ML25030A246
| ML25030A246 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/2025 |
| From: | Yamir Diaz-Castillo NRC/NRR/DRO/IQVB |
| To: | |
| References | |
| Download: ML25030A246 (12) | |
Text
Role of Appendix B to 10 CFR Part 50 in the NRCs Licensing Process and Pathways for Meeting Appendix B to 10 CFR Part 50 Nuclear Oversight Conference - February 6, 2025 St. Petersburg, FL Yamir Diaz-Castillo Quality Assurance & Vendor Inspection Branch Office of Nuclear Reactor Regulation
Source of Quality 2
Quality starts at initial design.
Designers determine classification of components.
Appropriate quality measures are then applied based on the classification of structures, systems, and components.
Without a standard there is no logical basis for making a decision or taking action
-Dr. Joseph M. Juran
General Design Criteria (GDC)
Appendix A to 10 CFR Part 50 3
Criterion 1 of Appendix A, Quality Standards and Records, contains three fundamental quality assurance (QA) requirements, as follows:
a)
Structures, systems, and components important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed.
b) A quality assurance program shall be established and implemented in order to provide adequate assurance that these structures, systems, and components will satisfactorily perform their safety functions.
c)
Appropriate records of the design, fabrication, erection, and testing of structures, systems, and components important to safety shall be maintained by or under the control of the nuclear power unit licensee throughout the life of the unit.
Principle Design Criteria (PDC) - Design Criteria for Non-Light Water Reactors 4
GDC not applicable to non-light water reactors.
RG 1.232, Developing Principal Design Criteria for Non-Light Water Reactors, provides design criteria.
Table 1, Non-Light-Water Reactor Crosswalk, provides guidance between the GDC and the PDC.
NRCs Regulatory Position: GDC Criterion 1 should be used for PDC Criterion 1 for all designs.
Nothing has changed for QA!!
Guidance on Classification of Structures, Systems, & Components 5
10 CFR Part 50 or 52 applications for Light Water Reactors RG 1.26 Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power plants RG 1.201 Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to Their Safety Significance
Guidance on Classification of Structures, Systems, & Components 6
Licensing Modernization Project (LMP)
Nuclear Energy Institute (NEI) 18-04,Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development, Revision 1 RG 1.233 Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors
Classifications 7
Safety-Related: those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:
1.
The integrity of the reactor coolant pressure boundary 2.
The capability to shut down the reactor and maintain it in a safe shutdown condition; or 3.
The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in § 50.34(a)(1) or § 100.11 of this chapter, as applicable.
Classifications 8
RISC 1: Safety-related SSCs that perform safety significant functions RISC 2: Non-safety-related SSCs that perform safety significant functions RISC 3: Safety-related SSCs that perform low safety significant functions RISC 4: Non-safety-related SSCs that perform low safety significant functions 10 CFR 50.69 Non-Safety-Related with Special Treatment SSCs: Non-safety-related SSCs that perform risk-significant functions or perform functions that are necessary for defense-in-depth adequacy
Graded Approach to Nuclear QA (Appendix B to 10 CFR Part 50) 9 Criterion II, Quality Assurance Program, states in part:
[]This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions.
The applicant shall identify the structures, systems, and components to be covered by the quality assurance program and the major organizations participating in the program, together with the designated functions of these organizations.
The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems, and components, to an extent consistent with their importance to safety.[]
Guidance for Implementing QA Programs 10 Guidance for Implementing Quality Assurance Programs NUREG 0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition Chapter 17.5 Quality Assurance Program Description
- Design Certification, Early Site Permit and New License Applicants RG 1.28, Quality Assurance Program Criteria (Design and Construction)
RG 1.33, Quality Assurance Program Requirements (Operation)
State and Jurisdiction Requirements 11 Reminder:
States and Jurisdictions have their own requirement for ASME code components with regards to quality.
Applicants should be aware of those requirements for the location of the reactor site.
In some cases, the State and Jurisdiction requirements maybe more limiting than the federal.