ML20034B441
| ML20034B441 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/17/1990 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-90-0062, WM-90-62, NUDOCS 9004270159 | |
| Download: ML20034B441 (5) | |
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W44.F CREEK NUCLEAR OPERATING CORPORATION amt o. www.
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April 17, 1990 WM 90-0062 l
l U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137
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Washington, D. C.
20555
Subject:
Docket No. 50-482: Request for Relief Concerning Procurement of ASME Section III Materials
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Gentlemen f
The purpose of this letter is to transmit a request for relief from certain l
requirements delineated in Section XI of the American Society of Mechanical l
Engineers (ASME) Boiler and Pressure Vessel Code.
The attachment contains a request for relief from ASME Section XI and resulting Section_ III requirements regarding procurement of ASME Section III materials from i
ven'. ors who are not ASME certificate holders, j
i If you have any questions concerning this matter, please contact me or Mr.
l H. K. Chernoff of my staff.
Very truly yours,
.Bart D.' Withers President and F
Chief Executive Officer ii BDW/aem
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Attachment I
cc R. D. Martin (NRC), w/a D. Persinko (NRC), w/a D. V. Pickett (NRC),w/a
'i M. E. Skow (NRC), w/a h
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F F DC PO. Bom 411/ Swfmpon, KS 66s39 / Phone: (316) 3644s31 An Equal opportrey Employer MS/HC/ VET l
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Attachment to WM 90-0062 Pag'e 1 of 4 CG(POWENT/ MATERIAL IDENTIFIC&YION American Society of Mechanical Engineers (ASME)Section III materials used i
in ASME Section XI Repairs and Replacements.
l DESCRIPTION I
The term ' material' as used herein is the ASME Section III use of the ~ term.
5 It is defined as metallic materials which are manufactured to an ASME Section II, SA, SB, or SFA specification or other material specifications allowed by ASME Section III.
Material does not include parts or t
components.
Parts are items which have work performed on them requiring i
verification by an Authorized Nuclear Inspector and which are subsequently
. i stamped with the ASME Section III NPT stamp and are accompanied by a Code Data Report.
Parts either attach to or become a portion of a component.
Components are completed N-type stamped items such as vessels, pumps and valves and are accompanied by a Code Data Report.
j REQUESTED RELIEF Subarticle IWA-7210 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....'.
In accordance with the design specifications governing the construction of Wolf Creek Generating Station (WCGS), materials are required to mest a variety of Editions of AbME Section III depending upon the specific component in which the materials are-used.
These Editions are predominately the 1974 and 1977 Editions with various Addenda.
Section III subarticle NA-3700 (or NCA-3800) requires amterial manufacturers and material suppliers to hold a quality System Certificate issued by ASME or have their programs surveyed, qualified and audited by an N-type Certificate Holder or Quality Systems Certificate (QSC)-
Holder.
Parsuant to 10CFR50.55a(a)(3).
Wolf Creek Nuclear Operating Corporation (WCNOC) is hereby requesting relief from ASME Section XI IWA.
7210 and the resulting administrative and quality requirements of Section III NA-3700/NCA-3800 which preclude WCNOC from qualifying and procuring materials from material manufacturers and material suppliers who do not possess a QSC.
WCHOC proposes that full compliance with the administrative and quality requirements of NA-3700/NCA-3800 of Section III results in hardship and unusual difficulties without a compensating increase' in the level of quality and safety over that provided by the alternatives contained in this relief request and that the alternatives contained in this relief request provide an acceptable level of quality and safety.
ALTERNATIVES i
In lieu of the requirements of Section III which require ASME QSC or Certificate of Authorisation Holders involvement in the qualification of material manufacturers and material suppliers who do not possess a QSC, WCNOC proposes the following alternatives:
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Attachment-to WM 90-0062 I
Page 2 of 4
- 1) If WCNOC selects vendors who do not possess an ASHZ QSC i
or Certificate
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of Authorization to furnish ASME materials for Section XI Repair'and Replacements, WCNOC will qualify and audit these vendors (except as provided in (5) below) to assure the adequacy.of these vendors' quality-F assurance programs and appropriate implementation of these programs la the manufacture and supply of materials :
- 2) Although not required by the 1974 and 1977 gditions of ASME Section III, WCNOC will utilize annual audits during'the' interval in which-WCN00. is obtaining material from these vendors, as required by the_ Winter 1977.
Addanda and later Editions and Addenda.
Ir. accordance with Regulatory-Guide 1.144 Rev.
1 and the provisions of Section III NCA-3125,; VCNOC may utilize audits performed by other organizatione, but WCNOC maintains!
responsibility for the qualification of these vendors supplying unterial for WCNOC use
that material meets-the requirements of ASME Esction III. except as!
modified by this relief request t
- 4) WCNOC will perform these activities under the.previsions of - th'e NRC approved WCGS Quality Assurance Programs-and
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need not audit the quality assurance programs utilized by.thooe plante.
WCNOC considers these nuclear power plants as being qualifiedLauppliers on-the basis of the implementation of their QA programs in: accordance with 10 CFR 50 Appendix B.
WCN00 will assure that these materials meet the requirements of Section III.-
except.au modified by this. relief.
E request.
BASIS FOR RELIEF q
Due to the decline in nuclear power plant orders in the.Uniteu States, many material manufecturers and material suppliers have allowed,their ASME QSC to; expire and many component manufacturers have allowed their N-type certificate of Authorization to expire.. Consequently, it is increasingly
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difficult for WCNOC to procure materials for use in ASME Section XI repairs and replacements.-
Although not allowed by the administrative - and - quality
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requirements of Section III, other currently available sources for materials include other nuclear power plants who do not possess a QSC,
-material-
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manufacturers and material suppliers who E8ve a quality assurance program-but do not have a QSC, and component manufacturers who have allowed: their ASHE N-type Certificate of Author.ization-to expirec I'
The difficulties being experienced by WCNOC can be illustrated by the' l
following examples WCNOC is currently having problems with procurement of replacement ASME materials for the Standby Emergency Diesel Generators.
l-The original manufacturer, Colt Industries, let their N-type; Certificate of.
Authorization expire.
The Colt supplied drawings and vendor manuals'often describe items by part number and description but do not have adequate ASME.
description nor manufacturing details. WCNOC must try to obtain description
Attachment to VM 90-0062 Page 3 of 4 and details from Colt and supply this information to other vendors who possess an ASME QSC or Certificate of Authorization.
Colt often considers these details to be proprietary.
Although WCNOC can procure replacement parte and components from Colt under the provisions of Generic Letter 89-09, the replacement ASME materials are not covered by the Generic Letter and must be procured from a vendor who has an ASME QSC or N-type certificate of Authorization.
Another example involves procurement of ASME materials from typical mater 3al supply companies.
If WCNOC finds the needed materials at a supplier who does not have a QSC, the procurement Imst be placed with an intermediate third-party supplier who possesses a ASME QSC.
This third party may procure the materials from the WCNOC identified non-QSC supplier.
The alternatives proposed in this relief request would resolve these L
examples by allowing WCNOC to qualify the vendors and aske the desirable direct procurements.
ASME Section III uses the terms
' Quality System Program" and
" Material Identification and Verification Program" to identify limited scope quality assurance programs covering the scope of activities performed by material
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manufacturers and material suppliers.
ASME Section III NA-3720/NCA-?820 requires that ASME verify the adequacy of the Quality System Program of the material manufacturer or the Material Identification and Verification Program of the material supplier before issuing a QSC.
Alternatively,Section III provides that an organization who holde a QSC or a Certificate of Authorization may survey, qualify and audit the quality assurance programe of material manufacturers or material suppliers and procure materials from them without requiring the material manufacturer or material supplier to hold a QSC.
The involvement of an ASME certificate holder in the qualification ar.d audit process is intended to assure that appropriate quality assurance program requirements are utilir-d in the manufacture ard supply of ASME materials.
Under the scope of AShh section III the ASKE N-type Certificate of Authorization Holder, as the ucer of the material, hse the final responsibility for the adequacy of the materials during the construction of new components.
The WCNOC Quality Assurance Program which has been approved by the NRC provides equivalent assurance that appropriate quality assurance program requirements are utilized in the manufacture and supply of materials.
Included within the scope of the WCNOC QA Program are measures for qualification and audit of vendors, procuremant document control measures, measures to verify the acceptability of procured items, measures to identify and control procured items and measures to control stored iterc.
These provisions are used by WCNOC to qualify vendors and procure,
- accept, and store non-ASME safety-related materials.
These provisions are waually adequate to allow WCNOC to qualify vendors not holding a QSC and procure and accept materials from these vendors for ASME Section XI repairs and replacements. No additional level of quality or safety would be obtained by the involvement of an ASME certificata holder.
Since Section III administrative and quality requirements for new construction allow a certificate holder to qualify non-QSC material manufacturers and material suppliers, it is our position that WCHOC, as the Licensee ultimately responsible for acceptance of items at WCGS, should be allowed to qualify non-QSC material manufacturers and material suppliers for operation phase ASME Section XI repair and replacement.
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i Attachment to WM 90-0062 Pag'e 4 of 4 Another source of ASME materials is other nuclear power plants who may have the needed materials in storage. These nuclear power plants are classified as material suppliers under the rules of 'ASME Section III and would be required to have a QSC or have their Material Identification and Verification (MIEV) Program qualified and audited by-a QSC or Certificate of Authorization Holder.
This MIEV ProgramLis essentially a limited scope QA Program covering those activities associated - with = procuring, receiving,-
identifying,
- storing, and controlling material.
Although other nuclear power plants may not passess'a QSC issued by ASME, -they do havo-full scope QA programs used to assure all procured safety-related items comply =with specified requirements.
These QA programs are implemented in accordance with 10 CFR 50 Appendix B and are periodically audited and inspected by utility QA organizations and the NRC.
As a result,.these QA programs are adequate to control those activities associated with procuring, receiving.
identifying, storing and controlling-ASME materials.
Therefore. as noted in the proposed alternatives of'this relief requent, WCNOC will not audit other nuclear power plants but considers them as qualified suppliers on.the basis of the implementation of their QA programs in accordance with 10 CFR 50 Appendix B.
WCNOC will verify that the material received from other nuclear power plants meets the requirements of Section III, except as modified by this relief request.
Additional basis for this relief request is provided by letter dated October 2, 1989, in which the NRC approved a'WCNOC relief request to procure'
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Swagelok and Unistrut materials for ASME Section XI repair and replacement-and by NRC Generic Letter 89-09.
The NRC approval of the Swagelok/Unistrut relief request was specific to those two vendors but provides support-for granting the generic relief requested herein.-
Approval of this generic relief request precludes the need for additional relief requests related to i
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other specific material procutements.
NRC Generic Letter 89-09 documents the difficulties nuclear powet plants are having obtaining replacement N-type stamped components and provides generic relief from the requirements of Section III for ASME parts and components.
However, 'theLGeneric Letter does not provide relief applicable to procurement of A,SME Materials.
In many cases, nuclear power plants need to procure ASME materials-from component manufacturers who have let their Certificates.of Authorization expire. This relief request provides alternatives to Section III applicable to the procurement of m terials not. covered by the Generic Letter.
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