ML20050H408
| ML20050H408 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1981 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML19270A353 | List: |
| References | |
| FOIA-82-7 NUDOCS 8204140142 | |
| Download: ML20050H408 (13) | |
Text
February 4, 1981 PRINCIPLES SET FORTH IN THIS EXCHANGE OF CORRESPONDENCE BETWEEN THE UNITED STATES NUCLEAR REGULATORY COMMISSION, THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS, AND THE NATIONAL BOARD OF BOILER AND PRESSURE VESSEL INSPECTORS REGARDING THE ACCREDITATION AND INSPECTION OF NUCLEAR SUPPLIER QUALITY ASSURANCE PROGRAMS I.
Purpose l
The purpose in.the exchange of correspondence is to define the actions which will be taken and the responsibilities wiich will be assumed by The American l
Society of Mechanical Engineers (ASME), The National Board of Boiler and Pressure Vessel Inspectors (National Board) and the Nuclear Regulatory Cormiission (NRC) relating to the ASME/NB accreditation program and third party inspection of Certificate Holders providing products or services to nuclear 2
facilities in accordance with the ASME Boiler and Pressure Vessel Code,
Section III (Divisions 1 and 2). The objective of this effort is to provide NRC licensees and license applicants with a procedure for accepting the AS"E/NB nuclear accreditation program and the monitoring of supplier activities to assure compliance with NRC, ASME, and National Board programmatic quality assurance (QA) requirements.
Additionally, this document is intended to serve as a basis for proceeding with the development and implementation of other codes and standards falling within the scope of interest of the three participating organizations.
i 8204140142 820122 "3 PDR-FOIA PHILIP S82-7 PDR
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II.
Background
The Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974 authorized the NRC to license and regulate the manufacture, construction, and operation of atomic energy production and utilization facilities from the standpoint of the common defense, security, public health and safety.
In exercising its authority, the NRC has incorporated portions of the ASME Code into its regulations except for complete recognition of the ASME accreditation program and stamping.
Concurrently, several of the states and political subdivisions (defined in the constitution of the National Board as any city of the United States having a population of 1,000,000 or more) have passed laws 3
requiring that the overall construction of certain components and systems, e.g. pressure vessels, piping, valves, pumps, etc., be performed in accordance with the rules of the ASME Code,Section III (Divisions 1 and 2).
The apparent overlapping of similar functions has resulted in the evolution of separate and independent survey, audit and inspection systems applicable to a common group of nuclear equipment suppliers and vendors.
The consequence of this overlapping has been duplication of effort in the areas of QA program evaluation and inspection.
In the interest of efficiency and greater effectiveness in assuring the ultimate safety of nuclear facilities, the NRC, the ASME, and the National Board are engaged in a mutual effort to establish QA requirements and applicable administrative procedures of each organization which are compatible.
The exchange of correspondence documents the understandings and agreements for proceeding with a cooperative program and defines administrative arrangements 2-
for implementing that program.
The immediate objective of this program is to provide for the establishment of suitable conditions to permit NRC recognition and utilization of the ASME/NB system of nuclear accreditation and third party inspection.
Completion of this phase is expected to culminate in NRC recognitier of the ASME/NB nuclear accreditation and inspection system as an acceptable procedure which may be used by NRC licensees and license applicants to satisfy NRC programmatic QA requirements relating to the evaluation and inspection of supplier QA programs.
A longer term objective is to provide a vehicle for initiating cooperative actions and understandings in other areas of mutual interest.
III.
General Understandings A.
T,he program will be periodically and independently evaluated by the NRC, ASME, and National Board a's appropriate to the needs of each organization.
B.
This program may be unilaterally terminated by any of the three parties upon submission of written notice giving reasons for termination to the remaining parties.
C.
To the extent practicable, each party will consult fully with the others with respect to any action concerning implementation of the program. -Specifically, each organization will appoint an individual to serve on a coordinating committee.
D.
The participating parties will implement the understandings set forth in this correspondence so as to avoid duplication of effort to the 1
maximum extent consistent with their professional and statutory obligations and the health and safety of the public. To this end, each party may use advice and information provided by the other parties for the purpose of carrying out its responsibilities.
E.
The NRC will conduct periodic audits of the ASME and National Board activities associated with nuclear accreditation and third party inspection activities on a planned and scheduled basis, report the findings, and cooperate in cbtaining corrective actions on areas found deficient.
The NRC audits will utilize the ASME Code, Standards and procedures to determine whether the activities are being implemented in an effective and consistent manner.
F.
Copies of correspondence and other documents relating to enforcement or corrective action of identified deficiencies will be furnished to the other parties upon request in accordance with the procedures and policies of the respective organizations.
G.
To coordinate surveys, inspections, audits, and reviews of activities and to efficiently implement requirements, each agency will regularly advise the other of its schedules for accomplishing assigned functions.
IV.
Agency Responsibilities and Agreements A.
The American Society of Mechanical Engineers agrees to the following:
1.
To continue its leadership role in developing, obtaining national consensus, and issuing nuclear codes and standards, t
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Toimproveandbroadenthetechnikalrequirementsandadministrative 2.
procedures associated with the Society's codes and standards and nuclear accreditation and inspection system.
See paragraph IV.C.3 and Appendix A for proposed actions and projected schedules for accomplishment.
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3.
To continue its leadership and administrative role in implementing the nuclear accreditation program.
Specifically with respect to accreditation of those providing products and services in accordance with Section III, the ASME will continue to: manage the survey teams, including the selection of qualified team members; review survey team reports, issue or defer issuance of Certificates of Authorization based upon information provided 1
by Society representatives or agents; provide opportunity for a hearing on charges of Code' violations; and, if necessary, recall the Certificate of Authorization and the Symbol Stamp involved; and maintain records of such transactions.
4.
To permit designated NRC representatives to inspect and audit the activities administered by the Society relating to the issuance of Nuclear Certificates of Authorization, including all survey team activities and appropriate records associated with the issuance of such nuclear certificates.
S.
To encourage and assist those organizations (National Board, 4
Jurisdictional Authorities, Aythorized Inspection Agencies) in achieving corrective actions satisfactory to the appropriate - - -
.s parties on items identified by designated NRC representatives as being deficient within the scope of the ASME Code,Section III (Divisions 1 and 2).
6.
To maintain administrative procedures for conducting and documenting the program of nuclear accreditation.
Inherent in these procedures shall be acceptance / rejection criteria for the issuance of Certificates of Authorization.
7.
To prepare and maintain on an updated basis an ASME/ National Board management program document describing the present nuclear accreditation and inspection system.
This document will be periodically reviewed, as appropriate, by the NRC and made available to the public.
8.
To make final documentation relating to nuclear accreditation activities available for public disclosure upon the request of' 5
the authorized NRC official,
B.
The National Board of Boiler and Pressure Vessel Inspectors agrees to the following:
1.
To carry out its enforcement and investigative activities associated with implementation of the ASME Code,Section III (Divisions 1 and 2).
2.
To assist Authorized Inspection Agencies in having their i
l inspection personnel meet or exceed the requirements of the l
ANSI /ASME N626 Standards by conducting or approving suitable training courses.
3.
To audit Authorized Inspection Agency inspection procedures and programs for compliance with ANSI /ASME N626 Standards.
4.
To permit designated NRC representatives to audit the activities performed by the National Board related to the auditing, monitoring and surveillance of third party inspection as required by the ASME Code,Section III (Divisions 1 and 2) and the ANSI /ASME N626 Standards.
5.
To assist, upon request, NRC designated representatives to arrange audits of the Authorized Inspection Agencies, including Jurisdictional Authorities,' to verify conformance with the applicaale requirements of the ASME Code,Section III (Divisions 1 and 2) and the ANSI /ASME N626 Standards.
6.
To assist Jurisdictional Authorities and Authorized Inspection Agencies in achieving corrective action on items identified by designated NRC, ASME or National Board representatives as being deficient within the scope of.the appropriate ASME codes and standards.
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7.
To assist Jurisdictional Authorities in carrying out inspection activities relating to compliance of a nuclear plant with requirements that are within the scope of the appropriate ASME codes and standards.,
C.
The Nuclear Regulatory Commission agrees to the following:
1.
To encourage industry (including NRC licensees) support of the ASME and National Board activities associated with implementation, verification and enforcement of the rules of the ASME Code,Section III (Divisions 1 and 2).
2.
To inform the public, including NRC licensees and applicants, of the objectives of this program and to cooperate with the Jurisdictional Authorities.
3.
To review and formally endorse the ASME/NB accreditation program and third party inspection and other ASME nuclear code and standards activities (Appendix A) when equivalency (i.e.,
compatibility with related NRC Regulations and Regulatory Guides) is achieved.
4.
To support the consensus system of codes and standards development to the maximum extent consistent with NRC's responsibility.
5.
To support, encourage and participate in the expansion and modification of the ASME nuclear codes and standards effort to an extent consistent with NRC responsibility.
6.
To provide assistance, advice, and guidance to the ASME and the National Board regarding implementation, and changes in administrative procedures or in code rules for activities included in this agreement.
4 To cooperate with' Jurisdictional kuthorities and the National 7.
Board in matters that relate to compliance of.a nuclear plant with the appropriate ASME codes and standards and provide guidance on achieving the appropriate balance of jurisdictional
-involvement so that all parties involved can effectively fulfill.
their legal obligations to protect the public without conflict or significant duplication of effort.
8.
To consider revision of related NRC Regulations and Regulatory Guides when experience indicates such a revision is desirable.
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_g.
I This exchange of correspondence supersedes all previous exchanges of correspondence between the ASME, the National Board, and the NRC regarding the ASME/NB accreditation program and third party inspection.
2The ASME Boiler and Pressure _ Vessel Code, hereinafter referred to as "the ASME Code".
3Construction, as used herein, is an all inclusive term comprising materials, design, fabrication, examination, testing, inspection, and certification required in the manufacture and installation of items.
4Jurisdictional authority denotes a regional or local governing body, such as a State or Municipality of the United States or Candian Province, empowered to enact and enforce boiler code legislation.
5The authorized NRC official shall be the individual serving on the coordinating committee (Item III.C), or his designee.
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Appendix A Actions to be Considered Under the Exchange of Correspondence (February 1981)
A.
Accreditation of Supplier Quality Assurance Programs To enable the NRC to recognize that the holder of an ASME Certificate of Authorization (N-stamp) satisfies NRC programmatic QA requirements, issuance of such certificates must be based upon the same or equivalent requirements.
The ANSI /ASME NQA-1 quality assurance standard, as supplemented by NRC positions documented in Regulatory Guides, is
, acknowledged by the NRC to be an acceptable standard for this purpose.
It is therefore necessary and agreed that the ASME will apply the NQA-1 standard or its equivalent as the basis for issuance of Certificates of Authorization by either incorporating that standard in Section III, as appropriate, as an inherent requirement or 'by any other equivalent method.
The NRC positions with respect to the NQA-1 Standard will be considered, as appropriate, in any future revisions to the ASME NQA-1 Standard or the ASME Boiler and Pressure Vessel Code.
Upon application of the revised programmatic QA requirements to the issuance of Certificates of Authorization, the NRC will review the _ changes for compatibility with similar NRC requirements.
To the extent that compatibility is established, the NRC will make changes, as appropriate, to its rules and/or its Regulatory Guides defining the extent to which
_ possession of a Certificate of Authorization satisfies NRC programmatic QA requirements.
The objective of these actions is intended to allow NRC
licensees or their agents to accept Certificate Holder's QA programs without further independent audit.
Surveillance of other QA activities i
that are not programatic in nature or those associated with product acceptance will continue to be the responsibility of the NRC licensee.
The goal for accomplishment of this activity by the ASME is July 1,1982 (1982 Summer Addenda of the Boiler and Pressure Vessel Code) with publication of the proposed NRC endorsement 120 days later.
NRC endorsement of this activity will be taken independently of any other joint matters covered in the following paragraphs.
B.
Operability and Functional Testing Standards In the case of certain components, such as pumps and valves which must retain the ability to perform mechanical motion, nuclear plant safety is dependent upon operability as well as pressure boundary considerations.
It is therefore desirable that appropriate operability and functional test type standards be developed and applied to the fabrication and manufacture of such components.
The ASME agrees to continue its sponsorship of the development of operability standards.
These standards will address the technical and QA aspects.
Following development and approval (via procedures accredited as meeting the criteria for American National Standards) of specific or individual standards, appropriate steps will be taken to assure that the operability and pressure boundary standards applicable to a component are consistent and compatible and that implementation of these standards will be p.
accomplished within the scope of the ASME/NB code and standard accreditation and inspection system to the maximum possible extent.
The NRC agrees to review and formally endorse as appropriate each ANSI /ASME standard developed and approved under this program.
The. goal for completion of these activities is the end of 1984.
C.
Section XI, Repair and Modification, Owner Accreditation ASME/NB accreditation activities applied to ASME code type work performed at operating facilities (Section XI, repair and modification) and to the
. organizations responsible for conducting that work, continue to differ from procedures applied to Section III fabrication and erection.
The development and implementation of equivalent concepts, policies and procedures for operating facilities is desirable and a logical extension of the activities covered in this document.
It is therefore agreed that the parties engaged in this exchange will provide guidance and input to the organizational units responsible for the development of requirements in the operational area. The intent will be to achieve consistency in accreditation procedures when applied to ASME Code work for new plants or for operating plants.
This will be an on-going activity without specific accomplishment schedules.
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