ML20035F091

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Requests That Encl NRC Rept on QA Activities to Fellow Members of ASME Nuclear QA Committee Be Placed in Public Document Room
ML20035F091
Person / Time
Issue date: 04/16/1993
From: Gormley O
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 9304200246
Download: ML20035F091 (5)


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UNITED STATES y

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NUCLEAR REGULATORY COMMISSION

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E WASHINGTON, D C. 20555 APR I C BM l

MEMORANDUM FOR:

Document Control Desk FROM:

0.P. G cmley

SUBJECT:

NRC Report on Quality Assurance Activities to Fellow Members of the American Society of Mechanical Engineers j

Nuclear Quality Assurance Committee 1

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Please place the enclosed report in the Public Document Room.

There are no j

restrictions on its distribution.

We expect little interest, and a useful lifetime of 3 months.

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J.W. Craig

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G.C. Millman l

M. Vagins j

R.A. Gramm j

Yours truly, l

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Owen Gormley i

Electrical and Mechanical Engineering Branch, DE/RES I

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NRC ACTIVITIES RELATED TO QUALITY ASSURANCE April 22, 1993 (1)

ENDORSEMENT OF N0A STANDARDS NQA-1 The public comment period for dras &.3 1.28 has closed, and we are in the process of evaluating the comments. A total of 14 written letters I

were received.

There were mixed opinions as to whether the RG should be published at tEis time. The concept of utilizing risk based techniques to grade the application of QA programs was supported in some comments.

Several respondents disagreed with the regulatory position pertinent to performing annual supplier evaluations. No decisions have been reached on how the comments will be dispositioned.

i NOA-2 We have revised the draft of the new regulatory guide endorsing NQA-2 to incorporate relatively minor staff comments and are preparing the RG for j

the remaining steps in the approval process. As we reported last time, the endorsement does not include Part 2.18 on maintenance because we are still waiting for completion of all NRC actions associated with the 4

Maintenance Rule before determining whether they are accurately reflected in Part 2.18.

l (2)

OTHER 0A STANDARDS REGULATORY GUIDE 1.33 The computer search for additional NRC guidance within the scope of ANS 3.2 was completed at the end of CY 1992, but the press of other business has prevented us from proceeding from that point. We were not able to make good on our commitment to give the ANS 3.2 writing group the regulatory issues before they finished their revision. While the writing group hasn't revealed vhat they will put in the standard, we assume that there will be a number of missing provisions that will necessitate an unacceptable number of regulatory positions in the guide. We met with the group on 3/25/93 and discussed hcw we might deal with that situation. One favorable circumstance of the problem is that for operating plants the positions will generally flow from positions already in force as a result of generic letters and bulletins.

I The IAEA is revising its QA Code 50-C-QA (Rev.1) and some of the Safety Guides to modernize them and make them more like NRC's SRP 17.3 and i

DOE's Chapter 5700.ri.

Frank Hawkins will probably report on the j

details of the revisions.

It wasn't po.csible for the Committee to give comments on earlier drafts. We will need comments on the latest drafts i

by late summer in order to incorporate them as part of the U.S.

comments.

A (3)

ENDORSEMENT OF ASME CODE ADDENDA (10 CFR 50.55A) l The Commission is amending its regulations to incorporate by reference the 1989 Addenda, 1990 Addenda, 1991 Addenda, and 1997 elition of Section III, Division 1, of the American Society ei K.4nical Engineers Boiler and Pressure Vessel Code (ASME Code), and tne 1989 Addenda,1990 Addenda, 1991 Addenda, and 1992 Edition of Section XI, Division 1, of the ASME Code. Additionally, the proposed amendment would expedite implementation of Appendix VIII of Section XI, Division 1, which provides rules for performance demonstration of ultrasonic examination systems. The proposed amendment would expand the scope of S 50.55a to require inservice testing and examination of safety-related snubbers.

The proposed amendment would, for the first time, incorporate by l

reference the 1990 Edition of the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code).

The ASME B&PV Code provides rules in Section III, Division 1, for the construction of components of light-water-cooled nuclear power plants, and Vovides rules in Section XI, Division 1, for the inservice inspection of those components.

Expedited implementation of Appendix VIII will help to improve the quality of inservice inspections.

Expanding the scope of S 50.55a to include safety-related snubbers will help to ensure that these component supports are tested and examined to quality standards commensurate with the importance of the safety functions to be performed. The ASME OM Code provides rules for the inservice testing of pumps, valves, and snubbers. Adoption of this proposed amendment will permit the use of improved methods for the construction, inservice inspection, and inservice testing of nuclear power plant components.

(4)

PROPOSED SALP REVISION The staff has conducted a ler.gthy introspective review of the SALP process. The program was evaluated with respect to the safety assessment needs of the agency.

Comments received during a public workshop were taken into consideration. On April 15, 1993, the proposed SALP program revision was presented to the Commission and the ACRS. Key program changes include: (1) revising the board composition to be Senior Executive Service (SES) members only, (2) reducing the length of the SALP report and revising the process in order to focus on the most significant issues in each of the functional areas, (3) providing additional guidance for the conduct of SALP public meetings, (4) defining a philosophy that NRC inspection resources will be allocated on the basis of licensee performance, and (5) condensing the report to four functional areas: plant operations, maintenance, engineering, and plant support (which includes radiological controls, security, and emergency preparedness). The changes to the program will enhance clear communication of NRC safety assessments with both licensees and the public.

m (5)

PROCUREMENT Between December 1991 and June 1992, the Vendor Inspection Branch (VIB) completed five pilot inspections that were conducted to evaluate the implementation of licensee programs for the procurement and dedication of commercial grade iteus (CGIs) and to finalize an inspection procedure for future inspections of this type. These inspections identified weaknesses in licensee CGI dedication programs and their implementation.

During this same period, the NRC received significant feedback from several utilities and the Nuclear Management and Rescurces Council (NUMARC) questioning the regulatory basis for the CGI dedication guidance contained in NRC Generic Letter (GL) 91-05, as well as specific interpretations of that guidance by the NRC inspection teams.

Because of the need for additional discussion of the requirements and implementing guidance for dedication of CGIs, no enforcement action was taken based on any of the five pilot inspections.

Rather, a series of meetings with several licensees and industry representatives (NUMARC and Electric Power Research Institute [EPRI]) were conducted to identify and gain insights into specific areas of differing interpretations of stated positions, and to identify areas in which additional clarifications or relaxations of NRC positions may be appropriate.

The NRC will be rmwcting a public workshop on April 21-22, 1993, to discuss and so b. comments on the key procurement and CGI dedication issues, and the draft revision to NRC Inspection T.acedure 38703,

" Commercial Grade Procurement Inspection". These comments, as well as comments received during the meetings with licensees, NUMARC, and EPRI, will be considered when finalizing the inspection procedure.

Following the public workshop and resolution of r.omments, the inspection procedure will be made part of the NRC Inspection Manual and issued for regional implementation.

(6)

Maintenance Rule Activities On July 10, 1991, the Commission published a new maintenance rule,10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This rule requires commercial nuclear power plant licensees to monitor the effectiveness of maintenance activities for cafety-significant plant equipment in order to minimize the likelihood of failures and events caused by the lack of effective maintenance. The rule is results-oriented and was written to be non-prescriptive to provide licensees maximum flexibility to utilize their existing programs, to the extent possible, to implement the requirements of the rule. Detailed or prescriptive requirements about how maintenance is to be conducted are not provided by the maintenance rule.

The key to the provisions of the maintenance rule is perforaance of the equipment under consideration. Maintenance effectiveness is to be evaluated by comparing how well equipment performs its intended functions against licensee established goals. The effective date of the rule is July 10, 1996.

In August 1991, the NRC began working in parallel with the Nuclear Management and Resources Council (NUMARC) in developing the guidance

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which would describe methods acceptable to the NRC for implementing the new maintenance rule.

In July 1992 the NRC determined the NUMARC

-j guideline was sufficiently acceptable and would form the basis for the 5

NRC regulatory guide. The NRC is now in-the final stages of completing the regulatory guide which will--endorse the NUMARC guideline for publication by late June 1993.

i (7)

NRC REACTOR INSPECTION PROGRAM l

The NRC is proceeding with a revision of the operating reactor inspection program to align the inspection effort allocated in the Core program element consistent with the SALP program revision that has four functional areas: (1) Plant Operations, (2) Maintenance, (3) l Engineering, and (4) Plant Support.

l Tha staff will perform service water system (SWS) inspections at plants i

licensed pre-1979.

Plants licensed after that date will be inspected if warranted due to having experienced problems in the SWS.

j (8)

HIGH LEVEL WASTE MANAGEMENT (HLWM) l There are no changes to report in this area.

(9)

LOW LEVEL WASTE i

l There are no thanges to report in this area._

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'i (10) TRANSPORTATION AND SECURITY OF RADI0 ACTIVE MATERIAL There are no changes to report in this area.

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