ML18275A097
| ML18275A097 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 10/01/2018 |
| From: | Richter M Nuclear Energy Institute |
| To: | Maureen Wylie NRC/OCFO |
| Hudson, Sharon | |
| References | |
| Download: ML18275A097 (2) | |
Text
MARK A. RICHTER, PH.D.
Senior Project Manager, Used Fuel and Decommissioning Programs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8106 mar@nei.org nei.org October 1, 2018 Ms. Maureen E. Wylie Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Fee Exemption Request for review endorsement of ISO/IEC 17025: 2017, "General Requirements for the Competence of Testing and Calibration Laboratories" Project Number: 689
Dear Ms. Wylie:
On November 30, 2017, ISO (International Organization for Standardization) published a new version of ISO/IEC 17025, "General Requirements for the Competence of Testing and Calibration Laboratories." In order for nuclear utilities and their suppliers to continue to utilize the ILAC process during commercial grade dedication of calibration and testing services, the nuclear industry must first gain the USNRC acceptance of ISO/IEC 17025:2017. The Nuclear Procurement Issues Corporation (NUPIC) in conjunction NEI1 is seeking the NRC's endorsement of ISO/IEC 17025:2017.
On October 1, NEI submitted a letter documenting the NUPIC/NEI Committee performance of a detailed review of the 2005 and 2017 versions of ISO/IEC 17025 to substantiate that the ISO/IEC 17025:2017 does not reduce technical commitments or quality requirements. This review verified that the major changes were essentially formatting and additions which enhance the ISO/IEC 17025 standard. A Requirements Traceability/Cross Reference Matrix (Attachment 2) was developed to perform this review. As a result, the NEI/NUPIC Committee concluded that the ISO/IEC 17025:2017 is equivalent to, or better than, ISO/IEC 17025:2005 in technical and quality requirements. The NUPIC/NEI Committee is requesting endorsement of ISO/IEC 17025:2017 by the USNRC on behalf of the nuclear industry during the three year transition period ending November 30, 2020 where either standard will be acceptable for use.
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. NEIs 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.
Ms. Maureen Wylie October 1, 2018 Page 2 We request that the NRC's review of ISO/IEC 17025: 2017, "General Requirements for the Competence of Testing and Calibration Laboratories," be granted a fee waiver pursuant to the provisions of 10 CFR 170.11.
The report meets the exemption requirement in 10 CFR 170.11(a)(1)(iii) in that it is a means of exchanging information between industry organizations and the NRCfor the specific purpose of supporting ongoing NRC generic regulatory improvements or efforts. In this case, the generic regulatory improvement is the NRCs endorsement of an updated international standard used by nuclear utilities and their suppliers to enable continued utilization of the ILAC process during commercial grade dedication of calibration and testing services.
Please contact me should you have any questions.
Sincerely, Mark A. Richter Attachments