ML20078R942
| ML20078R942 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/21/1994 |
| From: | Hagan R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| VT-94-0047, VT-94-47, NUDOCS 9412280023 | |
| Download: ML20078R942 (3) | |
Text
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1 W$LF CREEK
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NUCLEAR OPERATING CORPORATION Robert C. Hagan Vce President Techncal Services December 21, 1994 VT 94-0047 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C.
20555
Reference:
Letter WM 94-0102, dated July 26, 1994, from N. S. Carns, WCNOC, to L. J. Callan, NRC
Subject:
Docket No. 50-482: Operational Quality Assurance Program Change Pursuant to 10 CFR 50.54 (a) (3) - Quality Assurance Records Storage Requirements Gentlemen This letter provides a revision to a Quality Assurance Program change documented in the reference. Wolf Creek Nuclear Operating Corporation -(WCNOC) has decided to revise the previous submittal and take an exception to Regulatory Guide 1.88 for Quality Assurance records storage requirements rather than make commitments to ANSI N 45.2.9 - 1979.
This revision has been discussed with Mr. R.
Pate of NRC Region IV office, on November 2, 1994.
WCNOC proposes to revise the referenced submittal and change the Updated Safety Analysis Report to reflect an exception to the commitments to Regulatory Guide 1.88,
" Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records" for the fire rating of Quality Assurance i
records storage facilities only.
Regulatory Guide 1.88 endorses ANSI N 45.2.9 - 1974 for storage facilities.
This ANSI standard requires facilities to be Class A fire rated with a recommended four-hour minimum rating. The record storage facilities at Wolf Creek Generating Station (WCGS) have two hour minimum rating.
This rating is consistent with the guidance provided in previously NRC endorsed ANSI NOA 1983.
Pursuant to 10 CFR 50.54 (a) (3), this revised change has been evaluated by WCNOC and has been determined to be a reduction in commitments made in the approved Quality Assurance Program because WCNOC does not meet the requirements of ANSI N 45.2.9 - 1974.
However, based on that evaluation, WCNOC has also determined the change does not reduce the Quality Assurance Program and the Quality Assurance Program continues to satisfy the criteria of Appendix B of 10 CFR Part 50 because Quality Assurance records continue to be protected from the effects of fire in a manner accepted by the NRC and the industry.
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e o. Bo= 4ii i Buri.naton. Ks esea9 e enone: <ais) 384 8831 9412280023 941221 Equal opportunity Employer MF/HC/ VET l
PDR ADOCK 05000482
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4 VT 94-0047 Page 2 of 2 A copy of the change to the Updated Safety Analysis Report (page 3A-38) has been attached reflecting the proposed wording for this change.
If you have any questions concerning this matter, please call me at (316) 364-8831 extension 4553 or Mr. Richard D.
Plannigan at extension 4500.
Ve truly yours, j-
/
Robert C. Hagan RCH/jra Attachment cc:
L. J. Callan (NRC), w/a D. D. Chamberlain (NRC), w/a J.
P. Ringwald (NRC), w/a J. C. Stone (NRC), w/a l
s b
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' Attachment 1 to VT 94-0047
~Page.1 of 1 l
REGULATORY GUIDE 1.8&
REVISION 2 DATED 10/76 f-Collection, Storage, and Maintenance of Nuclear Power Plant l
Quality Assurance Records i
DISCUSSION:
(
The recommendations of Regulatory Guide 1.RR are met with the following interpretations and exceptions:
a.
Section 2 of ANSI N45.2.9 establishes requirements for records required by codes, standards, specifications, or regulatory requirements. The WCGS implements this requirement by specifying what is a QA record, based l
upon the following criteria:
1.
Those documents which would be of significant value in demonstrating capability for safe operation.
1 2
Those documents which would be of significant value l
in maintaining, reworking, repairing, replacing, or modifying the item.
f 3.
Those documents which would be of significant value in determining the cause of an accident or malfunction of an item.
4.
Those documents which provide baseline data for inservice inspection.
l 5.
Those documents which show evidence that safety-related activities were performed in accordance with applicable requirements.
l b.
Receipt of individual records will be acknowledged only when requested by the forwarding organization at the time of final transfer.
c.
ANSI N 45.2.9-1974 states that a records storage facility's structure, doors, frames and hardware should be Class A Fire Rated, with a recommended four-hour minimum rating. The record storage facilities at WCGS have a two hour minimum rating.
The Westinghouse position for all of WRD, except the NFD on Regulatory Guide 1.88, is presented in WCAP-8370, "WRD Quality Assurance Plan."
For activities which occurred during the period from January 1, 1975 to September 30, 1977, the position is presented in WCAP-8370, Revision 7A.
For activities which occurred from October 1, 1977 to October 31, 1979, the position is 3A-38 Rev.
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