ML20029D003
| ML20029D003 | |
| Person / Time | |
|---|---|
| Issue date: | 04/13/1994 |
| From: | Zech G Office of Nuclear Reactor Regulation |
| To: | Rossi C Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9405030224 | |
| Download: ML20029D003 (11) | |
Text
.
0 4
s:N '
s p atog
+I UNITED STATES
' f
,; j NUCLEAR REGULATORY COMMISSION C
'f
. WASHINGTON, D.C. 20566-0001
%****/
April 13, 1994
+
-MEMORANDUM FOR: Charles E. Rossi, Director-Division of' Reactor Inspection and Licensee Performance, NRR FROM:
Gary G. Zech, Chief Performance and Quality Evaluation Branch Division of Reactor Inspection and Licensee Performance, NRR
SUBJECT:
SUMMARY
OF THE FIRST NRC-INDUSTRY GRADED QUALITY ASSURANCE STEERING GROUPS MEETING ON MARCH 23, 1994 On March 23, 1994, the NRC graded quality assurance (QA) Steering Group met for the first time with their counterparts in the Industry Steering Group, consisting of NEI and industry representatives.
(See Enclosure 1.)
The staff initiated the meeting by reiterating its support of the industry graded quality assurance (QA) initiative and emphasized the potential safety benefits to be gained by allowing both the industry and regulators to concentrate their limited resources on the most safety significant structures, systems, and components (SSCs). The staff added that in 1993 the NRC Regulatory Review Group had identified-the need to examine the graded allocation of QA resources to SSCs based on their safety significance as one of its most important findings.
The staff repeated its earlier observations that current regulations, including Appendices A and B to 10 CFR 50, provide for the graded application of QA measures to SSCs commensurate with their intended safety function or significance.
In the past, the staff has identified specific QA provisions or controls to be applied to non-safety-related, balance-of-plant -(B0P) SSCs, to-address regulatory concerns; or, when required within a specific regulation, e.g., 10 CFR 50.62, (Requirements for reduction of. risks from anticipated transients without scram events) and 10 CFR 50.63 (Loss of all alternating current power)..
The industry representatives expressed agreement with the staff on the importance of the graded QA effort and provided some background on the activities of their Appendix B and Regulatory Threshold working groups.
They added that they remain encouraged by the support of the NRC staff to industry initiatives on the application of probabilistic safety assessment..
(PSA) technologies towards the resolution of motor-operated valve (M0V) and fire protection issues.
(79/rn - G -/)tct % g5 g- / - // - /,
ff, bb
('@k 940soso224 94042a PDR REVGP ERGNUMRC PDR
'NOC$7 1
~
d t
e
(
Charles E. Rossi April 13,1994 The; industry representatives stated that they envision the current graded QA effort, and 1ts reliance on PSA tools, as the initial step towards an ultimate goal of revising current regulations to explicitly include PSA insights within their framework.
They presented their key concepts for the implementation of the upcoming pilot program effort on graded QA (Enclosure 2), and the staff provided a list of, issues that have remained unresolved or not yet conclusively addressed.
(Enclosure 3.)
The staff. remained receptive to the conceptual approach advocated by industry for implementing a graded QA program and acknowledged that, within the proper framework, it could yield the desired results during the pilot program efforts. However, the staff cautioned that it would be unable to assess the acceptability of NEI's approach until the guidance document, clearly delineating the process and its limitations, is provided to the staff for review and comment.
NRC and industry representatives exchanged questions and comments on the material presented and agreed to meet again on May 12, 1994, to continue their discussions and to assess the progress of their respective working groups. is the meeting agenda, Enclosures 2 and 3 are copies of the material presented by industry representatives and the NRC staff, respectively, and Enclosure 4 is the gINAL SIGNgo gy of meeting participants.
GARY G. ZE G(ary G. Zech, CH Thief Performance and Quality Evaluation Branch Division of Reactor Inspection and Licensee Performance, NRR cc w/ enclosures:
Nuclear Energy Institute Attn: Alex Marion 1776 Eye Street NW Suite 300 Washington,-DC 20006-3706
Enclosures:
- 1. Meeting Agenda DISTRIBUTION:
- 2. NEI presentation material See next page
- 3. NRC presentation material
- 4. List of Attendees
- See previous concurrence OFC SEND RPE8:DRll:NRR RPER:DRILtNRR SC:RPES:DRIL:NRR
.8 (B;DR!L:NRR NAME TO JPeralta:cct RLatta RAgrarmi N/ ((J94 DATE PDR?
04 /08 /94*
'04 /08 /94*
04/08 /94*
/
/94 COPY 7 Yes No Yes No Yes No Yes No es )
No Yes No S:\\RPLBDOCS\\S'CilON.QA\\NEl-SGIMt(
OfflCIAL RECORD COPY DOCUMENT NAMEt t
Y
l' i
Charles E. Rossi.
DISTRIBUTION:
Central Files:(PI-22)
EJordan, 3701 PDR (PI-22)
RPEB R.F.
RZimmerman,-12 D22 ARamey-Smith, 10 E4 DRIL R.F.
JPage, NLS314 GMizuno, 15 B18 NRC Meeting Participants JJohnson, 10 E4 MModes, RI-l WTRussell, 12 G18 RrCorreia, 10 A19 FJape, RII FJMiraglia, 12 G18 JHolahan, 9112 BBurgess, RIII.
MDey, NLS314 RHWessman, 9.A2-Wang, RIV LReyes, 12 D9 Eleeds, 12 G18 MVirgilio, 8 E2 CMcCracken, 8 01 AGody, 13 E21 NRR Mailroom RVollmer, 1 F22 GMillman, NS217B 0Gormley, NLS217B WGleaves, NL2178 DFischer, 7 E23 OPA r
i t
l
)
m.,
, e
Agenda for NEl/NRC Steering Group Meeting on Graded QA March 23,1994
Introductions
NEl/NRC
Background
A. Thadani Open issues G. Zech NEl Comments B. Rasin Future Schedules NEl/NRC Closing Remarks NEl/NRC i
l i
i i
a 1
1
.o NRC STEERING GROUP i
1 J. L. Milhoan Deputy Executive Director for 4
Nuclear Reactor Regulation i
Regional Operations and Research C. J. Heltemes Deputy Director for Generic Issues and Rulemaking Office of Nuclear Regulatory Research A. C. Thadani Associate Director for Inspection and-Technical Assessment Office of Nuclear Reactor Regulation NEI STEERING GROUP W. H. Rasin Vice President Nuclear Energy Institute W. H. Bohlke Vice President Nuclear Engineering and Licensing Florida Power and Light J. L. Skolds Vice President Nuclear Operations South Carolina Electric and Gas J
NRC - INDUSTRY SENIOR MANAGEMENT STEERING COMMITTEE FOR GRADED, PERFORMANCE-BASED APPROACH TO IMPLEMENTING QUALITY T
i n'
l i
~j~,
a f
- ' ---^ ~-~ ^
~^-^ ^^^~~^ '^^^^^ ^'^^
^
^
^ ^ ^ ~ ~ ^ ^ '
^
uj.a dq }e,d
. KEY CONCEPTS m
c.;
Pilot arojects to.ae done on-line unc er 10 CFR 50.54(a) framework Pilots may neec to ad,'ust their approach after guidarice is finalized Grading entai.s use of PSA insights, operating experience and engineering judgment to establish sa"ety significance of SSCs Current QA practices will continue to apply to safety significant SSCs A performance-based approach (i.e., not prescriptive / programmatic) wil ae used :o demonstrate compliance for nonsa'ety significant SSCs
PILOT IMPLEMENTATION a
g!1L UNDER 10 CFR 50.54[a) o a dg.
Key Poin:s
- little or no change to UFSAR or QA Topical Report
- change is to the applicability of prior commitments to certain SSCs
- reduction in commitments is for nonsafety significant SSCs Proaosed Process per 50.54(a)
- letter to NRC stating which systems or portions of systems will be subject to reduced commitments
- stated reason is that SSCs are nonsafety significant as identified by using methods of NEl 94-XX
- SSCs will continue to meet Appendix B through a performance-based approach as described in NEl 94-XX
GRADED APPROACH TO
<;".;,j',g,'{
Ob$i3!/I' IMPLEMENTING QUALITY A
A Safety significant imp e en a ion per urrent practices (Safety related &
non-safety related) p Scope per A
Maint. Rule +
Performance-Non-safety significant based (safety related &
compliance non-safety related)
(New Reg.
Guide)
V U
Other SSCs-
+ Reg. Scope =.Maint. Rule Scope + Other SSCs from Other Regs.
March 23, 1994 OPEN GRADED OA ISSVES 1.
Agreement on the contents and details of guidance before commencing the pilot program.
Draft NEI document not yet received.
Staff is working on draft guidance separately.
2.
The treatment of safety-related SSCs determined to be of low risk significance through the application of NUMARC 93-01 guidance.
NEI has proposed the use of a " Company Quality Program" for these SSCs with NRC relief from commitments to reg guides, ANSI standards, etc.
The staff envisions a process that would consider other factors, in addition to risk, to define and establish appropriate QA measures that would be applied.
3.
Definition of what an on-line implementation of the graded quality assurance methodology during the pilot program will entail,.eg, NRC pre-approval of licensee relief from current QA plan provisions for low-risk significant, safety-related SSCs.
Also, NEI has proposed that decisions made during the pilot effort would be permanent.
NRC has questioned how decisions made during the pilots would be reviewed to identify potential safety impacts.
4.
The treatment of non-safety-related SSCs that are determined to be of high risk significance. Will the guidance include an approach to identify the QA provisions that should be applied to these SSCs?
'4 t
Page 1 of 1 Meeting Attendance List March 23, 1994
[M ORGANIZATION TELEPHONE Bill Rasin NEI (202) 739-8000 Bill Bohlke FPL (407) 694-3241 Alex Marion NEI (202) 872-1280 Jack Skolds South Carolina Elec. & Gas (803) 345-4001 Adrian Heymer NEI (202) 872-1280 Tony Pietrangelo NEl (202) 872-1280 Jack Heltemes NRC/RES (301) 492-3720 Ashok Thadani NRC/NRR (301) 504-1274-James Milhoan NRC/ DEDO (301) 504-1705 Gary G. Zeci; NRC/NRR/RPEB (301) 504-1017 Ernie Rossi NRC/NRR/DRIL (301) 504-2903 Richard Correia NRC/DRIL/RPEB (301) 504-1009 Robert M. Latta NRC/DRIL/RPEB (301) 504-1023 Juan Peralta NRC/NRR/DRIL (301) 504-1052 Gil Millman NRC/RES/DE (301) 492-3848 Roy Zimmerman NRC/ADP (301) 504-1009 Joel D. Page NRC/RES/DSIR/EIB (301) 492-3941 Bill Gleaves USNRC (301) 492-3817 Bruce L. Burgess USNRC - RGN III (708) 829-9705 Richard Wessman NRC/NRR/DRIL (301) 504-1243 Bill Dean NRC/0ED0 (301) 504-1726 John C. Ciccone NEI (202) 739-8023 Roy Karimi SAIC (301) 353-8326 Michael Knapik McGraw-Hill (202) 383-2167 David Teague Winston & Strawn (202) 371-5907 Hans Renner NUS Corp.
(301) 258-8693 3