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NQA – 1 QUALITY ASSURANCE REQUIREMENTS FOR NUCLEAR FACILITY APPLICATIONS Presented By – Robert G. Burns, PE 32 nd National Energy & Environmental Division.

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Presentation on theme: "NQA – 1 QUALITY ASSURANCE REQUIREMENTS FOR NUCLEAR FACILITY APPLICATIONS Presented By – Robert G. Burns, PE 32 nd National Energy & Environmental Division."— Presentation transcript:

1 NQA – 1 QUALITY ASSURANCE REQUIREMENTS FOR NUCLEAR FACILITY APPLICATIONS Presented By – Robert G. Burns, PE 32 nd National Energy & Environmental Division Conference in San Antonio, Texas

2 Slide 2 SCOPE NQA – 1 An Historical Perspective NQA – 1 User Community Scope, Structure and Content Basic, Supplements and Non-mandatory Appendices

3 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

4 Slide 4 PRECURSOR DOCUMENTS FOR DEVELOPING QA REQUIREMENTS FOR NQA-1 Mil - Q-9858 Quality System Mil - I Inspection System Mil - C Calibration System NASA NPC BUSHIPS BSI CFR50, Appendix B 10 CFR50 Appendix A, Criterion 1 The ASQ NPTC Matrix Initiative

5 Slide 5 QUALITY RELATED REGULATIONS, RULES, ORDERS, CODES & STANDARDS CIVILIAN NUCLEARDEPARTMENT OF ENERGYENVIRONMENTALCOMM’L/INTERNATIONAL 10 CFR 50, Appendix B ( NRC Programmatic ) 10CFR50, Part 21 ( Reporting Defects ) 10 CFR50.55 ( Codes & Standards ) R.G ( 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 ( QA Management System ) DOE G 414.I-1 ( Independent & Management Assessment ) DOE P ( Safety Management System ) ISO ( QA Program ) ISO ( 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 E ( Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs ) RW-0333P OCRWM-YMP ( Waste Repository QA Program )

6 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 N Qualification of Inspection, Examination and Testing Personnel for Nuclear Power Plants N Requirements for Collection, Storage and Maintenance of Quality Assurance Records N Quality Assurance Terms and Definitions N Quality Assurance Requirements for the Designof Nuclear Power Plants N Requirements for Auditing of Quality assurance Programs for Nuclear Power Plants N Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants N Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants NQA WITH 1995(a) ADDENDA QUALITY REQUIREMENTS for NUCLEAR POWER FACILITY APPLICATIONS

7 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

8 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.

9 Slide 9 OTHER DAUGHTER STANDARDS Incorporated into NQA N Fluid Systems N Packaging & Handling N Housekeeping N Civil / Structural Inspection N Mechanical Equipment Inspection N Hoisting & Rigging N Subsurface Investigations

10 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

11 Slide 11 DEVELOPMENTAL MILESTONES Performance Based vs. Compliance Graded Approach Risk Informed

12 Slide 12 PERFORMANCE BASED INITIATIVE 1993 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

13 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”

14 Slide 14 PERSPECTIVE ON MISSION Nuclear Regulatory CommissionNuclear Industry SAFETY CONSERVATISM COMPLIANCE PAPER TRAIL LICENSABLE 1993-NQA Committee Performance Based Initiative LICENSABLE SAFETY FUNCTIONALITY RELIABILITY COMPLIANCE VERIFICATION OF COMPLIANCE ATTAINMENT OF SAFETY AND RELIABILITY FOCUS nqa1.history.4.

15 Slide 15 FUTURE NQA APPLICATIONS Advanced & Generation IV Reactors Fuel Production Facilities Thermonuclear Power Projects

16 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

17 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

18 Slide 18 FEATURES Two meetings a Year Electronic Ballot Process Member Performance Evaluation Consideration of All positions Open Process

19 NQA – 1 QUALITY ASSURANCE REQUIREMENTS FOR NUCLEAR FACILITY APPLICATIONS Presented By – Robert G. Burns, PE 32 nd National Energy & Environmental Division Conference in San Antonio, Texas

20 THINGS YOU WONT FIND IN NQA-1 HELPFUL QA SURVIVAL HINTS

21 Slide 21 PLAN ABE LUCKY PLAN BBE DECEPTIVE PLAN CBE 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

22 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

23 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 IMPLEMENT SCHEDULE IMPACT USER BUY-IN DISCIPLINE / ACCOUNTABILITY RESELL THE PROGRAM & Reach Beyond Compliance

24 Slide 24 DEVELOPMENT DANGER - THE IMPROVEMENT DEATH SPIRAL Investigate Plan New Approach Implement New Approach Measure Improvement Modify New Approach Degrade to Original Practice Resume Investigation Find Any Non-Improvement


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