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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 Conference in San Antonio , Texas. SCOPE. NQA – 1 An Historical Perspective NQA – 1 User Community Scope, Structure and Content

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nqa 1 quality assurance requirements for nuclear facility applications

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

scope
SCOPE
  • NQA – 1 An Historical Perspective
  • NQA – 1 User Community
  • Scope, Structure and Content
  • Basic, Supplements and Non-mandatory

Appendices

Slide 2

typical users
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 3

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

PRECURSOR DOCUMENTS FOR DEVELOPING QA REQUIREMENTS FOR NQA-1

Slide 4

slide5

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 )

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 for

Environmental Data

Collection and Environmental

Technology Programs )

RW-0333P

OCRWM-YMP

( Waste Repository QA

Program )

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.

Slide 5

slide6

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 Plants

N45.2.9-Requirements for Collection, Storage and Maintenance of Quality

Assurance Records

N45.2.10-Quality Assurance Terms and Definitions

N45.2.11-Quality Assurance Requirements for the Designof Nuclear Power Plants

N45.2.12-Requirements for Auditing of Quality assurance Programs for Nuclear

Power Plants

N45.2.13-Quality Assurance Requirements for Control of Procurement of

Items and Services for Nuclear Power Plants

N45.2.23-Qualification of Quality Assurance Program Audit Personnel for

Nuclear Power Plants

NQA-1-1994 WITH 1995(a) ADDENDA

QUALITY REQUIREMENTS for NUCLEAR

POWER FACILITY APPLICATIONS

slide7

QA AS ESTABLISHED BY

REGULATORY RULEMAKING

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.

Slide 7

slide8

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 8

other daughter standards
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 9

nqa structure
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 10

developmental milestones
DEVELOPMENTAL MILESTONES
  • Performance Based vs. Compliance
  • Graded Approach
  • Risk Informed

Slide 11

performance based initiative 1993 san diego task force formed
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 12

performance based continued
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 13

slide14

PERSPECTIVE ON MISSION

Nuclear Regulatory Commission

Nuclear Industry

  • SAFETY
  • CONSERVATISM
  • COMPLIANCE
  • PAPER TRAIL
  • LICENSABLE
  • LICENSABLE
  • SAFETY
  • FUNCTIONALITY
  • RELIABILITY
  • COMPLIANCE

1993-NQA Committee

Performance Based Initiative

VERIFICATION OF

COMPLIANCE

ATTAINMENT OF SAFETY

AND RELIABILITY

FOCUS

Slide 14

nqa1.history.4.

future nqa applications
FUTURE NQA APPLICATIONS
  • Advanced & Generation IV Reactors
  • Fuel Production Facilities
  • Thermonuclear Power Projects

Slide 15

nqa committee

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 ProgramManagement Processes

SC on Interface and Administration

functions
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 17

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

Slide 18

nqa 1 quality assurance requirements for nuclear facility applications19

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

THINGS YOU WONT FIND IN NQA-1

HELPFUL QA SURVIVAL HINTS

audit strategies
AUDIT STRATEGIES
  • 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!

Slide 21

audit management
AUDIT MANAGEMENT
  • 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”

Slide 22

slide23

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

Slide 23

slide24

Investigate

Plan New Approach

Resume

Investigation

Implement

New Approach

Degrade to

Original Practice

Measure

Improvement

Modify New

Approach

Find Any

Non-Improvement

DEVELOPMENT DANGER - THE IMPROVEMENT DEATH SPIRAL

Slide 24