ML20115B005
| ML20115B005 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/03/1996 |
| From: | Muench R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ET-96-0048, ET-96-48, NUDOCS 9607090184 | |
| Download: ML20115B005 (3) | |
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WFLF CREEK NUCLEAR OPERATING CORPORATION l
. Richard A. Muench Vice President Engineering
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July 3, 1996 ET 96-0048 U.
S. Nuclear Regulatory Commission ATTN Document Control Desk Mail Station P1-137 Washington, D.
C.
20555
Subject:
Docket 50-482: Request for Use of Code Case N-517 Gentlemen:
Pursuant to the provisions of 10 CFR 50.55a (a) (3),
Wolf Creek Nuclear Operating Corporation (WCNOC) requests approval for use of ASME Section XI, Code Case N-517, " Quality Assurance Program Requirements for Owners," at Wolf Creek Generating Station.
Code Case N-517 provides an alternative to WCNOC's possession of an ASME NPT Certificate of Authorization in order to perform the following activities: 1) qualification of Material Manuf acturers and Material Suppliers in accordance with ASME Section III NCA-3800; 2) upgrading of stock material in accordance with ASME Section III NCA-3 86 7. 4 ( f) ; and 3) acceptance of small products in accordance with ASME Section III NB/NC/ND/NE/NF-2610(b) and (c).
WCNOC currently utilizes an NPT Certificate of Authorization in order to perform these activities.
There ir a significant economic hardship involved with maintaining the NPT Certificate of Authorization.
The ASME Boiler and Pressure Vessel Committee approved Code Case N-517 as an alternative to the ASME Section XI requirements in IWA-7210 on February 15, 1994.
IWA-7210 requires that owners meet Construction Code requirements when obtaining replacement materials.
WCNOC currently has quality assurance program provisions in place for performing these activities.
These quality assurance provisions have been reviewed and approved by the ASME Survey Teams during the initial survey in 1991 for issuance of the NPT Certificate and again during the 1994 renewal survey for renewal of the NPT Certificate.
These provisions will be revised to incorporate the additional requirements of Code Case N-517.
Use of Code Case N-517 will not affect the technical and quality assurance requirements used to determine the acceptability of material, but will eliminate the ASME Section III administrative requirements to have an ASME surveyed and approved quality assurance program for performing these activities.
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9607090184 960703 PDR ADOCK 05000482
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PDR RO. Box 411/ Burhngton, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Employer M F HC/ VET
'ET 96-0048 Page 2 of 2 Code. Case N-517 is not included.in the most. recent listing ' of NRC approved Code Cases in Revision 11 of ' Regulatory Guide 1.147, '" Inservice Int >pection Code Case Acceptability - ASME Section XI Division 1."
A copy of Code Case N-517 is enclosed for your convenience.
WCNOC con'siders the alternative provisions of Code Case N-517 to be ' a reasonable alternative ' to the existing requirements of ASME Section XI.
Because' the' use of the alternative affects only the ASME Section III administrative requirements for having, an ASME Section III Certificate of Authorization,' WCNOC considers this alternative to provide an. acceptable level of. quality and. safety.
Approval for use of Code Case N-517 is requested by September 6,
1996,. to support WCNOC's evaluation ' of renewal of ' the NPT Certificate of Authorization.
If you have any ' questions concerning this matter, please contact me ' at (316) 364-8831, extension 4034, or Mr. Terry S. Morrill at extension 8707.
Very truly yours, R$ Y Richard A. Muench RAM /jra Enclosure cc:
L. J. Callan'(NRC), w/e W. D. Johnson (NRC), w/e J.
F. Ringwald (NRC), w/e J.
C.
Stone (NRC), w/e
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CASE N-517 CASES OF ASME BOILER AND PRESSURE VESSEL CODE Approval Date: February 15,1994 See NumericalIndex for expiration and any restfirmation dates.
Case N-517 Case may be used by an Owner to perform the activities Quality Assurance Program Requirements for identified in the Inquiry, provided the following requim-Owners ments are met:
Section XI, Division I (a) This Case may be used only for the nuclear plants opetuted by the Owner performing these activities; Inquiry: What alternatives to possession of a Certifi-(b) The Owner's Quality Assurance Program cate of Authorization or Quality System Certificate (Ma-required by para. IWA 1400(n) shall describe how these terials), required by para. IWA-4170(c) and (d)' may be activities are controlled;
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used by an Owner to perform the following activities?
(c) When qualifying material manufacturers or ma-(a) Qualification of material manufacturers and sup-terial suppliers, the Owner shall use NCA-3800 of the pliers in accordance with NCA-3800; 1992 Edition with the 1992 Addenda; l
(b) Upgrading stock material iu accordance with (d) When accepting small products, the Owner shall NCA-3867.4(e) and (f);
perform the activities required of the Certificate Holder (c) Acceptance of small products in accordance with by NB/NC/ND/NE/NF-2610(b);
NB/NC/ND/NE/NF-2610(b) and (c).
(c) When upgrading stock material, the Owner shall perform the activities required of the Certificate Holder Reply: It is the opinion of the Committee that as an by NCA 3867.4(f);
alternative to possession of a Certificate of Authoriza-(f) Activities performed in accordance with this Case tion or Quality System Certificate (Materials), required shall be subject to monitoring by the Authorized Nu-by para. IWA-4170(c) and (d)', the provisions of this clear Inservice Inspector; (g) When upgrading stock material or accepting small products, use of this Case shall be recorded on a Certi-
'lWA 7210(b) and (c)in Editions and Addenda prior to the 1991 Ad-fled Material Test Report or a Certificate of Compli-denda.
ance, as applicable.
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