ML20002C296
| ML20002C296 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/24/1980 |
| From: | Reid R Office of Nuclear Reactor Regulation |
| To: | Widner W GEORGIA POWER CO. |
| References | |
| NUDOCS 8101090970 | |
| Download: ML20002C296 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION g
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December 24, 1980 Dockets Nos
-321 and 50-366 Mr. William Widner Vice President - Engineering Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302
Dear Mr. Widner:
By your letter dated October 15, 1980 you submitted revisions to FSAR commitments related to the Quality Assurance Program at Hatch Units Nos. 1 and 2.
We have reviewed your submittal and detemined that additional infor-mation, described in the enclosure, is required for us to conclude I
that the change does not decrease the effectiveness of the program.
We request that the additional infomation be pmvf ded within 45 days of your receipt of this request. The staff is willing to discuss this request either by phone or at a meeting if you so desire.
l Sincerely, f
bK h
Robert W. Reid, Chief Operating Reactors Branch #4 l
Division of Licensing l
Enclosure:
Request for Additional Infomation cc w/ enclosure:
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Hatch 1/2 50-321/366 Georgia Power Company cc w/ enclosure (s):
Director, Criteria and Standards G. F. Trowbridge, Esq.
Division Shaw, Pittman, Potts and Trowbridge Office of Radiation Programs (ANR-46b) 1800 M Street, N.W.
Washington, D. C.
20036 U. S. Environmental Protection Agency Washington, D. C.
20460 Ruble A. Thomas Vice President P. O. Box 2625 Southern Services, Inc.
Bimingham, Alabama 35202 Ozen Batum Charles H. Badger P. O. Box 2625 Office of Planning and Budget Southern Services, Inc.
Room 610 Bimingham, Alabama 35202 270 Washington Street, S.W.
Atlanta, Georgia 30334 Mr. H. B. Lee, Chairman Appling County Commi'.sioners County Courthouse Baxley, Georgia 31513 Mr. L. T. Gucwa Georgia Power Company Engineering Department P. O. Box 4545 Atlanta, Georgia 30302 Mr. Max Manry l
Georgia Power Company Edwin I. Hatch Plant P. O. Box 442 l
Baxley, Georgia 31513 l
l U. S. Environmental Protection Agency l
Region IV Office ATTN: EIS COORDINATOR l
345 Courtland Street, N.E.
j Atlanta, Georgia 30308 l
Appling County Public Library l
Parker Street l
Baxley, Georgia 31513 l
l Mr. R. F. Rodgers l
U.S. Nuclear Reculatory Commission Route 1, P. O. Box 279 l
Baxley, Georgia 31513
i Enclosure EDWIN I. HATCH NUCLEAR PLANT UNITS 1 & 2 Reauest for Additional Information 1.
We find your exceptions to Regulatory Guide 1.38, fiarch 16,1973," Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants" (endorses ANSI N45.2.2-1972) are not justified.
a.
The exceptions to Section 5.2.1 of ANSI N45.2.2-1972 will be mate.
rials or equipment designated for use in a safety-related system will not Se given a quality control receipt inspection upon delivery to determine shipping damage, but rather will only be issued from the warehouse following a quality control inspection is not acceptable.
This exception is contrary to the requirements of Criterion 7 of Appendix B to 10 CFR Part 50 which require examination of products upon delivery to assure purchased material, equipment, and services conform to procurement documents.
Further guidance on this requirement is provided in Section 8 of ANSI N45.2-1971 (as committed to in Apnendix A of the Hatch Nuclear Plant FSAR QA program description), and Regulatory Guide 1.38, March 16, 1973, to which you take exceptian. Additionally, the Hatch FSAR QA pro-gram description on page 17.2-14 specifically states safety-related items will be physically inspected for shipping damage, proper identification, and confonnance to procurement document requirements. The exception des-cribed above appears to be contrary to this comitment.
Therefore, to assure the necessary QA/QC programatic controls and require-ments of Criterir n 7 of Appendix B to 10 CFR Part 50 are fulfilled, it is an N'C staff position that shipping damage inspections be implemented and performed for all safety-related items upon delivery and that sufficient documentary evidence be available to demonstrate that these items are accept-able prior to use. Sole reliance on a quality control inspection prior to release from the warehouse is not acceptable.
b.
The exceptions to Sections 3.5.1 and 6.4.2 of ANSI N45.2.2-1972 in which the purpose of protective devices during transport or storage is reduced to an economic measure rather than to provide necessary protection for the quality of safety-related material and equipment are unacceptable.
Criterion 12 of Appendix B to 10 CFR Part 50 specifically requires measures be established to control the transport and storage of material and equip-ment in accordance with work and inspection instructions to prevant damage or deterioration. Your comitment to Regulatory Guide 1.28-1972 (endorsing Section 14 of ANSI N45.2) in the Hatch FSAR QA program description also requires protective measures to be implemented during transport and storage of safety-related items.
Consequently, to assure the requirements and quality objectives of Criterion 13 of Appendix B to 10 CFR Part 50 are met, it is an NRC staff position that measures be established, implemented, and documented during transport or storage for all safety-related items to control quality and to assure that
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these items can perform their intended functions.
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. 2.
Item (C) on page 17.2.7 of the Georgia Power Company October 15, 1980 submittal revises the commitment of ANSI N45.2.12, D/af t 3, Rev. 4, 2/74 to ANSI N45.2.12-1977. We find this revision acceptable providing also you commit to the guidance contained in Regulatory Guide 1.144 (Revision 0-January 1979), " Auditing of Quality Programs for Nuclear Power Plants," which endorses ANSI N45.2.12-1977. Any excep-tions and/or alternatives to this Regulatory Guide or ANSI Standard should be des-cribed in sufficient supporting detail to allow for NRC evaluaticn and determina-tion of acceptability.
i' 3.
On page 17.2-7, exceptions are taken to paragraphs 1.2.3 and 3.2.3 of ANSI N45.2.13-1976 with the phraseology of, "by methods other than review" and " methods other than direct review." In order for the staff to evaluate and determine acceptability of l
the proposed exceptions, it is necessary that you describe and explain the alterna-tive methods in sufficient detail. Therefore, provide a description of your pro-posed alternatives for those other methods by which acceptability of a supplier may be accomplished other than direct review of a supplier's documented quality pro -
gram with sufficient supporting detail for our evaluation.
l 4.
The exception to paragraphs 1.3 and 3.1 of ANSI N45.2.13-1976 requires additional clarification. Section 17.2.4, PROCUREMENT CONTROL, of the Hatch FSAR QA program l
description implies that the necessary QA/QC requirements of Appendix B to 10 CFR l
50 will be identified on the purchase requisition.
It was our understanding during evaluation of the Hatch FSAR QA program description, that the purchase requisition was the contractually binding documentation as defined in ANSI N45.2.10 for " Pro-curement Documents." The FSAR QA program description does not clearly indicate whether the requisition is the procurement document or whether the requisition is converted into a purchase order, thus becoming the procurement document as defined in paragraphs 1.3 and 3.1 of ANSI N45.2.13-1976. Therefore, it is necessary to clearly identify, in Section 17.2.4 of the Hatch FSAR QA program description, which document will be known as the procurement document that includes the necessary QA/
QC requirements to satisfy Appendix B to 10 CFR Part 50.
It is an NRC staff posi-tion that the review and concurrence of the adequacy of quality requirements stated in procurement documents is to be performed by personnel qualified in QA practices.
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