ML20052H042
| ML20052H042 | |
| Person / Time | |
|---|---|
| Issue date: | 04/01/1982 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20052H044 | List: |
| References | |
| ACRS-1959, NUDOCS 8205190298 | |
| Download: ML20052H042 (25) | |
Text
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ACRS SUBCOMMITTEE MEETItG
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/,9 INTRODUCTION The ACRS Subcommittee on Regulatory Activities met on Marc 982 at 1717 H Street, N.W., Washington, D.C. to discuss some proposed Regulatory Guides and Regulations. 'lhe entire meeting was open to public attendance.
Mr. Sam Duraiswarry was the Designated Federal Ertployee for the meeting. A list of I
documents submitted to the Subcomittee is included in Attachment A.
1 ATTENDEES i
ACRS:
C. P. Siess (Subcomittee Chairmn), W. Kerr, J. J. Ray, l
M. Bender, and S. Duraiswamy (Designated Federal Er:ployet.
Principal NRC Speakers:
W. Morrison, T. Scarbrough, F. Forscher, G. Reinmuth, Z. Rosztoczy.
(
Principal l
Industry i
Speakers:
A. Roby (Atomic Industrial Forum (AIF) Representative),
J. Perry (ASME Nuclear Quality Assurance (NOA) Comittee Repre-sentative)
EXECUTIVE SESSION Dr. Siess, the Subcommittee Chairman, convened the meeting at 8:45 a.m., and i
indicated that the purpose of this meeting was to discuss the following:
1.
Regulatory Guide 1.28, Revision 3, (Task No. RS 002-5), " Quality Assurance Program Requirements (Design and Construction)" (Post Comment).
j 2.
Comission Paper on Proposed Amendment to 10 CFR Part 50, Section 50.49a " Accreditation of Qualification Testing Organizations" (Pre Coment).
l He said that the Subcommittee had received requests from AIF and Yankee Atomic Cor:pany for time to trake oral statements on the proposed 10 CFR 50.49a " Accreditation of Qualification Testing Organizations".
(NOTE: During DE310NATEJ ORIGINAL 5
98 820401 Certified ry MM 1959 PDR
)
Regulatory Activities Meeting March 3, 1982 the break time of the meeting, Mr. Baxter representing Yankee Atomic Conpany and Mr. Roby reprecenting AIF decided to give only one (AIF) presentation to the Subcommittee). '1he Subcommittee had received also a request from the ASME NQA Standards Committee for time to make oral statements on Regulatory Guide 1.28, Revision 3.
He said that the Subcommittee will hear oral comments from representatives of these organizations at the appropriate time during the course of the meeting.
RD3UIAIORY GUIDE 1.28, REVISION 3, (TASK NO. RS 002-5). " QUALITY ASSURANCE PROGRAM REQUIREMENTS (DESIGN AND CONSTRUCTION)" (POST COMMENT)
This Guide describes a method acceptable to the NRC Staff for conplying with the provisions of Appendices A and B to 10 CFR Part 50 for establishing and inplementing a Quality Assurance (QA) program during design and construc-tion of nuclear power plants.
The proposed Revision 3 to this Guide endorses with certain exceptions ANSI /ASME NQA-1-1979, " Quality Assurance Program Requirements for Nuclear Power Plants"; this Standard is based on the contents of ANSI /ASME N45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities", and seven of the ANSI N45.2 series (N45.2.6, N45.2.9 through 13, and N45.2.23)
Standards which contain guidance on programmatic QA requirements.
Dr. Siess provided a brief preamble, indicating that a previous version of this Guide dated November 20, 1980 was submitted to the Regulatory Activities Subcommittee for review during the January 6,1981 meeting. However, owing to lack of sufficient time, the Subcommittee did not review it in detail; but, indicated that the NRC Staff could issue the Guide for public comment.
It was issued for public comment on April 17, 1981 and the current version, dated January 7,1982, reflects consideration of public comments. He indicated that the NRC Staff requests ACRS concurrence in the Regulatory Positions of the current version of this Guide.
The Subcommittee discussed the way in which the NRC participates in the preparation of voluntary consensus standards and the way NRC uses such standards.
4 Regulatory Activities Meeting March 3, 1982 Dr. Siess commented that the industry spends a lot of time and effort in developing voluntary consensus standards and the NRC endorses such standards in Regulatory Guides by taking certain exceptions in riost cases; it seems that the industry does not like to see the NRC taking exceptions to voluntary con-sensus standards.
If the industry does not like the way in which the NRC uses the voluntary consensus standards, one alternative is that they can let the NRC do the entire job.
However, he does not believe that this is a l
good idea because NRC may not have the time or expertise to do what the industry has been doing.
1 Dr. Siess commented further that the rationale for including certain items in the Standards as non-mandatory guidance has not been clear. He asked whether i
there are any guidelines to determine when certain items should be made mandatory.
Mr. Morrison responded that there are no such guidelines.
l The Subcommittee asked some questions with regard to the basis for making
" mandatory" some items in Regulatory Guide 1.28 that are included in the appendices of the ANSI /ASME NOA-1 Standard as "non--mandatory guidance".
Mr. Morrison responded that several of these items are mandatory in the existing ANSI N45.2 Standards or in the Regulatory Guides endorsing those Standards. However, in the proposed ANSI /ASME NOA-1 Standard which consoli-dates seven of the ANSI N45.2 series Standards, these items were changed to non-mandatory and included in the Appendices. 'Ihe NRC Staff has evaluated these non-mandatory guidance items includ.ed in the Appendices of the NOA-1 Standard with respect to their acceptability in meeting the requirements of 10 CFR Part 50, Appendices A and B.
Where this guidance is considered l
to have sufficient safety importance, the NRC Staff has made it mandatory by including it in the Regulatory Position of this Guide. Further, he believes that this sort of approach will provide specific guidance to the users of this Guide concerning the acceptability of such guidance to the NRC l
Staff; it will also make it easier to review, inspect and enforce the QA requirements of Appendix B to 10 CER Part 50.
Dr. Siess commented that it would have been very helpful if the Value-Irtpact Statement of this Guide included the rationale for making certain
Regulatory Activities Meeting March 3, 1982 items mandatory in this Guide that are included as non-mandatory guidance in the Appendices of the NOA-1 Standard; he is disappointed that the Value-Irrpact Statement does not include any such information.
Mr. Scarbrough reviewed briefly this Guide, the nature of public comments received during its public comment period, and the changes made as a result of the resolution of those cortments (Attachment B, Pages 1-7).
Some of the discussions are as follows:
Regulatory Position C.1 - This position discusses the relationship between Regulatory Guide 1.28, ANSI /ASME NQA-1 Standard, and the ASME Boiler and Pressure Vessel Code. Changes made subsequent to the public comment period were only editorial in nature.
With reference to the item on " Qualification of inspection and test personnel" that is included in this Position as an exartple of acti-vities that are not covered in detail in the ASME Code, Dr. Siess and Dr. Kerr asked why the Code does not cover this in detail.
l Mr. Scarbrough responded that, although the ASME Code states that the inspection and test personnel should be qualified, it does not provide specific information as to how to qualify these personnel.
However, an effort is currently underway by ASME to incorporate ANSI /ASME NOA-1-1979 in the Code.
1 Regulatory Position C.2 - This Position provides guidance for functional and education and experience qualifications of inspec-tion and test personnel. Changes were made to provide additional guidance to clarify alternatives to the recommendations of the ANSI /
ASME NOA-1-1979 Standard associated with personnel qualifications.
Dr. Siess asked why, in spite of strong objection from the industry l
to the requirement for high school graduation included in this l
l
~
Regulatory Activities Meating March 3, 1982 Position, the NRC Staff included that requirement. The NRC Staff responded that, since the Standard does not include any specific information for the qualification of personnel, coupled with the fact that specific guidance is necessary for the NRC Staff to evaluate and enforce cortpliance of NRC regulations, it has been incut'ed in this Position. This Position also states that if an applicant wants to use an alternate method for qualifying inspection and test personnel, he can propose such a method.
Dr. Siess and Dr. Kerr asked whether this Position is intended to require that documented evidence relating to the equivaldney of high school education should be'provided if an alternate approach'is used for qualifying personnel.
Mr. Scarbrough responded that it is not the Staff's intent.
Dr. Siess and Dr. Kerr suggested.that it~would helpful if the Staff's intent is made clear. The Staff ' agreed. }
With regard to the sentence in Position 2.a which states "As clarifica-tion, for qualification of personnel..... should be followed in lieu of the guidelines in ANSI /ASME NOA-1-1979," Dr. Kerr commented that the phrase "as clarification" in this sentence is misleading because it is not clear what it clarifies. He suggested deletion of this phrase.
The NRC Staff agreed.
Regulatory Position 3 - This Position provides guidance for education and experience qualifications of lead auditors. No changes had been made subsequent to the public comment period.
Dr. Siess asked whether there are any education and experience j
requirements that are used by the industry that are different from l
those listed in Appendix 2A-3 of the Standard which is referenced in this Position.
Mr. Morrison responded that to his knowledge there are l
none.
Regulatory Activities Meeting March 3, 1982 Regulatory Position 4 - This Position provides guidance for design control, design input, and design verification. Some of the changes made were editorial in nature. Changes were also made to reference the design irput list provided in the Standard rather repeating the same list in this Position.
Dr. Siess suggested that it would be helpful if the NRC Staff included in the heading of this Position, and other Pocitions as needed, reference to the Appendices of the Standard that are addressed by these Positions.
The NRC Staff agreed to do so.
With regard to the qualification requirement for personnel to perform design verification (included in Position 4.c), Dr. Siess asked why a supervisor is not eligible to do the design verification, if he is not involved in the original design.
Mr. Morrison responded that it would be very difficult to establish that a supervisor was not involved in the original design.
Dr. Siess commented that Supplement 3S-1 of the Standard does not call for an " independent" design verification, but merely states that the design verification shall be performed by a competent individual other than those who performed the original designs; however, the NRC Staff has called for " independent" design verification in this Guide. He believes that introducing the word "independertt" without defining it properly will cause confusion.
Mr. Morrison responded that the NRC Staff will try to avoid using the term " independent" for design verification in this Position.
Regulatory Position 5 - This Position provides guidance for document control. No changes were made subsequent to the public comment period of this Guide.
Regulatory Position 6 (Previous Position 7) - Previous Regulatory Position 6 " Control of Purchased Items and Services" that was included in the Pre-Comment version of this Guide had been deleted
s a
~
., Regulatory Activitics Meitting March 3, 1982 4
since Section 3.1 of Supplement 75-1 of the ANSI /ASME NOA-1 Standard
, rovides necessary guidance for control of purchased items and services.
p Changes were mde to clarify the provision for retention of records for short-life items and the commencement of the retention period.
\\
-With regard t'o the provir,ien that programmatic nonpermanent records should be retained for 3 years and product nonpermanent records should be retained for 10 years, Dr. Kerr commented that this provision may have significant imact,on the industry. He does not believe that this provision can be justified in terns of its contribution to the public
, health and safety. He asked whether the ig lementation of this provision will reduce risk in the operating plants.
Mr. Morrison responded that it would be difficult to say whether this would reduce risk. Mr. Scarbrough a
added that if certain records were not retained for a specific period after cocpletion of'.the work and prior to fuel load, it would be difficult to demonstrate the accetablility of the work performed.
Regulatory Position 7 (Previous Position 8) - This Position provides guidance for quality assurance audits. Changes were made to provide clarification and flexibility.
~
COMMENTS BY THE ASMti' OA COMMITTEE - MR. J. PERRY N
Mr. Perry, representir/j the ASME tQA Connittee, presented the current position of the ASME NQA Committee on the technical contents of Regulatory Guide 1.28, Revision 3.
(Attachment C, Pages 1-6). He said that several of the major concerns expressed by the.ASME NQA Cognittee in its letter dated June 12, 1981 on the public-comment version of this Guide are still outstanding. Some of the general conunents provided by Mr. Perry are as follows:
- 'Ihere is a trend in the NRC to overeghasize formal education as comared to actual work experience and the nature of the job itself in determining personnel qualification requirements.
For exagle, the proposed educational requirements included in Regulatory Position C.2 for inspection and test personnel
V Regulatory Activities Meeting March 3, 1982 unnecessarily limit the number of potentially qualified candidates with no apparent correlation to the tasks performed by these inspection and test personnel.
- In many instances, the proposed Regulatory Guide escalates to the level of requirements sections that are in the form and context of non-mandatory guidance in the ANSI /ASME NOA-1 Standard. Rese escalations circumvent the logic and rationale which appropriately identified those sections as non-mandatory guidance.
- Re NOA-1 Standard was developed in accordance with a consensus process accredited by the American National Standards Institute.
l he ASME NOA Committee believes strongly that the NOA-1 Standard is fully adequate technically and is a conplete programmatic QA Standard for application to nuclear power plants.
- We ASME NQA Committee feels that the large number of impacts of Regulatory Positions in Regulatory Guide 1.28, Revision 3 represent t
an unrealistically rigid approach to programmatic quality assurance.
If this approach is continued, they believe that two major problems i
l l
will develop:
a.
As an industry, they are moving toward a wider scope of applicability of formal QA,progams, with enphasis on a graded approach consistent with items of importance to safety. We approach of Regulatory Guide 1.28, Revision 3 seems to rigidly structure the QA program to severly limit the ability to apply a graded approach. Therefore, Regulatory Guide 1.28 Revision 3 as proposed would tend to discourage the increased QA program scope.
I b.
Continuing technical differences between Regulatory Guides and consensus standards is a discouragement to the voluntary standards process for the nuclear industry at the very time when this process needs to be most active and aggressive.
l
d' Regulatory Activities Meeting March 3, 1982 The Subcommittee discussed the specific comments of the ASME NQA Committee on Regulatory Guide a.28, Revision 3 (Attachment C, Pages 4-6).
With regard to one of the NQA Comittee's coments that Regulatory Guide 1.28 escalates some of the non-mandatory guidance of the Standard to mandatory re-quirements, Dr. Siess pointed out the reasoning for this approach provided by the NRC Staff in the Discussion Section of this Guide which states that the NRC Staf f has evaluated the non-mandatory item included in the NOA-1 Standard and, where applicable, some of those are included in the Regulatory Positions of this Guide. One of the reasons for such an approach is to inform the applicants in advance that although using the method included in the NOA-1 Standard is acceptable to the NRC Staff, if an applicant wants to propose an alternate method they can do so.
He believes that this sort of appproach provides a chance to those who want to use an alternate method other than that proposed in the NOA-1 Standard.
In his opinion, an applicant has just as nuch right to come in with an alternate method if he commits to Regulatory Guide 1.28 as if he ccmmits to ANSI /ASME NQA-1 Standard.
With regard to the comment on Regulatory Position C.2.la concering the level arrangement, Dr. Siess said that he does not believe that Regulatory Guide 1.28 specifies that one has to have levels I, II and III; it specifies certain acceptable qualifications for these personnel.
It is not clear to him how the ASME NQA Committee interpreted the provision of C.2.la to mean that an ?pplicant should have all these three levels.
J Dr. Kerr asked whether the NRC Staff has any intention of requiring that the applicants should have all three levels.
Mr. Morrison responded that it is not the intention of the Staff.
Mr. Perry said that he believes that the determination of the number of levels that are needed should be a management perogative.
Dr. Siess stated the he does not believe that anything in Regulatory Guide 1.28 removes it from a management perogrative.
i Regulatory Activities Meeting March 3,1982 Dr. Kerr asked how the ASME NQA Committee interpreted the Regulatory j
Guide to mean that each organization should have three levels. Mr. Perry responded that if an applicant committed to Regulatory Guide 1.28 without taking any exceptions, and if he did not have a level III because of the size of his organization, he still would have to describe the levels he had and how he correlated to the level of details described in this Guide; he believe, that such description is unnecessary.
The Subcommittee discussed the ASME NQA Committee's comment on Regulatory Position C.4a.
Mr. Perry pointed out that the ASME NQA-1 Standard will be used not only by the nuclear power plant applicants but also by their contractors and subcontractors.
A major portion of the 26 non-mandatory l
items for design input included in the Standard may not be applicable to I
every subcomponent design; by making these items mandatory in Regulatory Guide 1.28, a contractor or a Subcontractor needs to provide documentation to justify why those items are not applicable to his design. He believes that such an exercise will have no safety significance.
In addition, there may be some other important items that might not have been included in the suggested design input list of the Standard.
If these items were not made mandatory, there is a possibility that an applicant would have thought about some of those important items.
Dr. Siess commented that by making these 26 fems mandatory, the Staff sort of gives a chance to the applicants to pass the responsibility to someone to decide what is important. Further, it 'also provides room to overlook some other important items that might not have been thought about and included in the Standard.
Mr. Bender and Dr. Siess suggested that the NRC Staff try to revise Regulatory Position C.4a to say that a design input list similar to the one included in the NQA-1 Standard should be developed by the applicant. Mr. Morrison responded that there would not be any problem for the Staff to make that change. However, he is not sure whether an applicant would like it better to develop his own list instead of following the list that is already in the Standard.
Regulatory Activities Meeting March 3, 1982 Mr. Perry said that the development of a design input list is not the major concern. The major problem is the extent to which an applicant or his contractors should have to provide documentation justifying the items that are not applicable to their design.
The ASME NQA Committee's comment on the need for retaining nonpermanent records was discussed by the Subcommittee.
Dr. Siess commented on the argument provided by the Staff in its resolution of public comment on this issue, which states that "In order for the NRC to fulfil its role in protecting the health and safety of the public, the Staff requires certain records to be maintained, either for lifetime or for a specified amount of time." He is not sure that how the retention of certain records for a certain period will protect the public health and safety. He believes that if something happens during the operation of the plant and it has to do with some work done in the past, and if it is uncertain whether that work was done right, the NRC Staff can shut the plant down to protect the public safety as they did in the past when there were uncertainties about seismic design. He believes that it is up to the applicants to decide whether to retain certain nonpermanent records and for how long or to take a calculated risk of their plants being shut down in the absence of such records to dettonstrate the acceptability of certain work performed, if such a need arises in the future.
Dr. Siess asked whether Regulatory Guide 1.28 Revisien 3 will be reviewed by the Comittee to Review Generic Requirements (CRGR).
Mr. Morrison responded that it will be sent to CmR for review prior to issuing it for industry use.
l Dr. Siess suggested that it would be helpful if the CER got copies of the transcript and the minutes of the subject meeting to help them have a clear l
perspective of the concerns raised by the Subcommittee. He hopes that the CRGR will raise questions as to how some of the provisions of this Guide, such as the one for retention of nonpermanent records for a specific period of time, will irrprove the public health and safety.
Mr. Morrison said that he beliGves it may be difficult to defend the NRC's need for this Guide before the CRGR, because it was developed in response w,
Regulatory Activities Meeting March 3, 1982 to a request from the industry that the NRC develop a Guide to endorse the ANSI / ASME NOA-1 Standard.
Dr. Siess said that he does not believe that the ACRS is going to help the NRC Staff justify this Guide before CER. He believes that the Staff needs to answer several questions:
- What is tne Commission policy on the overall QA program?
- What are the benefits of making non-mandatory itens of the Standard mandatory? How much will this approach contribute to the public health and safety?
- Will the additional paper generated by the implementation of the pro-visions of this Guide result in additional quality? Will it contribute to the public health and safety?
Af ter further discussion, the Subcomittee decided to recommend the following to the full Comittee:
- 'Ihe Subcommittee does not believe that the ACRS should either approve or disapprove of the Regulatory Positions of Regulatory Guide 1.28, Revision 3 without review by the full Comittee.
If such a review is undertaken, it probably should be broader than this Guide and should include all aspects of quality assurance and the relation of quality assurance to quality and to safety or risk.
- An alternative to review by the full Comittee at this time is that the ACRS refer this Guide to CER to evaluate the value-inpact or risk-cost-inpact features of this Guide; ACRS should reserve the right to review this Guide after it is acted upon by the CPGR.
COMMISSION PAPER ON PROPOSED AMENDMENT 'IO 10 CFR PART 50, SECTION 50.49a,
" ACCREDITATION OF QUALIFICATION TESTING ORGANIZATIONS" (PRE COMMENT)
Dr. Siess provided a preamble indicating that the proposed amendment to 10 Cm Part 50, Section 50.49a is to require that all qualification testing of equipment inportant to safety, required by the proposed 10 Cm 50.49,
" Environmental Qualification of Electric Equipment for Nuclear Power Plants,"
shall be performed by testing organizations accredited by the Institute of Electrical and Electronic Engineers (IEEE). This proposed amendment 1
Regulatory Activities Meeting March 3, 1982 conforms to an agreement between the NRC and the IEEE, effective September 30, 1981, regarding the accreditation of testing organizations. 'Ihe require-ments of this proposed rule will apply to all qualification testing that will comence af ter the effective date of this rule.
It will not apply to equipment already installed or whose qualification testing was initiated before the effective date of this rule.
Inplementation of this proposed accreditation program would provide assuranc6 that an organization performing qualifi-cation testing has the capability to meet the requirements for the conduct of specific tests as required in the proposed 10 CFR 50.49. However, it t lld not assure the acceptability of qualification tests or the results of these tests. Licensees and applicants would still be responsible for assuring that equipment is adequately qualified.
Dr. Siess mentioned that, in addition to receiving a request from AIF for time to make oral statements on the proposed 10 CFR 50.49a, Mr. Holzman f rom Engineering Planning and Management, Inc. wanted to call the attention of the Subcommitte3 to the fact that the letter from Messrs. R. Larson and J. Owens of IEEE to Mr. C. Walske of AIF, dated February 3,1982 (Attachment D) includes a statement that IEEE has not taken a position on the need for the laboratory accreditation program.
In addition, he wanted to call the attention of the Subcommitteee to an article entitled "IEEE Position on Accreditation of Testing Laboratories," appearing in the Engineering Journal (Attachment E), in which Mr. Wylie, author of the article, states that IEEE's position is, and has always been, neutral regarding the NRC's laboratory accreditation program.
Dr. Siess asked how, in the absence of an accreditation program such as that proposed, the NRC Staff got assurance in the past that the testing was done in a facility with adequate capability. Mr. Reinmuth responded that the NRC Staff depended mainly on the licensees to pass on the NRC QA requirements to the facility who was doing the testing and to make sure, through audits, conformance with those requirements. The NRC Staff's assurance that the testing was done in a qualified facility was obtained only on a sanpling basis through the site audits of the licensee's activities.
l l
Regulatory Activities Meeting March 3, 1982 Mr. Forscher said that, as recomended by the CR3R that an inplementation date of this proposed rule be included, the NRC Staff has proposed January 1,1983 as the inplementation date for this proposed rule. The proposed rule is sdieduled to be issued in its final form in July 1982, giving the industry about six nonths to meet the proposed inplementation date of January 1,1983. However, should there be any delay in issuing the final rule as scheduled or should there be a need to revise the inplementation date because of public comments, the NRC Staff may come up with a different inplementation date.
Dr. Siess asked how many testing organizations does IEEE think it can get accredited by January 1,1983? Mr. Reinmuth responded that about 50 testing laboratories are expected to be accredited by IEEE by January 1,1983.
In response to a question from Dr. Siess as to whether there are any require-ments that seismic qualification testing should be performed in an accredited laboratory, Mr. Rosztoczy said that there are no such requirements at the present time. Seismic qualification tests are performed in accordince with the requirements of applicable General Design Criteria. The proposed 10 CFR 50.49a on Laboratory Accreditation Program is to require that the qualification testing of electrical equipment that would be required by the proposed 10 cm 50.49 should be performed by an IEEE-accredited testing organization.
Dr. Siess commented that there seems to.be a big loophole in the NRC regula-tions. He believes that the proposed rule could have been written to require that seismic qualification testing as required by the applicable General Design Criteria should be performed by an accredited organization. He asked l
about the reasons for such a narrow approach.
l l
Mr. Rosztoczy responded that the original version of proposed 10 Cm 50.49 included seismic qualification. However, the Comission decided not to include the seismic qualification at the present time. He believes that the proposed rule will be expanded in the future to include seismic and mechanical equipnent qualification.
l l
Regulatory Activities Meeting March 3, 1982 Mr. Bender commented that if we start getting into the testing of large electrical equipment, one has to know in detail the test program for the testing of such equipment prior to evaluating the capability of the quali-fication testing organizations. He is not sure that IEEE has the capability to do the job in the way it should have to be done or that the proposed program will be effective. He believes that, except in very few cases, there are not many facilities equipped to do the qualification testing of large electrical equipment.
Dr. Siess asked that, since all equipment is not qualified by tests, whether there are eny accreditation procedures to deal with the qualification of equipment by analysis. Mr. Rosztoczy responded that they normally get adequate documentation to justify the analytical work done to qualify an equipment. However, they may have to evaluate and decide whether this issue needs to be addressed.
COP 94ENTS BY AIF - MR. A. ROBY Mr. Roby, from Northeast Utilities, represented the AIF and presented the industry viewpoint on the proposed Laboratory Accreditation Program (Attachment F, Pages 1-5). He mentioned that an industry position paper expressing strong disagreement on the proposed accreditation program has been submitted to Mr. Dircks, NRC Executive Director for Operations, for consideration (Attachment G, Pages 1-5). Some of the comments provided by Mr. Roby are as follows:
- Industry disagrees strongly that a need exists for an accreditation program.
It is the industry view that irrposing an accreditation program would not result in any measurable increase in the quality of testing services or enhance public health and safety.
- The need for, or alternatives to, the development of an accredi-tation program has not been evaluated properly. Conpliance with the existing requirements of 10 CER Part 50, Appendix B already assures the use of high quality test facility services.
- While the cost reduction has been suggested as an ingredient contained within the accreditation program, industry does not share this viewpoint. Although the accreditation program may l
l
Regulatory Activities Meeting March 3, 1982 reduce the number of NRC audits and hence NRC manpower requirements, it will do so only by increasing the manpower and financial burden placed on the industry.
- Inplementation of the proposed accreditation program is very likely to result in:
a.
A reduction in the number of testing facilities that support the nuclear industry; an even further reduction in the number of suppliers of safety-related equipment.
b.
Stagnation of existing testing technology by facilities certified with current technology practices.
c.
A significant increase in the cost of testing facility services and hence qualified equipment.
d.
Diversion of manpower to a program neither safety related nor cost effective.
Dr. Kerr comented that it is not clear to him why there should be a rule to deal with this issue. He said that he would like to hear more about the basis for this rule and what is expected to be achieved by this accredita-tion program.
Mr. Bender suggested that it would be helpful if the NRC Staff provided a list of typical equipment that would be dealt with under this program.
Mr. Rosztoczy sai.i that the Staff will provide the Subcomittee with such a list.
l Af ter further discussion, the Subcommittee indicated that it has no objection to issuance of the proposed rule for public coment.
It decided also to re-commend to the full Comittee that the ACRS assign additional review of this proposed rule to the Subcomittee on Qualification Program for Safety Related Equipment with the following instructions:
a.
'Ihis Subcommittee may propose to the ACRS comments to be submitted to the Staff during the public comment period of this rule.
b.
This Subcommittee will review the actions by the Staff subsequent to the public comment period and will recommend appropriate action by the ACRS.
e n
Regulatory Activities Meeting March 3, 1982 REGUIKIORY POSITION CHANGE TO REGUIKIDRY GUIDE 1.33, REVISION 3 (TASK NO.
RS 902-4), " QUALITY ASSURANCE PROGRAM REQUIREMENTS" (OPERATION)
Dr. Siess informed the Subcomittee that a revised version of Regulatory Guide 1.33, Revision 3, incorporating the Commission policy concerning the nuclear power plant personnel working hour provisions, had been sent to the ACRS for information. He said that this Guide was reviewed by the Regulatory Activities Subcommittee at the September 9,1981 meeting and the full Comittee concurred in the Regulatory Positions of this Guide during the September 10-12, 1981 AGS meeting. During the September 9, 1981 Subcommittee neeting, the NRC Staff informed the Subcommittee of possible future changes to the Regulatory position of this Guide that concerned overtime limitations for nuclear power plant personnel. Subsequent to that meeting, in accordance with the Commission's directions included in a memorandum dated November 4,1981, from S. J. Chilk to W. J. Dircks, the NRC Staff had revised Regulatory Guide 1.33 to endorse the working hour provisions of ANSI /ANS 3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Powr Plants," taking exceptions as necessary where conflicts exist with the Commission policy on working hours.
Dr. Siess said that the revised Regulatory Guide 1.33 had been sent to the Subcommittee for information only and there is no need for Subcommittee l
action.
l FUTURE MEETING l
Dr. Siess informed the Subcommittee that there will not be a Regulatory Activities Subcommittee meeting in April 1982; the next meeting may be in the beginning of May 1982.
Dr. Siess thanked all participants and adjourned the meeting at 7:00 p.m.
1 NOTE: Additional details can be obtained from the transcript located in the Public Document Room,1717 H Street, N.W., Washington, D.C. 20555 or from Alderson Reporcing, Inc., 400 Virginia Avenue, S.W. Washington, j
D.C.
(202) 554-2345.
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Regulatory Activities Meeting 3/3/82 LIST OF DOCUMENTS SUBMITTED TO THE SUBCOMMITTEE 1.
Regulatory Guide 1.28, Revision 3, (Task No. RS 002-5), " Quality Assurance Program Requirements (Design and Construction)" (Post Comment).
2.
Commission Paper on Proposed Amendment to 10 CFR Part 50, Section 50.49a
" Accreditation of Qualification Testing Organizations" (Pre Comment).
3.
Committee correspondence, dated March 3,1982 - Comments on Revision 3 to Regulatory Guide 1.28, dated January 7,1982 " Quality Assurance Program Requirements (Design and Construction") - J. Perry.
4.
Changes to Regulatory Guide 1.28 from "For Coment" Version.
5.
Proposed Accreditation of Qualification Testing organization - Industry viewpoint (Arnold Roby).
6.
Letter from Robert Larson and James Owens to Carl Waiske, dated February 3, 1982.
l 7.
Article from Engineering Journal, entitled "IEEE Position on Accreditation l
of Testing Laboratories for Safety System Equipment for Nuclear Power l
Generating Stations" by C. J. Wylie.
8.
Letter dated February 24, 1982, from Art Bivens, AIF, to Sam Duraiswamy transmitting an AIF paper "A Nuclear Industry Position on the NRC's pro-posed Test Facilities Accreditation Program" dated February 2,1982.
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ATTACHMENT A
a CmNrfS TO EG GIIIE 1.28 FROM "FOR CCFffNT" VERSION EGilATORY POSITION SIRECT DieNGE_
1 AS E B0llED @ PRESSlHE EnITORIAL VESSEL CONE 2
INS CTIfN AND TEST PERS0tNEL 2.]A IDEL III KRSntNEL CAPABILITIES NOCMNGE 2.1B EPirATION ann EW.RIENE.
AnnITIONALGilIIMNCETO QUALIFICATIONS (1) CLARIFY ALTERNATIVES TO TE EC0tENMTIONS OF TE STANMRn AND (2) PROVIE K1E SPECIFIC CONTROL FOR i
TE IlSE OF lEEL I ERSCfMEL.
2.2 (PEVIOUS 2.2A)
EIEIPINATION OF INITIAL AtinITIONALGUIIMNCETOLIMIT CAPABILITY TE N T N 1 QIMLIFIED BY ETES OTHER TI%N THOSE PROVIE IN TE STA % RD.
\\
~
A rrne m en r a t
1 i
OMNGES TO REG. GUIE 1.28 FROM "FOR C0tOIT" VERSION EGilATORY POSITION SIBJECT OMNE l
2.2B (ELETED)
AIAPA C0f61ERATIONS EGlLATORY GUIE 8.8 ADDRESSES THIS AEA.
3 EDUCATION AND EXPERIENE OF
' NO OMNE LEADAUDITORS 4
KSIGN Q N FDL 4A (PREVIOUS 4.2)
ESIGNINPUT EDITORIAL 4B (PEVIOUS 4.1A)
ESIGN WVIEW POSITION EVISED TO EEWNCE TE DESIGN IslJrLISTPf0VIEDIN TE STANDARD RATER llMN EPEATING llE LIST IN ITE GUIE.
4.1B (DELEIED)
ALTERNATIVES TO DESIGN EVIEW POSITION ELETED SINE llE USE OF ALTERNATE 4
CALO1ATIONS OR QUALI-4 FICATION TESTS AE ACEP-TABLE IN LIEU OF AlHESS-ING ESIGN EVIEW QlESTI(Ri B-s
CHANGES TO REG. GtlIE 1.28 FRm "FOR C(Melt" VERSION EGllATORY POSITION SIBJECT OMNGE __
4.1C (ElBED)
IfREENTATION OF ESIM POSITION IRE 1ED SINE WRIFICATION FINDINGS IT IS ADIE SSED BY BASIC EQUIENNT 16, CORECTlW ACTI0ft 0F lHE STANIMRD.
4C (PRVIOUS 4.1D)
IltEDIATE SIERVISOR ERF0 MING NO OMNE DESI G W RIFICATION 4D (PEVIOUS 4.1E)
TIELIESS OF ESIGN WRIFICATION NSITION EVISED TO ALLOW CDrRETION OF ESIGI WRIFICATIm BY TE TIE MEN EQUIPf9fT Wil.L E ELIED lPON TD ERmm A SEETY FmCTION 1
4E (PEVIOUS 4.1F)
CONTIDL OF GMNES TO DESIGN NO GANGE 6
e
OMNGES TO REG. GUIE 1.28 FROM "FOR C& TENT" VERSION EGl1ATORY POSITION SIBJELT OMNGE 5
D00fENT (DNTROL NO OMNGE 6 (DELETED)
QNTR)L OF PUROMSED ITEFS #iD SERVIES 6A (DELETED)
EVALlMTION OF SUPPLIER'S POSITION ElBED SINE KRF0ffWF HISTOR(
Elm 3.1 T N 7S-1 PADVICES CONTROL FOR EVAllRTION OF SlPPLIER'S HISTORf.
6B (ELETED)
EVAllMTION OF StPPLIER'S TEONICAL #8 OlMLITY CAPABILITY FOSITION ElEIED SINE SECTION 3.10F SlFPLENNT 7S-1 PIPilES GUIDANE ON llE EVAL!MTION OF SLPPUER'S TEGNICAL #lD OlMLITY CAPABILITY.
8 -4
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CHANGES TO REG GUIE 1.28 FROM "FOR CCMelT" VERSION l
EGilATORY POSITION SIBJECT WANE 6C GRETED)
EEIVING INSKCTION POSITION EETED SINE SECTION 8.2.3 0F SlFPLEENT 7S-1 Pl0 VIES CCNTROL OER TE USE OF EEIVING INSRCTIm.
6D (ELETED)
POST-INSTitlATION TESTING POSITION EETED SINE SECTIm 8.2.110F StPPlDOIT 7S-1 PRDVIES CMTIOL OER M IEE OF POST-INSTAL 1ATION TESTING.
6 (PEVI0lE 7)
QUALITY ASSURANE ECORDS l
7.1A GREED)
EERATION OF ECORDS POSITION ELETED SINE THIS l
PRNISION HAS EEN INCLUED IN NW1A - 1981 ADENDA.
6.1A (PEVIOUS 7.1B)
ETENTION OF ECORDS FOSITION EVISED TO QAiilFY G)
TE PRNISION FOR [TENTION OF RECDRDS R)R SHORT LIE ITEE AND (2) TE (INEN(DENT OF TE RETENTIm RRIOD.
"M%M7!.R5"S*1-B-S
e; CHANGES TO REG. GUIE 1.28 FRm "FOR CCMfNT" VERSION EGllATORY POSITION SIBJECT OMNE 6.1B (PEVIOUS 7.1C)
SAREEPING OF ECORDS POSITIm EVISED TO A110W ADDITION 4_ TIE RR ECDRD EPLAEENT.
6.1C (PEVIOUS 7.1D)
SA EEPING OF ECDES POSITIm EVISED TO AlifM PRIOR TO STORAGE FLEXIBILITY IN TE LENGTH '
OF TIE PRIOR TO STORAE.
6.1D (PEVIOUS 7.1E)
STORAE FACILITIES
. NO DIANGE 6.2A (PEVIOUS 7.2A)
LIETIE ECORDS POSITION EVISED TO CLARIFY THOSE RADIOGRAPHS THAT SH0llD E CONSIEED LIRTIE ECDRDS.
6.2B (PEVIOUS 7.2in AS-BUILT ECDRDS EDITORIAL 7 ( PEVIOUS 8)
AUDITS 7.1.1 (PEVI0tB 8.1.1)
AUDIT TE#1 LEADER EDITORIAL 7.1.2 (PEVIOLS 8.1.2)
RRR)HNE OF AUDITS EDITORIAL Bb
CPANGES TO REG. GUIE 1.28 FRm "FOR CCttelT" VERSION EGil.ATORY POSITION SIEJECT OMNE 7.1.3 (PEVIOUS 8.1.3)
AUDIT ECORDS NO 0@NGE 7.1.4A (PEVIOUS 8.1.4A)
AUDIT S001 LING (INTERNAD NO 0%NGE 7.'1.4B(P[VIOUS8.1.4B)
AUDIT SOEDLLING (E)GERNAD F05 TION EVISED TO CLARIFY Mel RXIIIE l
EXIEBNAL AUDITS AE NOT i IEV SEbO'E FOS CONSISTENT WITH POSITION 7.2.1 R)R KRR)RTNE OFSIPPLEPENTALAUDITS.
7.2.1 (PEVIOUS 8.2.1)
SlPPIBDITAL AUDITS NO OMNGE 7.2.2 (PEVIOUS 8.2.2)
POST-AUDIT CONEBENES POSITIGi EVISED TO ALLOW REXIBILITY R)R INST #iES WB1 POST - AUDIT CONRR-EN&S AE IIPPACTICABLE.
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