ML20099L719
| ML20099L719 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/27/1995 |
| From: | Maynard O WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WO-95-0189, WO-95-189, NUDOCS 9601020283 | |
| Download: ML20099L719 (6) | |
Text
_ _ _ _ - _ _ _ _.
e WQLF CREEK NUCLEAR OPERATING CORPORATION Otto L. Maynard Vice President Plant operations December 27, 1995 WO 95-0189 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D.
C.
20555
Reference:
Lettor ET 95-0112 dated October 31, 1995, from R.
C. Hagan to USNRC
Subject:
Docket 50-482: Clarification to Requeat for Use of Code Case N-532 Gentlemen:
Pursuant to the provisions of 10 CFR 50.55a (a) (3),
Wolf Creek Nuclear Operating Corporation (WCNOC) requested, by submittal of the Reference, approval for use of ASME Section XI, Code Case N-532,
" Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000," at Wolf Creek Generating Station, with one exception regarding reporting of corrective measures.
In a December 7, 1995 telephone conference call with Mr.
Jim Stone and NRC Technical Reviewers, WCNOC agreed to supplement and supersede our previous request as described below.
Code Case N-532 provides an alternative to the current ASME Section XI repair and replacement documentation requirements as well as regulatory reporting requirements relating to Inservice Inspection (ISI).
This alternative will reduce the resources required to prepare NIS-2 forms and prepare and submit the ISI Summary Report currently required after each refueling outage.
This is a significant reduction in the administrative burden required by IWA-6000.
The use of Code Case N-532 only affects documentation and reporting requirements and does not affect the level of quality or safety provided by the Inservice Inspection Program.
Code Case N-532 was approved by the ASME Boiler and Pressure Vessel Code Committee on December 12, 1994, but is not included in the most recent listing of NRC approved code cases in Revision 11 of Regulatory Guide 1.147,
" Inservice Inspection Code Case Acceptability - ASME Section XI Division 1."
A copy of Code Case N-532 is attached for your convenience.
The NRC Staff has made recommendations supporting the development of Code Case N-532 in SECY-94-093 "NRC Staff Assessment of Reporting Requirements for Power Reactor Licensees."
The use of Code Case N-532 is consistent with the recommendations of SECY-94-093.
9601020283 951227 PDR ADOCK 05000402 Qg O
PDR I
PO Box 411/ Burlington, KS 66839 / Phone (316) 364-8831 020.100
~~e-r -c-i t i
WO 95-0189 Paga 2 of 2 This request to use Code Case N-532 includes compliance with the code case with the following clarification regarding reporting of " corrective measures."
A6ME Section XI uses the term, " corrective measures," in two different. ways.
One use of the term involves Code required activities such as repair and replacement.
The other use of the term, as used in IWX-3000, involves maintenance activities that do not involve repairs or replacements. With this clarification, WCNOC proposes not to report corrective measures which only 1
include routine mtintenance activities such as tightening threaded fittings to eliminate leakage, torquing of fasteners to eliminate leakage at bolted connections, replacing valve packing due to unacceptable packing leakage, tightening loosened-mechanical connections on supports, adjustment and realignment of supports, cleanup of corrosion on components resulting from leakage, etc.
Including these routine maintenance activities in the OAR-1 form required by Code Case N-532 would be a significant expansion of current requirements.
In addition, it would be an unnecessary reporting burden and provides little benefit.
Reporting of these minor maintenance corrective measures has no safety significance and clutters the reporting of the meaningful information of repairs, replacements, and evaluations performed to accept flaws and relevant conditions. exceeding Section XI acceptance criteria.
Corrective measures which refer to Code required activities, such as repair and I
replaccnent, will be reported in compliance with Code Case N-532.
Therefore, use of Code Case N-532 is requested with the above clarification regarding the provisions in paragraph 2 (c) for reporting corrective measures.
WCNOC considers the alternative documentation and reporting requirements of Code Case N-532 to be a reasonable alternative to existing requirements.
Because the use of this alternative only affects documentation and reporting requirements, WCNOC considers this alternative to provide an acceptable level-of quality and safety.
Approval for use of Code Case.N-532, with the noted clarification, is requested to support the refueling outage scheduled to begin in early March 1996.
If you have any questions concerning this matter, please contact me at (316) 364-8831, extension 4450, or Mr. Richard D. Flannigan at extension 4500.
Very truly yours, 0$/
ape /
Otto L. Maynard OLM/jra Attachment cc:
L. J. Callan (NRC),.w/a W.
D.
Johnson (NRC), w/a J.
F. Ringwald (NRC), w/a J.
C. Stone (NRC), w/a
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N-532 CASES OF ASME BOILER AND PRESStJRE VESSEL CODE k
l i
Approval Date: December ia,1994 See Nurneric Index for experation and any reememenon deeen.
i
{
Case N 532 (e) The completed Form NIS 2A shall be main.
Alternative Requirements to Repair and tained by the Owner.
2 Replacement Documentation Requirements and (f) The Owner shall maintain an index of Repair /
Inservice Summary Report Preparation and Replacement Plans in accordance with IWA4340.
Submission as Required by IWA 4000 and IWA-The index shall identify the identification number
}
60001 required by (b) above and the inspection interval and Section XI, Division 1 Period during which each repair or replacement was i
completed.
Inquuy What alternatives may be used to the re.
I 20 OWNER'S AC. IVITY REPORT T
quirements of IWA-4910(d) and IWA4210(e) for i
completion of Form NIS 2 following repair or re-PREPARATION AND SUBMITTAL placement, and IWA4210(c) and (d), IWA4220, An OWNER'S ACTIVITY REPORT FORM IWA4230(b), (c), and (d), and IWA4240(b) for OAR 1 shall be prepared and certified upon com-(
preparation and submittal of the inservice summary pietion of each refueling outage. Each Form OAR-report and Form NIS 17 1 prepared during an inspection period shall be sub-mitted following the end of the inspection period.
Reply: P. is the opinion of the Committee that as Each Form OAR 1 shall contain the following:
)
an alternative to the requirements of IWA 4910(d),
(a) Abstract of applicable examinations and tests IWA4210(c), (d), and (e), IWA4220, IWA 6230(b),
with the information and format of Table 1.
(c), and (d), and IWA-6240(b), the following provi-(b) A listing of item (s) wii flaws or relevant con.
4 sions may be used. This Case shall be utilized at least ditions that required evalaation to determine ac-i until the end of the inspection period in which it was ceptability for continued service, whether or not the invoked.
flaw or relevant condition was discovered during a scheduled examination or test. De listing shall pro-1.0 CERTIFICATION OF THE REPAIR OR vide the information in the format of Table 2. -
}
REPLACEMENT (c) Abstract for repairs, replacements and correc-(a) De Owner's Repair / Replacement Program tive measures perfonned, which were required due j
shallidentify use of this Case.
to an item containing a flaw or relevant condition (b) A Repair / Replacement Plan shall be prepared that exceeded IWB 3000, IWC 3000, IWD 3000, in accordance veith IWA-4140', and shall be given a IWE 3000, IWF 3000, or IWL 3000 acceptance cri-unique idedfication number.
teria; even though the discovery of the flaw or rele-(c) Upon completion of all required activities as.
vant condition that necessitated the repair, replace-sociated with the Repair / Replacement Plan, the ment or corrective measure, may not have resulted i
Owner shall prepare a REPAIR / REPLACEMENT from an examination or test required by this Division.
CERTIFICATION RECORD, FORM NIS 2A.
If acceptance criteria for a particular item is not i
(d) Form NIS 2A shall be presented to the speci6ed in this Division, the provisions o" IWA-Inspector for certification.
3100(b) shall be used to determine which repairs, replacements, and corrective measures are required
(
.AH references to IWA-4000 and IWA.6000 used in this Case refer to be included in the abstract. He abstract shall pro-to the 1992 Edition.
vide the information in the format of Table 3.
929 supp.5i _ uc l
4 4
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__ _____ CASE (continued)- - - -- -
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' N-532 CASES OF ASME BOILER AND PRESSURE VESSEL CODE 1
l
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FORM NIS 2A REPAIR / REPLACEMENT CERTIFICATION RECORD l
OWNER'S CERTIFICATE OF CONFORMANCE I certsfy that the restesent by Repew/Reo6scement reone or; Plan numeer conforme to the rogueremente of Seccon XL Type Code Symool Stamo Certificate of Authonsecon No.
l Empiration Date Signed Date
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owner er ownere cemenee, rise I
CERTIFICATE Or INSEIMCE INSPECTION
- t. the undefeigned, holding a vaW commession leeued by the National Board of Soller and Pressure Vesselinecoctore and the State or Province of and emotoyed try of have mopected the nome oeecneed 6n Receirateolecement Plan number dunne the sened to and state that to the best of my knowledge and belief, the Owner has performed all the activitmo descr eed in ene RepairiRentecement Pien in accorcance with the reeuwemeens of Seenon XI.
By signing tnte ceraficem nortner tne insoector nor his empiover rnekee any warranty. empressed or emphed, concoming the activet6ee desenbod in the Repow/Rectacement Plan. Furthermore, nenhor the 6nopector not his employer sheti be hable 6n erry menner for spy personal infury or procefty demoge or lose of any kind eriemg from or connected with this inspecton.
Commrosione essessereS e e feemenee seers. Easte. Prennse, one Eneernemones Date This form (E00128) may os obtemed from the Order Coot., ASME. 22 Low Drive. Som 2300. Fairfield. NJ 07007 27,00.
SUPP.11 - NC N
CASE (c ntinued)
N-532 CASES OF ASME BOILER AND PRESSURE VESSEL COIE
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VgficATE OF INSERVICE INSPECTION
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meessner nor rue emperor enes ne heese m en, menwr ter saw sersons swry or erocerer osmoge or e toes of any eme supng from er eennesees wnn the.
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Thss term tE001271enev se sensees from me Oreer Dest., ASME. 22 Law Onve. Ses 2300. Feeeeed. NJ 07007 2300.
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931 SUPP.11 - NC O
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. N-532
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CASES OF ASME BOILER AND PRESSURE VESSEL CODE j
TABLE 1 A8STRACT OF EXAMINATIONS AND TESTS Total Total Total Total Esaminattens Esamenstlens Esaminadens Esaminations Crested (%)To Esarn6aation koodsed for Crested for Csedhed (%).
Date der The Catsgery The Interves nas Pwled Fw m Peted latwwas Rome,te i
TABLE 2 ITEMS WITH FLAWS OR RELEVANT CONDITIONS THAT
]
REQUIRED EVALUATION FOR CONTINUED SERVICE Flaw Flaw or Relevant Cenetien Feens Examination item Item Characterization During Scheduled Secuen XI Catsgery Neunber Descreden (IWA 330M Examinaden or Test (Y.s er No)
TABLE 3 A8STRACT OF REPAIRS, REPLACEMENTS, OR CORRECTIVE MEASURES REQUIRED FOR CONTINUED SERVICE Flaw or Reinant Candidon Found
- Receir, Dwing Scheduled Reglassment,Section XI Asse6p/
Code or Correcthe item Descreden Esaminaden or Date Regiacement Class seenswo Ossanodon of Werk Test (Yes/No)
Complete Plan Number i
suPP.11 - NC 932
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