ML19212A214
| ML19212A214 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/09/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19207B153 | List: |
| References | |
| REGGD-01.028, REGGD-1.028, NUDOCS 7908230491 | |
| Download: ML19212A214 (6) | |
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x Preliminary Value/ Impact Assessment on Quality Assurance Program Requirements for fluclear Power Plants
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E G l.2 8 I.
The Preccsed Action A.
Description The applicant (licensee) of a nuclear po'wer plant is required by the Commissicn's regulations to establisa and implement a quality assurance program. The proposed ' action will provide updated guidance for establishing and implementing a quality assurance program for nuclear p0, er plants.
B.
fleed for the Prc:csed Action Guidance on establishing and implementing the quality assurance program is centained in Regulatory Guide 1.28, " Quality Assurance Program Requiremants (Design and Construction)," dated. June 7,
'1972.
The regulaccry guide endor:cd A?!5I Standard iMS.2-ig71.
On April 7,1977, AliSI approved Revisicn 1 to N45.2-1971 and designated the standard AilSI t!45.2-1977.
The revision makes tha standard applicable to all nuclear fuel cycle facilities.
Present i!RC guidance should be updated to reflect experienca in use of the present guidance and to establish an llRC positica on the appreved flaticnal Standard.
C.
Value/Iccact of the Precosed Action sjs12SO 1.
f!RC Guidanca on quality assurance pregram requirements fcr t!:e design and construction phases for nuclear pc.ver plants is presently contained in Regulatcry Guida 1.23 (Safety Guide 23, q90823 N N
2 dated June 7,1972) and is being used by the RRC staff in the evaluation of applications for construction permits as specified in Secticns 17.1 and 17.2 of th: Standard Review Plan.
Since the purpose of the proposed action is to provide updated guidance to reflect' experience with use of present guidance and to establish an MRC position en an approved national standard,. the va,lue/ impact will be based on changes proposed to the guidance contained in Regulatory Guide 1.28.
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Since the primary purpose of. this revision of the AMSI standard was to make the standard applicable to both nuclear
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power piants and other fuel cycle facilities', most changes were in this area.
The proposed action will be 1.imited to application to nuclear power plants and coordinated with other SD efforts in other areas. Therefore, the icpact of this change will be negligible.
The pravious version of this standard, ANSI M45.2-1971, contains both requirements and guidelines. A letter was rereived frca General Electric (N. D. Gilbertl to A. Giambuss:
dated February 20, 1975, asking for clarificatien of the intent when MRC endorses both requirements and recc=:enda-tions of a standard.
The MRC replied (R. B. Minogue to W. Gilbert, dated May 6,1975) to G.E. and in the repiy
w stated that we were undertaking a ree afnation of some of the regulatcry guides which endorse MISI standards, par-ticularly in the quality assurance area, to determine whether it might not be appropriate to qualify our endorse-ment of at least scme of the guidelines since not a11 have substantive safety importance. A copy of this correspendence is attached. Also attached is an e$cerpt frca,the minutes of the January 21, 1976 in'teroffice Quality Assurance Task Force meeting which cutlines the total project.
This area was considered by NRC perst nnel during the process of
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revision of the standard. f.ction.,. consistent uith current
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licensing practice as specified in Sections 17.1 and 17.2 of the Standard Review Plar.. to resolve this' problem was made during revision of 'ne standard and uill serve as the basis for staff positions in the preposed action.
Therefore, the impact to the NRC staff will be negligibTe.
The resoletion of this problem will be of valw to 'the staff in that a cc:cnitment by the applicant to the proposed action will be.
specific and will not require point-by-point analysis of i
each question in the license. review process.
The onTy other substantial change is in the requirements for records retenticn.
Retention of records which correctly identify the "as-built" condition of items in the nuclear
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c-4 facility are required by ANSI H?S.2-1971 to be maintained for the life of the facility.
The revision requires they be maintained only for the life of the particular item while it is installed in the nuclear facili,ty and stored for future use by o~ r for the owner.
This change is con-sistent with current staff requirements and therefore the impact will be minimum.
Since record retention prcvisions z.
,must be, reviewed regardless of the change,.the time and effort expended ay the staff in the review will not be more or less than that previously expanded.
2.
Other Government Agencies Not applicable', unless the govern =ent agency is an. applicant as TVA.
3.
Industry The value/ impact of the changes to =ake the standard appliceble to fuel cycle facilities will be the same as for the ilRC staff.
The action to resolve the confus' ion existing due to endorse-ment of both the requirements and recc=cendations of the s
present standard will have no impact.cn the industry.
The applicant must cc= ply with all rec,uir'ements and recem-mendations unless an exception is granted in the license review.
The value to industry will be that those rec:m-cendations unich are not considered to have substantia
s safety signific$nce will be identified, and a, plicants will no longer have to address them.
The proposed change in the requirement for records retention will have no impact on industry.
The adtio.n will be of value in that the licensee will not he required to maintain records en items which have been removed frem the plant and no longer reflect the "as-built" condition of the plant.
4.
Public Since all requirements related to safety of the plants will still be in effect, no impact to the public is foreseen.
The only identifiable values are a minor decrease in cost of nuclear pcwer plants and a slight acceleratica in the review precess.
D.
Decision on the Draccsed Action Updated guidance should be furnished on quality assurance prog requirements fcr the detign and es.,struction phases.
II. Technical Accroach This section is not applicable to thi: vieze/'c;act statement since the proposed actica is an update of previousi issued guidance.
The technical issues have been previously discussed.
.s III. Procedural Accroach Since the proposed action is an update of infor=ation contained in an existing regulatory guide, the only appropriate procedural alternativ is a revision to the existing guide.
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IV.
Statut:ry Considerations A.
tiRC Authority This guide would fall under the authority and safety requiremerits of the Atcmic Energy Act.
In particular under 10 CFR Part 50, Appendix 8 which establishes quality assurance requirements for the design and const.ruction of nuclear pouer plant structur:",
, systems, and ccaponents.
B.
?!eed for !!EFA Assessment The proposed action is not a major actien, as defined by 10 CFR Sl.5(a)(10), and does not require an environmental impact statacent.
V.
salationshic to Other Existino or Procased Reculations or Policies.
flo existing or proposed reguTations or policies, other than Regulatcry Guide 1.28, will be affected.
Implementation of the proposed action will be discussed in Section D of the proposed guide.
VI.
Summary and Ccnclusions A revision to Regulatory Guide 1.28, " Quality Assurance Progra:a Requirements (Design and Construction)," should be prepared.
The revision should endorse, with certain exceptions, At!SI Standard
!!?5.2-1977.
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