ML20121A319
| ML20121A319 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/2020 |
| From: | Leslie Fields Licensing Processes Branch |
| To: | Richter M Nuclear Energy Institute |
| Fields L | |
| References | |
| Download: ML20121A319 (2) | |
Text
1 Fields, Leslie To:
mar@nei.org Cc:
Kavanagh, Kerri; Park, Dong; Morey, Dennis; Diaz-Castillo, Yamir
Subject:
Request for Additional Information for NEI 14-05A Revision 1
Dear Mr. Richter of the Nuclear Energy Institute:
I have placed an electronic version of this Request for Additional Information (RAI) for NEI 14-05 A, Revision 1, Guidelines for the use of Accreditation In Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, in the BOX.com folder and have given you access to it. This email serves as the formal transmittal of this RAI.
The RAI has been placed in ADAMS as nonpublic so it can be declared an Official Agency Record. When responding to the RAI, please confirm if there is any proprietary information in the RAI and the response. Your formal response, provided via letter under authorized signature, will generate the public version of the RAI as well as the response.
In order to support the staffs review schedule, please provide your response no later than May 15, 2020.
If you have any questions or would like to discuss the RAI with staff to ensure you understand them, please let me know.
This email will be uploaded in ADAMS and declared public in a couple days.
Leslie Fields, Senior Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 301-415-1186 leslie.fields@nrc.gov Transmittal of NRCs Request for Additional Information Associated with NEI 14-05A, Revision 1, Guidelines for the use of Accreditation In Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services RAI Section 3.4, Limitations of Use, states, in part, that the International Laboratory Accreditation Cooperation (ILAC) accreditation process cannot be used for the commercial-grade dedication of non-destructive examination (NDE) services based on the laboratory's ISO/IEC 17025:2017 accreditation due to there being specific personnel qualification and certification requirements for personnel performing NDE activities for the nuclear industry that may not be addressed during the accreditation process.
In addition, Section 4, Purchasers Quality Assurance Program, states, in part, that A template for describing the use of the ILAC process in lieu of a commercial grade survey in a purchasers QA Program is provided in Appendix A. Although a purchaser is not required to use the template in Appendix A, all of the actions and steps described in Appendix A need to be included in the purchasers QA Program.
The NRC staff noted that the prohibition of using the ILAC accreditation process for the commercial-grade dedication of NDE services is not part of the template in Appendix A, Quality Assurance Program Template. Although not mandatory, a licensee or a vendor may elect to implement the template without incorporating this requirement.
2 In order to avoid any confusion, the template in Appendix A should be updated to clearly state that the ILAC accreditation process may not be used for the commercial-grade dedication of NDE services. NEI should submit updated information to address NRCs comments per this request.