

9. The April 1,1984 cutoff date will be observed and subsequent work wf11 be identified. That wort will be assessed as to its impact on meeting mquirements, on design adequecy, and on the design process. It will also be assessed for its significance to other areas outside the immediate scope'of the IDA. Where the 10R team concludes there is a concern. this will be pursued.

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10. W purpose of the field as-built review is for Bechtel to ascertain whether the S&L design documents were effectively understood by the users. This will be accomplished by selection of representative design documents and development of a review plan based on the essential features called for by such design documents. This is an engineering / design check, not a construction work inspection. hrefore, ,

10R Procedum #4 - Walkdown will emphasize general arrangements, correct orientation of parts, selection of options for spectfic applications and satisfactory appearance of installation. The review plan will be developed and made available to the hAC during the course of the IDR.

11. Activities for which procedures were not followed will be documented, as described in the NRC comments.

12. hre procedures are twquired but not available, they will be documented i at described in the NRC cosaments.

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August 17, 1984

13. The IOR will follow the requirements of ANSI N45.2.11 in evaluating the .

design process as desertbed in the NRC cassents.

14. All potentisi observations will be ntained in files of the IDR.

15. He concur with the NRC cements and expect to discuss its mccueendations for the 10R report content at a later date.

16. We concur that Protocol will not be constmed as Ifsf ting discussions mith the estc.

17. The Protocol will be interpreted as stated in the NRC comuments. -

18. The example review plans are intended to be used in the vertical reviews. The samples pmvfdad by the NRC are consistent in depth of review with what we intend for the specific design activities covered.

The same depth of review is intended .for other design activities. We do not believe it is necessary to mwrite the existing 8echtel plans to provlde addf tional deta11.

AUG 171934