ML20154C416

Forwards Response to Request for Addl Info Re Generic Ltr 83-28.Info Concern Development,Maint & Use of Equipment Location Index & Sys Evaluation Documents

ML20154C416
Person / Time
Site:	Hatch
Issue date:	09/08/1988
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20154C420	List: ML20154C416 ML20154C452
References
GL-83-28, HL-32, NUDOCS 8809140361
Download: ML20154C416 (8)

Text

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's ,,', J g /Wanta. Georg2a 30308 e Telechcce 404 526 6526 Fb i 54 5 At:anta Georg.a 30302 W G Ha rsto I tre sgen et12rt sylem N;cteaf OreraSons HL-32 0447I X7GJ17-H600 September 8, 1988 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Hashington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES OPR-57, NPF-5 RE0' JEST FOR ADDITIONAL INFORMATION GENERIC LETTER 83-21 Gentlemen:

On May 9, 1988, Georgia Power Company (GPC) received a requert for additional information (RFAI) from the NRC, dated May 6,1988, relative to GPC's response to Generic Letter (GL) 33 28. On July 19, 1988, GPC met with NRC representatives in Rockville, Maryland, to discuss the items contained in the RFAI.

The requested information was generally related to the development, maintenance, and use of the Equipment Location Index (ELI) and System Evaluation Documents (SEDs). Enclosure I delineates GPC's response to the RFAI. In previous correspondence with the NRC, the ELI was identified as the document which would be used to satisfy Section 2.1 of GL 83-28. Additionally, in previous correspondence, GPC stated that the ELI would be reviewed against the SEDs to assure accuracy and completeness, once the SEDs were completed. At the July 19 meeting, GPC informed the NRC that the SEDs would be completed by the end of 1989.

Subsequent to the July 19 meeting, GPC re-examined the necessity of maintaining tha ELI and the SEDs as basic documentation for the ilsting of safety-related components. Based on the evaluation, GPC detertW"d the SEDs fully satisfy all the requiremer,ts of GL 83-28, Section 2.1 ,

therefore, presenting the information via the ELI is redundai.t.

Accordingly, GPC wishes to inform the NRC that the SEOs, rather than the prulously indicated ELI, vill be used to satisfy the requirements of Section 2.1 of GL 83-28. A sample SED is included in Enclosure 2.

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U.S. Nuclear Regulatory Commissien September 8, 1988 -

Page Two If you have questions in this regard, please contact Mr. L. T. Gucwa at (404) S26-7015. i Sincerely,  !

a i&.h. .A W .

H. G. Hairston, III Enclost.as:

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1. GPC's Response to NRC Request for Additional Information dated May 6, 1988. ,

2. Sample SED.

l c: Georaik Power Cetrany ~

] Mr. H. C. Nix, General Manager - Hatch

Mr. L. T. Gucwa, Manager Licensing and Engineering - Hatch

GO-NORMS i

l l U.S. Nuclear Regulatory Commission. Hashington. D.C.

Mr. L. F. Crocker, Licensing Project Manager - Hatch

U.S. Nuclear Regulatory Commission. Region II 1

Dr. J. N. Grace, Regional Administrator 1

4 Mr. J. E. Henning, Senior Resident Inspector - Hatch I

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ENCLOSURE 1  ;

i l l PLANT HATCH - UNITS 1, 2  ;

4 NRC DOCKETS 50-321, 50-366 1

OPERATING LICENSES DPR-57. NPF-5 REOUEST FOR ADDITIONAL INFORMATION

! GENERIC LETTER 83-28 ,

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1 i GPC's RESPONSE TO NRC DATED May 6, 1988  !

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j ENCLOSURE 1 1

PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5  !

, RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION DATED MAY 6. 1988 i

j Procram; Generic Letter 83-28. Item 2.2.1 i'

) At Georgia Power Company's Plant Hatch, the determination of safety

! related and nonsafety related, as provided in the Equipment Location ,

3 Index tELI), is ultimately made by the architect engineers (AEs) l (Southeri. Company Services and Bechtel) or the nuclear steam siipply .

l system (NSSS) vendor (General Electric). l The safety-related and nonsafety-related determination is made by using '

the following inputs.

I. Quality Class "Q"*

i A. Function - Safety Related i 1 1. Licensing Considerations i a. FSAR l l b. 10 CFR 50 Appendix A '

s c. Regulatory Guides

! d. Generic Letters

e. Sa^ty Evaluation Reports (SERs)

f. Other

2. Design Considerations j a. Single Failure

b. Loss-of-Offsite Power (LOSP) l c. Hazards

d. Equipinent Qualification

e. Design Basis Earthquake i f. ASME 1, 2, and 3 2 g. Mode of Operation

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h. Quality Assurance Program

1. Other 1

! 3. Safety Criteria

a. Maintain Reactor Coolant Pressure Boundary

b. Shut Down and Maintain Reactor Safety

) c. Prevent or Mitigate Consequences of an Accident 1

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• - Quality Class "Q" and "Non-Q" are notations found in the ELI of j which safety-related and nonsafety-related are subsets.

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] 0420I El-1 09/08/88 HL-32 1

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O Georgia Power d ENCLOSURE 1 (Continued)

BESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION DATED W.Y j .1931 B. Function - Nonsafety Related

1. Design Considerations

a. Utility Discretion

b. Quality Assurance Program (as applicable)

c. Anticipated Transient Hithout Scram (ATHS)

d. Fire Protection

e. ASME 3

f. Radwaste  !

g. Other II. Quality Class "Non-Q"*

A. Function - Nonsafety Related '

1. Design Considerations

a. Seismic Class II/I  :

b. Other  ;

i Plant Hatch documents that control work are physically designated as '

safety related or nonsafety related. Examples are plant procedures, Maintenance Work Orders (MH0s), and procurement documents.

Plant procedures concol work and are designated as safety related and '

nonsafety related. Procedures are designated nonsa.fety related by exception following a documented evaluation by the Nuclear Safety and Compliance Department.

MH0s are designated as safety related and nonsafety related. This ,

designation is made by the Quality Control Organization by using the ELI and consulting with the Engineering Department, as required. The ELI is discussed further in the discussion of Item 2.2.1.1, Information Handling '

System.

Plant Hatch Procurement uses a procurement classification system. Within  !

the classification system, the determination of safety related and '

nonsafety related is required. This determination has been made by the AE and previously recorded in plant design documents (i.e., specifica-tions and design drawings). The Nuclear Procurement Review Group uses this determination to assign procurement levels as discussed in Item 2.2.1.5. .

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• - Quality Class "Q" and "Non-Q" are notations found in the ELI of which safety-related and nonsafety-related are subsets.  ;

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HL-32

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Georgia Power d ENCLOSURE 1 (Continued)

RESPONSE TO NRC RE00EST FOR ADDITIONAL INFORMATION

, DATED MAY 6. 1988 1

Generic Letter 83-28. Item 2.2.1.1 Information Handlina System l

j The Plant Hatch Information Handling System, which identifies plant 1

I components and their associated safety classifications, is the Equipment Location Index (ELI). The ELI is a computerized database that was developed and is maintained by the architect engineers (AEs). Unit I was developed by Southern Company Services and Unit 2 by Bechtel. The ELI ,

database includes drawing numbers for P& ids, elementaries, vendor manuals, and layout drawings. In add ^1on, the ELI contains purchase order numbers, specification numbers, physical location, and quality designator for each plant r aponent.

i The maintenance of the ELI is controlled by plant procedures and 4 supporting AE procedures. The update process is audited by Georgia Power

? Company Quality Assurance and AE Quality Assurance. Concerns relating to 1 these audits are reported to upper management, and corrective action is j identified. t In 1985, an ELI upgrade program was initiated in the form of System Evaluation Documents (SEDs) designed to provide functional safety 3

classifications for plant equipment. These safety classifications are d

used to replace the simple "Q"/"Non-Q" designation provided in the original ELI. The safety-related classification is a subset of the "Q" l

designation.

SEDs for 56 safety systems have been completed by the AEs. Approximately  :

20 safety-related systems /SEDs remain to be completed. The SEDs are scheduled for completion by the end of 1989.

4 Generic Letter 83-28. Item 2.2.1.3 Use of Eauioment Classification Lil_tj ag t j The Plant Hatch Equipment Classification Listing is the Equipment Location Index (ELI). The ELI is used by most plant and AE personnel as ,

a reference document to provide easy access to drawings, specifications, i purchase orders, and physical locations; however, some specific plant i functions rely specificaily on the ELI and the Safety Classification

System. These functions are controlled by plant procedures.

Specifically, one use of the ELI is to designate Maintenance Work Orders (MH0s) as safety related or nonsafety related. This function is

, controlled by plant procedures and is performed by the Quality Control (QC) Organization. All MW0s are reviewed by the QC Department and 2

designated as safety related or nonsafety related. Additional assistance is requested from Engineering, as required.

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.. 2 Georgia Power d ENCLOSURE 1 (Continued)

RESPONSE TO NRC REOUEST FOR ADDITIONAL INFORMATION DATED MAY 6. 1988 Generic Letter 83-28. Item 2.2.1.5 Desian Verification and Procurement All Plant Hatch requisitions foi safety-related parts and equipment are reviewed by a Nuclear Procurement Review Group (NPRG) to ensure appropetate descriptive technical and quality details are incorporated prior to further processing. The elements of this review include assignment of a prccurement level, technical requirements including l reference to design specifications or drawings, and specification of ypropriate verification documentation and quality program references.

Any spetici testing required by the design specification is identified in this review, including certification to a test report for environmentally qualified items. The decision to procure certain items commercial grade is also made during this review. Requirements for this review activity and the elements of the review are contained in the NPRG Nuclear Procurement Policy Manual and site procedures.

In many cases, the site NPRG identifies the required information by performing a document records search in the Documtat Control Records Management System. This system contains such information as: original design specification requirements, codes / standards, verification Ocumentation, and test requirements. The Equipment Location Index is also used as a reference. Requirements for environmentally qualified equipment are contained on site in equipment qualification files ,

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The Quality Assurance audit of a supplier is an additional part of the l verification process. Safaty-related items are procured from qualified I suppliers as determined by the results of triennial audits and annual I evaluations. A list of qualified vendors is maintained and used by the NPRG and buying personnel.

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j j ENCLOSURE 2 i i 6

j PLANT HATCH - UNITS 1. 2 i NRC DOCKETS 50-321. 50-366 i

OPERATING LICENSES DPR-57. NPF-5 i

REQUEST FOR ADDITIONAL INFORMATION 1 GENERIC LETTER 83-13  !

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