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1 JUL 2 41979 MEMORANDUM FOR:
W. M. Morrison, Assistant Director for General Engineering Standards, Division of Engineering Standards, SD FRON:
Walter P. Haass, Chief, Quality Assurance Branch, Division of Project Mana9ement
SUBJECT:
QAB C0iMENTS ON PROPOSED REGULATORY GUIDE 1.XXX (RS-704-4)
At the meeting of the Interoffice QA Task Force in my office on June 6,1979, you provided copies of the subject proposed regulatory guide for task force review. This guide is intended to resolve the dichotomy that has developed since promulgation of Appendix B to 10 GR 50 regarding the applicability of the QA criteria in Appendix B to all the structures, systems, and components addressed in the GDC of Appendix A.
The QAB has reviewed the guide and offers the following comments:
1.
The guide attempts to establish equivalency between the definitions of "important to safety" (see second sentence of first paragraph of the Introduction to Appendix A) and " safety-related" (see third, fourth, and fifth sentences of the first paragraph of the Introduction to Appendix B) as applied to structures, systems, and components of in-terest to NRC that are included in nuclear power plants. While it may not have been the intent of the writers of these regulations to establish a difference -in the meaning of these tems, users of these regulations, namely NRR revie: rs and industry personnel, have per-ceived a difference and have based many decisions regarding the need and extent of QA requirements for specific items in a nuclear power plant on this difference.
One major result of this perception is the establishment of a list of specific SSC's (i.e., the Q-list) tn which the provisions of Appendix B are applicable.
At this point in time, we.ind it extremely difficult to see how NRC, through the mechanism of a regulatory guide with its inherently lower stature, can obviate these perceived differences in definitions without a corresponding change in the regulations. The proposed regulatory guide does not merely provide guidance on how to implement the regulations, which is its normal function, but rather attempts to modify the meaning of_ the regulations to be different than they have been perceived to be 3 or f
several years.
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2-W. M. Morrison 2.
The approach proposed for resolving the Appendix A/ Appendix B problem in the subject regulatory guide is viewed by the QAB to be excessively simplistic and, consequently, of little use to QAB reviewers and, we think also, to IE inspectors.
In discussions we have had with QA representatives of utilities, A-E fims, and reactor vendors on this subject, it is our understanding that presently very little QA is imposed on items derived from Appendix A but not on the Q-list. Their responses to our questions on how much QA is applied
[ generally are like, "We don't know," "Very little," or'" Commercial practice" although the staff would generally agree that, at a minimum, the require-ments of GDC #1 (Appendix A) are applicabig. As an example, when we asked a fcmnal question en the QA requironents imposed on the Offsite Power System (i.e., the electrical switchyard located onsite but outside plant buildings) on a particular project, we were far from satisfied with the fomal response.
Therefore, QAB is concerned that, absent more specific guidance on the QA requirements for non-Q-list items, utilities could, under the proposed regulatory guide, sieply add the new items to the Q-list and justify no further QA requirements by citing application of the graded approach (s'ee lines 117 and 118 of the proposed regulatory guide). Conversely, some utilities would escalate the QA requirements to the point where all Appendix B requirements would be imposed (as you state in lines 45 through 47 of the subject guide). What we really believe to be necessary is a QA program with requirements somewhere between these extremes and we believe the quickest and surest way to achieve this is by establishing clear guidance that defines,
the level of QA requirements necessary. Otherwise, the utilitias and their contractors would establish a wide range of QA requiraaents for a specific item that only after years of jawboning in meetings, discussions, and inspec-tions would converge to the level we believe is appropriate.
3.
The proposed regulatory gui:de gives no guidance regarding the determination of what additional SSC's should be included on the Q-list. We have no specific suggestions to nffer at this time, but we believe a set of criteria defining "the SSC's that provide reasonable assurance that the facility can be operated without undue risk to the health ard safety of the public" needs to be developed and included in the guide. The general, nonspecific nature of the wording in the GDC's of Appendix A establishes a clear need for such guidance. Further, the items to be added to the Q-list are not always simply SSC's; we strongly believe that pertinent design data (e.g., " ology" me~asuremer?s derived during site investigations), consumables, and other such items should be included.
This is recognized to some extent in lines 111 through 115 of the proposed guide.
We believe the criteria for detennining those "SSC's that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public" are fairly well in hand (Regulatory C-uide 1.29), although scme may disagree. The criteria presented in proposed Regulatory Guide 1.XYZ are more definitive, however.
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W. M. Morrison 4.
Other questions that come to mind and appear to require investigation when
" safety-related" and "important to safety" are equated are:
a.
Is the scope of the reporting of defects and noncompliances under Part 21 affected?
b.
Is the scope of the deficiencies reporting rule under-10 CFR'50.55(e) affected?
1 c.
Are the SIP, standard fomat guide, and other regulatory guides affected?
5.
Other commeilts of a more minor nature have not been identified in this memo.
They will be provided when the issues we consider to be more significant, as described above, are resolved.
Alternate Approach -
In lieu of the approach to resolving the Appendix A/ Appendix B problem presented in the subject regulatory guide, we recommend that an alternate approach be con-sidered that retains the existing definitions for "important to safety" and " safety-related" and provides c-clear definition of the QA requirements we believe are appropriate fnr non-Q-listed Appendix A SSC's to be added to the program. The latter definition would serve as a QA programatic " umbrella" for the Appendix A SSC's fran which the requirements for a specific SSC could depart, cs appropriate, using the graded approach in a mnner analogous to the current use of the Appendix 8 " umbrella" for safety-related SSC's. This approach muld pmvide a more oefini-tive target for utilities in establishing QA requirements for these kinds of SSC's '
and would also assist our IE inspectors in determining whether NRC requirements were being specified and met. The new SSC's from Appendix A could be included within the Appendix B program but subject to the QA programatic requirements defined by the new " umbrella."
In the past year or so. QAB has developed censiderable background and experience in developing graded QA programs for various activities and items for which NRC is responsible. Primary examples are QA for radioactise material transportation containers (for NHSS) and QA for research programs (for ES).
In each of these cases, we have utilized the acceptance criteria given in SRP Sections 17.1 and 17.2 as a starting point and, based on the objectives and characteristics of the activity / item under consideration, made judgment decisions regarding the need for each acceptance criterion in the QA program. We believe a similar approach could be applied to developing a QA "tsnbrella" program for "important to safety" SSC's and, with the agreement of the Intemffice QA Task Force and other NRR management, are prepared to undertake such a develppment. This QA
" umbrella" or checklist could be part of a new regulatory guide that would provide guidance to industry. The new guide would also include criteria for determining the SSC's that should be subject to the requirements of the check-list as noted in cannent 3 above.
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W. M. Morrison.
We are available for additional discussion on our cocments. We suggest an early meeting of the Interoffice QA Task Force for this. purpose.
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Orfginal signed by
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WMtat P. Haass Walter P. Haass. Chief Quality Assurance Branch Division of Project Management-cc:
D. Skovholt J. Heltemes
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W. Reinmuth M. Peranich S. Richardson J. Gilray W. Belke J. Conway F. Liederbach J. Spraul DISIRIBUTION:
W entral File QAB Projects QAB Chror.. File NRR Reading File WHaass,-QAB
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