ML20077P999

Transmits Request for Relief from Certain Requirements Delineated in Section XI of ASME Boiler & Pressure Vessel Code

ML20077P999
Person / Time
Site:	Wolf Creek
Issue date:	08/15/1991
From:	Bailey J WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NO-91-0224, NO-91-224, NUDOCS 9108200187
Download: ML20077P999 (4)

Text

c m m na u ;: a

.i LF CREEK W@ NUCLEAR OPERATING John A. Dailey n, pr.w.ni August 15, 1991 NO 91-0224 U. S. Nuclear Regulatory Cocnission ATTN:

Document Control Desk Mail Station F1-137 Washington, D. C.

20555

Subject:

Docket No. 50-482: Request For Relief Prom ASME Section XI Gentlemen:

The purpose of this letter is to transmit a request for relief from certain requirements delineated in Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code.

The attachment contains the request for relief which concerns ASME material *. hat was procured from another utility that does not pcssess a quality System Certificate issued from ASME.

The detai~a of the relief request were discussed with Mr. D.

V.

Pickett and other members of the Nuclear Regulatory Conmission Staff on August 8, 1991.

If you have any questions concern.ing this matter, please contact me or Mr.

H. K. Chernoff of my staff.

Very truly yours, b

John A. Bailey Vice President Operations JA5/nem Attachment cci L. L. Gundrum (NRC), w/a A. T. Howell (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a l

.! b U O t1 9108200187 910815 L

{DR ADOCK03OO{g2 RO. Box 411/ Burhrgton, KS 56839 / Pnone. (316) 364-8831 l

An Equa' Opportunity Empioye* M F.HcNET ava -

~-

n.

coa na 7c:z:

.ie a t 10

.a

=.-

C

1. Attachment to No 91-0224 Page 1 of 3 REQUEST FOR RELEIF

_Comeonent/ Material Identification American Society of Mechanical Engineers (ASME)Section III replacement disc for Class 1 check valve EP-8818A (Residual Heat Removal to Accumulator Injection Discharge Loop 1).

Descrietion The subject disc was procured as part of a disc arm assembly from Union j

Electric's callaway Plant and installed in December 1907 during the Wolf j

Creek Cenerating Station (WCGS) second refueling outage.

The disc was supplied to Union Electric as ASHE Section III material by Westinghouse Advanced Energy Systems Division (Westinghouse AESD) under contract by Westinghouse Nuclear Services Integrated Division (Vestinghouse NSID).

During the time frame in which the disc was supplied. Westinghouse AESD was an ASME Certificate holder and was qualified to supply ASME Section III

valves, valve parts and iatorials.

In accordance with ASME Section III rules (NA-3713, and NCA-9000 in late: Editions), Union Electric's activity of handling and storing the Abh Section III material and supplying it to Wolf Creek Nuclear Operating Corporation (WCNOC) would categorite Union Electric as an ASME Section III material supplier.

Recuested Relief Subarticle IVA-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 Westinghouse Design Specification 957894 and the ASME Code Data Report for valve EP-8818A,- this material was required to meet the 1974 Edition through Winter 1975 Addenda of ASME Section III.

Because WCNOC did not possess an ASME Certificate at the time of the procurement,Section III, subparagraph NA-3720(b) requires that WCNOC procure material from a material supplier that-holds a Quality System Certificate (QSC) issued by ASME..

Contrary to

.this requirement, WCNOC procured and installed.the supplier furnished check valve disc even though the supplier did not possess a QSC.

WCNOC in hereby requesting relief from the Code pursuant to 100FR50.55a(g)(6'(1) which

states,

'the Commission will evaluate determinations under paragraph (g)(5) of this section that Code requiraments are impractical"..

10CFR50.55a(g)(5)(iii) states that, "If the licensee has determined that conformance with certain Code requirements, is impractical for its facility, th3 licensee shall notify the Commission and submit...

information to support the determinations.' WCNOC has determined that the Code requirement for the subject instelled disc to have been furnished by a supplier that possesses a QSC, in order for the disc to be acceptable, is impractical and that no additional level of quality or safety would be obtained by replacing the installed disc with a disc which has _been furnished by an ASME QSC holder or N-type Certificato Holder.

Therefore, WCN00 is requesting that m n m m

4-vca na Ir:st it a: 1; 1

i e

'W 1

~

Attachment to NO 91-0224 page 2 of 3 i

the installed replacement disc be allowed to remain installed until such time when the disc would need to be replaced for maintenance or performance reasons.

Basis for Rollef WCNOC has determined that the installed replacement disc meets all technical requirements of the ASME Code.

Furthennero, although an administrative requirement of ASME Section III which is intended to assure quality use not

met, the quality acceptability of the disc rece!ved from Union Electric is not in question.

The basis for these statements le provided below.

Union Electric ordered the replacement disc from Westinghouse NSID.

O accordance with the provisions of the NSID Quality Assurance Program anu implementing procedure OPR 405.5,

" Renewal Parts Procurement and Supply System'.

WCNOC utilizes this same procurement process ar.d supplier for ordering Westinghouse replacement ita:a for WCGS and invokes the same NSID QA Program and OPR 405.5.

j l

Because both the Callaway Plant and wCGS weis SNUPPS plants, the subject check valve has the same identification number (EP-8818A) and was constructed to the same Code, specifications and drawing requirements for both plants. Therefore, the technical requirements of the disc arm assembly which contained the disc are the same for the Callaway Plant and WCGS.

WCNOC has vrrified that the WCNOC technical requirements for the disc were met by che Union Electric supplied replacement disc.

West!.nghous e NSID ordered the replacement disc from Westinghouse AESD.

Vest nghouse AESD had ASME N and NPT Certificates of Authorization at the time the replacement disc was providad. WCNOC has verified by review of the supplied documentation that Westinghouse AESD furnished the replacement disc as ASME Section III Class I material in compliance with ASMS Section III requirements.

Therefore, the replacement disc met Code requirements up to the point in tLae at which WCNOC ordered the disc from Union Electric.

The administrativs requirement of ASME Section III for material suppliers to possess a QSC is intended to assute the identification and traceability of material while in the material supplier's possession.

Union Electric maintained the disc arm assembly in accordance with their Quality Assurance Program while in storage at the Callaway Plant.

Union Electric procurement documents and receipt records provided with the disc material allowed WCNOC to verify traceability of the material chile in storage at the callaway Plant and verify the identity of the material and the accor.panying Certified Material Test Reports.

Therefore, even though Union Electric did not possess a QSC, WCNOC has verified that the Code certified material received by Union Electric was acceptably maintained while at the Callaway Plant and passed on to WCNOC.

WCNOC has performed a review of the records supplied by Union Electric and the. WCNOC receipt and installation records and has determined that the ASME i

Section III and ASME Section lI requirements have been met, tith the eingle j

exception that WCNOC placed the order with Union Electric even though Union Electric did not possess an ASME QSC.

i

.ncauw mm~uaa m 3

~

U w

i.,

Attachment to No 91 Cr>4 page 3 of 3 l

Additionally, as part of the WCGS Cheek Valve Degradation Program, EP-8818A was disassembled and inspected in April 1990 during the third refueling outage.

No degradation of the disc was identified as a result of this inspection.

To replace the disc *

• th one supplied by an ASMS QSC or N-type Certificate Holder would provide Jditional level of quality or safety.

Also, replacement of the t ac would unnecessarily increase the radiation dose to WCNOC workers and create unnecessary radwaste.

WCNOC therefore has concluded that replacement of the disc is impractical until such time as when the disc would need to be replaced for maintenance or performance reasons.

4 8

f f

I W

I,f

\\j ti

/,'

. l':

b

.t t

i i

6 i

a t.

4 4

1 A

A

• f 1.*

.$2Af L

- n% 611) MOM.

Sal \\dM o Mh1.Al a i rJ h i Vr?W9 l9^V'lf ![70