ML20134D774

Forwards Comments on Proposed Implementation Plan of ASME Code Case N-517

ML20134D774
Person / Time
Site:	Wolf Creek
Issue date:	01/31/1997
From:	Stone J NRC (Affiliation Not Assigned)
To:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
References
TAC-M97749, NUDOCS 9702050364
Download: ML20134D774 (5)

Text

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January 31, 1997 Mr. Otto L. Maynard President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 4Il Burlington, Kansas 66839

SUBJECT:

IMPLEMENTATION OF ASME CODE CASE N-517, WOLF CREEK GENERATING STATION (TAC N0. M97749)

Dear Mr. Maynard:

The NRC staff has reviewed the January 2, 1997, letter that described how Wolf Creek Nuclear Operating Corporation (WCN0C) intends to implement ASME Code Case N-517. The staff is in general agreement with your implementation plans. However, the staff has some comments on the proposed implementation pl an. These comments are enclosed.

Sincerely, Original Signed By James C. Stone, Senior Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-482 DISTRIBUTION:

-Docket File 9 EWoolridge, RES

Enclosure:

Comments PUBLIC BHermann PDIV-2 Reading BGallo cc w/ encl: See next page JRoe UPotapovs EGA1 LCampbell 0GC SBlack EPeyton WBateman JStone ACRS JDyer DOCUMENT NAME:97749RES.WC Ta receive a copy of tNo document, Indicate in the box: "C" = Copy without enclosures *E' = Copy with enclosures "N" = No copy 0FFICE LA/PD4-2 l PM/PD4-2 , d,j HQMB l8 ,

NAME EPeyton W JStone T' SBlack RG fe

' f DATE 01Eo/97 01/y /97 01/3, /97 I )

0FFICIAL RECORD COPY l gQ$$

000150 9702050364 970131 PDR ADOCK 05000482 P PDR

. Mr. Otto L. Maynard January 31, 1997 cc w/ encl:

Jay Silberg, Esq. Vice President Plant Operations Shaw, Pittman, Potts & Trowbridge Wolf Creek Nuclear Operating Corporation 2300 N Street, NW P. O. Box 411 Washington, D.C. 20037 Burlington, Kansas 66839 i

Regional Administrator, Region IV Supervisor Licensing U.S. Nuclear Regulatory Commission Wolf Creek Nuclear Operating Corporation l 611 Ryan Plaza Drive, Suite 1000 P.O. Box 411 Arlington, Texas 76011 Burlington, Kansas' 66839 i Senior Resident Inspector U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Resident Inspectors Office ,

P. O. Box 311 8201 NRC Road i Burlington, Kansas 66839 Steedman, Missouri 65077-1032  ;

l Chief Engineer Supervisor Regulatory Compliance Utilities Division Wolf Creek Nuclear Operating Corporation l Kansas Corporation Commission P.O. Box 411 i 1500 SW Arrowhead Road Burlington, Kansas 66839 l Topeka, Kansas 66604-4027 l 1

Office of the Governor State of Kansas Topeka, Kansas 66612 '

Attorney General Judicial Center 301 S.W. 10th 2nd Floor Topeka, Kansas 66612 f

County Clerk Coffey County Courthouse Burlington, Kansas 66839 Public Health Physicist Bureau of Air & Radiation Division of Environment Kansas Department of Health and Environment i

Forbes Field Building 283 Topeka, Kansas 66620 i

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IMPLEMENTATION OF ASME CODE CASE N-517 WOLF CREEK NUCLEAR GENERATING STATION NRR STAFF COMMENTS During a meeting on October 16, 1996, between Wolf Creek Nuclear Operating Corporation (WCN00) and the NRC to discuss the NRC safety evaluation, dated September 11, 1996, for WCNOC's use of Code Case N-517, WCNOC indicated that it would be submitting additional correspondence to the NRC concerning the use of Code Case N-517. By letter dated January 2, 1997,-WCN0C provided additional information describing how it will implement Code Case N-517 and identified elements and clarifications to be incorporated into its Updated Safety Analysis Report (USAR), Chapter 17.2, Quality Assurance (QA) Program to reflect the use of the code case. The following are the staff's comments on these proposed WCN0C QA Program elements and clarifications.

1. WCNOC Proposed 0A Proaram Element

, Qualification of material manufacturers and suppliers shall be in

accordance with the 1990 Edition, 1992 Addenda of NCA-3800.

Additionally, those material manufacturers and suppliers qualified by WCNOC will be evaluated to ensure effective implementation of their

quality assurance program.

NRC Comment i Item (b) of Section 5.0 of the NRC safety evaluation for the use of Code

Case N-517 addresses the above proposed text. Suppliers of safety-

related systems, structures, and components, including items supplied in accordance with NCA-3800, need to be evaluated to verify that they are effectively implementing their QA program. As discussed in the safety i evaluation and in the October 16, 1996, meeting, WCNOC needs to verify 4 that material manufacturers and suppliers, including those qualified by WCN0C and ASME that supply safety-related items in accordance with l NCA-3800, are effectively implementing their QA Programs.

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2. WCN0C Proposed 0A Proaram Element Upgrading of stock material shall be in accordance with NCA-3867.4(e).

NRC Comment

! The proposed text is consistent with item (c) of Section 5.0 of the NRC safety evaluation.

3. WCNOC Proposed 0A Proaram Element Acceptance of small products shall be stipulated in accord &nce with j NX-2610.

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NRC Comment The proposed text is consistent with Item (d) of Section 5.0 of the NRC '

safety evaluation, j

4. WCNOC Proposed 0A Proaram Element Activities defined above shall be performed in accordance with written procedures, instructions, or drawings and in accordance with the  ;

requirements of the USAR Quality Assurance Program. l NRC Comment

. l The proposed text is consistent with Item (e) of Section 5.0 of the NRC safety evaluation.

5. WCN0C Proposed 0A Proaram Clarificatjons On Page 2 of the attachment to its January 2,1997, letter to the NRC, WCN0C identified six clarifications or unique quality requirements  !

considered applicable when using Code Case N-517.  !

NRC Comment Item (a) of Section 5.0 of the NRC safety evaluation for the use of Code ,

Case N-517 addresses the need to identify the items addressed on Page 2 '

of the Attachment to the January 2, 1997, WCNOC letter. As discussed in  ;

the safety evaluation and in the October 16, 1996, meeting, WCN0C needs to incorporate the identified clarifications into its QA Program.

In addition to the proposed clarification on Page 2 on the Attachment to the January 2, 1997, letter, the WCN0C QA Program should state that when processing small products in accordance with NX-2610, the detailed plant procedures shall contain measures to provide assurance that the material is furnished in accordance with the material specification and with the applicable special requirements of the applicable ASME Section III Code i Subsection.

6. Additional NRC Comment Reference is made to performing an evaluation of material manufacturers and suppliers qualified by WCN0C and qualified by ASME. The evaluation of the material manufacturers and suppliers should be performed in order to verify that the organizations furnishing ASME Code items in accordance with NCA-3800 are effectively implementing their QA programs.

NRC Regulatory Guide 1.144, " Auditing of Quality Assurance Programs for  !

Nuclear Power Plants," Revision 1, dated 1980, and NRC Information ,

dotice (IN) 86-21, " Recognition of American Society of Mechanical Engineers Accreditation Program for N Stamp Holders," dated March 31, 1986, including its Supplements 1 and 2, issued on December ' 1986, and

O

. April 1, 1991, respectively, provide NRC positions on acceptable methods to verify that material manufacturers and suppliers are effectively implementing their QA programs.

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