ML20059B768

Requests Code Case N-520 Approval for Nuclear Projects 1 & 3

ML20059B768
Person / Time
Site:	Washington Public Power Supply System, Satsop
Issue date:	10/20/1993
From:	Coleman D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO1-93-0032, GO1-93-32, GO3-93-151, NUDOCS 9310290091
Download: ML20059B768 (4)

Text

,

4 WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968

• 3000 George Washington Way

• Richland, Washington 99352 October' 20, 1993 G01-93-0032 G03-93-151 Docket Nos. 50-460 and 50-508 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D.C. 20555

Subject:

NUCLEAR PROJECTS NO.1 AND NO. 3 REQUEST FOR CODE CASE N-520 APPROVAL Washington Public Power Supply System Units 1 and 3 have been in a preservation mode since 1982 and 1983 respectively. Since that time, the ASME Certificates of Authorization have been maintained by resurvey every 3 years. Each renewal survey has becn performed in strict accordance with ASME Code requirements, including program demonstration. The level of Code activity at each facility has abated over time. Current physical construction activities are at a standstill, with only those activities required for preservation (including material storage, limited design activities, handling, and recor' keeping) being performed.

Code Case N-520 was prepared by the Supply System and has been submitted to the ASME for review and approval, as the need to perform construction type activities no longer exists during the preservation phase. This Code Case provides an alternative method of recertification for those nuclear power plants being maintained in a preservation mode pending restart of construction. Application of Code Case N-520 to defer resurveys until construction restart will also provide a great financial benefit to the utility by eliminating the cost of each resurvey.

Renewal of an applicant's "N" type Certificate of Authorization per Code Case N-520 accomplishes the following:

• Assures the ability of the owner of the facility to complete the program at a later date.

• Permits the "N" type Certificate Holder to continue to perform selected Code Activities and retain the ability to perform other Code activities upon successful completion of a full suncy prior to restart of additional Code activities (e.g., physical construction).

f 9310290091 931020 P' PDR ADOCK 05000460I' l P pyg ,j

U.S. Nuclear Regulatory Conaission Page Two REQUEST FOR CODE CASE N-520 APPROVAL

• Allows the current "N" type Certificate Holder to retain responsibility for work ,

performed to date without the need to complete Code Data Report Forms.

• Precludes the "N" type Certificate Holder from performing construction type (i.e.,

welding, field erection, testing) activities while this Code Case is in effect.

• The significant savings to the plant permits the "N" type Certificate Holder to maximize its available resources in maintaining the program.

• The current Preservation Program would remain unchanged with no degradation of quality.

All of the above can be accomplished at a high level of quality by the "N" type Certificate Holder, in a cost effective manner, through an increased interface with the applicable Authorized Inspection Agency. This is also a specific requirement of the Code Case. In addition,' under the conditions of the Code Case, any changes to the program must be approved by the Society (ASME).

The Society is in the final stages of the approval process, having approved the Code Case through the committee procedure. ASME will now issue a letter ballot to confirm the verbal approval. Following this approval, the Code Case is then sent to the Board of Nuclear Codes and Standards .for final approval. The Washington State Jurisdictional Representative has been apprised of the pending Code Case and has indicated full support for its use at these sites.

The current Certificates of Authorization expire on June 21,1994, requiring either application for resurvey by December 20,1993, or invocation of the Code Case in lieu of resurvey. With the time involved with the final approval process and the plants' limited time schedule for renewal, the Supply System requests that upon approval by the Society, Code Case N-520 be authorized for use at WNP Units 1 and 3 under the provisions of 10CFR50.55a(3) prior to official endorsement in NRC Regulatory Guide 1.84. The Supply System recognizes that while this request for endorsement of the Code Case is somewhat premature, the time constraints imposed by the renewal requirements dictate accelerating the endorsement process. We will commit to keeping your office apprised of any changes to the text of the Code Case.

1

l U.S. Nuclear Regulatory Commission Page Three REQUEST FOR CODE CASE N-520 APPROVAL Your expeditious response will be appreciated.

Sincerely, blTitLg)

D. W. Coleman, Acting Manager Regulatory Programs (PE20)

DWC\LCO:llw Attachment cc: Mr. W. L. Bryan, Washington Water Power Co.

Mr. R. E. Dyer, Portland General Electric Co.

Mr. J. R. Lauckhart, Puget Sound Power & Light Co.

Mr. J. R. Lewis, Bonneville Power Administration (399)

Mr. D.P. Steinberg, Pacificorp dba Pacific Power & Light Co.

Ms. R. M.Jenkins, Ebasco - Elma Ebasco - New York Mr. M. M. Mendonca, U.S. Nuclear Regulatory Commission Mr. N. S. Reynolds, Winston & Strawn Mr. B. N. Faulkenberry, U.S. Nuclear Regulatory Commission Mr. C. E. Revell, BPA (399)

Mr. N. C. Kierulff, BPA (399)

NRC Site Inspector (927N)

Mr. D. Barkdoll, State Boiler Inspector

x ._ _a.. s-a - - -a g - a e 4

t Cnse N-520 Alternntive Rules for Renewn! of N-type Certifientes for Plants Not in Active Construction Inquiry: What alternative requirements the renewal of the Certificate shall .acconpany the - ,

~

(NCA-8100) may be used for the renewal of N-type application.

Certificates of Authorization held by the Owner / Designee / Certificate Holder of a nuclear power (h) The renewal application shall include a plant where fabrication and installation activities at the complete listing of any Code activities to be Owner's site have been intenupted? performed. A Certificate providing for activities to meet the provisions of NX-2000, NX-4000, NX-5000, -

Replyt It is the opinion of the Committee.that and NX-6000 shall not be issued without a survey by an N-type Certificate of Authorization (applicant) the Society, referenced in the Inquiry may be renewed without a survey of the applicant's facilities by the Society, (i) At least six months prior to performance of provided the following alternative rules are met: any Code activities not listed in the last renewal application, to meet the provisions of NX-2000, NX-(a) The applicant shall notify the Society and the 4000, NX-5000, and NX-6000 the N-type Certificate Authorized Nuclear Inspection Agency ofits intent to use Holder shall apply to the Society for a renewal survey.

this Code Case.

(b) The applicant is responsible for documenting compliance with the provisions of NCA-Il40.

(c) The Quality Assurance Program previously accepted by the Society shall be continually implemented ,

(NCA 8140) and any revisions to the program shall be acceptable to the Authorized Nuclear Inspection Agency.

(d) All revisions to the Quality Assurance Manual -

shall be reviewed and accepted by the Society prior to implementation.

(c) An agreement with an accredited Authorized Nuclear Inspection Agency shall be maintained by the N-type Certificate Holder in accordance with NCA-8130.

(/) In addition to the duties specified in NCA-5000, the Authorized Nuclear Inspection Agency shall verify the applicant's activities through audits of the applicant's facilities on a semi-annual basis. Repons of the semi-annual audits shall be forwarded to the Society for review. <

l (g) Not later than six months prior to the date of  !

l expiration of the N-type Certificate, the applicant shall apply for renewal of the certificate. The renewal application shall reference this Code Case. A letter from the Authorized Nuclear Inspection Agency recommending .)

l l

l 1