ML19212A215
| ML19212A215 | |
| 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 7908230496 | |
| Download: ML19212A215 (2) | |
Text
.
Value/ Impact Assessment for Regulatory Guide 1.28, Revisicn 1,
" Quality Assu ar nce Program Requirements (Design and Construction)"
The value/ impact assessment presented with the Task Initiatio-Form dated May 19,1977 (copy attached), Section C, Value/ Impact of the Proposed Action, is valid for the guide at this stage of devel'.pment. Staff review of the proposed guide resulted in only editorial revision. One additional topic was discussed in the working ;; aper of the proposed guide which was forwarded for staff review that was not considered in the preliminary value/ impact assessment. The value/ impact of this additicn is discussed below.
Value/Imcact of Raculator-/ position C.1.
Regulatory Position C,1 provides guidance en implemanting Sectien' 2 of ANSI M5.2-1977 which requires that applicable sections and elements of the standard shall be established at the earliest
~
practical time consistant with the schedule for acccmplishing.the activities.
The guidance clarifies the applicability of the standard to those safety related activities which are initiated by the applicant prior to submitting its application for a ccastruction permit (CP).
The value of this position to the MRC staff is the assurance that the' activities initiated prior to application for a CP are controlled by a quality assurance program acceptable to the staff. This allows more systematic r'eview of the information submitted with the f./
application. The value to the applicant wili be that the activities he has undertaken prior to CP applicat'fon will be proparly controlled and documented and, therefore, more li'xely to be acceptable to the NRC staff. This could prevenc delays in review of the applicatien.
m 7 9 08 2 3 0Y/T,!
The it.. pact on both NRC staff and applicants is expected to be negligible. The guidance provided was included in NASH 1233, Revision i, May 29, 1974 (Grey Scok) and has been used by the staff and appifcants since that time.
It represents no change in MRC staff practice and is included in the guide to provide more complete guidance in the guine aithout relying on other supporting dcct=ents.
Additionally, should the staff withdraw WASH 1283 when the guidance provided by the draft standards included in it is updated, the guidance on activities prior to Cp application would no longer be available to applicants, unTess it is included in a regulatory guide.
s4 Y
e a
.4 e
e g
e 9
c61297
,