Quality Assurance Guidance for ATWS Equipment That Is Not Safety-Related (Generic Letter 85-06)

                                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