ML20003F034

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Draft Value/Impact Statement of Proposed Reg Guide 1.28. Proposed Action Provides Opportunity to Clarify & Upgrade NRC Requirements Based on Experience & from Use of ANSI N45.2
ML20003F034
Person / Time
Issue date: 03/31/1981
From:
NRC OFFICE OF STANDARDS DEVELOPMENT
To:
Shared Package
ML20003F032 List:
References
TASK-OS, TASK-RS-002-5, TASK-RS-2-5 REGGD-01.028, REGGD-1.028, NUDOCS 8104200018
Download: ML20003F034 (4)


Text

DRAFT VALUE/ IMPACT STATEMENT 1.

PROPOSED ACTION 1.1 Description Appendix A, " General Design Cr iteria for Nuclear Power Plants," to 10 CFR Part 50, "Oomestic Licensing of Production and Utilization Facilities," estab-lishes requirements for structures, systems, and components importar.t to safety; that is, structures, systems, and components that provide reasonable assurance that a facility can be operated without undue risk to the health and safety of the public.

Criterion 1, " Quality Standards and Records," of these general design ( riteria requires that a quality assurance program be established and in.plemented in order to provide adequate assurance that those structures,

ystems, and components will satisfactorily perform their safety functions.

Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50 establishes quality assurance require-ments for the design, constru; tion, and operation of those structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.

The criteria for the quality assurance program required by Criterion 1 of Append'v A are the criteria contained in Appendix B.

The proposed action will provide up-dated guidance for compliance by the applicant with quality assurance program requirements during the design and construction phases of nuclear power plants.

1.2 Need for Proposed Action Current guidance on methods the NRC staff considers acceptable for comply-ing with the Commission's regulations concerning quality assurance during design and construction has been provided in a number of regulatary guides that endorse the standard ANSI N45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities," and seven N45.2-series standards that cover specific quality assurance topics.

A new standard, ANSI /ASME NQA-1-1979, was approved by the American National Standards Institute on July 24, 1979, that consolidates ANSI N45.2 and these st.ven N45.2-series standards.

NRC guidance concerning O

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quality assurance during design and construction of nuclear power plants should s

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,f be revised to reflect updated requirements in the consolidated standard.

1. 3 Value/I-alct of Prop,osed Action 1.3.1 NRC Since current guidance for quality assurance programs is contained in a series of different standards and corresponding regulatory guides, the proposed action will be of value to the staff owing to the consolidation of a large number of requirements and recommendations concerning quality assurance into a single document.

The proposed action also provides an opportunity to clarify and upgrade NRC requirements based on experience and from the use of ANSI N45.2 and its series standards.

Additionally, consolidation of design-and-construc-tion phase quality assurance guidance should provide a more effective evaluation of compatability between ANSI quality assurance requirements and the quality assurance requirements in the ASME Boiler and Pressure Vessel Code in support of the ASME third party inspection program.

By taking advantage of previous staff effort in conjunction with approval of ANSI /ASME NQA-1-1979, the proposed

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action will also establish an NRC position on the recently approved standard a

with minimum impact on the staff.

Only Regulatory Position 7.1 of this proposed revision to the guide represents an upgrade of current guidance; however, the upgrade is not considered of sufficient significance to warrant backfit to existing plants at this time.

1. 3. 2 Other Government Agencies Not applicable, unless the government agency is an applicant.

1.3.3 Industry ANSI /ASME NQA-1-1979 represents an advanced consensus document on require-ments for quality assurance programmatic action.

In a letter dated March 10, 1980, from Jack E. Vessely, Chairman, ASME Main Committee on Nuclear QA to W. J. Dircks, Executive Director for Operations of the NRC, early endorsement by the NRC of ANSI /ASME NQA-1-1979 was requested since, according to the letter, many companies are anxious to use the standard.

However, some members of

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the industry have indicated reservations regarding the usefulness of this docu-ment.

By committing to a " consolidated" standard and the regulatory guide that endorses it, the industry should understand more clearly the requirements and recommendations for the quality assurance program and the coordination of the various aspects of the program.

The proposed action establishes an NRC position on an existing national standard and therefore reduces uncertainty as to what the staff considers acceptable in the area of quality assurance requirements for the design and construction of nuclear power plants.

l 1.3.4 Workers (Relative to ALARA)

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No effect on workers is anticipated.

1.3.5 Public i

The consolidation of quality assurance criteria should result in more f

effective reviews of nuclear power plant quality assurance programs.

l The consolidation document should also result in improved quality assur-I ance programs at nuclear power plants and hence, increased safety of the l

public.

The financial impact on the public will be a slight increase in the cost of generating power as a result of any procedure modifications necessary to comply with this regulatory guide after the implementation date for new plants.

1. 3. 6 Decision on Proposed Action As previously Etated, consolidated guidance on requirements for quality assurance programs during the design and construction of nuclear power plants should be esteolished.

2.

TECH.t

_ APPROACH This section is not cpplicable to this value/ impact statement since the proposed action is an endorsement of a recently approved and published national standard.

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3.

PROCEDURAL APPROACH

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Since the proposed action is an update of information contained i-an existing regulatory guide, the only appropriate procedural alternative is a revision to the existing guide.

4.

STATUTORY CONSIDERATIONS 4.1 NRC Regulatory Authority Authority for this guide is derived from the safety requirements of the Atomic Energy Act.

In particular, Appendix A to 10 CFR Part 50 requires that a quality assurance program be established.

4.2 Need for NEPA Assessment The proposed action is not a major action as defined by paragraph 51.5(a)(10) of 10 CFR Part 51 and does not require an environmental impact statement.

5.

RELATIONSHIP TO OTHER EXISTING REGULATIONS OR POLICIES No conflicts or overlaps with requirements promulgated by other agencies are foreseen.

6.

SUMMARY

AND CONCLUSIONS A proposed revision to Regulatory Guide 1.28 on consolidated quality assurance program requirements during the design and construction of nuclear power plants should be issued.

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UNIVED $7ATES NUCLEOR REGULATORY COMMISSION

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WASHINGTON, D. C. 20S55 POST AGE AND F E ES PAIO U.S. N UCLE A R R E GUL A TO R Y OFFICI AL SUSINESS COMMisseON PE990LTY FOR PRIVATE USE, $300 k

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