Regulatory Guide 1.33

Quality Assurance Program Requirements (Operation)

ML003739995
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Issue date:	02/28/1978
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RG-1.33, Rev 2
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Revlklon 2 U.S. NUCLEAR REGULATORY COMMISSION February 1978 REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 1.33 QUALITY ASSURANCE PROGRAM REQUIREMENTS

(OPERATION)

A. INTRODUCTION

ANS-3.2, "Administrative Controls and Quality As surance for the Operational Phase of Nuclear Power Appendix B, "Quality Assurance Criteria for Nu Plants," by the American National Standards Insti clear Power Plants and Fuel Reprocessing Plants," to tute on February 19, 1976.

10 CFR Part 50, "Licensing of Production and Utili zation Facilities," establishes quality assurance re There had been some uncertainty with regard to the quirements for the operation of nuclear power plant NRC staff's position when a regulatory guide en safety-related structures, systems, and components. dorses, as an acceptable method, the "guidelines" as This regulatory guide describes a method acceptable well as the "requirements" included in a standard.

to the NRC staff for complying with the Commis The NRC staff has evaluated the guidelines contained sion's regulations with regard to overall quality as in N18.7-1976/ANS-3.2 with respect to importance surance program requirements for the operation phase to safety. Revision I of this regulatory guide clarified of nuclear power plants. The Advisory Committee on the NRC staff's position on the "requirements" and Reactor Safeguards has been consulted concerning "guidelines" included in ANSI N18.7-1976/ANS

this guide and has concurred in the regulatory 3.2. Where conformance to the recommendations of position. this regulatory guide is indicated in an application without further qualification, this indicates the appli

B. DISCUSSION

cant will comply with the "requirements" of ANSI

N18.7-1976/ANS-3.2, as supplemented or modified Subcommittee ANS-3,' Reactor Operations, of the by the regulatory position of this guide.

American Nuclear Society Standards Committee de veloped ANSI N18.7-1972, which contained criteria for Section 1, "Scope," of ANSI NI8.7-1976/ANS

administrative controls for nuclear power plants dur 3.2 states that this standard contains criteria for ad ing operation. This standard, along with ANSI ministrative controls and quality assurance for nu N45.2-1971, "Quality Assurance Program Require clear power plants during the operational phase of ments for Nuclear Power Plants," was endorsed by plant life and that this phase is generally considered Regulatory Guide 1.33. The dual endorsement was to commence with initial fuel loading, except for cer necessary in order for the guidance contained in the tain preoperational activities. In this regard, a sepa regulatory guide to be consistent with the require rate regulatory guide addressing the quality assurance ments of Appendix B to 10 CFR Part 50; however, program for the preoperational phase will be issued.

this dual endorsement caused some confusion among Other regulatory guides may be issued or this regula users. To clarify this situation, ANSI N18.7-1972 tory guide may be revised, if necessary, to amplify was revised so that a single standard would define the the general requirements contained in this standard.

general quality assurance program "requirements"

for the operation phase. This revised standard was Appendix A to this guide has been further revised approved by the American National Standards Com as a result of additional' comments received on the mittee NI8, Nuclear Design Criteria. It was sub guide and additional staff review.

sequently approved and designated N18.7-1976/

,Copies may be obtained from American Nuclear Society, 555

-*Lines indicate substantive changes from previous issue. North Kensington Avenue, La Grange Park, Illinois 60525.

USNRC REGULATORY GUIDES Comments shoukl be sent to the Secretary of the Commission. US. Nuclear Regu latory Commission, Washington, D.C. 20555, Attention: Docketing and Service Regulatory Guides ore issued to describe and make available to the Public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate techniques used by the staff in evaluating specific problems The guides are issued in the following ten broad divisions or postulated accidents, or to Provide guidance to applicants. Regulatory Guides awt not substitutes for regulations, and compliance with them is not required. 1. Power Reaclors 6. TProducts Methods and solutions different from those set out in the guides will be accept. 2. Research and Test Reactors 7. Trancsortation aWle if they provide a basis for the findings requisite to the issuance or continuance 3. Fuels and Materials Facilities a. Occupational Health o fa p ecr mitor license aby th eCo mni, son. 4. Environm etntl and Siting

9. Antitrust Review

5. Materials and Plant Protection t0. General Comments end suggestions for improvements in these guides we encouraged at all Requests for single copies of issued guides iwhich may be reiroduced) or for place tires, and guides will be revised, as appropriate, to accomnmodate comments and ment on an automatic distribution list for single copies of future guides in specific

"toreflect new information or experience. This guide was revised as a result of divisions should be made in writing to the US. Nuclear Regulatory Commission.

eubltantive comments received from the Public and additional staff review. Washington, D.C. 20555. Attention Director. Division of Document Coistrol.

C. REGULATORY POSITION

and will be endorsed by a regulatory guide The overall quality assurance program require upon its approval as an ANSI standard.

ments for the operation phase that are included in ANSI N18.7-1976/ANS-3.2 are acceptable to the 3. Section 4.3.4, "Subjects Requiring Independ NRC staff and provide an adequate basis for comply ent Review," Item (3) states, in part, that changes to ing with the quality assurance program requirements the technical specifications or license amendments re of Appendix B to 10 CFR Part 50, subject to the fol lated to nuclear safety are required to be reviewed by lowing: the independent review body prior to implementation.

It should be noted that proposed changes to technical I. ANSI N18.7-1976/ANS-3.2 requires the prep specifications or license amendments should be re aration of many procedures to carry out an effective viewed by the independent review body prior to their quality assurance program. Appendix A, "Typical submittal to the Commission for approval.

Procedures for Pressurized Water Reactors and Boil ing Water Reactors," to this regulatory guide should 4. Section 4.5, "Audit Program," of ANSI

be used as guidance to ensure minimum procedural N18.7-1976/ANS_3.2 states that audits of selected coverage for plant operating activities, including re aspects of operational phase activities shall be per lated maintenance activities. Appendix A lists typical formed with a frequency commensurate with their safety-related activities that should be covered by safety significance and in such a manner as to ensure written procedures but does not provide a complete that an audit of all safety-related functions is com listing of needed procedures. Many other activities pleted within a period of 2 years. In amplification of carried out during the operation phase of a nuclear this requirement, the following program elements power plant require written procedures not included should be audited at the indicated frequencies:

in Appendix A. Appendix A may also contain proce dures that are not applicable to an applicant because a. The results of actions taken to correct de of the configuration of the nuclear power plant. The ficiencies that affect nuclear safety and occur in facil procedures listed in Appendix A may be combined, ity equipment, structures, systems, or method of separated, or deleted to conform to the applicant's operation-at least once per 6 months.

procedures plan. b. The conformance of facility operation to pro

2. Throughout ANSI NI8.7-1976/ANS-3.2, other visions contained within the technical specifications documents required to be included as a part of this and applicable license conditions-at least once per standard are identified at the point of reference. The 12 months.

specific acceptability of these standards listed in ANSI N18.7-1976/ANS-3.2 has been addressed in c. The performance, training, and qualifications the latest revision of the following regulatory guides: of the facility staff-at least once per 12 months.

5. The ANSI Standard Regulatory Guide "should") guidelines (indicated by the verb of ANSI N18.7-1976/ANS-3.2 contained N45.2 1.28 in the following sections have sufficient safety impor N45.2.1 1.37 tance to be treated the same as the requirements (in N45.2.2 1.38 dicated by the verb "shall") of the standard:

N45.2.3 1.39 N45.2.4 a. Section 4.4-The guidelines concerning re

1.30

N45.2.5 view activities of the onsite operating organization,

1.94 except the guideline that refers to screening subjects N45.2.6 1.58 N45.2.8 of potential concern.

1.116 N45.2.9 1.88 b. Section 5.2.3-The guideline concerning re N45.2. 10 1.74 view and updating of standing orders.

N45.2. I I 1.64 N45.2.13 1.123 c. Section 5.2.4-The guideline concerning re N18. 1 view, updating, and cancellation of special orders.

1.8 N 18.17 1.17 d. Section 5.2.7. 1-The guidelines that address N 101.4 1.54 adequate design and testing of replacement parts.

Note: N45.2.12 is discussed in NRC e. Section 5.2.13.4-The guideline concerning documents WASH-1283, "Guidance on special handling tools and equipment.

Quality Assurance Requirements During Design and Procurement Phase of Nuclear f. Section 5.2.19(2)-The guideline for check Power Plants," (Grey Book) and WASH ing plant operating procedures during the testing pro

1309, "Guidance on Quality Assurance Re gram.

quirements During the Construction Phase of Nuclear Power Plants," (Green Book) g. Section 5.2.19. 1-The guidelines for preop erational tests, except the guideline that refers to a

1.33-2

tification in Section 5.3.9.1(2); automatic actions in run-in period for equipment. In addition to these Section 5.3.9.1(3); immediate operator action, guidelines, the prerequisite steps for each equipment excluding those guidelines contained in the examples,

- test should be completed prior to the commencement in Section 5.3.9.1(4); and subsequent operator ac of the preoperational test. tions in Section 5.3.9.1(5).

h. Section 5.3.2-The guidelines that describe the content (excluding format) of procedures, except

D. IMPLEMENTATION

for the guidelines that address (1) a separate state ment of applicability in Section 5.3.2(2), (2) inclu The purpose of this section is to provide informa sion of references in procedures, as applicable, in tion to applicants and licensees regarding the NRC

Section 5.3.2(3), and (3) inclusion of quantitative staff's plans for using this regulatory guide.

control guides in Section 5.3.2(6). This guide reflects current NRC practice. There fore, except in those cases in which the applicant i.. Section 5.3.9-The guideline concerning proposes an acceptable alternative method for com emergency procedures requiring prompt implementa plying with the specified portions of the Commis tion of immediate operator actions when required to sion's regulations, the method described herein is prevent or mitigate the consequences of a serious being and will continue to be used in the evaluation condition. of submittals for operating license applications until j. Section 5.3.9.1-The guidelines that describe this guide is revised as a result of suggestions from the content (excluding format) for.' the title in Section the public or additional staff review.

5.3.9.1 (1); the inclusion of symptoms to aid in iden-

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APPENDIX A

TYPICAL PROCEDURES FOR PRESSURIZED WATER REACTORS

AND BOILING WATER REACTORS

The following are typical safety-related activities b. Control Rod Drive System (including part that should be covered by written procedures. This length rods)

appendix is not intended as an inclusive listing of all c. Shutdown Cooling System needed procedures since many other activities carried d. Emergency Core Cooling System out during the operation phase of nuclear.power e. Component Cooling Water System plants should be covered by procedures not included f. Containment in this list.

(1) Maintaining Containment Integrity

1. Administrative Procedures (2) Special Containment Systems a. Security and Visitor Control (a) Atmosphere b. Authorities and Responsibilities for Safe Opera (b) Subatmospheric tion and Shutdown (c) Double-Wall Containment with Controlled c. Equipment Control (e.g., locking and tagging) Interspace d. Procedure Adherence and Temporary Change (d) Ice Condenser Method (3) Containment Ventilation System e. Procedure Review and Approval

(4) Containment Cooling System f. Schedule for Surveillance Tests and Calibration g. Shift and Relief Turnover g. Atmosphere Cleanup Systems h. Log Entries, Record Retention, and Review h. Fuel Storage Pool Purification and Cooling Sys Procedures tem i. Access to Containment i. Main Steam System j. Bypass of Safety Functions and Jumper Control j. Pressurizer Pressure and Spray Control Systems k. Maintenance of Minimum Shift Complement k. Feedwater System (feedwater pumps to steam and Call-In of Personnel generator)

I. Plant Fire Protection Program 1. Auxiliary Feedwater System m. Communication System Procedures m. Service Water System n. Chemical and Volume Control System (includ

2. General Plant Operating Procedures ing Letdown/Purification System)

a. Cold Shutdown to Hot Standby o. Auxiliary or Reactor Building Heating and b. Hot Standby to Minimum Load (nuclear start Ventilation up) p. Control Room Heating and Ventilation c. Recovery from Reactor Trip q. Radwaste Building Heating and Ventilation d. Operation at Hot Standby r. Instrument Air System e. Turbine Startup and Synchronization of s. Electrical System Generator (1) Offsite (access circuits)

f. Changing Load and Load Follow (if applicable) (2) Onsite g. Power Operation and Process Monitoring h. Power Operation with less than Full Reactor (a) Emergency Power Sources (e.g., diesel Coolant Flow generator, batteries)

i. Plant Shutdown to Hot Standby (b) A.C. System j. Hot Standby to Cold Shutdown (c) D.C. System k. Preparation for Refueling and Refueling t. Nuclear Instrument System Equipment Operation I. Refueling and Core Alterations (1) Source Range

(2) Intermediate Range

3. Procedures for Startup, Operation, and Shutdown (3) Power Range of Safety-Related PWR Systems (4) Incore System Instructions for energizing, filling, venting, drain u. Reactor Control and Protection System ing, startup, shutdown, and changing modes of oper v. Hydrogen Recombiner ation should be prepared, as appropriate, for the fol lowing systems:

4. Procedure for Startup, Operation, and Shutdown a. Reactor Coolant System of Safety-Related BWR Systems

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Instructions for energizing, filling, venting, drain 5. Procedures for Abnormal, Offnormal, or Alarm ing, startup, shutdown, and changing modes of oper Conditions ation should be prepared, as appropriate, for the Since these procedures are numerous and corre following systems:

spond to the number of alarm annunciators, the pro cedures are not individually listed. Each safety related annunciator should have its own written a. Nuclear Steam Supply System (Vessel and procedure, which should normally contain (1) the Recirculating System) meaning of the annunciator, (2) the source of the sig b. Control Rod Drive System nal, (3) the immedate action that is to occur automat c. Reactor Cleanup System ically, (4) the immediate operation action, and (5) the d. Liquid Poison System (Standby Liquid Con long-range actions.

trol System)

e. Shutdown Cooling and Reactor Vessel Head Spray System

6. Procedures for Combating Emergencies and Other f. High Pressure Coolant Injection Significant Events g. Reactor Core Isolation Cooling System h. Emergency Core Cooling Systems a. Loss of Coolant (including significant PWR

i. Closed Cooling Water System steam generator leaks) (inside and outside primary j. Containment containment) (large and small, including leak-rate

(1) Maintaining Integrity determination)

(2) Containment Ventilation System b. Loss of Instrument Air

(3) Inerting and deinerting c. Loss of Electrical Power (and/or degraded power sources)

k. Fuel Storage Pool Purification and Cooling d. Loss of Core Coolant Flow System e. Loss of Condenser Vacuum I. Main Steam System (reactor vessel to turbine) f. Loss of Containment Integrity m. Turbine-Generator System g. Loss of Service Water n. Condensate System (hotwell to feedwater h. Loss of Shutdown Cooling pumps, including demineralizers and resin i. Loss of Component Cooling System and Cool regeneration) ing to Individual Components o. Feedwater System (feedwater pumps to reactor j. Loss of Feedwater or Feedwater System vessel) Failure p. Makeup System (filtration, purification, and k. Loss of Protective System Channel water transfer) 1. Mispositioned Control Rod or Rods (and rod drops)

q. Service Water System m. Inability to Drive Control Rods r. Reactor Building Heating and Ventilation n. Conditions Requiring Use of Emergency Bora Systems tion or Standby Liquid Control System s. Control Room Heating and Ventilation o. Fuel Cladding Failure or High Activity in Systems Reactor Coolant or Offgas t. Radwaste Building Heating and Ventilation p. Fire in Control Room or Forced Evacuation of Systems Control Room u. Standby Gas Treatment System q. Turbine and Generator Trips v. Instrument Air System r. Other Expected Transients that may be w. Electrical System Applicable

(1) Offsite (access circuits) s. Malfunction of Automatic Reactivity Control

(2) Onsite System t. Malfunction of Pressure Cdntrol System (a) Emergency Power Sources (e.g., diesel u. Reactor Trip generator, batteries) v. Plant Fires (b) A.C. System w. Acts of Nature (e.g., tornado, flood, dam (c) D.C. System failure, earthquakes)

x. Nuclear Instrument System x. Irradiated Fuel Damage While Refueling y. Abnormal Releases of Radioactivity

(1) Source Range

(2) Intermediate Range

(3) Power Range z. Intrusion of Demineralizer Resin Into Primary System (BWR Plants) I

(4) TIP System 7. Procedures for Control of Radioactivity (For limit y. Reactor Protection System ing materials released to environment and limiting z. Rod Worth Minimizer personnel exposure)

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a. Liquid Radioactive Waste System

(1) Pressurized Water Reactors

( I) Collection. Demineralizing. Filtering, Evaporating and Concentrating, (a) Containment Leak-Rate Tests and Neutralizing (b) Containment Isolation Tests

(2) Sampling and Monitoring (c) Containment Local Leak Detection Tests

(3) Discharging to Effluents (d) Containment Heat and Radioactivity b. Solid Waste System Removal Systems Tests

(1) Spent Resins and Filter Sludge Handling (e) Containment Tendon Tests and

(2) Baling Machine Operation Inspections

(3) Drum Handling and Storage (f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests c. PWR Gaseous Effluent System (hi Fire Protection System Functional Tests

(1) Collection. Storage. and Discharge (i) Boric Acid Tanks-Level Instrumenta tion Calibrations

(2) Sampling and Monitoring

(3) Air Ejector and Stack Monitoring (j) Emergency Core Cooling System Tests

(4) Ventilation Air Monitoring (k Control Rod Operability and Scram Time Tests d. BWR Air Extraction. Offgas Treatment. and (1) Reactor Protection System Tests and Other Gaseous Effluent Systems Calibrations

(1) Mechanical Vacuum Pump Operation (m) Permissi',es-Tests and Calibrations

(2) Air Ejector Operation (n) Refueling System Circuit Tests

(3) Packing Steam Exhauster Operation (o) Emergency Boration System Functional

(4) Sampling Tests

(5) Air Ejector. Ventilation. and Stack Monitor (p) DNB Checks and Incore-Excore Flux Monitor Correlations e. Radiation Protection Procedures (q) Emergency Power Tests (I) Access Control to Radiation Areas Includ. tr) Auxiliary Feedwater System Tests ing a Radiation Work Permit System (s) NSSS Pressurization and Leak

(2) Radiation Sur\e\s Detection

(3) Airborne Radioactiv.ity Monitoring (t) Inspection of Reactor Coolant System

(4) Contamination Control Pressure Boundary

(5) Respiratory Protection (u) Inspection of Pipe Hanger Settings

(6) Training in Radiation Protection (v) Control Rod Drive System Functional

(7) Personnel Monitoring Tests

(8) Bioassay Program (w) Heat Balance-Flux Monitor

(9) Implementation of ALARA Program Calibrations Ix) Pressurizer and Main Steam Safety f. Area Radiation Monitoring S)stem Operation Valve. Tests g. Process Radiation Monitoring System (y) Leak Deection Systems Tests Operation (z) Axial and Radial Flux Pattern Determi h. Meteorological Monitoring nations

8. Procedures for Control of Measuring and Test (aa) Area. Portable. and Airborne Radiation Equipment and for Surveillance Tests, Proce M on it or Calibrations dures. and Calibrations (bb) Process a. Procedures of a type appropriate to the cir Radiation Monitor Calibrations cumstances should be provided to ensure that tools, (cc) Environmental Monitor Calibrations gauges. instruments, controls, and other measuring (dd) Safety Valve Tests and testing devices are properly controlled, calib (ee) Turbine Overspeed Trip Tests rated. and adjusted at specified periods to maintain (ff) Water Storage Tanks-Level In accuracy. Specific examples of such equipment to be strumentation Calibration calibrated and tested are readout instruments, inter (2) Boiling Water Reactors lock permissive and prohibit circuits, alarm devices, sensors. signal conditioners, controls, protective cir (a) Containment Leak-Rate and Penetration cuits, and laboratory equipment. Leak-Rate Tests (b) Containment Isolation Tests b. Specific procedures for surveillance tests, in (c) Containment Vacuum Relief Valve spections. and calibrations should be written (imple Tests menting procedures are required for each surveillance (d) Containment Spray System Tests test. inspection, or calibration listed in the technical (e) Standby Gas Treatment System Tests specifications): (including filter tests)

1.33-6

(f) Service Water System Functional Tests c. Procedures for the repair or replacement of (g) Main Steam Isolation Valve Tests equipment should be prepared prior to beginning (h) Fire Protection System Functional Tests work. Such procedures for major equipment that is (i) Nitrogen Inerting System Tests expected to be repaired or replaced during the life of (j) Emergency Core Cooling System Tests the plant should preferably be written early in plant (k) Control Rod Operability and Scram Time life. The following are examples of such procedures Tests for major equipment:

(1) Reactor Protection System Tests and (1) Repair of PWR Steam Generator Tubes Calibrations (2) Replacement and Repair of Control Rod (m) Rod Blocks-Tests and Calibrations Drives (n) Refueling System Circuit Tests (3) Replacement of Recirculation Pump Seals (o) Liquid Poison System Tests (4) Replacement of Important Strainers and (p) Minimum Critical Heat Flux Checks and Filters Incore Flux Monitor Calibrations Repair or Replacement of Safety Valves

(5)

(q) Emergency Power Tests (6) Repair of Incore Flux Monitoring System (r) Isolation Condenser or RCIC Tests Replacement of Neutron Detectors

(7)

(s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System d. Procedures that could be categorized either as Pressure Boundary maintenance or operating procedures should be (u) Inspection of Pipe Hanger Settings developed for the following activities. Instructions (v) Control Rod Drive System Functional for these activities may be included in systems Tests procedures.

(w) Heat Balance

(1) Exercise of equipment that is normally idle (x) Autoblowdown System Tests (y) Leak Detection System Tests but that must operate when required (z) Axial and Radial Flux Pattern Determi (2) Draining and Refilling Heat Exchangers

(3) Draining and Refilling Recirculation Loop nations (aa) Area, Portable, and Airborne Radiation (4) Draining and Refilling the Reactor Vessel Monitor Calibrations (5) Draining and Refilling Steam Generators (bb) Process Radiation Monitor Calibrations (6) Removal of Reactor Head

(7) Disconnection and Reconnection of Wiring I (cc) Environmental Monitor Calibrations Penetrating Reactor Vessel Head (dd) Safety Valve Tests

(8) Demineralizer Resin Regeneration or (ee) Turbine Overspeed Trip Test Replacement (ff) Water Storage Tanks-Level In strumentation Calibrations e. General procedures for the control of mainte (gg) Reactor Building Inleakage Tests nance, repair, replacement, and modification work should be prepared before reactor operation is begun.

9. Procedures for Performing Maintenance These procedures should include information on areas such as the following:

a. Maintenance that can affect the performance

(1) Method for obtaining permission and clear of safety-related equipment should be properly pre planned and performed in accordance with written ance for operation personnel to work and for logging procedures, documented instructions, or drawings such work and appropriate to the circumstances. Skills normally (2) Factors to be taken into account, including possessed by qualified maintenance personnel may the necessity for minimizing radiation exposure to not require detailed step-by-step delineation in a pro workmen, in preparing the detailed work procedures.

cedure. The following types of activities are among those that may not require detailed step-by-step writ 10. Chemical and Radiochemical Control Procedures ten procedures: Chemical and radiochemical control procedures

(1) Gasket Replacement should be written to prescribe the nature and fre

(2) Trouble-Shooting Electrical Circuits quency of sampling and analyses, the instructions

(3) Changing Chart or Drive Speed Gears or maintaining water quality within prescribed limits, Slide Wires on Recorders and the limitations on concentrations of agents that may cause corrosive attack or fouling of heat-transfer b. Preventive maintenance schedules should be surfaces or that may become sources of radiation developed to specify lubrication schedules, inspec hazards due to activation. These procedures should tions of equipment, replacement of such items as fil specify laboratory instructions and calibration of lab ters and strainers, and inspection or replacement of oratory equipment. Extreme importance must be parts that have a specific lifetime such as wear rings. placed on laboratory procedures used to determine

1.33-7

concentration and species of radioactivity in liquids and gases prior to release, including representative sampling, validity of calibration techniques, and ade.

quacy of analyses.

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