Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
April 16, 1985
TO ALL POWER REACTOR LICENSEES AND ALL APPLICANTS FOR POWER REACTOR LICENSES
Gentlemen:
SUBJECT: QUALITY ASSURANCE GUIDANCE FOR ATWS EQUIPMENT THAT IS NOT
SAFETY-RELATED (Generic Letter 85-06)
On June 1, 1984, the Commission approved,publication of a final rule, 10 CFR
50.62, regarding the reduction of risk from anticipated transients without
scram (ATWS) events for light-water cooled nuclear power plants (49 FR
26036). At the same time, the Commission directed the staff to complete and
issue in the form of a generic letter explicit quality assurance (QA)
guidance for non-safety-related equipment encompassed by the ATWS rule.
Section 50.62(d) of the ATWS rule requires that each licensee develop and
submit (to the Director of the Office of Nuclear Reactor Regulation) a
proposed schedule for meeting the requirements of the rule within 180 days
after issuance of the QA guidance. The NRC staff issued a proposed generic
letter in the Federal Register (49 FR 44337) on November 6, 1984. The staff
has considered the comments room 22 interested parties that were received by
December 31, 1984 and has revised the proposed generic letter.
To develop QA guidance for non-safety-related ATWS equipment, the NRC staff
both surveyed quality practices applied to non-safety-related equipment at
some operating nuclear power plants and reviewed the comments from
utilities, industry organization,, and other concerned parties. As a result,
the staff continues to view the observed industry practices as acceptable
for non-safety-related ATWS equipment. The practices that were observed
during the plant visits or were described by utilities in their comments
generally consisted of the application of quality controls comparable to
selected portions of their Appendix 8 program. However, utility procedures
and practices did not specifically reference such controls as Appendix B
requirements.
The QA controls in Appendix B to 10 CFR 50 describe one form of a
comprehensive management control system for a complex task. While Appendix B
describes only one such system, licensees and applicants have expressed a
desire to minimize proliferation of different kinds of management control
systems for their plants. The NRC staff concurs with this desire not to
establish new and separate management control systems for non-safety-related
ATWS equipment.
CONTACT: S. Goldberg, IE 492-4968
8504120206
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Accordingly, Appendix B is viewed as a useful reference in which to frame
the staff's guidance for non-safety-related ATWS equipment. However, this
does not mean that the Appendix B QA program, including the adopted
regulatory guides and the industry standards, or an equivalent to such a
program is required to meet the intent of this generic letter. Further, the
use of Appendix B as a reference does not indicate that the guidance in this
letter imposes any Appendix B requirements on non-safety-related ATWS
equipment, and, therefore, NRC would not judge compliance with this generic
letter by using Appendix B or itS associated regulatory guides. Instead,
NRC's inspections will focus on the implementation and effectiveness of the
quality controls whose attributes are described in this letter.
The enclosure to this letter provides the explicit QA guidance required by
10 CFR 50.62. The lesser safety significance of the equipment encompassed by
10 CFR 50.62, as compared to safety-related equipment, necessarily results
in less stringent QA guidance. We have incorporated this lesser degree of
stringency by eliminating requirements for involvement of parties outside
the normal line organization and requirements for a formalized program and
detailed recordkeeping for all quality practices.
Issuance of this QA guidance shall he considered the reference date
initiating the schedule in 10 CFR 50.62(d).
Reporting requirements relating to the ATWS rule are presented in 10 CFR
50.62. There are no additional reporting requirements associated with this
letter.
Information collection requirements under the ATVIS rule were approved by
the Office of Management and Budget under clearance number 3150-0011, which
expires April 30, 1985 (49 FR 26036, p. 260441). Comments on burden and
duplication may be directed to the Office of Management and Budget, Reports
Management, Room 3208, New Executive Office Building, Washington, DC 20503.
Sincerely,
Hugh L. Thompson, Jr., Director
Division of Licensing
Office of Nuclear Reactor Regulator
Enclosure:
QA Guidance
List of Generic Letters