ML20004E370
| ML20004E370 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1981 |
| From: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19252A551 | List: |
| References | |
| FOIA-81-97 NUDOCS 8106120096 | |
| Download: ML20004E370 (6) | |
Text
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po w.:cn n-DRAFT PRElll1114ARY VALUE Il4 PACT
/g g i STATEliENT FOR i
REVISION OF 10 CFR 50 LABORATORY ACCREDITATION
- 1. _ PROPOSED ACTION 1.1 Description Amend liRC regulations to add the requirement that utilities, operating or~
constructing a nuclear power plant, have the qualification testing of safety-relate ( equipment performed by a laboratory accredited, through a program acceptable to the NRC, to perform those tests.
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- 1. 2 Need 1
The Commission.i.e-concernd about the quality of the qualification testing g
j of safety-related equipment They rAquested-that-tht: dioil' looK int.o Lite j
mattee. The Office of Inspection and Enforcement (IE) developed an outline for a program to independently verify equipment qualification.
Sandia Labora-tories was contracted to perform a study on the various ways of independently verifying equipment qualification.
The alternative proposed by Sandia labora-expensive, i g g a d g he time to l
tory were c gt and obtain results was too long.g manpewer l
implemen j
j In Commission Paper, SECY-80-319, the Office of Inspection and Enforcement proposed a program which included a laboratory accreditation program.
The laboratory accreditation program would reduce the manpower requirements to an acceptable level anddnTcs2he level of confidence that e. qui ment is properly qualified. OnSeptemberiS,1980,ina.msioo_fromthelommissi o the EDO,
/
the Commission approved the initiation of a' laboratory accreditation program.
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- 1. 3 Value/ Impact 7
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1.3.1 NRC Using a third party accreditation program, the only impact to the NRC would be the manpo cer necessary to initiate the program. The use of the ID 81061200Ho.
1
program would grcatly reduce the number of r.anhours spent in verifying equip :nt i
qualifications.
The value far out weighs the iripact.
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1.3.2 Other Government Agencies The Department o'f' Commerce could b6 impacted if the National 'foluntary laboratory Accreditation Program (NAVLAP) was selected to run any portion of the program.
Additional manpower would be needed to run the program.
Other government agencies that use similar laboratory services could benefit if they selected a laboratory based on the fact it was accredited, rather than perform separate audits to determine acceptability.
1.3.3 Industry Pdrchasej of laboratory services usually perform some form of audit and observe some of their equipment being tested.
Given the large number of purchasers this amounts to a lot of duplicated effort.
Alabogratryacredita-tion program would provide the same level of confidence arAhe audits and t4ist inspections.
At the-same-the, tin: p vyi om would reduce-the r,euhours-expandad by 1he ourchasers and._the_1aboratories--by-eliminating the7edondant-audits =aed-
$spections.___
1.3.4 Public f
The level of confidence the public has in the industry and the regulatory bodies would increase if an accreditation program is implemented.
k.4 Decisions on the Proposed Action i
The Commission has requested that laboratory accreditation program be initiated. The Equipment Qualification Branch in HP.R has proposed a schedule for rulemaking on laboratory accreditation, which includes an Advance Notice i
of Rulemaking, a Proposed Rule and an Effective Rule.
Rulemaking should be initiated.
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2.
TECHNICAL APPROACH j
t 2.1 T_echnical Alternatives There are three alternatives:
1.
A government accreditation program (NAVLAP) 2.
An industry accreditation program - each company using its own program
,WhW 3.
Aprofessionalsocietiesaccreditationprogram/AmericanSocietyof Mechanical Engineers - ASME, Institute of Electrical and Electronic Engineers - IEEE, American Society of Metals -ASM, American Associa-tion for Laboratory Accreditation-AALA) 2.2 Discussion The Office of Inspection and Enforcement (IE) asked IEEE if they would consider developing and managing a laboratory accreditation program covering laboratories that qualify safety related electrical equipment.
At a meeting between IEEE and IE, held on February 14 and 15, 1981, IEEE agreed to undertake the development of a laboratory accreditation program.
The program would initially cover the accreditation of laboratories providing environmental qualification of electrical equipment.
l As other standards become available more subjects will.be considered for inclusion under the rule. Areas being considered for future inclusion are nondestructive testing, destructive testing, calibration anc' mechanical equip-l ment.
These accreditation programs would be developed and administered by organizations with expertise in the given area.
s 2.3 Decisions on Technical Alternative IEEE will develop and administer the laboratory accreditation pro _ gram I
covering the qualification of safety-related electrical equipment..
3
3.
PROCEDURAL APPROACH
[
t 3.1 Procedural Alternatives I
5*
The Commission approved SECY Paper 80-319, which preposed that a rule requiring accreditatiMeloped.
The alternatives are to issue a pro
~
h' f t posed rule or an advance notice of rulemaking (ANR).
Q 3.2 Discussion 0(
Because the accreditation standard has not been written yet it is not possible to issue a proposed rule.
However, it is desirable to let industry and the public know that the NRC intends to require equipment be qualified by an accredited laboratory.
The issuance of an ANR would notify the industry and the public of the intended action and allow them a chance for participa-tion early in the procedure.
It would also provide an opportunity to get information for the value/irpact statement.
3.3 Decision An Advance Noticar of Rulemaking-should be issued.
4.
STATUTORY CONSIDERATIONS 4.1 NRC Authority The Commission has the authority to initiate rulemaking, pursuant to Sections 83 and 166 of the Atomic Energy Act, as amended.
4.2 Need for NEPA Assessment The proposed action is not a major action as defined by 10 CFR 51.5(3) and does not require an environmental impact statement.
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5.
RELATIONSHIP TO OfHER EX1511NG OR PROPOSED REGULATIONS OR POLICIES j
t This ANR is part of a program that consists of three rulemaking actions.
[
The Commission has rg, quested that rulemaking be initiated on the following subjects:
~
Environmental Qua'.ification of Safety-Related Electrical Equipment 1.
2.
Environmental Qualification of all Safety-Related Equipment 3.
Accreditation of Laboratories Performing Qualification Testing The first rule will be issued as soon as possible.
The second rule can not be made effective until the supporting standards have been developed.
The rule on accreditation of laboratories performing environmental qualification testing will be issued as soon as possible.
Other areas requiring accredita-tion will be added as the necessary standards are developed.
6.
SU!stARY AND CONCLUSIONS An advance notice of rulemaking will be prepared.
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ADVAflCEO fiOTICE OF PROPOSED RllLEfMK!flG - LABORATORY ACCRE0lTATION f
m.
Prepare Prelim. Value/ Impact Statement & TIF 2/5/81 3/13/81 TIF-Approved Initial Draft Complete 3/20/81 Final Division Review Complete 4/3/81 Resolution of Comnents Complete 4/17/81 Office, Concurrence 4/24/81 Submitted to ED0/ Commission 5/5/81 AfiR Published in Federal Register 6/23/81 O
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DRAFT PREllMINARY VALUE IMPACT I
STATEMENT FOR REVISION OF 10 CFR 50 i
LABORATORY ACCREDITATION w.
1.
PROPOSED ACTION 1.1 Cescription Amend NRC regulations to add the requirement that utilities, operating or constructing a nuclear power plant, have the qualification testing of safety-related equipment performed by a laboratory accredited, through a program acceptable to the NRC, to perform those tests.
1.2 Need The Commission is concerned about the quality of the qualification testing of safety-related equipment.
They requested that the staff look into the matter.
The Office of Inspection and Enforcement (IE) developed an outline for a program to independently verify equipment qualification.
Sandia Labora-tories was contracted to perform a study on the various ways of independently verifying equipment qualification.
The alternative proposed by Sandia Labora-tory were considered to expensive, in dollars and manpower or the time to implement them and obtain results was too long.
In Commission Paper, SECY-80-319, the Office of Inspection and Enforcement proposed a program which included a laboratory accreditation program.
The laboratory accreditation program would reduce the manpower requirements to an acceptable level and increase the level of confidence that equipment is properly qualified.
On September 16, 1980, in a memo from the Commission to the EDO, l
the Commission approved the initiation of a laboratory accreditation program.
- 1. 3 Value/ Impact 1.3.1 NRC l
Using a third party accreditation program, the only impact to.the NRC I
would be the manpower necessary to initiate the program. The use of the l
1
program would greatly reduce the number of manhours spent in verifying equipment qualifications.
The value far out weighs the impact.
8 i
1.3.2 Other Government Agencies The Department of Commerce could b6 impacted if the National Voluntary Laboratory Accreditation Program (NAVLAP) was selected to run any portion of the program.
Additional manpower would be needed to run the program.
Other government agencies that use similar laboratory services could benefit if they selected a laboratory based on the fact it was accredited, rather than perform separate audits to determine acceptability.
1.3.3 Industry Purchases of laboratory services usually perform some form of audit and observe some of their equipment being tested.
Given the large number of purchasers this amounts to a lot of duplicated effort.
A laboratory accredita-tion program would provide the same level of confidence as the audits and the inspections.
At the same time, the program would reduce the manhours expanded by the purchasers and the laboratories by eliminating the redundant audits and inspections.
1.3.4 Public The level of confidence the public has in the industry and the regulatory bodies would increase if an accreditation program is implemented.
1.4 Decisions on the Proposed Action The Commission has requested that laboratory accreditation program be initiated. The Equipment Qualification Branch in NRR has proposed a schedule for rulemaking on laboratory accreditation, which includes an Advance Notice of Rulemaking, a Proposed Rule and an Effective Rule.
Rulemaking should be initiated.
m 2
1 2.
TECHNICAL APPROACH i
g i
2.1 Technical Alternatives i
wi.
There are three alternatives:
A government accreditation program (NAVLAP) 1.
2.
An industry accreditation program - each company using its own program 3.
A professional societies accreditation program (American Society of Mechanical Engineers - ASME, Institute of Electrical and Electronic Engineers '- IEEE, American Society of Metals -ASM, American Associa-tion for Laboratory Accreditation-AALA)
- 2. 2 Discussion The Office of Inspection and Enforcement (IE) asked IEEE if they would consider developing and managing a laboratory accreditation program covering l
laboratories that qualify safety-related electrical equipment.
At a meeting between IEEE and IE, held on February 14 and 15, 1981, IEEE agreed to undertake the development of a laboratory accreditation program.
The program would initially cover the accreditation of laboratories providing environmental l
qualification of electrical equipment.
As other standards become available more subjects will.be considered for 1.nclusion under the rule.
Areas being considered for future inclusion are nondestructive testing, destructive testing, calibration and mechanical equip-ment.
These accreditation programs would be deseloped and administered by organizations with expertise in the given area.
2.3 Decisions on Technical Alternative IEEE will develop and administer the laboratory accreditation program covering the qualification of safety-related electrical equip. ment..
3
o 3.
PROCEDURAL APPROACH
=
I I
3.1 Procedural Alternatives w.;
~
The Commission approved SECY Paper 80-319, which proposed that a rule requiring accreditation be deyeloped.
The alternatives are to issue a pro-posed rule or an advance notice of rulemaking (ANR).
3.2 Discussion Because the accreditation standard has not been written yet it is not possible to issue a preposed rule.
However, it is desirable to let industry and the public know that the NRC intends to require equipment be qualified by an accredited laboratory.
The issuance of an ANR would notify the industry and the public of the intended action and allow them a chance for participa-tion early in the procedure.
It would also provide an opportunity to get information for the value/ impact statement.
3.3 Decision An Advance Notice of Rulemaking should be issued.
4.
STATUTORY CONSIDERATIONS 4.1 NRC Authority The Commission has the authority to initiate rulemaking, pursuant to Sections 83 and 166 of the Atomic Energy Act, as amended.
l' 4.2 Need for NEPA Assessment The proposed actfon is not a majoe action as defined by 10 CFR 51.5(3) and does not require an environmental impact statement.
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i 5.
RELATIONSHIP 10 OTHER EXISTING OR PROPOSED REGULATICNS OR FOLICIES i
t E'
This ANR is part of a program that consists of three rulemaking actions.
The Commission has teq,uested that rulemaking be initiated on the'following subjects:
1.
Environmental Qualification of Safety-Related Electrical Equipment 2.
Environmental Qualification of all Safety-Related Equipment 3.
Accreditation of Laboratories Performing Qualification Testing The first rule will be issued as soon as possible.
The second rule can not be made effectiva until the supporting standards have been developed.
The rule on accreditation of laboratories performing environmental qualification testing will be issued as soon as possible.
Other areas requiring accredita-tion will be added as the necessary standards are developed.
6.
SUMMARY
AND CONCLUSIONS An advance notice of rulemaking will be prepared.
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