ML19340B363
| ML19340B363 | |
| Person / Time | |
|---|---|
| Issue date: | 09/04/1980 |
| From: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19340B362 | List: |
| References | |
| TASK-OS, TASK-RS-902-4 REGGD-01.033, REGGD-1.033, NUDOCS 8010220176 | |
| Download: ML19340B363 (26) | |
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DRAFT VALUE/ IMPACT STATEMENT
- 1.
PROPOSED ACTION 1.1-Description Appendix A,'" General' Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, " Domestic LicensingLof Production and Utilization Facilities," estab-lishes requirements for structures, systems, and components important to safety; that is,. structures, systems, and cocoonents that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public.' Criterion 1 of these general design criteria, " Quality Standards and Records," requires that a. quality assurance program be established and implemented in order to provide adequate assurance that tho' e structures, systems, and compo-
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nents will satisfactorily perform their safety functions.
Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50 establishes quality assurance require-ments for the design, construction, and operation of certain structures, systems, I
and components; namely, those that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the h'ealth and safety of the 4
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-public. The criteria for the quality assurance program required by the Appendix A, i
General Design Criteria' for Nuclear Power Plants," Criterion 1, are those.
criteria contained in Appendix B.
The proposed action will provide updated.
i guidance for compliance by the applicant with cuality assurance program require-
'ments for. the operational phase of nuclear power plants.
1.2 Nee'd for Proposed Action Revision'2.to Regulatory Guide 1.33, " Quality Assurance Program-Requirements (Operation)," dated February 1978, provides guidance on quality assurance program requirements :for the operational phase of nuclear power -
plants-and endorses ANSI Standard:N18.7-1976/ANS-3.2. With the implementation-of the-SD/IE Feedback Program.between the Offices of Standards Development and Inspection and Enforcement,-improvements neces'sary in guidance on quali_ty-assurance program requirements' for the operations phase of nuclear power plants were. identified in early 1979. The first proposed Revision 3 to Regulatory 35 8010220 ~
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Guide 1.33 was developed to incorporate this improved guidance.
In August 1979, the first proposed Revision 3 was issued for comment in order to receive i
additional public input on the proposed modifications to the guide. Also, comments and suggestions were requested on improvements in regulatory guidance necessary as a result of the Three Mile Island Unit 2 accident.
As a result of.the assessment of the Three Mile Island-Unit 2 nuclear power plant accident by the industry, the NRC, and others, a number of improvements in l
the quality assurance requirements for the eneration of nuclear power plants have been recommended. A number of studies and investigations that have been l
conducted have a significant impact on the guidance provided in this regulatory guide. Also, ANSI N18.7/ANS 3.2 is undergoing extensive revision to incorporate the improvements in quality assurance requirements that have been recommended in the various studies and investigations. The NRC staff, with the consent of the ANSI organization, has decided to endorse Draft 5 (dated August 1980) of the l
proposed revision to the ANS standard. This draft has incorporated many of the I
NRC staff concerns regarding quality assurance requirements including several j
regulatory positions and Appendix A of Revision 2 to Regulatory Guide 1.33.
l The NRC staff has also developed a substantial amount of' regulatory guidance to improve the draft ANS 3.2 standard. This guidance has been stated as regulatory positions in the second proposea Revision 3 to Regulatory Guide 1.33.
l These additions are discussed in Section 1.3 of this Value/ Impact Statement.
l Current NRC guidance should be updated to provide improved guidance for compli-l ance with quality assurance program requirements for the operational phase of j
nuclear power plants and endorse the draft national standard.
1.3 Value/Imoact of Prooosed Action l
1.3.1 NRC Guidance for complying with'the Commission's regulations with regard to overall quality assurance program requirements for the operational phase of nuclear power plants is currently contained in Revision 2 to Regulatory Guide l
1.33, dated February 1978, and is being used by the NRC staff in the evaluation of' applications for operating licenses.
Since the purpose of the proposed action is to provide updated regulatory guidance, the value/ impact will be based on changes proposed,.o guidance contained in Revision 2 to Regulatory Guide 1.33.
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The following is aglist of regulatory positions and changes to Appendix A
. included in the first proposed Revision 3 with a discussion of any modification made to each in the second proposed Revision 3:
1 a.
Regulatory position l'of the first proposed Revision 3 stated that the. identified procedures in Appendix A should be omitted only if they are not applicable to an applicant because of the configuration of the nuclear power plant. Applicants had expressed some confusion concerning the interpretation of the previous wording of this regulatory position.
This Regulatory position has been deleted since the draft ANS standard has been revised to incorporate the guidance.
b.
Regulatory position 2 of the first proposed Revision 3 discussed the acceptability of standards listed in ANSI N18.7/ANS 3.2.
This position'is renumbered regulatory position 1 in the second proposed Revision 3 to the regulatory guide.
I c.
Regulatory position 3 of the first proposed Revision 3 discussed the review of proposed changes to technical specifications or license amendments by the independent review body.
This Regulatory position has been deleted since the draft ANS standard has been revised to incorporate the guidance.
'd.
Regulatory position 4 of the first proposed Revision 3 ' discussed i
the audit frequencies of various' audit program elements.
This regulatory position has been deleted since the draft ANS standar'd.has been revised to incorporate the guidance.
e.
Regulatory position 5 of the first proposed Revision 3 was i
inserted to clarify the NRC staff position that verification of-measures for control of equipment to maintain personne1land 4 1 t
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reactor safety and to avoid unauthorized operation of equipment should be. performed in all instances.
This position has been moved to Regulatory position 11 of the second proposed Revision 3 to the Regulatory guide and has been revised to be more explicit. This position will be discussed later in Section 1.3.
f.
Regulatory Position 6 of the first proposed Revision 3 lis'ted guidelines that should be treated the same as requirements.
Items a thru i have been incorporated into the draft ANS standard and, therefore, have been deleted from the second proposed Revision 3 to the regulatory guide.
Item j was partially incorporated into the draft standard. The remaining part of this item is included in Item h of Regulatory position 26 of the second proposed Revision 3 to the regulatory guide.
d.
In Appendix A to the first proposed Revision 3 to the regulatory guide, the following items were included to provide a more complete list of activities that should be covered by procedures:
(1) Quality assurance program implementation procedures (2) Inservice inspection (3) -Hydrogen explosions These items have been incorporated into the draft ANS standard along with Appendix A.
e.
.In Paragraph 8.a of Appendix A to the first proposed Revision 3, the requirement to have approve 1 written procedures for the cali-bration of measuring and test equipment was reinforced. A
' proposed sentence _specifically stated that procedures tnat delineate on a step-by-step basis the correct calibration method for each type cf equipment to be calibrated should be provided.
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Appendix A with this additional sentence has been incorporated into the draft ANS standard.
f.
In Paragraph 8.a of Appendix A to the first proposed Revision 3,
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identification of the types of instruments that require periodic calibration and procedural coverage was clarified to specifically include both portable and installed equipment.
Appendix A with this clarification has been incorporated into the draft ANS standard, g.
In Paragraph 8.b of Appendix A to the first p'roposed Revision 3, clarification of the position that procedures should be prepared for all technical-specification-required surveillance, whether included in the surveillance section or not, was accomplished.
Appendix A with this clarification has been incorporated into
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the draft ANS standard.
h.
In Paragraph 8.b of Appendix A to the first proposed Revision 3, a change was made to more clearly specify the need to establish procedures that cover all aspects of reactor engineering surveillance.
Appendix A and this change have been incorporated into the draft ANS standard.
i.
Paragraph 9.a of Appendix A to the first proposed Revision 3 was modified to state that even though minor, routine
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maintenance activities may not' require detailed procedural l
coverage, they are still subject to general administrative -
procedural controls.
Appendix A_ and this modification (now in Section 6.a of Appendix A to the draft ANS standard) have'been incorporated into the draft ANS standard.
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j.
In Paragraph 9.d of Appendix A to the first proposed Revision 3, it was stated that the items listed are only examples of activities that could be considered either maintenance or operating procedures.
Because of the previous wording of this paragraph, confusion arose within the industry concerning procedures that could be categorized either as maintenance or operating procedures.
Appendix A and this statement (now in Section 6.d of Appendix A to the draft ANS standard) have been incorporated into the draft ANS standard.
k.
In Paragraph 9.e of Appendix A to the first proposed Revision 3, additional areas that should be addressed by administrative proce-dures were included to assist in solving the problems of :nadequate retest requirements, inadequa:1 review of significant vendor work, and the absence of approved procedures for significant maintenance activities.
Appendix A and these areas (now in Section 6.e of Appendix A to the draft ANS standard) have been incorporated into the draft ANS standard.
l.
Section 10 of Appendix A to the first proposed Revision 3, which dealt with chemical and radiochemical control procedures, was expanded to provide additional guidance.
Appendix _A including Section 10 (r.ow Section 9 of Appendix A to draft ANS standard) has been incorporated into the draft ANS standard.
Below the individual regulatory positions of this second proposed Revision 3' to Regulatory Guide 1.33 are discussed as to their value.
The impact to the NRC of all the positions is the time and effort spent to ensure that the additional guidance is implemented by.the industry.
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t a..
Regulatory posittor. 1 addresses the applicability of documents referenced in the draft.ANS 3.2 standard. This position has-been provided as is customary in many regulatory guides to assist the user of the guide in determining the applicability of referenced documents.
l b.
Regulatory position 2 provides guidance in addition to that provided in the draft ANS 3.2 standard in the area of authorities and responsibilities for administrative controls and quality l '
assurance that training and radiation protection of plant assurance program activities. The value will be the additional personnel are not reduced because of operating pressures. Also, the quality assurance organization will be able to maintain control over the performance of reviews of activities such as to ensure independence of this function from operating pressures.
L c.
Regulatory position 3 provides guidance in addition tc, the draft i
ANS 3.2 standard in the area of requirements for the onsite l
operating organization. The additional areas of expertise listed in the regulatory position are ones which should already be
_ possessed by the operating' organizations.
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d.
_ Regulatory position 4 takes exception to the draft ANS 3.2 standard in the response time for technical support personnel for the on-duty operating staff.
The two hour interval allowed in the draft ANS 3.2 standard
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appeared too long for~ obtaining technical assistance during an L
emergency..The interval recommended in the regulatory position provides-greater assurance that technical support is available to assist the onsite organization during an emergency.
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.e.
Regulatory position 5 discusses the establishment of an Indepen-j!
dent Safety Engineer _ing Group (ISEG). The.value will be addi-tional assurance that potential problems are identified by this-l oversight review group.
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f.
Regulatory position 6 states that each standing committee responsible for the independent review program should formally convene a quorum to act on tasks in their areas of responsibil-ity.
By. formally convening, it will be assured that the commit-tee agrees as to the meaning, result, and proper resolution of-each particular task.
The value will be the assurance that each committee is fulfilling its responsibility of reviewing carefully those items assigned to the committee.
g.
Regulatory position 7 provides guidance in addition to that of the draft ANS 3.2 standard for the development of an acceptable audit program.
The position. states that the quality assurance organization should assure that audits are performed in accordance with quality assurance program requirements. Also, the position clarifies.the term " performance" to include training records and supervisory evaluations of the facility staff.
The value of this clarification is that the audit program will have the l
capability to verify the competence of the f'acility staff and, thus, the adequacy of the training program.
h.
Regulatory. position 8 provides guidance for the development of shift change procedures. The value will be the increased assurance that shift changes are performed in a manner that does not jeopardize the safety of the plant.
The value of the short tour prior to shift change is that the shift supervisor will be more informed as to the status of, and possible problems involving, maintenance and surveillance testing.
This first hand knowledge will provide greater assurance-of proper control of the plant during a shift change.
i.
' Regulatory position 9 provides guidance in addition to that of the draft ANS 3.2 standard in regard to work time limitations.
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4 The regulatory position states that the: work time schedule of the ANS 3.2 standard (with one exception to ensure consistency with IE Circular No. 80-02) should be applied to all personnel who maintain structures, systems, and components important to safety and is consistent with IE Circular No. 80-02 and the draft proposed rule change to 10 CFR 50.54.
The value will be greater assurance that all operating personnel are alert so that fatigue related errors are limited as much as possible. Also, the position states that this schedule should be considered a maximum and not a normal schedule.
The value will be the clari-fication of the requirements for operating personnel work hours.
j.
Regulatory position 10 takes exception to the draft ANS 3.2 standard regarding the approval of temporary procedures.
The value will be guidance that is consistent with that of
. standard technical specifications and ensures that personnel approving temporary procedures are adequately experienced and knowledgeable in plant operation.
k.
Regulatory position 11 provides additional guidance and, in some cases, takes exception to the guidance of the draft ANS 3.2 stand-ard for the proper control' systems and equipments.
By specifying that the on-duty snift supervisor should only be l
allowed to release systems or equipment, the position ensures L
that the shift supervisor maintains control over the activities l
in the plant that could affect safety. Verification by a second qualified person of correct implementation of equipment control measures in all instances with the exception of cases where high l
radiation exposure of personnel may result will-help to ensure that equipment is properly controlled. Judgment will have to be_used in the case of high radiation areas to ensure compliance
_ ith the ALARA principle.
The position also provides guidance >
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to ensure that functional testing is adequate when used to verify proper alignment.
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The position describes the qualified person who performs the verification of correct implementation of equipment control measures or proper alignment prior to returning equipment to service as one who is qualified to perform such tasks for the particular systems involved, possesses operating knowledge of the particular systems involved and their relationship to plant safety, and holds a valid reactor operator or senior reactor operator license. The use of a licensed operator to perform these tasks will ensure that the verifying individual is aware of the operating status of the plant and has at least a minimum level of knowledge of plant systems. However, judgement must be used to ensure that the verifying individual is qualified to perform these tasks for the particular systems involved.
1.
Regulatory Position 12 states that if surveillance testing and inspections are performed by personnel who are not members of the quality assurance organization, the quality assurance organi-l zation should review and concur in the selection of personnel who S
Y perform the surveillance testing and inspection'; should review and concur in the procedures associate.d with the surveillance testing and inspections, and should perform audits to assure that:the surveillance testing and inspections have been accomplished in accordance with those procedures.
The value of this_ position will be to ensure that surveillance testing and f
inspection are properly controlled and performed.
m.
Regulatory position 13 clarifies the guidance of the draft ANS l
3.2 standard regarding the extent of compliance of suppliers with the ANSI N45.2 and the applicable N45.2 series standards j
that must be specified in procurement documents.
The value will
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be to ensure that suppliers are' fully aware of the extent to L
which they must comply with'N45.2 and the N45.2 series standards.
-n.
Regulatory position 14 expands and, in_some cases, takes exception to the guidance provided in the draft ANS 3.2 standard for the review, approval and control of procedures.
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The position provides guidance for the quality assurance o,gan-ization to assure that procedures have been prepared, reviewed, and approved in accordance with established procedures. The position also specifies the members of the plant staff who are allowed to approve procedures.
This will ensure that procedures ~
are approved by only qualified individuals. By taking exception to the draft ANS 3.2 standard to recommend that the review of procedures be an independent activity, the position ensures that procedure review is performed as necessary. The step-by-step walk through of initial procedures discussed in the position will ensure that procedures are carefully developed prior to implementation.
o.
Regulatory position 15 states that, if qualified individuals who perform inspections of activities affecting safety are not members of the_ quality assurance organization, then the quality assurance organization should review and concur in the selection of personnel who perform the inspections, should review and con-cur in the procedures associated with the inspections, and should perform audits to assure that the inspections are properly accomp-lished.
The value of this position will be to assure that inspec-tion of activities affecting safety are properly controlled and performed.
p.
Regulatory position-16 clarifies the guidance.of the draft ANS 3.2 standard regarding the use of checklists during preoperational tests.
The value will be to provide additional assurance that equipment, valve, and switch lineups are correct.
g.
Regulatory position 17 provides guidance in addition to that of the draft ANS 3.2 standard concerning the responsibilities and scheduling of the initial startup test program following fuel loading. The provisions to ensure correct equipment, valve, and switch lineups that are discussed in the position will provide additional assurance that all systems are ready for plant operation.
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Regulatory position 18 ssates that if precautions are specified separate from the procedur'es, as allowed in the draft ANS 3.2 standard, then the procedure should require that the precautions be reviewed prior to commencement of the activity.
The value will be the additional assurance that precautions are reviewed and heeded by users of the procedures.
s.
Regulatory position 19 specifically states that system procedures should contain checklists. Or reference documents that contain checklists, in all instances.
The value will be the additional assurance that systems are properly aligned through th,e use of checklists.
t.
Regulatory position 20 provides guidance in addition to that of the draft ANS 3.2 standard for the use of checklists during maintenance. -Tne value will be the additional assurance that equipment is returned to its proper state following maintenance.
Regulatory position 21 clarifies the guidance of the draft ANS u.
3.2 standard regarding the memorization of emergency procedures.
The value of this clarification will be that necessary immediate operator actions will be memorized regardless of the name of the procedure. The position also states that departure from an emergency procedure by a reactor operator should receive price approval by the senior reactor operator directing operations in the control room. Also, the position states that, in addition to permission to override of engineered safety features, the shift stipervisor should approve the changing of flow rates.
The value will be to ensure that supervisors maintain proper control over a plant during an emergency.
v.
Regulatory position 22 provides guidance in ' addition to that of the draft ANS 3.2 standard regarding emergency procedure content and format.
The value will be the additional assurance that
. plant operators are provided with sufficient information and direction to successfully cope with a plant emergency.
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~ Regulatory position 23 clarifies the guidance of the' draft ANS I
-3.2 standard in that instructions to restore. systems to their
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proper condition.should be included, or referenced,'in all test
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and inspection procedures. The value will be the additional l.
assurance that plant personnel are aware of. the correct method
~ to return systems to their proper condition.
x.
Regulatory position 24 lists additional activities that should
.be addressed by administrative procedures. The value will be preparation ofJprocedures toiensure the proper control of these-activities.
1/.
Regulatory position 25 states that each control room annunciator associated with structures, systems,.or components important,to i
fsafety should have a separate written procedure.
The value will E
be the reduced chance of confusion or -improper: action by an 1'
J-operator during an abnormal, offnormal, or alarm condition, k.
z.
Regulatory position 26-indicates guidelines contained in the c
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draft ANS 3.2 standard that should be considered as requirements.
The value will be the assurance of the implementation of these particular important guidelines.
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. 1.3.2 Other Government' Agencies Not applicable unless the government agency is an applicant such as TVA.
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- 1. 3. 3 Industry l
The value ofLthe proposed action will-be to provide more specific guidance l
concerning qualityiassurance program requirements.
The impact of the majority-of.the regulatory positions will.be the significant organizational modifications necessary toTimplement the more: specific guidance.
Below is an indication of-i --
the, impact on -industryfof the most significant individual regulatory positions E
of 'this~second proposed Revision.3-~to Regulatory Guide 1.33.
The value of each individual regulatory. position'was discussed in Secticn 1.3.1.
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a.
The impact of Regulatory position 4 will be the effort necessary to ensure that technical support is available within one-half l
hour,'as opposed to two. hours.
b.
The impact of Regulatory position 5 will be significant in cost and organization changes necessary to establish the Independent Safety Engineering Group.
c.
The impact of Regulatory position 8 will be significant in that shift changes procedures must be reviewed and revised to comply with the guidance of the position. The short tour to be performed by the oncoming shift supervisor will have the impact of addi-tional salary costs for the increased work time.
d.
The impact of Regulatory position 9 will be significant in that the industry must ensure that the plant is adequately staffed to prevent exceeding the work time guidance of the position.
e.
The impact of Regulatory position 10 will be the organizational l
changes necessary to ensure that members of the plant staff who 4 are allowed to approve temporary procedures by the guidance of V the position are available at all times during plant operation.
f.
The impact of Regulatory position 11 will be significant in that
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industry must. ensure that the. guidance is implemented. Also, l
.~ verification by a second qualified person must be performed in
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all instances, except where high radiation exposure may result and then, judgment must be used.
Functional testing will only be allowed if this method can be done safely and prove that the affected systems are properly aligned.
l Additional impact will be the organizational changes necessary to provide for the use of qualified personnel holding valid peictor operator-or senior reactor ope'rator licenses to perform verifications.of equipment control measures and proper alignment prior.to. returning equipment to service. Considerablejudgement 48 w
will be necessary to ensure that the verifying individual is qualified to perform these tasks for the systems involved.
g.
-The impact of Regulatory position 14 will be the organizational changes necessary to ensure that the review, approval and control t
of procedures are performed in accordance with the guidance of the position.
- h.. The impact of Regulatory position 24 will be the effort necessary to prepare and implement administrative procedures to cover the activities listed in the position.
i.
The impact of Regulatory position 25 will be effort necessary to prepare a procedure for each annunciator associated with structures, systems, or components important to safety.
1.3.4 Workers (ALARA Considerations)
Those regulatory positions in second proposed Revision 3 which may involve increased exposure of nuclear power plant personnel are discussed below:
a.
Regulatory Position 8 of the second proposed Revision 3 states 4pthat the oncoming shift supervisor should perform a short tour of the plant prior to assuming the duty station with special-attention paid to ongoing maintenance and surveillance testing.
l A short tour of'the plant will provide the oncoming shift super-visor with better knowledge.of the current status of plant equip-ment than is available in the control room alone.
The conduct of a short tour will provide this increased knowledge while complying with the ALARA concept.
b.
Reg 11atory Position 11 of the second proposed Revision 3 states that verification by a second qualified person of correct imple-mentation-of measures provided for control of equipment should be performed in all instances with the allowable exception of cases where high radiation exposure may result and in that case, other means may be utilized. The 'importance of ensuring that 49 A
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equipment is properly ' controlled is such that verification by a se.ond qualified person should be performed in as many instances as possible.
In areas of high radiation, judgment must be used to comply-with the ALARA concept.
1.3.5 Public'
-The value to the public will be greater safety of nuclear power plants by the maintenance of an improved quality assurance program.- The impact will be the costs involved in improving quality assurance programs by the industry.
1.4 Decision on Proposed Action Improved guidance should be furnished on quality assurance program require-ments for the operational phase of nuclear power plants.
2.
TECHNICAL APPROACH This section is not applicable to this value/ impact statement since the proposed action is an update of previously issued guidance.
3.
PROCEDURAL APPROACH Since the' proposed action is an update of information contained in an existing regulatory guide, the only appropriate procedural alternative is a revision to the existing guide.
4.
STATUTORY CONSIDERATIONS 4.1 NRC Authority Authority for this regulatory guide would be derived from the safety require-ments of the Atomic Enargy Act through the Commission's' regulations, in particular, Appendix B, " Quality Assurance Cr_iteria for Nuclear Power Plants and Fuel Repro-cessing Plants," to 10'CFR Part 50, " Domestic Licensing of Production and Utiliza-tion Facilities." ~ Appendix B establ.ishes quality assurance requirements for 50
the operation of certain structures, systems,'and components; namely, those that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
4.2 Need for NEPA Assessment The proposed action is not a major action, as defined by paragraph 51.5(a)(10) of 10 CFR Part 51, and does not require an environmental impact statement.
5.~
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES Regulatory position 1 of this proposed revision to Regulatory Guide 1.33 lists standards that are referenced in the draft ANS 3.2 standard with the regulatory guide that addresses the specific acceptability of these standards.
The guidance of this proposed revision to Regulatory Guide 1.33 is consistent with that provided in the regulatory guides listed in Regulatory position 1.
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A number of efforts completed, or currently underway,* interface with the vues proposed action. Thefollowingisadiscussionofbkeheincipalefforts.
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a.
NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident" (Ref. 1), was developed to provide a comprehepsive and integrated plan for the actions now judged necessary by the NRC to correct or improve the regulation and operation of nuclear facilities based on the experience-from the accident at TMI-2 and the official studies and investigations of the accident.
The discrete scheduled tasks identified in the action plan were developed from the recommendations of organizations who investi-gated the accident..These organizations include the Congress, the General-Accounting Office, the President's Commission on the Accident at Three Mile' Island, the NRC Special Inquiry Group,-the NRC Advisory Committee on Reactor Safeguards (ACRS),
the Lessons-Learned Task Force and the Bulletins and Orders Task Force of the NRC Office of Nuclear Reactor Regulation, the Special Review Group of the NRC Office of Inspection and Enforcement, the NRC.staf_f Siting Task Force and Emergency 51 1
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Preparedness Task' Force, and the NRC Offices of Standards Development and Nuclear Regulatory Research.
Due to the broad scope of activities in which quality assurance is involved, many of the tasks described in NUREG-0660 will directly, or indirectly, affect the guidance provided in the ANS 3.2 standard and Regulatory Guide 1.33.
These related tasks of NUREG-0660 will be followed to ensure that the guidance provided by Regulatory Guide 1.33 is consistent with guidance developed as a result of these tasks.
b.
In early 1980, Basic Energy Technology Associates, Inc. (BETA) completed a study for the Office of Nuclear Reactor Regulation which outlined the results of a comparative review of current NRC requirements, licensed nuclear power plant practices and the Naval Nuclear Propulsion Program procedures for the selection, training and qualification of personnel involved in nuclear plant operation and maintenance.
The results of the BETA study enti.tled, " Power Plant Staffing," are documented in NUREG/CR-1280/ BETA-103-(RLf. 2).
Public comments were requested on this study. The recor,aendations of this study are currently being considered for their applicability to Regulatory Guide 1.33.
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~ Three recommendations have been used in providing improved
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guidance in this proposed revision to Regulatory Guide 1.33.
These recommendations involved (1) equipment'or system failure reporting (Regulatory position 5), (2) substituticns of specified parts-(Regulatory position 5), and-(3) operator working hours (Regulatory postion 9).
f c.
-Commission Information Paper SECY-80-242 (Ref. 3) discusses the establishment of a group, referred to as the Independent Safety Engineering Group, that is' independent of the plant staff, but is assigned onsite to perform independent reviews of plant operational activities and to provide a capability for evaluation of operating experiences at nuclear power' plants. Task I.B.I.2 52
a of NUREG-0660 discusses the requirement for the establishment of this group by each near-term operating license applicant.
The guidance provided in this proposed revision to Regulatory Guide 1.33 is consistent with-guidance provided in Commission Information Paper SECY-80-242.
d.
The NRC staff has under development criteria for onsite and offsite organizations, both management and technical, including the radiological protection organization, that will provide assurance of the safe operation of the plant during normal-an*'
abnormal conditions and the capability necessary to respond to-unusual or unexpected situations. A contractor was selected (NRC-03-80-105, TEKNEKRON Research, Inc.) to assist in criteria development. TEKNEKRON submitted its final report entitled,
" Utility Management and Technical Resources" (Ref. 4), to the NRC in May 1980. This report is currently being reviewed to determine its impact on the guidance provided in Regulatory Guide 1.33.
Task I.B.1.1, "Organizatien and Management of Long-Term Improvements," and Task I.8.1.2, " Evaluation of Organiza-
, tion and Management Improvements of Near-Term Operating License Applicants," of NUREG-0660 describe the criteria development effort. As described in Task I.B.1.2, the near-term operating license applicants are being required to comply with the findings and requirements generated in an interoffice NRC review of licensee organization and management.
The review is based, in part, on an NRC document entitled " Criteria for Utility Manage-ment and Technical. Competence" (Ref. 5).
A draft of this docu-ment was dated July 17, 1980, but the document is changing with use and experience in ongoing reviews.
The document addresses the organization, resources, training, and qualifications of plant staff, and management (both onsite and offsite) for routine operations and accident conditions.
As the final criteria are developed, Regulatory Guide 1.33 will be revised to be consistent in the applicable areas.
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e.
In February 1980, IE Circular No. 80-02 (Ref. 6) on Nuclear Power Plant Staff Work' Hours was issued and discussed the ill effects l
l that-can result from extended personnel work hours. The IE.
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' Circular recommend: a maximum work hour schedule for certain personnel..In addition, a proposed rule change to 10 CFR 50.54 is currently under, development that will establish requirements l
-in'this area.
~The guidance provided in this proposed revision to Regulatory Guide 1.33 and the draft ANS standard is consistent with the guidance of. IE Circular No. 80-02 and the draft version of the
-proposed rule change to 10 CFR 50.54.
f.
.In Janaary 1980, NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (Ref. 7) was published for interim use and comment.
The purpose of this interim guidance and upgraded acceptance criteria is to provide a basis for NRC licensees, state cod local governments to develop rafiological emergency plans and improve emergency preparedness.
The guidance is the product of the joint FEMA /NRC Steering e..
Comm' tee established to coordinate the agency's work in emergency preparedness associated with nuclear power plants.
It will be i
used by. reviewers in determining the adequacy of state, local and nuclear power plant operator emergency plans and prepared-ness. The guidanc.c provided in the document will be published in final form after public comments are reviewed and resolved.
This proposed revision to Regulatory Guide 1.33 references
.NUREG-0654 for. guidance in devrioping emergency plans.
Table B-1,
" Minimum Staffing Requirements for NRC Licensees-for Nuclear l
Power Plant Emergencies," of NUREG-0654 discusses minimum capabilities and staffing on-shift and available within 30 minutes following the declaration of.the emergency.
This proposed.
revision to Regulatory Guide 1.33 references NUREG 0654 with respect to the availability of technical support personnel following.the declaration of the emergency.
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-When th,: guidance provided NUREG-0654 is finalized, Regulatory Guide 1.33 and NUREG-0654 will be reviewed to ensure that the guidance provided by both documents is consistent.
g.
In May 1980, NUREG/CR-1368/ SAN 080-7053, " Development of a Check-list for Evaluating Maintenance, Test and Calibration Procedures Used in Nuclear Power Plants" (Ref. 8), and NUREG/CR-1369/
SAN 080-7054, " Procedures Evaluation Checklist for Maintenance, Test and Calibration Procedures" (Ref. 9) were published as a result of a study done by Human Performance Technologies, Inc.,
for the Division of Reactor Operations _ Inspection of the Office of Inspection and Enforcement. NUREG/CR-1368 describes the process for developing a checklist to be used by I&E inspectors during their evaluation of maintenance, test and calibration procedures.
NUREG/CR-1369 describes the checklist and provides instruction of use by I&E inspectors in implementing the checklist.
Analysis of these documents is currently underway and Regulatory Guide 1.33 will be revised as necesnry to provide improved guidance and ensure consistency between the documents.
h.
As a result of an internal review of the operator licensing program by the Office of Nuclear Reactor Regulation, a proposed rule change is currently under development that will amend 10 CFR Part 50 and 10 CFR Part 55.
The proposed changes to Part 50 and-Part 55 were forwarded to the ACRS for review on May 14, 1980 (Ref.10) and discussed with the ACRS Regulatory Activities Subcommittee on June 4, 1980.
The purpose of the amendments to 10 CFR Part 55 is to specify requirements designed to improve operator performance in order'to prevent accidents induced by the cperator_'and to improve the operator's ability to mitigate an accident if it should occur. The purpose of the amendment to 10 CFR Part 50 is to ensure an operator is familiar with current plant condition prior to being allowed to manipulate the controls or_. supervise the manipulation of the controls of the facility.
~Specifically Paragraph 50.54(r) is proposed to be added as 55
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follows: " Administrative procedures shall be develcped by the licensee to provide assurance that-an operator or senior operator is proficient'at manipulating the~ controls or supervising the manipulation of contro1r' prior.to performing licensed duties."
~This proposed revision to Regulatory Guide 1.33 discusses administrative procedures and has included guidance consistent with the pronosed rule change.
Work on the proposed rule ' change and the proposed revision to Regulatory Guide l.33 concerning these administrative procedures will be coordinated to maintain consistency in the final guidance.
i.
Regulatory Guide 1.8, " Personnel Selection and Training" (Ref. 11),
is currently undergoing revision to provide improved guidance with regard 'to the qualifications of nuclear power plant personnel filling various functional positions. American Nuclear Society Standard ANS 3.1, " Qualifications and Training of Personnel 'for Nuclear Power Plants," which is endorsed by Regulatory Guide 1.3, has undergone significant revision as a result o'f the anessment of the Three Mile Island accident. The effort to revise Regulatory Guide 1.8.will be followed to ensure that the guidance provided by these two. regulatory guides remains consistent.
j.
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable (ALARA)" (Ref. 12), provides information relevant to attaining goals and objectives for planning, designing, constructing, operating, and decommissioning a nuclear power plant to meet the criterion that exposures of station personnel to radiation during routine operation will be "as low as is reasonably achievable" (ALARA). Regulatory Guide 8.10,
" Operating, Philosophy for Maintaining Occupational Radiation
' Exposures As low As Is Reasonably Achievable" (Ref. 13), describes La general operating philosophy as a necessary-basis for a program-of maintaining occupational exposures to radiation ALARA. The 56
guidance provided in this proposed revision to Regulatory Guide 1.33 is consistent with the guidance of these two regulatory guides.
4 k.
Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" (Ref. 14), provides guidance for designing a program to ensure the quality of the results of measurements of
~
radioactive materials in the effluents and the environment of f
nuclear facilities during normal operations. The guidance pro-vided in this proposed revision to Regulatory Guide 1.33 is consistent with that of Regulatory Guide 4.15.
l.
An NRC staff effort is currently underway to evaluate the quality assurance program requirements for the operation phase of nuclear power plant regarding the independence of-the quality assurance organization from operating pressures.
For example, the effective-ness of an organizational structure where the onsite quality assurance organization reports functionally to offsite management versus reporting functionally to the Plant Management is being evaluated by the NRC staff.
In regard to these requirements, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," states in Criterion I, Organization (Ref. 15):
"The persons and organizations performing quality assurance functions shall have sufficient authority and organi-zational freedom to identify quality problems; and to verify implementation of solutions.
Such persons and organizations performing quality assurance functions shall report to a manage-ment level such that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
Because of the many variables involved, such as the number of personnel, 57
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the type of activity being performed, and the location or loca-tions where activities are performed, the organizational structure for executing the quality assurance program may take various forms provided that the persons and organizations assigned the quality assurance functions have this required authority and organizations assigned the quality assurance functions have this requifed authority and organization freedom.
Irrespective of the organizational structure, the individual (s) assigned the responsibilit'y for assuring effective execution of any portion of the quality assurance program at any location where activities subject to this Appendix are being performed shall have direct access to such levels of management as may be necessary to perform this function."
An NRC document entitled " Guidance on Quality Assuranca Requirements During the Operations Phase of Nuclear Power Plants" (Ref. 16) dated October 26, 1973 indicates several organizational structures that are acceptable to the NRC staff for providing
. independence of the quality assurance organization from operating pressures.
.S Furthermore, Section 3.3, " Authorities and Responsibilities for Administrative Controls and Quality Assurance Program Activi-ties, of the Draft ANS 3.2 standard states:
"The persons or organzations responsible for defining and measuring the overall effectiveness of the program shall be designated, shall be suffi-ciently independent from cost and scheduling considerations when opposed to safety considerations, shall have direct access to responsible management at a level where action appropriate to the mitigation of safety.related quality assurance concerns can be accomplished, and shall report regularly on the effectiveness of the program to the plant manager and the cognizant offsite management. Persons or organizations performing functions of assuring that the administrative controls and quality assurance program is established and implemented or of assuring that an
- activity has been correctly performed shall have sufficient 58
L authority and organizational. freedom to:
identify quality problems;_ initiate, recommend or provide solutions, through designated channels; and verify implementatin of solutions."
.In the distribution letter that accompanies this proposed
. revision to the regulatory guide, public comment is specifically requested on the quality assurance program requirements is this area.
The results of this request will be used.in the NRC staff determination of the need for revision of the requirements for independence of the quality assurance organization from operating pressures.
l As these and other efforts are completed, the guidance that is developed l
will be reviewed and compared to the guidance provided in the revision :1 l
6.
SUMMARY
AND CONCLUSIONS A proposed revision to Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," has been prepared.
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REFERENCES 1.
NUREG-0660, "NRC Action Plan Developed as.a Result of the TMI-2 Accident."
May 1980.
2.
NUREG/CR-1280/ BETA-103, " Power Plant Staffing," March 1980.
3.
Commission Information Paper SECY-80-242,
Subject:
Independent Safety Engineering Group (ISEG), dated May 13, 1980.
4.
.TEKNEKRON Research, Inc., report entitled " Utility Management and Technical i
-Resources," NRC-03-80-105, dated May 1980. Document contains proprietary information..Not publicly available.
.5.
NRC Oraft Document entitled " Draft Criteria for Utility Management and Technical Competence," dated February 25, 1980.
6.
IE Circular No. 80-02,
Subject:
Nuclear Power Plant Staff Work Hours, dated February 1, 1980.
7.
NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," January 1980.
8.
NUREG/CR-1368/ SAND 80-7053, " Development of a Checklist for Evaluating Maintenance, Test and Calibration Procedures Used in Nuclear Power Plants,"
May 1980.
9.
NUREG/CR-1369/ SAND 80-7054, " Procedures Evaluation Checklist for Maintenance, Test.and Calibration Procedures," May 1980.
10.
Memo. dated May 14,-1980.with enclosures from Guy A. Arlotto, Director,
-Division of Engineering Standards, Office'of Standards Development to
-Raymond F. Fraley, Executive Ofrector, Advisory Committee on Reactor Safeguards,
Subject:
Proposed Revisions to 10 CFR Part 55, " Operator's 60 f
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' Licenses" and 10 CFR Part 50 " Domestic Licensing of Production and Utilization Facilities," Standards Development Task No. RS 019-1.
11.
Regulatory Guide'1.8, " Personnel Sel ection and Training."
12.
Regulatory Guide 8.8. "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable (ALARA)".
13.
Regulatory Guide 8.10, " Operating Philosphy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable."
14.
Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment."
15.
Code of Federal Regulations Title 10, U. S. Government Printing Office, Washington: 1980.
16.
NRC Document entitled " Guidance on Quality Assurance Requirements During I
the Operations Phase of Nuclear Power Plants" dated 10/26/73.
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