ML19325C888
| ML19325C888 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/02/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19325C826 | List: |
| References | |
| NUDOCS 8910180021 | |
| Download: ML19325C888 (4) | |
Text
{{#Wiki_filter:- \\iy. l.Y \\'g - NUCLEAR REGULATORY COMMISSION UNITED STATES h. f WA&HING TON, D. C. 20666 6-SAFETY EVALUATION BY THE OFFICE OF-NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF FROM CERTAIN REQUIREMENTS DELINEATED IN ASME SECTION XI ' WOLF CREEK NUCLEAR OPEP.ATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482 .l. INTRODUCTION In a lette dated December 13, 1988, and as supplemented on February 3, 1989, the licensee submitted two requests for relief from certain requirements in Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. Subarticle IWA 7219 of ASME Section XI states in part, " Replacements shall meet the requirements of the edition of the Construction Code to which the original component or part was constructed." The first request for relief involves material purchased from Unistrut Diversified L-Products which is used in ASME, Section 111, Subsection NF supports for ASME Class 2 and 3 instrument tubing. For Wolf Creek, this material is required to meet the 1977 Edition of ASME Section !!!. The second request involves the purchase of ASME Section 111 Class 2 and 3 stainless steel Swagelok compression type instrument fittings 3/4" nomintl pipe size and less. This material is required to meet the 1974 Edition up to and including the summer 1975 Addenda of ASME Section III. ASME Section III NCA-3820 in the 19'? Edition anc NA-3720 in the summer of 1975 Addenda both require that flaterial l Manufacturers and Material Sup)11ers either hold a Quality System Certificate (QSC) issued by AStiE or have tieir quality systems programs surveyed and . ualified by an N-type Certificate Holder, p q y II. RELIEF REQUEST #1 - PURCHASE OF UNISTRUT PRODUCTS Unistrut Diversified Products (Unistrut) is the Materials Supplier of strut channels, standard strut fittings, threaded fasteners and washers which are L used for ASME Class 2 and 3 instrument tubing supports. Unistrut does not possess a QSC. During the construction phase of the Wolf Creek plant, the ? Installer of these supports was the Daniel International Corporation (DIC) which'did possess an N-type cortificate. In accordance with ASME Section III, ECA-3820, Dic qualified Unistrut's quality program. Subsequent to the end of the construction phase in July 1984, Dit was no longer under contract as the Installer. As a result, curing the startup and operations phases of the Wolf Creek plant, the licensee has procured material from Unistrut without the ' involvement of an ASME Certificate Holder. The licenste is requesting relief h 8910180021 891002 DR ADDCK 050 2 a
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from the ASME code requirement for all past and future procurements of Unistrut i uterial wMch did not and will not involve an ASME Certificate Holder. The licensce's easts for this request is discussed in Section IV below. !!!. RELIEF REQUEST #2 - PURCHASE OF 3/4" AND LESS SWAGELOK COMPRESSION TYPE $5TRUMENTFITTINGS This request is similar to Relief Request #1 except that in this case, both of the Materials Manufacturers, Cajon and Crawford Valve and Fitting Companies sosses a QSC. The local distributor of these fittings is Kansas City Valve and ritting (KCV) which is the Materials Supplier but does not have a QSC. The Daniel Intersational Corporation was also the Installer for these fittings during the cotistruction phase and qualified the Supplier's quality program in accordance with ASME Section III, NA-3720. As in Relief Request #1, DIC was no longer involved after the end of construction in July 1984, and the licensee continued to purchase these fittings from the Materials Supplier without the involvement of an ASME Certificate Holder. The licensee was forced to purchase the Swagelok fittings from the Material Supplier because the Materials Manu-facturers Caion and Crawford, sell their prcducts through a strict distribution L system and refuse to sell directly to any user. Instead, they supply the fittings to a Swagelok authorized sales and service representative, who carries a diversified local inventory of Swagelok products. The licensee's orders are required to be placed with this local representative, which is KCV. The licensee is requesting relief.from the ASME Code requirement for all past and future procurements of Swagelot fittings inanufactured by Cajon and Crawford i Valve and Fitting Cortpanies but supplied by a distributor which does not possess a QSC. The licensee's basis for this request is discussed below. IV. LICENSEE'S BASIS FOR RELIEF, REQUESTS Subsequently to July 1984, when the N-type Certificate Holder, DIC, was no longer involved, the licensee maintains that it had met the applicable ASME Section III, 1977 Edition requirements by performing the following actions. An initial qualification of quality programs of both Unistrut and KCV was conducted by the licensee's quality personnel in August 1984, to assure elements t L of 10 CFR Part 50, Appendix B. This was performed untilizing pre-establ4hed l checklists and documented as a Quality Assurance (QA) Program Manual Evaluation. l This initial qualification included evaluation of on-site audits previously performed by DIC to qualify the two Materials Suppliers quality programs. These evaluations by the licensee were utilized to establish the initial I. credibility of the Suppliers with respect to furnishing ASME material. Following the initial qualification, annual off-site evaluations of both l Suppliers' QA Program Manuals were performed by the licensee in accordance L with Position 3.b(2) of Regulatory Guide 1.144, " Auditing of Quality Assurance l l l
f,jy j y r ,, f. f P Programs for Nuclear Power Plants. In addition periodicon-siteauditswhich wereconductedbythelicenseeexceededtheinitlaiauditperformedbythe N-type Certificate Holder DIC in that the DIC audit only concentrated on the programandmaterialrequIremen,tsofASMESectionIII.NA-3700&NCA-3800. The licensee's audits have not only duplicated the DIC audits, but have also concentrated on the following: -1.. The technical requirements of the design specification. i 2. Configuration control of the items supplied. 3. Procurement requirements unique to Wolf Creek. L 4. Industry and trend information with respect item / material performance. c 5. The basis of supplier certification. 6. Noncenforraance control - specifically 10 CFR Part 21 evaluations and 1 reportability perforned by the suppliers. The information in I through 6 above is not typically covered by an ASME i survey perforned to NA-3700 & NCA-3800 requirements. If these relief requests are approved, the licensee has comnitted to perform similar audits of Unistrut and KCV annually, which is also beyond the requirements in the 1977 Edition of l ASME Section III. The licensee maintains controlled copies of the QA Program tianuals. Purchase i orders to the two suppliers invoke requirements which assure that all changes } to the QA Progran fianuals are approved by the licensee. The licensee further points out that although KCV has been included in its audits, the KCY quality program requirements are significantly less than Unistrut's )rogram because all KCV material is furnished by Crawford and Cajon who are boti QSC Holders. The licensee's audits have also included Crawford and Cajon, although ASME Section III does not require a QSC Holder to be audited. 4 V. STAFF EVALUATION AND CONCLUSION On the basis of the information in Section IV above, the staff has concluded that for past and future procurements of Unistrut material and Swagelok fittings the licensee has demonstrated that it successfully performed and will perform the activities related to material supply and quality assurance which are required to be performed by an ASME Section III Certificate Holder. The staff has further concluded (1) that the licensee's QA audit program has met and will meet the requirements in 10 CFR 50.55a(3)(1) by implementing alternatives to ASME Section XI rules for replacements which have provided and will provide an acceptable level of quality and safety and (2) that there is reasonable assurance that the health and safety of the public will not be endangered by these alternatives. Therefore, the staff finds that for past procurements, which includes those shelf items that are being maintained as spare parts, the relief requests discussed in Section 11 and III above are acceptable. The staff understands that the ASME is planning to review the existing ASME Section III Code requirements pertaining to this specific type of relief with r n ,,v.- -,--,---,-.-.,-.c.,-,--,v.,-,
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L i [ 4-the objective of reconmending Code changes to accommodate such requests. Therefore, for future procurerents, the staff finds that the relief discussed in Section 11 and III can be granted on a three year interim basis pending i such changes. It is expected that after three years following the date of- - this safety evaluation, the licensee will evaluate any changes made to the ASME Section III. Code requirements and determine whether relief in this area is l still applicable. In the interim, the licensee is encouraged to explcre other options of procuring replacement parts. i Date: October 2, 1989 1 Principal Contributors: H. Brammer E. Baker E. Sullivan D. Pickett W. Brach 5 5 1 l r 1 s J l I e %-d n v v ,cw---- ,e --e, = - ~ - - -}}