ML20147E393

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Value/Impact Assessment of Rev 1 to Reg Guide 1.28, QA Program Requirements (Design & Const). Impact on NRC & Applicants Minimal
ML20147E393
Person / Time
Issue date: 09/05/1978
From:
NRC OFFICE OF STANDARDS DEVELOPMENT
To:
Shared Package
ML20147E238 List:
References
REGGD-01.028, REGGD-1.028, NUDOCS 7810160218
Download: ML20147E393 (2)


Text

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' Value/ Impact Assessment for Regulatory Guide 1.28, Revisfon 1, -

, " Quality Assurance Program Requirements (Design and Construction)"

The value/ impact assessment presented with the Task Initiation '

Form dated May 19,1977 (copy attached), Section C, Value/ Impact of the proposed Action, is valid for the guide at this stage of development. Staff review of'the proposed guide resuTted in only editorial revision. One additional topic was discussed in the working paper of the proposed guide which was fonsarded for staff review that was not considered fri ther preliminary value/ impact assessment. The value/ impact of this addition is discussed below.

Value/ Impact o'f Regulatory Position C.T. -

, Regulatory Position C.1 provides guidance on implementing Section~

.22ofAdSIM45.2-1977 which recuires that, applicable sections ,

and elements of the standard shall be established at the earliest practical time consistent with the schedule for accompitshing the

, activities. The guidance clarifies the applicability of the standard to those safety related activitia: which are initiated by the applicant prior to submitting its appifcation for a construction permit (CF).

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The value of this position to the NRC staff is the assurance that the' activities initiated prior to appifcation for a C7 are controlled by a quality assurance program acceptable to the staff. This a11cws-more s'ystematic r'eview of the information submitted with the CP application. The value to the appiteant will be that the activities he has undertaken prior to CP application will be properly controlled and documented and, therefore, more likely to be acceptable to the NRC staff. This could prevent' delays in review of the appitcation.

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The inspact on both NRC staff and applicants is expected to be negligible.

The guidance:previded was included in WASH 1283,

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Revision 1, May 29,1974 (Grey Sock) and has been used by the staff and applicants since that time.

It represents no change in NRC staff practice and is included in the guide to provide more complete guidance in the guide without relying on other supporting s a m ts.

Additionally, should the staff withdraw WASH 1283 when the guidance provided by the draft standards included in it is updated, the guidance on activities prdor to CP application would no longer be avafiable to ap'pifcants, unless it is included in a regulatory guide.

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