ML19212A211
| ML19212A211 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/15/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19207B153 | List: |
| References | |
| REGGD-01.033, REGGD-1.033, NUDOCS 7908230471 | |
| Download: ML19212A211 (10) | |
Text
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h "arcn 15, 1979 I
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2 VALUE/ IMPACT ASSESSMENT ON 3
QUALITY ASSURANCE REQUIREMENTS FOR THE OPERATION OF NUCLEAR POWER PLANTS 4
I.
The Proposed Action 5
A.
Description 6
Appendix B, " Quality Assurance Criteria for Nuclear Power Plants 7
and Fuel Reprocessing Plants," to 10 CFR Part 50, " Licensing of 8
Production and Utilization Facilities," establishes quality assur-9 ance requirements for the operation of nuclear power plant safety-10 related structures, systems, and components.
The proposed action 11 will provide updated guidance for compliance by the applicant 12 with quality assurance program requirements for the operation 13 phase of nuclear power plants.
14 B.
Need for the Procosed Action 15 Regulatory Guide 1.33, Revision 2, 'Qu&lity Assurance Program 16 Requirements (Operation)," dated February 1978, provides guid-17 ance on quality assurance program requirements fe. the operation 18 phase of nuclear power plants and endorses National Standard AN,SI 19 N18.7-1976/ANS-3.2. With the implementation of the SD/IE Feed-20 back Program between the Offices of Standards Development and 1
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1 Inspection and b,forcement, several problem areas (discussed in 2
Section C of this Preliminary Value/ Impact Statement) with regard 3
to guidance on quality assurance program requirements for the 4
operations phase of nuclear power plants have been identified.
5 Current NRC guidance should be apdated to provide more concise 6
guidance and reflect experience in the use of this Regulatory 7
Guide.
8 C.
Value/Imoact of the Prooosed Action 9
1.
NRC 10 Guidance for complying with the Commission's Regulations 11 with regard to overall quality assurance program requirements 12 for the operation phase of nuclear power plants is currently 13 contained in Regulatory Guide 1.33, dated Feoruary 1978 and 14 is being used by the NRC staff in the evaluation of applica-15 tions for operating licenses.
Since the purpose of the pro-16 posed action is to provide uodated guidanca to reflect 17 experience with the use of cui rent guidance, the value/ impact 18 will be based on changes proposed to guidance contained in 19 Regulatory Guide 1.33 (Revision 2,.
20 The following is a list of the significant changes to be made to 21 the Regulatory Guide and the associated value/ impact assessment 22 for each change.
2 s' Yp '?. mtigt}Ry
1 (a) Regulatory Position 1 will be reworded to specifically state 2
that the identified procedures should be cmittec only if they 3
are not applicable to an applicant due to the configuration 4
of the nuclear pnwer plant.
5 The present wording of cc.e Regulatory Position allows for 6
the misinterpretation that the applicant can omit procedures 7
without careful justification.
8 The value of the proposed change will be less time spent by 9
the NRC staff informing applicants of the requirements for 10 having detailed written procedures.
Since there is no change 11 in staff position, the impact will be minimal.
12 (b) To provide a more complete list of typical procedures in 13 Appendix A of the Guide, the following items will be added:
14 (1) Quality Assurance Program implementation procedures 15 (2)
Inservice Inspection 16 (3)
Hydrogen Explosions 17 The addition of these procedures to Appendix A will provide 18 improved guidance concerning which activities should be 19 covered by written procedures.
The value will be less time 20 spent by the NRC staff to inform applicants of those activities 3
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1
.,hich require detailed written procecures.
Since the addi-2 tional guidance is a present staff position, the impact will 3
be negligible.
4 (c) Identification of the types of instruments that require 5
periodic calibration and procedural coverage will be clari-6 fied to specifically include both portable and installed 7
equipment.
8 Subdivision 8.a of Aopendix A is intonded to apply to 9
installed instruments as well as portable equipment.
- ow-10 ever, there is some confusion within the industry concerning 11 the application of the subdivision.
The value of the change 12 will b3 the clarification of a present staff position.
This 13 will reduce the amourt of time spent by the NRC staff to 14 inform applicants of the types of instruments that require 15 periodic calibration and procedural coverage.
The impact 16 will be negligible since there will be no change in staff 17 position.
18 (d) Clarification of the position that procedures should be 19 prepared for all Technical Specification required surveil-20 lance, whether included in the surveillance section or not, 21 will be acco.aplished.
4
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1 The 5 31ue of this action will be the removal of confusion 2
that results from the use of older technical specifications 3
which do not apply to Subdivision 8.b of Appendix A.
The 4
NRC staff will spend less time to inform applicants of the 5
true staff position.
The impact will be negligible since 6
the result of this action is the clarification of a staff 7
Dosition.
8 (e) A change will be made to more clearly specify the need to 9
establish procedures which cover all aspects of reactor 10 engineering surveillance.
11 The expansion of these procedures will provide additional 12 guidance to the industry.
The valua will be less time spent 13 by the NRC staff to inform applican;s of the need for written 14 procedures in this area.
Since there will be no change in the 15 staff position, the impact will be negligible.
16 (f) Subdivision 9.a of Appendix A will be modified to state that 17 even though minor, routine maintenance activities may not 18 require detailed procedural coverage, the; are still subject 19 to gen *ral administrative procedural controls.
5
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e 1
This change re.T,0ves the misleacing inolication that major 2
maintenance activities could be accomplished without proce-3 dures.
The ' 31ue of this proposed action will be less time 4
spent by the NRC staff to inform applicants of activities 5
which require detailed procedural coverage.
Since this 6
change does not effect the present staff position, there will 7
be negligible impact.
8 (g) To remove the impli ation that only the activities listed 9
in Subdivision 9.d c f Appendix A could be considered either 10 maintenance or oper iting procedures, it will bc stated that 11 the items listed a e only examoles of such activities.
12 Due to the wording of this subdivision, confusion has arisen 13 within the industry concerning procedures that could be 14 categorized either as maintenance or operating procedures.
15 The value will be less time spent by the NRC staff to inform 16 the applicant of the true intention of the subdivision.
17 The impact will be minimal since the change corre: ponds to 18 the present NRC staff position.
19 (h) Additianal areas which should be addressed by administrative 20 procedures will be included in Subdivision 9.e of Appendix A 21 to assist in solving the problems of inadequate retest 6
VM270
1 a significant. rdar work, 2
_cacures for significant mainte-,-
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3 4
is vill ce " pro.ed guidance in the 5
1 th.t.e issuance of 7, ore useful 6
ei stry, the NRC staff should 7
rithin the industry of quality 8
"s.
This improvement of guidance 9
.t.in SC staff.
10 (i)
' <.1 Aich deals with chemical and radio-11 2du.?s vill be expanded to provide addi-12 13
.Miticnal guidance will be less time spent 14 inform acpiicants individually of this 15
.?
this gui;ince is presently a staff position, 16 3
j M e.
i 17 The sult in more efficient license evalua-
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18 tion
' c ;uidance for ccmpliance with quality 19 assu
-c.ents for the operation phase of nuclear 20 powe-
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1 2.
Other Government Agencies 2
Not applicable, unless the gosernment agency is an applicant, 3
as TVA.
4 3.
Industry 5
The changes to be made to Regulatory Guide 1.33 will not 6
alter present regulatory bases for license evaluations.
7 The value of the proposed action will be to provide more 8
specific guidance concerning quality assurance program 9
requirements.
In addition to removing confusion within 10 the industry, the proposed action will facilitate the 11 development of a method acceptable to the NRC staff for 12 complying with the Commission's Regulations with regard 13 to quality assurance program requirements for the opera-14 tion phase of nuclear power plants.
The expansion of 15 guidance presented in the Regulatory Guide may initially 16 appear to increase the requirements for compliance with 17 the Commission's regulations.
However, since the addi-18 tional guidance is presently used by the NRC staff in 19 license evaluation, the impact on industry will be minimal.
20 4.
Workers ( ALARA Considerations) 21 Not Applicable.
8
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1 5.
Public 2
The value to the public will be more efficient license appli-3 cation preparation by industry which could reduce the cost 4
of nuclear power plants.
Additional value would be more 5
efficient use of tax dollars as a result of the increased 6
guidance for license evaluations by the NRC staff.
7 0.
Decision on Procosed Action 8
Updated guidance should be furnished on quality assurance prog-7 9
requirements for the operation phase of nuclear power plants.
10 II.
Technical Acoroach 11 This section is not applicable to this value/ impact statement since 12 the proposed action is an update of previously issued guidance.
13 III. orocedural Acoroach 14 Since the proposed action is an update of information contained in an
~. 5 existing regulatory guide, the only appropriate procedural alterna-16 tive ie a revision to the existing guide.
17 IV..
Statutory Cor siderations 18 A.
NRC Authority 19 This guide would fall under the authority of the Atomic Energy Act.
20 In particular, under 10 CFR Part 50, Appendix B, which establishes 9
(CNZ73
1 quality assurance requirements for the operation of nuclear pooer 2
plant safety-related structures, systems, and ccracnents.
3 B.
Need for NEPA Assessment 4
The proposed action is not a major action, as defined by 10 CFR 5
51.5(a)(10), and does not require an environmental impact 6
statement.
7 V.
Relationshio to Other Existing or Procosed Regulations or Policies 8
The relationship of the guidance furnisned by the proposed action to 9
guidance provided by other Regulatory Guides is discussed in Regula-10 tory Position C.2 of Regulatory Guide 1.33.
11 VI.
Summary and Conclusions 12 A revision to Regulatory Guide 1.33, " Quality Assurance Program 13 Requirements (Operation)," should be prepared.
10
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