ML101390560
| ML101390560 | |
| Person / Time | |
|---|---|
| Issue date: | 06/03/2010 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| R. A. Jervey, RES/DE/RGDB, 301-251-7404 | |
| Shared Package | |
| ML100160002 | List: |
| References | |
| DG-1215 RG-1.028, Rev 4 | |
| Download: ML101390560 (2) | |
Text
6/3/2010 Page 1 REGULATORY ANALYSIS Proposed Revision 4 of Regulatory Guide 1.28, Quality Assurance Program Criteria (Design and Construction)
Statement of the Problem Significant improvements have been made to NQA-11 since 1985 when the U.S. Nuclear Regulatory Commission (NRC) endorsed Regulatory guide (RG) 1.28, Revision 3. These improvements have been incorporated into the standard through the issuance of NQA-1a-2008 Addenda to NQA 20082. The NRC has also consolidated the expectation for a quality assurance (QA) program for nuclear power plants into one document. A new standard review plan section on QA programs entitled, Quality Assurance Program Description-Design Certification, Early Site Permit, and New License Applicants, (see Section 17.5 of NUREG-08003), contains the NRCs consolidated expectations. NUREG-0800, Section 17.5 references NQA-1.
Additionally, the NRC has issued generic letters and bulletins to establish new guidance or to clarify guidance in problem areas within QA programs. Also, alternatives that the NRC has approved as part of the licensing process needed to be addressed so that applicants and licensees are aware of them for their consideration when reviewing or revising their QA programs. This proposed RG 1.28, Revision 4, is needed to incorporate appropriate new features from the generic letters and bulletins, and to address the alternatives approved as part of the licensing process.
Objective The objectives of this regulatory action are as follows:
Present NRC guidance on QA programs.
Endorse changes to QA requirements developed through the consensus process.
Establish a new point of broad reorientation and update for NRC guidance related to QA.
Provide more detailed guidance to support the implementation of Section 17.5 of NUREG-0800.
Alternative Approaches The NRC staff considered the following alternative approaches:
Do not revise RG 1.28.
Update RG 1.28.
1 ANSI/ASME NQA-1-1983, Quality Assurance Program Requirements for Nuclear Power Plants, American National Standards Institute/American Society of Mechanical Engineers, New York, NY.
2 ASME NQA-1-2008, Quality Assurance Requirements for Nuclear Facility Applications, American Society of Mechanical Engineers, New York, NY.
3 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (LWR Edition),
Section 17.5, Quality Assurance Program DescriptionDesign Certification, Early Site Permit, and New License Applicants, Revision 0, U.S. Nuclear Regulatory Commission, Washington, DC, January 2006.
6/3/2010 Page 2 Alternative 1: Do Not Revise Regulatory Guide 1.28 Under this alternative, the NRC would not revise this guidance, and the original version of this regulatory guide would continue to be used. This alternative is considered the baseline or no-action alternative and, as such, involves no value/impact considerations.
Alternative 2: Update Regulatory Guide 1.28 Under this alternative, the NRC would update Regulatory Guide 1.28, taking into consideration the updated NRC guidance for review of QA programs and changes to QA requirements developed through the consensus process.
One benefit of this action is that it would enhance reactor safety by providing licensees with the latest guidance for QA program requirements in one consensus standard.
The impact to the NRC would be the costs associated with preparing and issuing the regulatory guide. The impact to the public would be the voluntary costs associated with reviewing and providing comments to the NRC during the public comment period. The value to the NRC staff and its applicants would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for license applications and other interactions between the NRC and its regulated entities.
Conclusion Based on this regulatory analysis, the staff recommends that the NRC revise RG 1.28. The staff concludes that the proposed action will enhance reactor and fuel cycle safety by providing licensees with the latest guidance for QA program requirements in one consensus standard. It could also lead to cost savings for the industry, especially with regard to applications for standard plant design certifications and combined licenses.