NQA – 1 QUALITY ASSURANCE REQUIREMENTS FOR NUCLEAR

FACILITY APPLICATIONS

Presented By – Robert G. Burns, PE

32nd National Energy & Environmental Division Conference in San Antonio , Texas

Slide 2

SCOPE

• NQA – 1 An Historical Perspective

• NQA – 1 User Community

• Scope, Structure and Content

• Basic, Supplements and Non-mandatoryAppendices

Slide 3

TYPICAL USERS

• Utilities / Power Generators• ASME Section III Users• Department of Energy• National Laboratories, Repositories and

Fuel Fabrication facilities• Trans Alaska Pipeline• Offshore Nuclear Power Projects• LES Enrichment Project

Slide 4

PRECURSOR DOCUMENTS FOR DEVELOPING QA REQUIREMENTS FOR NQA-1

• Mil - Q-9858 Quality System• Mil - I-45208 Inspection System• Mil - C-45662 Calibration System• NASA NPC 200-2 • BUSHIPS BSI 4410.17• 10CFR50, Appendix B• 10 CFR50 Appendix A, Criterion 1• The ASQ NPTC Matrix Initiative

Slide 5

QUALITY RELATED REGULATIONS, RULES, ORDERS, CODES & STANDARDS

CIVILIAN NUCLEAR DEPARTMENT OF ENERGY ENVIRONMENTAL COMM’L/INTERNATIONAL

10 CFR 50, Appendix B( NRC Programmatic )

10CFR50, Part 21( Reporting Defects )

10 CFR50.55( Codes & Standards )

R.G. 1.28( NRC Adoption of

ANSI/ASME Standards)

ASME Section III( BPVC – Nuclear )

ASME NQA-1( Quality Program )

10CFR 830, Subpart A( Nuclear – Programmatic )

10CFR820, Appendix A( Price Anderson)

DOE O 414.A( Quality Assurance )

DOE G 414.1-2( QA Management System )

DOE G 414.I-1( Independent &

Management Assessment )

DOE P 450.4( Safety Management System )

ISO-9001-2000( QA Program )

ISO-14001( Environmental

Management System )

ASME VIII( Non-nuclear QA/QC )

Note Adoption / use of an

ISO program does not require Certification.

EPA QA/R-2( EPA Requirements for

Quality Management Plans )

EPA QA/R- 5( EPA Requirements for

QA Project Plans )

ANSI/ASQC E4-1994( Specifications and Guidelines

for Quality Systems forEnvironmental Data

Collection and EnvironmentalTechnology Programs )

RW-0333POCRWM-YMP

( Waste Repository QAProgram )

BRIEF HISTORY OF NQA-1

ANSI

ASME-American Society of Mechanical Engineers AIChE -American Institute of Chemical Engineers

N45.2 Quality Assurance Requirements for Nuclear Power Plants N46.2 QA Program Requirements for Post

Nuclear Fuel Cycle Facilities

N45.2.6-Qualification of Inspection, Examination and Testing Personnel for Nuclear Power PlantsN45.2.9-Requirements for Collection, Storage and Maintenance of Quality Assurance Records N45.2.10-Quality Assurance Terms and DefinitionsN45.2.11-Quality Assurance Requirements for the Designof Nuclear Power PlantsN45.2.12-Requirements for Auditing of Quality assurance Programs for Nuclear Power PlantsN45.2.13-Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power PlantsN45.2.23-Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants

NQA-1-1994 WITH 1995(a) ADDENDAQUALITY REQUIREMENTS for NUCLEAR

POWER FACILITY APPLICATIONS

Slide 7

TITLE 10, APPENDIX B to PART 50

Quality Assurance Criteria for Nuclear Power Plants & Reprocessing Facilities

“ Quality Assurance Comprises All Those Planned and Systematic Actions Necessary to Provide Adequate Confidence That a System, Structure or Component Will Perform Satisfactorily in Service”

Quality Assurance includes Quality Control, Which Comprise Those Quality Assurance Actions Related to The Physical Characteristics Of A Material , Structure , Component , or System Which Provides A Means To Control The Quality Of The Material, Structure Component Or System To Predetermined Requirements.

QA AS ESTABLISHED BY REGULATORY RULEMAKING

Slide 8

QUALITY REQUIREMENTS ESTABLISHED BY REGULATORY RULEMAKING

TITLE 10 APPENDIX A TO PART 50

Criteria 1. – Quality Standards and Records. Structures, Systems , and Components Important To Safety Shall Be Designed, Fabricated, Erected and Tested to Quality Standards Commensurate With The Importance Of The Safety Functions To Be Performed. Where Generally Recognized Codes and Standards Are Used , They Shall Be Identified And Evaluated To Determine The Applicability, Adequacy, And Sufficiency And Shall Be Supplemented Or Modified As Necessary to Assure A Quality Product In Keeping With The Required Safety Function. A Quality Assurance Program Shall be Established And Implemented In Order To Provide Adequate Assurance That These Structure, Systems, And Components Will Satisfactorily Perform Their Safety Functions. Appropriate Records Of The Design,Fabrication, Erection, And Testing Of Systems, Structures And Components Important To Safety Shall Be Maintained By Or Under The Control Of The Nuclear Power Unit Licensee Throughout The Life Of The Unit.

Slide 9

OTHER DAUGHTER STANDARDS

Incorporated into NQA-2-1983

• N45.2.1 Fluid Systems

• N45.2.2 Packaging & Handling

• N45.2.3 Housekeeping

• N45.2.5 Civil / Structural Inspection

• N45.2.8 Mechanical Equipment Inspection

• N45.2.15 Hoisting & Rigging

• N45.2.20 Subsurface Investigations

Slide 10

NQA STRUCTURE

– Part I, “Requirements” ( sometimes referred to as “basic requirements”) which coincide with the 18 Criteria contained in 10CFR50, Appendix B.

– Part II, ”Requirements” ( formerly NQA-2, various daughter standards)

– Part III, “Non-mandatory Guidance” ( formerly Non-mandatory Appendices to

Slide 11

DEVELOPMENTAL MILESTONES

• Performance Based vs. Compliance

• Graded Approach

• Risk Informed

Slide 12

PERFORMANCE BASED INITIATIVE1993 SAN DIEGO TASK FORCE FORMED

• SEVEN CRITERIA FOR REWRITE OF PART I• Is it performance base related• Does it contribute to safe/reliable plant ops• Is benefit commensurate with implementation

cost• Is it consistent with current technology and

industry maturity• Is the level of detail required to achieve desired

result

Slide 13

PERFORMANCE BASED (CONTINUED)

• For the intended activity, is this a minimum requirement that applies to all applications

• Is the requirement stated once and not duplicated

Application of these seven criteria were intended to move the focus from “Compliance “ to the verification of the “Attainment of safety and reliability”

Slide 14

PERSPECTIVE ON MISSION

Nuclear Regulatory Commission Nuclear Industry

• SAFETY

• CONSERVATISM

• COMPLIANCE

• PAPER TRAIL

• LICENSABLE

1993-NQA CommitteePerformance Based Initiative

• LICENSABLE •SAFETY

• FUNCTIONALITY

• RELIABILITY

• COMPLIANCE

VERIFICATION OF COMPLIANCE

ATTAINMENT OF SAFETY AND RELIABILITYFOCUS

nqa1.history.4.

Slide 15

FUTURE NQA APPLICATIONS

• Advanced & Generation IV Reactors

• Fuel Production Facilities

• Thermonuclear Power Projects

NQA COMMITTEE

Main Committee (35 Members)

• SC on Assessment & Verification• SC on Waste Management• SC on Applications• SC on Engineering and Procurement

Processes • SC on Program Management Processes• SC on Interface and Administration

Slide 17

FUNCTIONS

• Maintain the NQA documents• Planning for changes and new documents• Balloting changes and new documents• Responding to Inquiries• Working with Regulators• Outreach to Users• Balance of Interest

Slide 18

FEATURES

• Two meetings a Year

• Electronic Ballot Process

• Member Performance Evaluation

• Consideration of All positions

• Open Process

NQA – 1 QUALITY ASSURANCE REQUIREMENTS FOR NUCLEAR

FACILITY APPLICATIONS

Presented By – Robert G. Burns, PE

32nd National Energy & Environmental Division Conference in San Antonio , Texas

THINGS YOU WONT FIND IN NQA-1

HELPFUL QA SURVIVAL HINTS

Slide 21

• PLAN A BE LUCKY

• PLAN B BE DECEPTIVE

• PLAN C BE COMPLIANT

BEST STRATEGY:• ACCEPT RESPONSIBILITY - BE ACCOUNTABLE

• RESPOND IN RELATION TO SEVERITY- MOST CRITICAL-SAFETY

- NEXT IS FUNCTIONALITY

- LAST IS COSMETIC COMPLIANCE

• CONTEND INANE FINDINGS- THEY REFLECT BADLY ON THE AUDITOR AND YOU. REMEMBER A NONSENSE FINDING IS OFTEN IMPOSSIBLE TO ANSWER LOGICALLY!

AUDIT STRATEGIES

Slide 22

• PRESENTATIONS• LUNCHES & DINNERS• FACILITY TOURS• NON-AUDIT DISCUSSIONS

FALL-BACK STRATEGY

• “NEW SYSTEM”

• “ PLEAD GUILTY TO EASY TO FIX ERRORS”

• “CONTEND THEN SURRENDER”

• “ PRAY FINDING TRACKS TO PREVIOUS QA MANAGER”

AUDIT MANAGEMENT

Slide 23

SELLING AN NQA QUALITY PROGRAM OR PLAN

• PLAY CLIENT MUSIC & LYRICS• BUILD FLEXIBILITY INTO TEXT – Shall, Should May• MAXIMIZE USE OF DIAGRAMS, MAPS, FLOWCHARTS• SELL THE PROGRAM AS A PRODUCT• IT’S NOT BIBLICAL – Plan for Revision

• ASSESS EFFECTIVENESS COST TO IMPLEMENTSCHEDULE IMPACTUSER BUY-INDISCIPLINE /

ACCOUNTABILITY

• RESELL THE PROGRAM & Reach Beyond Compliance

Slide 24

DEVELOPMENT DANGER - THE IMPROVEMENT DEATH SPIRAL

Investigate

Plan New Approach

ImplementNew Approach

Measure ImprovementModify New

Approach

Degrade toOriginal Practice

ResumeInvestigation

Find AnyNon-Improvement