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
• NQA – 1 An Historical Perspective
• NQA – 1 User Community
• Scope, Structure and Content
• Basic, Supplements and Non-mandatory
Appendices
Slide 2
TYPICAL USERS
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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
Slide 4
QUALITY RELATED REGULATIONS, RULES, ORDERS, CODES & STANDARDS
CIVILIAN NUCLEAR
DEPARTMENT OF ENERGY
ENVIRONMENTAL
10 CFR 50, Appendix B
( NRC Programmatic )
10CFR 830, Subpart A
( Nuclear – Programmatic )
EPA QA/R-2
( EPA Requirements for
Quality Management Plans )
10CFR50, Part 21
( Reporting Defects )
10CFR820, Appendix A
( Price Anderson)
10 CFR50.55
( Codes & Standards )
DOE O 414.A
( Quality Assurance )
R.G. 1.28
( NRC Adoption of
ANSI/ASME Standards)
ASME Section III
( BPVC – Nuclear )
ASME NQA-1
( Quality Program )
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- 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 )
Slide 5
COMM’L/INTERNATIONAL
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.
BRIEF HISTORY OF NQA-1
ANSI
ASME-American Society of Mechanical Engineers
N45.2 Quality Assurance Requirements for
Nuclear Power Plants
AIChE -American Institute of Chemical Engineers
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
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
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
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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
– 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
• Performance Based vs. Compliance
• Graded Approach
• Risk Informed
Slide 11
PERFORMANCE BASED INITIATIVE
1993 SAN DIEGO TASK FORCE FORMED
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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)
• 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
PERSPECTIVE ON MISSION
Nuclear Regulatory Commission
Nuclear Industry
• SAFETY
• LICENSABLE
• CONSERVATISM
•SAFETY
• COMPLIANCE
• FUNCTIONALITY
• PAPER TRAIL
• RELIABILITY
• LICENSABLE
• COMPLIANCE
1993-NQA Committee
Performance Based Initiative
VERIFICATION OF
COMPLIANCE
nqa1.history.4.
FOCUS
Slide 14
ATTAINMENT OF SAFETY
AND RELIABILITY
FUTURE NQA APPLICATIONS
• Advanced & Generation IV Reactors
• Fuel Production Facilities
• Thermonuclear Power Projects
Slide 15
NQA COMMITTEE
Main Committee (35 Members)
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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
FUNCTIONS
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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
• 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 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
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
• 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
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
DEVELOPMENT DANGER - THE IMPROVEMENT DEATH SPIRAL
Investigate
Resume
Investigation
Plan New Approach
Implement
New Approach
Degrade to
Original Practice
Measure
Improvement
Modify New
Approach
Find Any
Non-Improvement
Slide 24