ML23037A987
| ML23037A987 | |
| Person / Time | |
|---|---|
| Site: | 99901365 |
| Issue date: | 02/22/2023 |
| From: | Licensing Processes Branch |
| To: | |
| Shared Package | |
| ML23037A980 | List: |
| References | |
| BQ-TOP-1, BQ-TOP-1, Rev 4, BQ-TOP-1, Rev 004, BQ-TOP-1, Revision 4, BQ-TOP-1, Revision 004, EPID L-2022-TOP-0037 | |
| Download: ML23037A987 (1) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION FINAL SAFETY EVALUATION FOR BECHTEL POWER CORPORATION QUALITY ASSURANCE PROGRAM FOR NUCLEAR POWER PLANTS TOPICAL REPORT, BQ-TOP-1, 2007 EDITION, REVISION 004 (DOCKET NO. 99901365)
1.0 INTRODUCTION
By letter dated June 6, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22158A012), Bechtel Power Corporation (Bechtel) submitted for the U.S. Nuclear Regulatory Commission (NRC) staffs review Bechtel Power Corporation Quality Assurance [(QA)] Program for Nuclear Power Plants Topical Report, BQ-TOP-1, 2007 Edition, Revision 004.
Revision 004 of the Bechtel QA program addresses organization re-structure, changes in job title and line of reporting, and adoption of Nuclear Energy Institute (NEI)14-05A, Revision 1, Guidance for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services (ADAMS Accession No. ML20255A367).
2.0 REGULATORY BASIS The NRCs regulatory requirements related to QA programs for non-licensees are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.4(b)(7)(ii). This regulation requires that a change to an NRC-accepted QA program description from non-licensees (i.e., architect/engineers, nuclear steam system suppliers, fuel suppliers, constructors, etc.)
must be submitted to the NRC.
Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, establishes QA requirements for the design, fabrication, construction, and testing of structures, systems, and components (SSCs) of the facility. The pertinent requirements of Appendix B to 10 CFR Part 50 apply to all activities affecting the safety-related functions of those SSCs and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying.
In evaluating the adequacy of the Bechtel QA program, the NRC staff used the guidance contained in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, (SRP) Section 17.5, Revision 0, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants (ADAMS Accession No. ML063190019), dated March 2007, hereafter referred to as SRP Section 17.5, which provides acceptance criteria for QA program descriptions based on the American Society of Mechanical Engineers Standard NQA-1, Quality Assurance Program for Nuclear Facilities, 1994 Edition.
3.0 TECHNICAL EVALUATION
The Bechtel QA program revision was submitted by letter dated June 6, 2022, in accordance with the provisions of 10 CFR 50.4(b)(7)(ii). The letter included a summary of changes, and the Bechtel QA program, BQ-TOP-1, 2007 Edition, Revision 004.
The revised Bechtel QA program includes changes in its organization, job titles, and lines of reporting. The NRC staff reviewed the changes using the guidance of SRP Section 17.5 and determined that Revision 004 of the Bechtel QA program continues to meet the requirements of Appendix B to 10 CFR Part 50. Specifically, the NRC staffs review confirmed that the revised Bechtel QA program continues to ensure that persons and organizations performing QA functions have the required authority and organizational freedom and remain sufficiently independent from cost and schedule when opposed to safety considerations.
Bechtels QA program, BQ-TOP-1, 2007 Edition, Revision 004, also included changes to adopt NEI 14-05A, Revision 1. This change updated the International Standard Organization /
International Electrotechnical Commission standard 17025 from the 2005 edition to the 2017 edition. The updated standard calls for using laboratory accreditation by Accreditation Bodies (ABs) that are signatories to the International Laboratory Accreditation Cooperation Mutual Recognition Arrangement in lieu of performing commercial-grade surveys for procurement of calibration and testing services. The revised Bechtel QA program includes the additional requirements that the laboratories have achieved accreditation based on an on-site accreditation assessment by the selected AB within the past 48 months, and a prohibition on subcontracting these accredited services. The NRC staff finds that the changes are adequate because the changes are consistent with the NRC safety evaluation for the approval of NEI Technical Report 14-05A, Revision 1 (ADAMS Accession No. ML20322A019).
4.0 CONCLUSION
The NRC staff used the acceptance criteria of SRP Section 17.5 as the basis for evaluating the acceptability of the Bechtel QA program, BQ-TOP-1, 2007 Edition, Revision 004. The NRC staff concludes that the Bechtels QA program follows the NRC guidance contained in SRP Section 17.5 and complies with the requirements in Appendix B to 10 CFR Part 50, and is therefore, acceptable.
5.0 REFERENCES
- 1. Bechtel letter to the U.S. NRC, Submittal of Bechtel Power Corporation Quality Assurance Program for Nuclear Power Plants Topical Report, BQ-TOP-1, 2007 Edition, Revision 004, dated June 6, 2022 (ADAMS Accession No. ML22158A012).
- 2. U.S. NRC letter to Bechtel, Safety Evaluation for Bechtel Quality Assurance Program for Nuclear Power Plants Topical Report, BQ-TOP-1, 2007 Edition, Revision 003, dated February 7, 2019 (ADAMS Accession No. ML19029A105).
- 3. Bechtel letter to the U.S. NRC, Submittal of Bechtel Quality Assurance Program for Nuclear Power Plants Topical Report, BQ-TOP-1, 2007 Edition, Revision 003, dated July 31, 2018 (ADAMS Accession No. ML18212A363).
- 4. U.S. Safety Evaluation, Final Safety Evaluation by the Office of Nuclear Reactor Regulation for the Nuclear Institute Technical Report 14-05A, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1, dated November 23, 2020 (ADAMS Accession No. ML20322A019).
- 5. NEI 14-05A, Revision 1, Guidance for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, dated September 2020 (ADAMS Accession No. ML20255A367).
- 6. NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 17.5 Revision 0, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, dated March 2007 (ADAMS Accession No. ML063190019).