ML20078R942
| ML20078R942 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/21/1994 |
| From: | Hagan R WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| VT-94-0047, VT-94-47, NUDOCS 9412280023 | |
| Download: ML20078R942 (3) | |
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W$LF CREEK NUCLEAR OPERATING CORPORATION Robert C. Hagan Vce President Techncal Services December 21, 1994 VT 94-0047 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555
Reference:
Letter WM 94-0102, dated July 26, 1994, from N. S. Carns, WCNOC, to L. J. Callan, NRC
Subject:
Docket No. 50-482: Operational Quality Assurance Program Change Pursuant to 10 CFR 50.54 (a) (3) - Quality Assurance Records Storage Requirements Gentlemen This letter provides a revision to a Quality Assurance Program change documented in the reference. Wolf Creek Nuclear Operating Corporation -(WCNOC) has decided to revise the previous submittal and take an exception to Regulatory Guide 1.88 for Quality Assurance records storage requirements rather than make commitments to ANSI N 45.2.9 - 1979. This revision has been discussed with Mr. R. Pate of NRC Region IV office, on November 2, 1994. I l
WCNOC proposes to revise the referenced submittal and change the Updated Safety Analysis Report to reflect an exception to the commitments to Regulatory Guide 1.88, " Collection, Storage and Maintenance of Nuclear Power I Plant Quality Assurance Records" for the fire rating of Quality Assurance i records storage facilities only. Regulatory Guide 1.88 endorses ANSI N 45.2.9 - 1974 for storage facilities. This ANSI standard requires ;
facilities to be Class A fire rated with a recommended four-hour minimum rating. The record storage facilities at Wolf Creek Generating Station (WCGS) l have two hour minimum rating. This rating is consistent with the guidance provided in previously NRC endorsed ANSI NOA 1983. Pursuant to 10 CFR 50.54 (a) (3) , this revised change has been evaluated by WCNOC and has been determined to be a reduction in commitments made in the approved Quality Assurance Program because WCNOC does not meet the requirements of ANSI N 45.2.9 - 1974. However, based on that evaluation, WCNOC has also determined the change does not reduce the Quality Assurance Program and the Quality Assurance Program continues to satisfy the criteria of Appendix B of 10 CFR Part 50 because Quality Assurance records continue to be protected from the effects of fire in a manner accepted by the NRC and the industry.
01OD[6 9412280023 941221 e o. Bo= 4ii i Buri.naton. Ks esea9 e enone: <ais) 384 8831 Equal opportunity Employer MF/HC/ VET O@ '
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4 VT 94-0047 Page 2 of 2 A copy of the change to the Updated Safety Analysis Report (page 3A-38) has been attached reflecting the proposed wording for this change. If you have any questions concerning this matter, please call me at (316) 364-8831 extension 4553 or Mr. Richard D. Plannigan at extension 4500.
Ve truly yours, j- / .
Robert C. Hagan RCH/jra Attachment cc: L. J. Callan (NRC), w/a D. D. Chamberlain (NRC) , w/a J. P. Ringwald (NRC) , w/a J. C. Stone (NRC), w/a ,
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' Attachment 1 to VT 94-0047
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REGULATORY GUIDE 1.8& REVISION 2 DATED 10/76 f- Collection, Storage, and Maintenance of Nuclear Power Plant l Quality Assurance Records i
DISCUSSION:
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The recommendations of Regulatory Guide 1.RR are met with the following interpretations and exceptions:
- a. Section 2 of ANSI N45.2.9 establishes requirements for records required by codes, standards, specifications, or regulatory requirements. The WCGS implements this requirement by specifying what is a QA record, based l upon the following criteria:
- 1. Those documents which would be of significant value in demonstrating capability for safe operation.
1 2 Those documents which would be of significant value l in maintaining, reworking, repairing, replacing, or modifying the item.
f 3. Those documents which would be of significant value in determining the cause of an accident or malfunction of an item.
- 4. Those documents which provide baseline data for inservice inspection.
l 5. Those documents which show evidence that safety-related activities were performed in accordance with applicable requirements.
l b. Receipt of individual records will be acknowledged only when requested by the forwarding organization at the time of final transfer.
! c. ANSI N 45.2.9-1974 states that a records storage facility's structure, doors, frames and hardware should be Class A Fire Rated, with a recommended four-hour minimum rating. The record storage facilities at WCGS have a two hour minimum rating.
The Westinghouse position for all of WRD, except the NFD on Regulatory Guide 1.88, is presented in WCAP-8370, "WRD Quality Assurance Plan." For activities which occurred during the period from January 1, 1975 to September 30, 1977, the position is presented in WCAP-8370, Revision 7A. For activities which occurred from October 1, 1977 to October 31, 1979, the position is 3A-38 Rev. l