ML20135H214
| ML20135H214 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/13/2020 |
| From: | Richter M Nuclear Energy Institute |
| To: | Leslie Fields Licensing Processes Branch |
| Fields L | |
| References | |
| Download: ML20135H214 (4) | |
Text
MARK A. RICHTER, PH.D.
Senior Project Manager, Used Fuel and Decommissioning Programs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8106 mar@nei.org nei.org May 13, 2020 Ms. Leslie Fields Senior Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC 20555-0001
Subject:
Submittal of Response to Request for Additional Information (RAI) for 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" Project Number: 689
Dear Ms. Fields:
On May 1, 2020,1 the U.S. Nuclear Regulatory Commission (NRC) requested additional information to continue portions of its review of NEI 14-05A, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1.2 This revised guidance provides an approach to utilize accreditation by signatories to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) as part of a purchasers commercial grade dedication of laboratory services.
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)3 submits this response to the NRCs request for additional information (RAI) and a mark-up of NEI 14-05A Revision 1 that reflect updates in response to the RAI. We believe that this response will allow the NRC to complete its review and endorse the revised guidance as an acceptable method for continuing the use of accreditation by ILAC MRA 1 Email from Leslie Fields (NRC) to Mark Richter (NEI), Request for Additional Information for NEI 14-05A Revision 1, May 1, 2020, ADAMS ML20121A319.
2 M. A. Richter (NEI) letter to K. A. Kavanagh (NRC), Submittal of 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, February 20, 2020 (ADAMS ML20054C066.
3 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Ms. Leslie Fields May 13, 2020 Page 2 signatories in lieu of commercial grade surveys. Three additional clarifications were made to the document that are considered to be inconsequential to receiving the NRC's endorsement. All changes are described in the attached response.
We appreciate the NRCs consideration of the guidance and look forward to a timely endorsement. If you have any questions or require additional information, please contact me.
Sincerely, Mark A. Richter Attachments (2) c:
Ms. Kerri Kavanagh, Chief, NRC/NRR/MVIB Mr. Yamir Diaz-Castillo, NRC /NRR/MVIB Mr. Dong Park, NRC/NRR/MVIB Mr. Dennis Morey, NRC15525/
Mr. Earl Mayhorn, NUPIC/Ameren NRC Document Control Desk May 13, 2020 Page 1 NEIs response to the question contained in the May 1, 2020 email titled: "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, follows below. The changes indicated in the response are included in the update to Revision 1 of NEI 14-05A attached.
NRC RAI NEI 14-05A 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 nondestructive 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.
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.
NEI Response The NEI ILAC Task Force has reviewed the NRC's Request for Additional Information (RAI) and agrees that Appendix A should be updated to clarify that the ILAC accreditation process described in NEI 14-05A may not be used for the commercial grade dedication of NDE services. As noted in the RAI, Section 3.4 of NEI 14-05A, Rev. 1 clearly indicates this point. Therefore, for consistency and clarity, Appendix A has been updated by adding the following statement: "As discussed in Section 3.4 of this document, NEI 14-05A cannot be used to dedicate NDE services (including ASME Code and non-Code safety related applications) in lieu of a commercial grade survey."
In addition, Appendix A has been updated to clearly indicate that a commercial grade dedication technical evaluation is required to document the critical characteristics and acceptance methods when dedicating calibration and testing services based on the ILAC Process. Attachment 1 and Attachment 2 of May 13, 2020 Page 2 NEI 14-05A include acceptable examples of a technical evaluation for calibration services and testing services, respectively.
Two other inconsequential updates were made:
1.
NEI 14-05A, Section 2.2, "DESCRIPTION OF THE REGIONAL ORGANIZATIONS" was updated to indicate there are now five (5) regional cooperation bodies within ILAC instead of three (3). The current regional bodies include: Asian Pacific Accreditation Cooperation (APAC), African Accreditation Cooperation (AFRAC), Arab Accreditation Cooperation (ARAC), European Accreditation (EA), and Inter-American Accreditation Cooperation (IAAC). The addition of two regional cooperation bodies has no impact on the ILAC process utilized to dedicate calibration and testing services based on accreditation to ISO/IEC 17025:2017.
2.
Appendix A was updated to reference Regulatory Guide 1.1641 and the latest NRC-endorsed commercial grade dedication guidance (EPRI TR-30020029822). EPRI TR-3002002982 is referenced in other sections of this document.
1 U.S. Nuclear Regulatory Commission Regulatory Guide 1.164, Dedication of Commercial-Grade Items for Use in Nuclear Power Plants, Revision 0, July 2017 (ADAMS ML17041A206).
2 Electric Power Research Institute (EPRI) Technical Report 3002002982, Plant Engineering: Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications, Revision 1, September 2014 (ADAMS ML181999A161)