ML20059J831
| ML20059J831 | |
| Person / Time | |
|---|---|
| Issue date: | 01/25/1994 |
| From: | Zech G Office of Nuclear Reactor Regulation |
| To: | Rossi C Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9402010206 | |
| Download: ML20059J831 (4) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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%.~.sJ January 25, 1994 MEMORANDUM FOR: Charles E. Rossi, Director t
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 MEETING ON GRADED QUALITY ASSURANCE ON JANUARY 6, 1994 e
On January 6, 1994, a meeting was held between the NRC staff and representatives of the Nuclear Utilities Management and Resources Council (NUMARC) to discuss the graded application of 10 CFR Part 50, Appendix B.
This was a follow-up meeting to one held on December 16, 1993, on the same i
subject.
l The staff restated the view it expressed at the December meeting that-flexibility exists in the current regulations to accommodate a graded approach towards Quality Assurance, but that the NRC's guidance to industry and to NRC inspectors would need to be reviewed to address any inconsistencies.
NUMARC agreed that the problem is primarily in terms of implementation rather than with the regulations themselves.
The staff also restated the goal of pilot-testing a graded QA program at a few utilities starting this Fall. The staff recommended that the approach discussed at the December meeting be considered for the pilot program.
That approach would use a process similar to that developed by NUMARC to identify a
the risk significance of structures, systems and components (SSCs) within the scope of the maintenance rule, as described in NUMARC 93-01. As envisioned, safety related SSCs that are determined to have a lesser impact on safety from a risk significance standpoint would be subject to the Appendix B criteria and related requirements in a graded or proportionate manner.
NUMARC indicated that they had considered this approach in more detail since the December meeting and have concluded that a graded QA equipment selection o
process utilizing the risk methodology described in NUMARC 93-01 is feasible, i
NEE However, the approach they envision would differ in that those SSCs identified gn.
as being risk significant would continue to be subject to a full Appendix B i
ou program, wnereas those identified as not being risk significant, although currently classified as safety related, would be addressed by a suitable commercial quality assurance program, in lieu of any Appendix B program.
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goed The staff cautioned NUMARC on such an approach and indicated that it would be more difficult to implement under current regulations.
NUMARC acknowledged O
the difference between the two approaches, but a final resolution was not SE reached. The participants agreed to discuss this issue further at the next 7 0-meeting.
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4 Charles E. Rossi January 25, 1994
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NUMARC indicated that its guidance for utilizing a process similar to that described in NUMARC 93-01 would be available for NRC staff review by April 1994. In the meantime, the staff and NUMARC agreed to proceed in parallel with the next step which is to identify the manner in which Appendix B requirements would be applied to SSCs with consideration given to their risk significance.
Although developed separately, the intent would be to meet frequently enough so that the staff is able to endorse an industry approach that would be pilot-tested at a few facilities.
Regarding the longer-term schedule, the staff would issue a draft regulatory guide for public comment, following completion of the pilot program in early 1995. A final regulatory guide would then be issued in early 1996, prior to the effective date of the maintenance rule (July 1996), to allow licensees the option of implementing the two programs together, since the two efforts would be closely related.
F The staff and NUMARC agreed on the objective of developing guidance for pilot-testing a graded QA program and also agreed on the tentative schedule.
However, NUMARC indicated that its Appendix B and Regulatory Threshold Working Groups would be meeting in late January to discuss this initiative and that they would be in a better position following those meetings to discuss the final schedule.
The participants agreed to meet again on February 3, 1994, to continue their discussions on this subject.
A list of attendees and a cepy of the staff's tentative schedule are enclosed.
A copy of a January 6,1994, letter on this subject from Mr. James Sniezek, NRC to Mr. Joe Colvin, NUMARC which was provided to NUMARC at the meeting is also enclosed.
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Ebs Gary G. Zech
,2EQ/ y performance and Quality Evaluation Branch Division of Reactor Inspection and licensee Performance, NRR CC:
DISTRIBUTION:
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Enclosures:
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List of Attendees ssurgess, Rcu-!!!
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Graded QA Implementation Schedule LConstable, RGN-IV 3.
Letter to Mr. Joe Colvin acau en, 12 Gia OFC SEND RPEB:DRIL RPEB:DR!L SC:RPEB:DRIL
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Page 1 of 1-MEETING ATTENDANCE LIST January 6, 1994 Meeting with NUMARC to discuss issues related to the graded implementation of 10 CFR 50 Appendix B NAME ORGANIZATION Bob Gramm NRR/DRIL/RPEB Juan Peralta NRR/DRIL/RPEB Gil Millman RES/DE/EMEB Adrian lleymer NUMARC Alex Marion NUMARC Tony Pietrangelo NUMARC Richard Correia NRR/DRIL/RPEB John W. Craig RES/DE Gary G. Zech NRR/DRIL/RPEB Ernie Rossi NRR/DRIL Eric Leeds NRR/ADP Bill Dean OEDO David Teague Winston & Strawn i
Owen Gormley
_ NRR/RRG Claudia Craig RES/DE/EMEB Joel Page RES/DSIR/RPEB R. M. Latta NRR/DRIL/RPEB R. P. Zimmerman ED0/ Regulatory Review Group-Implementation Task Force Ann Ramey-Smith NRR/DSSA/SPSB Mark Rubin NRR/DSSA/SPSB i
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- Enclosure 2 i
GRADED QA IMPLEMENTATION SCHEDULE 12/93 -
Initial NUMARC Meeting on Graded QA 1/94 -
First working level meeting
- 2/94 --
Visit to Grand Gulf 6/94 -
Draft methodology for Graded QA implementation 9/94 --
Implementation of pilot Graded QA program 1/95 -
Evaluate pilot program 4/95 -
Issue draft Reg Guide 6/95 -
Evaluate public comments 1/96 -
Issue final Reg Guide
- Scheduled meetings to follow on approximately 3-week interval
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January 6,1994 Mr. Joe Colvin President and Chief Executive Officer Nuclear Management and Resources Council 1776 I Street, N.W.
Suite 300 Washington, DC 20006
Dear Mr. Colvin:
On December 16, 1993, the NRC staff met with h M RC and industry representatives to discuss the graded appliutir of 10 CFR Appendix B, Quality Assurance. As discussed at the meetuc, the NRC considers this issue to be extremely important, and, in fact, the Regulatory Review Group identified the development of guidance to address the use of graded quality assurance as one of its most important recommendations.
The benefits to be gained from a graded quality assurance program could be significant.
First and foremost, in terms of enhanced public health and safety by focusing both the NRC's reviews and inspections and the industry's resources on the more safety-significant structures, systems and components (SSCs); and, secondly, in terms of cost savings to the industry by avoiding the dilution of resources on less safety-significant issues.
The NRC's regulations (10 CFR Part 50, Appendices A & B) require quality assurance programs that are comensurate (or consistent) with the importance to safety of the functions to be performed. However, the practice that has evolved has not been graded and, generally, has either been a full Appendix B program or none at all.
In the development of guidance for the implementation of the maintenance rule, a methodology to determine the risk significance of SSCs within the scope of the rule was proposed by industry in NUMARC 93-01 and endorsed by the NRC in Regulatory Guide 1.160. During the December 16th meeting, it was suggested that the staff and industry could build on the experience gained with the maintenance rule to develop a policy and criteria for a graded quality assurance program. Once developed, they would then be tested in a pilot program, sial ar to the V&V effort by industry with NUMARC 93-01. Considering the benefits that could be realized from a garallel and coordinated effort with the mafntenance rule implementation, t1e timing for developing guidance for a graded quality assurance program is important.
In view of the above, the NRC has established a steering group of senior managers to provide guidance to the staff and for the timely resolution of any policy issues. The steering group membership includes rqyself, Jack Heltemes (RES) and Bill Russell (NRR). The NRC's working level lead on this issue is
, Gary Zech, Chief of the Performance and Quality Evaluation Branch. Mr. Zech will also be the NRC's day-to-day point of contact for NUMARC and industry on this subject. A schedule has been established that identifies the summer of 1994 for the development of guidance for a graded quality assurance program Ol[()!UUTDO r
'4 Mr. Joe Colvin January 6,1994 that can be pilot-tested at a few utilities, starting in about September 1994.
This near-term goal, although ambitious, is important in terms of benefitting from the experience that will be gained by utilities in determining the risk significance of SSCs within the scope of the maintenance rulc.
Once the pilot program is complete, the longer-term schedule includes the issuance of-draft guidance for public comment in the spring of 1995 and a final regulatory guide in the spring of 1996, prior to the effective date of the maintenance rule in July 1996.
If you are in agreement with the views and priorities expressed above and with the approach described for the development of guidance for a graded quality assurance program, I request that you identify a senior level contact to interface with our steering group.
I look forward to your prompt response on this important issue.
[ lined by Jamce H. Sn!.nc James H. Sniezek Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research l
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