ML17145A285

Comment (2) of Mark A. Richter Regarding Comments on Draft Regulatory Guide DG-1326 Quality Assurance Program Criteria (Design and Construction) Docket Id NRC-2017-0079

ML17145A285
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/22/2017
From:	Richter M Nuclear Energy Institute
To:	Cindy Bladey Rules, Announcements, and Directives Branch
References
82FR15242 00002, DG-1326, NRC-2017-0079
Download: ML17145A285 (3)

Text

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~I MARK A. RICHTER, PH.D.

Senior Project Manager, '

Fuel and Decommissioning Programs 1201 F Street, NW, Suite 1100 Washington, DC 20004 NUCLEAR ENERGY INSTITUTE P: 202.739.8106 mar@nei.org nei.org g/~7'j~J7 t c:2.J r ;( /0 'o2 4-~ .JJ ~~:.:"'~ -i May 22, 2017 Ms. Cindy K. Bladey Chief, Rules, Announcements, and Directives Branch g r-n

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Subject:

Comments on Draft Regulatory Guide DG-1326 "Quality Assurance Program Criteria (Design and Construction)" Docket ID NRC-2017-0079 Project Number: 689 Dear Ms. Bladey~

In a March 27, 2017 Federal Register Notice (82FR15242), the U.S. Nuclear Regulatory Commission (NRC) requested public comments on Draft Regulatory Guide DG~ 1326, "Quality Assurance Program Criteria (Design and Construction)" The proposed DG revision updates guidance to endorse, with clarification or exceptions, multiple revisions of the American Society of Mechanical Engineers standard NQA-1 titled "Quality Assurance Requirements for Nuclear Facility Applications." The proposed revision describes methods that the NRC considers acceptable for establishing and implementing a quality assurance program for the design and construction of nuclear power plants and fuel reprocessing plants. Nuclear Energy Institute (NEI) 1 appreciates the opportunity to submit the attached comments, on behalf of the industry, for NRC consideration.

The attached comments include suggested changes to statements identified DG-1326, intended to improve clarity and reduce potential ambiguities. Since Regulatory Guides are not used to express a new NRC position, this proposed revision is not imposed upon licensees and its use is voluntary.

1 NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy industry.

SUNS! Review Complete NUCLEAR. CLEAN AIR ENERGY Template= ADM -013 E-RIDS= ADM-03 Add= fl-* 'j/~~ (_qclj?J_)

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Ms. Cindy Bladey May 22, 2017 Page 2 If you have any questions or require additional information, please contact me at 202-739-8106, mar@nei.org.

Sincerely, Mark A. Richter, Ph.D.

Comments on DG-1326 "Quality A.ssurance Program Criteria (Design and Construction)"

ID Section, Comment Proposed Page,* Resolution and Line#

1 Sec: C.1.a(l) The alternative demonstration of ability discussed in this Include the following statement at the end of the section (taken Page 6 section should include a statement concerning acceptance from NQA-1, Requirement 2, Section 303.3): "Such of this demonstration. demonstration shall be subject to review and acceptance by the organization responsible for quality assurance audits and / or the certifying authority prior to their use for qualification."

2 Sec: C.3.b(l)(e) "Random inspections" is non-specific and may lead to. NIRMA TG 15-2011, Section 8.4.5 provides suggested specific Page 7 different interpretations of what is required. actions and intervals and should be recommended as the basis for any review of possible record degradation.

3 Page4, As stated, this sentence appears to equally assign Change "provide the most current guidance for QA" to "provide Background, preference to NQA-lb-2011 Addenda to ASME NQA-1 2008, adequate guidance for QA".

first paragraph, NQA-1 2012, and NQA-12015 above all previously endorsed last sentence revisions of NQA-1.

4 Page 6, Audit Comparable industry experience may be very loosely Allow flexibility that is more in line with NQA-1, requirement 2, Participation (1) translated. Translation could offer latitude that may allow section 303.3, such as:

qualification of individuals who lack the in-field practice Prospective lead auditors must participate in at least one necessary to perform as a lead auditor.

nuclear audit within the year preceding the date of qualification.

Participation in independent assessments may be used to satisfy the other four quality assurance audits required within a period of 3 years prior to the date of qualification, provided that

.the activities can demonstrate the following:

Independence from the functional areas being assessed .

• Planning that establishes the scope of the activities and evaluation criteria.

.* Performance by technically qualified personnel.

Results that are documented and reported .

• Appropriate corrective action initiated and tracked to resolution.