ML20133E510

Forwards Description of Implementation of ASME Code Case N-517,per Response to NRC SER Approving Use of Subject Code

ML20133E510
Person / Time
Site:	Wolf Creek
Issue date:	01/02/1997
From:	Maynard O WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CO-96-0103, CO-96-103, NUDOCS 9701130058
Download: ML20133E510 (3)

Text

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Otto L Maynard l Chief Administrative Offcer January 2, 1997 CO 96-0103 U. S. Nuclear Regulatory Commission l ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555 References 1) Letter ET 96-0048, dated July 3, 1996, from R. A. Muench, WCNOC, to USNRC ,

2) Letter dated September 11, 1996, from USNRC, to N. S.

Carns, WCNOC

Subject:

Docket No. 50-482: Response to Nuclear Regulatory Commission Safety Evaluation Report Approving the Use of ASME Code Case N-517 at Wolf Creek Generating Station j Gentlemen:

Reference 1 transmitted Wolf Creek Nuclear Operating Corporation's (WCNOC)

-request to use ~ASME Code Case N-517, " Quality Assurance Requirements for Owners," at Wolf Creek Generating Station (WCGS). Reference 2 provided approval of Code Case N-517 at WCGS contingent upon conditions specified in the Safety Evaluation Report. -

On October 16, 1996, WCNOC personnel met with members of the NRC Staff to discuss WCNOC's intent to utilize ASME Code Case ' N-517 The Attachment provides information describing how WCNOC will implement ASME Code Case N-517.

If you should have any questions regarding this response, please contact me at (316) 354-8831, extension 4450, or Mr. Terry S. Morrill at extension 8707.

Very truly urs, n>>

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Otto L. Maynard OLM/jad Attachment cc: L. J. Callan (NRC) , w/a W. D. Johnson ~ (NRC) , w/a ' 5,

_ J. F. Ringwald (NRC) , w/a -

d h h. % Stone (NRC), w/a 9701130058 970102 PDR ADOCK 05000482 \

P PDR \

PO. Box 411/ Burlington, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Employer M F HC VET

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WCNOC personnel met with the NRC staff on October 16, 1996, to discuss WCNOC's intent to utilize the ASME Code Case N-517 in place cf the NPT Certificate, and the NRC Safety Evaluation Report (SER) approving its use at WCNOC, At this meeting, the NRC staff clarified that their intent was not for the Updated Safety Analysis Report (USAR) to detail the entire program, but to reflect the use of specific elements of Code Case N-517 in the USAR (Reference I 2). During the meeting, the NRC staff noted the SER was in error in the second paragraph of page 6, where it stated: "NCA-4130 provides additional discussion of Section III Code activities that are required to be discussed in the FSAR QA Manual ." The NRC staff indicated that it was not the intent of the SER that the USAR contain the level of detail required by NCA-4000(Quality Assurance Requirements).

WCNOC will revise the USAR Quality Assurance Program, Chapter 17.2, to reflect the use of Code Case N-517. Specific elements that will be a part of this revision are as follows:

• Qualification of material manufacturers and suppliers shall be in l accordance with the 1990 Edition, 1992 Addenda of NCA-3800 Additionally, those material manufacturers and suppliers qualified by WCNOC will be evaluated to assure effective implementation of their quality assurance j program. i

• Upgrading of stock material shall be in accordance with NCA-3867.4(e). l

• Acceptance of small products shall be as stipulated in accordance with NX-2610 (b) .  !

• Activities defined above shall be performed in accordance with written procedures, instructions, or drawings and in accordance with the i requirements of the USAR Quality Assurance Program.

Additionally, during this meeting the NRC staff stated that use of the Code Case N-517 eliminates the requirement for accreditation, and requires owners to meet other Section III requirements, including unique Section III provisions in NCA-4000. WCNOC disagrees with this interpretation of the requirements of Code Case N-517. However, WCNOC agrees to abide by the NRC staff interpretation of Code Case N-517. Therefore, WCNOC is providing this information to further define how certain requirements of NCA-4000 will be addressed.

WCNOC performed a review of the quality assurance requirements of NCA-4000 in the 1980 Edition, Summer 1982 Addenda of the ASME Code. This Edition and Addenda was chosen because it is the last addenda prior to invoking the requirements of NQA-1; WCNOC does not currently implement NQA-1. The WCNOC Quality Assurance Program will comply with the requirements of NCA-4000, as it is applicable to the scope of Code Case N-517, with the following clarifications:

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The Authorized Nuclear Inspector (ANI) is involved in the WCNOC Quality Assurance Program, procedures, instructions, and drawings. The Quality Assurance Program and documents generated through this program are available to the ANI for his review.

• Evaluation of a material manufacturer or material supplier qualified by WCNOC will be performed annually. Evaluation of a material manufactu;er or material supplier that is qualified by ASME, will be performed on a triennial basis.

When upgrading stock material, WCNOC utilizes a process whereby the upgrade is documented on an upgrade request and the results are documented on a material verification test plan. This process satisfies the requirements of the checklist as detailed in NCA-4134.8 for stock ret. This process is detailed in plant procedures.

• Processing of small products through the provisions of NX-2610 (b) will be documented as required on Certified Material Test Reports or Certificates of compliance. This process is detailed in plant procedures.

• The ANI is involved in the processing of code material through the documentation review prior to the use of the material. Therefore, specific requirements for the use of hold points is not applicable to the scope of Code Case N-517.

• NCA 4134,18 requires that the minimum audit frequency be specified in the Certificate Holder's Quality Assurance Manual. It is WCNOC's intent that the elements of Code Case N-517 will be included in the Purchasing and Material Services audit conducted as outlined in Section 17 2.18 of the USAR operating quality program. This audit is currently conducted every 2 years as outlined in Technical Specification 6.5.2.8 (d) .