ML20043H025

Responds to NRC 900508 Ltr Forwarding LER-89-018,Rev 1,dtd 900228 Re Quality Classification of Electric Equipment. Implication Re Other Plants Not Identified,Because Instrument Indices Not Used to Establish Classifications

ML20043H025
Person / Time
Site:	Grand Gulf
Issue date:	06/07/1990
From:	Kansal D BECHTEL GROUP, INC.
To:	Brach E Office of Nuclear Reactor Regulation
References
QAS-90-058, QAS-90-58, NUDOCS 9006210461
Download: ML20043H025 (2)

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- Garthersburg. Marylar1d 20877- 1454 (301) 258 3000 June 7, 1990 E. William Brach, Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Brach:

In a letter dated May 8, 1990, you provided to us Licensee Event Report (LER) No.89-018, Revision 1, dated February 28, 1990, which addressed the quality classification of certain electric equipment at Grand Gulf, Unit 1, and questioned reliance on an Instrument Index to determine the validity and bases of quality classifications. The letter stated that:

The NRC is concerned regarding the potential for inadequate classification and use of nonsafety-related equipment and the possible generic application this issue may represent with respect to other plants using this Bechtel service. Based upon these concerns, the NRC requests that you review this matter and respond to us regarding the potential for reportability pursuant to 10 CFR  !

Part 21. ,

We have reviewed this matter and have not identified any generic implications. First, the Instrument Index was not used to establish quality classification but rather was used for tracking and reference purposes of the classifications that had already been made. For Grand Gulf and other projects where Bechtel has performed the original

, design, the specifications and/or P& ids were used as the principal  ;

controlled documents which determined and recorded the QA requirements  !

for the instrumentation. Second, the classifications assigned to the electrical components at Grand Gulf were based on engineering judgment and standards, on a case-by-case basis. Finally, the LER itself shows there was no broad classification issue at Grand Gulf. Of more than 23,000 instruments reviewed only a fraction of one percent required further review for classification issues. ,

For the foregoing reasons, we have not' identified any implication with 1 respect to other plants, because the assignment of quality l t

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... i E. William Brach, Chief June 7, 1990 Page 2 1

i classifications was a project-specific activity and instrument indices 4 were not used to establish these classifications. 1 Sincerely, 1

i BECHTEL POWER CORPORATION Dinesh C. Kansal 1 Manager of Quality Assurance DCK/RHR/jms l

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