Chair’s Message | Jarrod Suire...

Inside This Issue

ENERGY & ENVIRONMENTAL DIVISIONNEWSLETTER

Chair’s Message | Jarrod Suire

E-Organizing Our Structure As part of its transformation efforts, ASQ has recently launched a new online community,

myASQ, to serve as a centralized location for quality professionals to interact with like-minded individuals. The platform, accessible at my.asq.org, offers a community where quality professionals can seamlessly connect, share, and learn. In addition, the new backend software structure allows for future growth as technology evolves.

Likewise, the organizational structure of ASQ is evolving as well. The processes and workflows instituted 20+ years ago must evolve to ensure we’re sustainable for the future. Our organizational structure is fundamentally shifting with the overarching goal to remove administrative tasks from member leaders, allowing those leaders to focus on adding value to the members they serve. While the flow of information and titles will change, what’s not changing is the service provided to members. Like every ASQ member, the board of directors and leadership at all levels recognize the need to improve service to our members and grow our organization.

During our careers, most of us have experienced organizational change in some form or fashion. Our goal within EED is to keep our members involved and continue to strive toward improved member value. You can read the latest ASQ Transformation FAQ here. I encourage everyone to stay informed, provide feedback, and get involved.

Jarrod Suire

Chair, ASQ Energy and Environmental Division

About the chair:

Jarrod Suire’s quality experience was molded during a 22-year Air Force career, during which he received an undergraduate degree from the University of Maryland and a graduate degree from Jones International University. After retiring as a Major, he joined the oil and gas industry in a variety of quality and management positions. Suire’s ASQ journey started in 2011, with his most recent position as EED treasurer.

SEPTEMBER 2018 | VOLUME 2, ISSUE 3

FEATURED ART ICLES :

STATUS OF REMEDIATION AND DECOMMISSIONING

ASQ/ANSI E5 QUALITY PROGRAM GUIDELINES FOR NONNUCLEAR POWER GENERATION FACILITIES

A QUALITY PERSPECTIVE ON CHANGE, CONTROLS, AND ASQ TRANSFORMATION

IF YOU BUILD IT, IT WILL CORRODE

INTRODUCTION TO LAWS, REGULATIONS, AND STANDARDS FOR NUCLEAR POWER GENERATION IN CHINA

CHANGES IN REQUIREMENT 2 AND REQUIREMENT 18 OF THE ASME NQA STANDARD

REDUCING ENERGY THROUGH BEHAVIOR CHANGE REQUIRES MULTI-PRONGED APPROACH

NATURAL GAS QUALITY STANDARDS ADJUST TO NEW SUPPLY AND DEMAND

COMMERCIAL GRADE DEDICATION FOR ITEMS IN NUCLEAR SAFETY APPLICATIONS

WORKING TOWARD SECURING THE NUCLEAR ADVANCED MANUFACTURING SUPPLY CHAIN

QUALITY MANAGEMENT 4.0 FOR BOTH PHYSICAL AND DIGITAL NUCLEAR POWER PLANT

http://my.asq.org

https://my.asq.org/files/440

ENERGY & ENVIRONMENTAL DIVISION | SUMMER/FALL 20182

Status of Remediation and Decommissioning

Author

Tom Koepp is a mechanical engineer with 45 years of experience with the Department of Energy (DoE) and private industry in the areas of quality assurance management/engineering, project management, and environmental remedia-tion/D&D. Koepp is the current vice chair for the Energy and Environmental Division (EED).

The EED Remediation and Decommissioning Committee has been tracking the status of the environmental cleanup located in Oak Ridge, TN, one of three major cleanup operations that hit several milestones in 2017, with more ahead. It is currently unclear how the recent Oak Ridge Environmental Management (OREM) major budget request reductions will be distributed, resulting in major slowdowns or even stopping operations among the accounts (East Tennessee Technology Park [ETTP], Y-12 National Security Complex, and Oak Ridge National Laboratory [ORNL]). These budget request reductions are funded out of two different

accounts, with a third dedicated to historic preservation activities at the East Technology Park, as cleanup wraps up at one site and intensifies at the others.

East Tennessee Technology Park

The status of the East Tennessee Technology Park (ETTP), which was the

original K-25 uranium enrichment plant, was previously reported in the January 2017 EED newsletter. K-25 was one of five gaseous diffusion buildings on the site. Last year contractors tore out the slab of K-27, the last one to come down at ETTP.

At ETTP, contractors also demolished a cooling tower and pump house that were part of a group of highly contaminated structures called the Poplar Creek Facilities.

Most of the ETTP tie lines that enabled transport of enriched uranium throughout the site have been removed.

Energy & Environmental Division Newsletter


Demolition of the ETTP site’s electricity support structures generated enough recyclable metal to offset $115,000 of the $3.8 million project’s cost and the removal of an old sanitary treatment facility at the park is well underway.

Deactivation at ETTP K-1037 is underway, and crews are removing asbestos and preparing hazardous chemicals present in the building for disposal. Cleanup work at ETTP is quickly wrapping up. The Oak Ridge cleanup contractor is slated to finish cleaning up the ETTP and turn it over to the city for commercial use by 2020.

Y-12 National Security Complex

As work at ETTP comes to an end, OREM plans to transition its resources to Y-12 National Security Complex’s excess contami-nated buildings.

Site preparation has begun for the Mercury Treatment Facility that will prevent contamination released by demolition on the site from entering the waterways. DoE is seeking a contractor to construct it and another to clean up and tear down Y-12 buildings.

OREM retrieved more than 2,000 pounds of mercury from the site last year when it cleaned out column exchange equipment connected with Alpha-4, one of the uranium separation buildings that is slated for demolition.

The demolition contract will cost $2 billion and $55 billion over 10 years. It also includes construction of a new low-level waste landfill near the site and transuranic waste processing at ORNL.

Oak Ridge National Laboratory

Costly cleanup maintenance and surveillance work continues at ORNL, where contamination from reactor experiments and enriched uranium storage is still present.

Contractor crews are removing asbestos in the laboratory’s homogenous reactor experiment building, the home of one of a few successful experimental reactors DoE passed in favor of water-cooled reactors in the 1960s.

Another one was the Molten Salt Reactor Experiment, a liquid-fueled, graphite moderated test reactor.

The Office of Environmental Management is considering entombing the reactor’s core in concrete to reduce the cost of cleaning it up.

OREM also stabilized the remaining hot cells in a radioisotope laboratory that was used during the Manhattan Project. Hot cells are heavily shielded rooms where scientists can perform research on radioactive materials.

Workers installed material to protect the cells from rain and poured concrete over previously demolished cells to contain surface contamination.

Contractor crews also treated hot cell ports at the Source Development Laboratory, which worked with radioactive cobalt and iridium isotopes in the mid-20th century.

Last year, OREM completed uranium 233 disposition at ORNL, eliminating more than 1,000 containers of highly enriched uranium that were left over from a project to solidify and store uranium from New York’s defunct Indian Point 1 Reactor.

The remaining uranium inventory at ORNL is stored in building 3019, the oldest operating nuclear facility in the world. The Office of Science transferred the building across from it to OREM last year to be used to down-blend the remaining uranium stores, making its transport much less difficult. A contract modification to allow a third-party medical company to extract thorium from the existing uranium for cancer research should speed things along, too. The sooner the thorium is removed, the buildings that house it can be demolished.


ASQ/ANSI E5 Quality Program Guidelines for Nonnuclear Power Generation Facilities

Author

Chuck Moseley is ASQ Standards Board vice chair and EED standards chair. He can be reached at [email protected].

The Energy and Environmental Division Standards Committee submitted a new work item proposal (NWIP) to the ASQ Standards Board in April 2018.

The title for the proposed new standard is ASQ/ANSI E5 Quality Program Guidelines for Nonnuclear Power Generation Facilities.

This standard will provide principles and practices that address the definition, attainment, verification, and validation of the quality of a non-nuclear power facility’s design, construction, operations, and main-tenance. It will address a facility’s design; construction, and installation of equipment; operations and maintenance; public and employee safety and health; emergency preparedness and response; environmental protection; and security.

Economic growth necessitates the design and construction of new fossil and renewables (non-nuclear) electricity generation facilities. This standard will provide current guidance for these activities.

A working group has been formed with co-chairs Ben Marguglio and Greg Lily. ([email protected]; [email protected])

The project has industry support as evidenced by 17 quality professionals partic-ipating in the revision effort. A representative balance of interests has been achieved on the working group.

This new document will replace E1-1996 ANSI/ASQC, Quality Program Guidelines for Project Phase of Nonnuclear Power Genera-tion Facilities, which was withdrawn in 2006, and ANSI/ASQC E3, Quality Guidelines for Commercial Operations Phase of Nonnuclear Power Facilities, which was approved but never published in the mid-1990s.

The NWIP was approved ahead of schedule in May 2018. The new standard is scheduled to follow the ANSI-approved development, review, and comment resolution process, culminating in publishing by Quality Press in late 2019.

Guidelines for a Robust Safety CultureEED is affiliated with the Center for Offshore Safety (COS), which recently published Guidelines for a Robust Safety Culture. This document is available on the COS website http://www.centerforoffshoresafety.org. This document is provided to you as a benefit of your EED membership. Please contact Ben Marguglio, [email protected], for additional information.

mailto:[email protected]



http://www.centerforoffshoresafety.org



A Quality Perspective on Change, Controls, and ASQ Transformation

Author

Jeffrey Worthington is an ASQ EED member at large and ASQ Fellow.

Change and Control

After 30+ years as a quality professional, my most memorable quality epiphany was realizing almost every professional meeting I attended was about change or control or both. Sometimes the meetings may have addressed control of changes or changing

controls, e.g., a typical project status meeting addressed project controls or project changes.

One epiphany can change your world view. I recog-nized many past quality successes had resulted from leading change. I had functioned as an active change agent for two decades and had never studied the change body of knowledge. Some peers

have told me change topics were often presented during ASQ conferences and programs. I don’t remember the presentations; I mostly remember the oft-repeated quality lesson: You must garner senior management support for the quality program. I now translate the lesson as: Quality managers need to ensure that senior manage-ment understands and supports the changes needed and takes required actions to demonstrate their support for quality systems.

Governance and Change

Most governance processes for federal, state, and local govern-ment are about change and controls. Every politician’s platform



addresses things they want to change. Usually, the anticipated change would be accomplished by changing controls, strengthening controls, establishing new controls, or abolishing controls. In gov-ernance, controls take the form of laws, regulations, processes, procedures, etc.

ASQ and ASQ Changes

ASQ, likewise, has governance processes. Many ASQ division and technical community meetings I attended addressed change or control. Organizations—both businesses and member organiza-tions—are in constant change, whether the changes are organized or not. As a member of ASQ (formerly ASQC) since 1986, I witnessed many Society changes—some changes more memorable than others.

ASQ change example 1: ASQ dropped the term control from the Society name in 1997, maybe to placate those who confused actual controls with “controlling.” Certainly, no one likes to be controlled. We (quality professionals) hear the same fear about the term audit. Much better to be the subject of a review or survey. Early in my quality career, I grew to look forward to audits, especially from outside parties, because I could often get free information about quality program status.

ASQ change example 2: Several years ago, ASQ refocused a certification and I magically transformed from an ASQ Certified Quality Manager (CQM) to an ASQ Certified Manager of Quality/Organizational Excellence (CMQ/OE). I had not studied organizational excellence; however, in my work I had aligned quality

program processes with performance and excellence measures.

ASQ change example 3: Another notable Society change was transforming the annual World Quality Congress (AQC) to the World Conference on Quality and Improvement (WCQI). Nevermind that improvement is inherent in quality, unless you missed Quality 101, Lesson 1: the plan-do-check-act (PDCA) cycle.

ASQ change example 4: One memorable Society change was the acceptance of an external change. ASQ tacitly accepted NIST’s changes to the Malcolm Baldrige National Quality Award (MBNQA) program. NIST now refers to the program as the Baldrige Performance Excellence Program; the term quality has either been mostly removed or replaced in criteria documents with the term performance, although the award is still deemed a quality award.

ASQ Governance, Controls, and Change Leadership

ASQ has extensive governance. ASQ governance takes the form of various controls, which are the bylaws, proce-dures, and other governing documents. Some members who expressed concerns about the recent proposed Society transformation cited Society controls and the apparent disregard for their implemen-tation. Interestingly enough, some Society controls are intended to address the Society change process.

Change is always a process, and structured change can be cast as a project with a beginning, middle, and end. For those who study the subject, change often requires:

• Leadership

• Planning

• Management

• Stewardship

• Enablement

• Reporting

ASQ has given some thought to change leadership. Former ASQ board member Steve Wilson once told me he had brought Federal Office of Personnel Management (OPM) Executive Corps Qualifications (ECQ) criteria to ASQ for discussion as a leadership model for the Society. The first of the five ECQs is “leading change.”

ECQ “leading change” definition: This core qualification involves the ability to bring about strategic change, both within and outside the organization, to meet organizational goals. Inherent to this ECQ is the ability to establish an organizational vision and to implement it in a continuously changing environment.

OPM ECQ features of leading change include:

• Creativity and Innovation: Develops new insights into situations; questions conventional approaches; encourages new ideas and innovations; designs and implements new or cutting-edge programs/processes.

• External Awareness: Understands and keeps up to date on local, national, and international policies and trends that affect the organization and shape stakeholders’ views; is aware of the organization’s impact on the external environment.

• Flexibility: Is open to change and new information; rapidly adapts to new



information, changing conditions, or unexpected obstacles.

• Resilience: Deals effectively with pressure; remains optimistic and per-sistent, even under adversity. Recovers quickly from setbacks.

• Strategic Thinking: Formulates objec-tives and priorities; implements plans consistent with the long-term interests of the organization in a global environ-ment. Capitalizes on opportunities and manages risks.

• Vision: Takes a long-term view and builds a shared vision with others; acts as a catalyst for organizational change. Influences others to translate vision into action.

I am grateful for the service of all ASQ board of directors (BoD) members both current and past, and for their many hours of free time spent as unpaid volunteers. If they find the additional time to address any change leadership criteria suggested above, I am more grateful.

Change and Control for Future ASQ Success

Change leadership and effective member organization controls are vital to continued ASQ success. All members expect the Society to change, to strengthen, and to improve. The ASQ BoD and other member leaders, ASQ staff, and ASQ members may need to consider the following quality, change, and control factors as any restructuring occurs:

• Change leadership

– Am I a part of leading this change?

– Do I know what actions and skills constitute change leadership?

– What are my responsibilities as a change leader?

• Change planning

– Who is responsible for change planning?

– Do I know what actions and skills constitute successful change planning?

– How does the transformation align with ASQ’s strategic objectives?

– What options do I need to take into account while planning change?

– Who needs to be involved in planning the change?

– Should a formal change plan be developed? Who writes the plan? Who approves the plan?

– Does planning include specific: benefit analysis, cost analysis, an anticipated schedule, measures of completion, and measures of benefits success?

• Change management

– Who is responsible for managing the change?

– Do I know what actions and skills constitute successful change management?

– How will change progress be tracked and reported?

– How will change success be tracked and reported?

• Change enablement

– Should ASQ address change enablement processes?

– Who is responsible for enabling change for ASQ staff?

– Who is responsible for enabling change for ASQ members?

– Do I know what actions and skills con-stitute successful change enablement?

Applying Change and Controls to the Proposed ASQ TransformationIn November 2017, the ASQ BoD approved a TCC transformation structure. According to the initial TCC announce-ment, key factors and benefits included:

• The transformed Technical Communities will have increased access (both in person and virtually) to resources, talents, and skills across ASQ members (individual and organizational), member leaders, and ASQ staff through consoli-dation and resources.

• Technical Communities will continue to expand on ASQ’s mission to increase the use and impact of quality in response to the evolving needs of the world.

The resolution language provided for:

• Revoking and removing policies regarding member unit establishment and dissolution.

• Evolving the current divisions and Technical Communities into established Technical Communities operating under the Technical Communities Council into established virtual technical units operating under three market segments.

• The transfer of the reserved and general funds of current divisions and Technical Communities into a centralized BoD-con-trolled reserve fund.

The ASQ BoD and other member leaders, ASQ staff, and ASQ members may need to consider the following quality, change, and control factors:



• Quality planning

– Does the scope of ASQ quality planning address transformation (i.e., change)?

– Is ASQ quality planning addressed in the transformation?

– How is ASQ quality planning and transformation aligned?

– Is ASQ quality planning an ASQ “control”? How does this control interact and align with other related ASQ controls?

• Controls and change

– What controls does ASQ have in place for transformation (i.e., change)?

– Is ASQ implementing the controls?

– What are the related controls ASQ must address during transformation?

– Is ASQ addressing controls during the transformation process?

– What specific controls is ASQ implementing during the transfor-mation process? Spending controls? Reporting controls?

– As a result of transformation, will any ASQ controls be: strength-ened, improved, revised, removed, or developed?

– Does ASQ know if all ASQ controls currently in place for all ASQ operations are being implemented? If not, does this need to be addressed in the transformation?

ConclusionASQ, a member organization, is composed of a large body of quality and management professionals, many with extremely high levels of expertise in quality, management, change, improvement, controls, and performance. ASQ is also staffed with experienced member organization leaders. The strength of ASQ lies in its inclusiveness and openness to new ideas. Together, they should be able to demonstrate to the world ASQ continues to be the best member organization in the world, serves its members best, and maintains and shares the best Quality Body of Knowledge (QBOK). ASQ should continue to do so by 1) ensuring that any restructuring are active pillars of the Society supported by the members and 2) demonstrating expertise in leading, planning, and managing effective change.

Why Become an EED VolunteerWe are always looking for interested professionals to share their leadership, organizational, and technical skills. Please consider volunteering and be sure to keep your ASQ and EED membership current.

If you have any questions about how to get involved or would like to volunteer, please contact Abhijit Sengupta by phone or at [email protected] and attach your résumé.

Being an ASQ member provides you with benefits you cannot get elsewhere: Quality Progress magazine, a members-only website, The Insider, career assistance, member discounts on valuable ASQ resources like training, Quality Press books, professional quality certification, technical journals, and more. Renewing your membership as soon as possible will ensure the continued unbroken delivery of these valuable ASQ benefits.

I hope you will also elect to rejoin EED. Being a member of EED provides access to energy and environ-mental sector-specific quality information, EED lead-ership opportunities, conferences, job opportunities, and publications—just a partial list of member value we provide. Another key benefit of EED membership is access to a vast array of quality resources through the ASQ EED and LinkedIn websites. If you have not had the opportunity to participate, here’s what’s currently happening with EED:

• Our 1,700+ member website is also a great place to post questions, share project updates, and discuss best practices. Join the conversation!

• Go to asq.org/ee for further information about EED.

mailto:sengupta%40hotmail.com?subject=ASQ%20EED%20opportunities

http://asq.org/ee


If You Build It, It Will Corrode: Corrosion and Corrosion Control in Light Water Reactors (LWRs)

Author

Barry Gordon has consulted on various light water reactor (LWR) corrosion and material issues for more than 50 years with special emphasis on stress corrosion cracking (SCC). He has addressed numerous materials and corrosion problems in the LWR industry over a wide range of subjects including reactor internals, piping, fuel hardware, water chemistry transients, repairs, crack growth rate modeling, alloy selection, failure analysis, license renewal, NRC inspection relief, decon-tamination, etc. He has over 75 peer-reviewed publications and four LWR-related patents.

Gordon has served as an expert witness testifying before the Advisory Committee on Reactor Safeguards and Atomic Safety Licensing Board. He also chaired and co-authored “Corrosion in the Nuclear Power Industry” for ASM Handbook, Volume 13C (2006) and prepared a chapter on BWR IGSCC for Woodhead Publishing (2012). He also taught a 32-hour “Corrosion and Corrosion Control in LWRs” class at the U.S. Nuclear Regulatory Commission (NRC). Gordon has been the Structural Integrity Associates program manager and/or co-author of over 35 Electric Power Research Institute (EPRI)-sponsored programs and reports. He is a NACE International Fellow and corrosion specialist. He can be reached at [email protected].

Introduction

Serious corrosion problems that have plagued the light water reactor (LWR) industry for decades.1 The complex corrosion mechanisms

involved and the develop-ment of practical engi-neering solutions for their mitigation will be discussed with emphasis intergranular stress corrosion cracking (IGSCC) in boiling water reactors (BWRs) and pressur-ized water reactors (PWRs). Finally, the corrosion future of LWRs will be discussed as plants extend their period of operation for an additional 20 to 40 years.

Although corrosion was somewhat considered in both plant designs, corrosion was not considered as a serious concern. Their major concern was general corrosion and it was well known at the time of LWR design and construction that the primary structural materials used in the fabrication of the nuclear steam supply system (NSSS), i.e., stainless steels and nickel-based alloys, were characterized by very low general corrosion rates in high- temperature, high-purity LWR-type environments. The problem was that the “qualifying” laboratory tests did not necessarily reproduce the reactor operating conditions (e.g., especially the high residual tensile stresses from welding and cold work) and the test times were




of short duration relative to the initial plant design lifetime of 40 years, which is currently being extended to 60 to 80 years.

The initial operation of the early commercial light water reactors encountered few corrosion problems. Any problems were quickly repaired and did not have a major impact on plant availability. As more plants entered service and more operating time was accumulated on existing plants, more corrosion-related incidents appeared in the piping, reactor internals, and other components such as containment. Eventually, the corrosion of the plant and fuel materials did seriously impact plant availabil-ity, economics, reliability, and, in some cases, plant safety.

IGSCC in LWRs

IGSCC has been observed in various BWR and PWR structural components over the last 40+ years due to the simultaneous interactions of specific susceptible material, environmental, and tensile stress conditions, Figure 1.

For the BWR, the initiation of IGSCC of austenitic stainless steel and nickel-base alloys occurs when the following necessary fundamental conditions are simultaneously present: 1) chromium

depleted zone at the grain boundary in weld heat affected zones (HAZs) due to chromium carbide (Cr23C6) precipitation, i.e., “sensitization”, 2) tensile stress greater than the at tempera-ture yield stress (e.g., ~140 MPa at 288°C [550°F] for Type 304 stainless steel) and 3) high temperature (>93°C [200°F]) water where the corrosion potential of the stainless steel in the coolant is >-230 mV(SHE). For the PWR, the initiation of IGSCC of nickel-base alloys (e.g., Alloys 600, 182, and 82), and austenitic stainless steel occurs by a different mechanism, i.e., internal oxidation.

The mitigation of IGSCC in LWRs follows the path laid out by the Venn diagram, Figure 1. That is, utilize more sensitiza-tion-resistant stainless steels (e.g., Type 316NG stainless steel) in BWRs and more internal oxidation-resistant higher chromium alloys (e.g., Alloys 690, 152, and 52) in PWRs. Assemble LWRs with techniques that minimize tensile stresses and apply water jet or laser peening to induce compressive stresses in reactor internals. Relative to the environment, reduce the oxidizing power of the BWR environment by the addition of hydrogen and catalyst Pt while increasing the dissolved hydrogen and adding zinc in the PWR coolant.

Corrosion in LWRs Summary and Future Considerations

LWRs have suffered through a variety of corrosion problems aside from IGSCC over their history, and corrosion concerns will continue to have a dramatic impact on plant performance in plants that are undergoing license renewal for an additional 20 or 40 years. While the new plants under construction utilize more corrosion-resistant alloys, better welding techniques, and improved water chemistry, it is doubtful that corrosion concerns will be completely mitigated, for time is a great innovator of degradation.

Finally, it has been argued that because of defense-in depth design and operating features, materials degradation issues such as SCC of piping and core internals in current BWR and PWR designs do not increase significantly a plant’s baseline core damage frequency (CDF) or large energy release frequency (LERF).2,3 However, there is no question that such failures have a marked negative impact on both the economy of plant operation and the public perception of nuclear reactor safety. Thus, the resolution of such problems is essential,

Tensilestress

Susceptiblematerial

Corrosiveenvironment

SCC

Figure 1. Venn Diagram for Stress Corrosion Cracking



especially with changes in the plant’s licensing basis associated with, for example, life extension/license renewal and power up-rates that may affect corrosion susceptibility.

The corrosion challenges for the future will be governed by changes in operating and regulatory conditions.2 For instance, in the United States, there is a steady movement toward regulations that are not only performance-based, but also risk- informed. This development emphasizes decision making that considers the relative importance of various maintenance, in- service inspection, and procurement activities, etc., in terms of their impact on plant safety (e.g., CDF, LERF) (U.S. NRC Reg. Guides 1.174, 1.175, 1.176, 1.177, and 1.178). To date, time-dependent materials degradation phenomena have not been included in the probabilistic risk assessments and the associated event trees and fault trees that address, for instance, either the accident initiation frequency or the reliability of components that play a role in subsequent accident mitigation. Thus, the near-term challenge in materials-degradation technology is to extend the current deterministic and mechanisms-informed understanding of the cracking phenomena to cover the uncertainties associated

with the random crack initiation processes, and the uncertainties associated with the propagation rate data and models.

A further operational driver that presents challenges is the constant desire for longer fuel cycles and the resultant increase in time between component inspections and over 60 years of plant operation.2 This puts a premium on defining the kinetics of damage accumulation and the development of inspection techniques that have adequate resolution and probability of detection capabilities for the particular system at risk.

References1. B. M. Gordon, “Corrosion and Corrosion Control in Light Water Reactors,” Journal of Metals, Volume 65, Issue 8, August 2013, p. 1,043.

2. F. P. Ford, B. M. Gordon, and R. M. Horn, “Intergranular Stress Corrosion Cracking (IGSCC) in Boiling Water Reactor (BWRs),” Nuclear Corrosion Science and Engineering, Ed. Damien Féron, Woodhead Publishing, Abington Hall, Abington, Cambridge, 2012, p. 548.

3. D. G. Ware, et al. “Evaluation of Risk Associated with Intergranular Stress Corrosion Cracking in Boiling Water Reactor Internals,” NUREG/CR-6677, INEEL/EXT-2000-00888, July, Rockville, MD, 2000.

ASQ EED Membership

MEMBERSHIP UPGRADE INFORMATIONSenior membership information is available at: asq.org/membership/individuals/senior Advancement to Senior member. The application merely requires just a few checked boxes, your signature, member number, and date.

Requirements for advancement are:

• ASQ Full member in good standing for one year• Have 10 years of active professional experience (up to four

years of this vocational requirement may be satisfied by graduation from a college, university, or similar institution)

• Meet any one of these professional criteria:• Currently hold an ASQ certification that requires recertifi-

cation• Have been a Senior member or comparable type in a

recognized professional organization• Have taught quality or related arts or sciences at an

accredited institution for at least two years

• Have conducted quality-related engineering, inspection or audit, or statistical work, or applied the methods and principles of quality on the job for at least two years

Advancement to Senior member is FREE!

Fellow nominations are available at: asq.org/members/account/fellow.html

Fellows elected by ASQ’s board of directors are recognized as having achieved professional distinction and pre-eminence in the technology, theory, education, application, or management of quality control. An ASQ Fellow must be nominated by an ASQ member unit or other ASQ Fellows, is elected by the board of directors, and must meet specified criteria.

http://asq.org/membership/individuals/senior

http://asq.org/members/account/fellow.html


Introduction to Laws, Regulations, and Standards for Nuclear Power Generation in China

Author

Ronald Post has 18 years of experience in the nuclear industry in quality programs, manufacturing, systems design, and instrumentation and control for nuclear applications. He is a Lead Auditor 10CFR50 Appendix B, ISO 9001, ISO 14001, HAF003, RCC-M, and a Six Sigma Black Belt. Post is a quality manager for Westinghouse Electric Company, Shanghai, China.

China has a growing nuclear generation sector that continues to have the support of the central government. The World Nuclear Association reports that as of May 2018, there are 38 power reactors operating in China with about 20 under construction or

planned for starting construction. This growth represents opportunities and challenges for suppliers to the sector and potential benefits and risks for nuclear power plant owners and operators around the world as the

Chinese nuclear industry and regulatory body influence will increase impacting the behavior of industry suppliers around the world. China has amassed the technologies from different major nuclear countries including Russia, Canada, France, and the United States, and has fuel fabrication facilities in Baotou capable of building fuel for each type.

The laws for the manufacturing or design of nuclear safety equipment require five years of experience at a location in China before foreign-owned nuclear suppliers can establish a local presence in the Chinese market supplying such equipment in-coun-try. Foreign companies can work directly with the Chinese utilities, and the licensing process HAF604 allows these companies to utilize the laws of the home country for the supplier as an export

National People’sCongress Laws

Decrees andregulations

NURGS, regulatoryguidance ...

Acts

Rules, guides,referencedocuments

Code of FederalRegulationsSection 10 – Energy

State’s councils

Congress

Commissions andagencies

(Nuclear RegulatoryCommission: NRC)Departments

(National Nuclear SafetyAdministration: NNSA)

United StatesChina

Figure 1. Government Structure, Laws, And Regulations: China vs. United States



and import process. A challenge for many foreign companies, especially those that are U.S. based, is the export (from the U.S.) and import (to China) controls. The export controls restrict the flow of technology and the import controls limit importing electronics and many other manufactured items. China is still primarily an importer of nuclear technology, but with the potential opportunities in countries like Saudi Arabia, Turkey, England, and India, it is just a matter of a few years before Chinese companies are a major competitor in the world market.

For companies wanting to be part of the nuclear business in China, one of the first tasks is to become familiar with the government structure, laws, and regulations. Fortunately, the government publishes a report once every three years, with the latest being “The Seventh National Report Under the Conven-tion on Nuclear Safety (2013-2015),” published in June 2016. It describes the hierarchy of the nuclear safety laws, structure of the regulatory councils and departments, and responsibilities for the industry along with some history and basis.

The National People’s Congress establishes the laws in China, similar to how the U.S. Congress establishes laws in the United States. The State Councils are established by the laws of the National People’s Congress, which establishes departments such as the National Nuclear Safety Administration, which oversees commercial nuclear power in China. The Decree of State Council (Number 500) was established for commercial nuclear power providing the high-level requirements. (See figure on page 12.)

Decree 500 Regulation on the Supervision and Management of Civil Nuclear Safety Equipment

The current revision of Decree 500 became effective on January 1, 2008, and was updated in 2016. This regulation has two primary purposes: It establishes the requirements for licensing for the design, fabrication, installation, or nondestructive testing of civil nuclear safety equipment and it lists what is considered civil nuclear safety equipment. The approach differs from the approach by the NRC, which defines the term “basic component” and expects designers and plant operators to designate what items meet that definition. Subcomponents of an item on the Decree 500 list require a graded approach

to quality depending on their importance as defined by the designer or plant operator, which differs from the flow of requirements in the United States for items defined as a basic component. There is no commercial dedication process in China because of this difference in approach, but the NNSA does expect an appropriate application of quality assurance for commercial items. The holders of the HAF601 or HAF604 licenses are accountable for flowing applicable requirements and determining acceptability of supplied items.

Licenses

There are four licenses defined for the design, fabrication, instal-lation, or nondestructive testing of civil nuclear safety equipment:

• HAF601: Supervision and Management Regulation on Civil Nuclear Safety Equipment Design, Manufacturing, Installa-tion, and NDE

• HAF602: Qualification Management on the Nondestructive Testing Personnel of Civilian Nuclear Safety Equipment

• HAF603: Qualification Management for Welding and Welding Operators of Civilian Nuclear Safety Equipment

• HAF604: Provisions for the Supervision and Administration of Imported Civil Nuclear Safety Equipment

Plant operators and companies in China performing activities that require a license for manufacturing or design activities utilize the HAF601 process, which may include the scope of HAF602 and HAF603 licenses. For companies based outside of China, the HAF604 license is required to supply similar items, and this license also may include the scope of HAF602 and HAF603.

There are different approaches for quality programs for the HAF601 and HAF604 licenses. The HAF601 process implements the requirements of HAF003 “Safety Regulations for Quality Assurance of Nuclear Power Plants,” whereas HAF604 requires the company with the license to implement the approved quality program based upon regulations of the host country (e.g., 10CFR21 and 10CFR50 Appendix B). There are also two scopes for the HAF601 and HAF604 licenses: design and manufacturing. The NNSA has not approved mixing the licenses, e.g., HAF604 for design using a Chinese location, with a HAF601 license for manufacturing.



HAF003 Safety Regulations for Quality Assurance of Nuclear Power Plants

The regulation HAF003 is comparable to the US 10CFR50 Appendix B but does not have a one to one relationship. It incorporates some requirements from NQA-1 in addition to Appendix B, e.g., HAF003 section 1.1.4 defines that the primary responsibility for achieving quality in performing a particular task rests with those assigned the task and not with those seeking to ensure quality by means of verification, which does having a direct relationship to an Appendix B section but is in NQA-1 2008 section 201(b).

HAF003 10 CFR 50 Appendix B

General Introduction

02 Quality Assurance Program

II. Quality Assurance ProgramV. Instructions and Procedures

03 Organization I. Organization

04 Document Control VI. Document ControlIV. Procurement Document Control

05 Design Control III. Design Control

06 Procurement Control VII. Control of Purchased Material, Equipment, and Services

III. Design ControlXVIII. Audits

07 Control of Items VIII. Identification and Control of Materials, Parts, and Components

XI. Test ControlXII. Control of Measuring and Test

EquipmentXIII. Handling, Storage, and Shipping

08 Process Control IX. Control of Special Processes

09 Control of inspection and Test

X. InspectionXI. Test Control

10 Control of Nonconfor-mances

XV. Nonconforming Material, Parts, or Components

11 Corrective Actions XVI. Corrective Action

12 Records XVII. Records

13 Audits XVIII. Audits

HAF003 to 10CFR50 Appendix B comparison of sections

The regulation has other areas where there are differences, including:

• Defining the concept of “effective management” for all functions of an organization

• Specific additions of scope such as decommissioning

• The regulation does not require the use of a specific language but requires a language to be used for which the persons performing the activity shall have significant knowledge. This is important when considering HAF604 licenses as proce-dures or documents might be in Mandarin, English, French, Russian, or other local language.

• The requirements for clear interfaces between organizations must be defined in written form

• Training has a stronger focus

• Maintenance of items is clarified to include items in storage

• Includes all processes, not just special processes, when discussing requirements

• Requires the establishment of a baseline for expected performance of an item

• Requirements for disposal of records

Like 10CFR50 Appendix B, there are supporting guides to assist with the implementation of quality program requirements like the concept of NQA-1, except they are published by the department and titled HAD003. There are 10 parts of the guide providing additional coverage for implementation of quality requirements. It is also common for utilities to require standards such as ASME, ESPN, RCC-M, and ISO 9001 when procuring items. While this is not clearly documented in the regulations, use of these standards is expected by the NNSA.

Summary

Supplying items in the Chinese commercial nuclear industry is not easy for a foreign company, and it takes long-term investment strategies, development of business relationships, and working with the NNSA to understand and meet expectations. The regulations and guides of China establish familiar rules for many international companies, often copied word for word in cooperation with other country regulatory bodies and establishing comparable protections like other countries around the world using commercial nuclear power. The few areas where there are differences will introduce significant risks and costs if not understood.

Providing commercial nuclear items to China or procuring from China are both possible. The growth of the industry in China means their laws and regulations will continue to have stronger market influence around the world and compete with U.S., Russian, Canadian, and French standards.


Changes in Requirement 2 Training and Qualification Requirements and Requirement 18 Audit Requirements Between the 2008 and 2017 editions of the American Society of Mechanical Engineers (ASME) Nuclear Quality Assurance (NQA) Standard

Authors

Daren Jensen (above) is quality assurance program manager at the Idaho National Laboratory and owner of Optimum Perfor-mance Solutions Consulting. He is an Exemplar Global- certified QMS Lead Auditor and Lean/Six Sigma Black Belt. He earned a master of science degree from the University of Idaho and a bachelor of science degree from Idaho State University.

Jensen serves as the chair for the ASME NQA-1 Applications Subcommittee, is a contributing member of the NQA-1 Main Committee, a member of the NQA-1 Executive Committee, a member of the NQA-1 International Subcommittee, a member of the DoE Quality Council, a member of the ASQ Technical Advisory Group (TAG) to ISO/PC 302, Guidelines for Auditing Man-agement Systems, a member of ASTM ISO/TC 85 Working Group, a member of the ASQ EED, and is the chair of the ASQ Intermountain Section.

(continued on next page)

This American Society of Mechanical Engineers (ASME) Nuclear Quality Assurance (NQA-1) standard is the only safety- and compliance-based QA standard in the United States that is accepted by NRC. Other QA standards are customer satisfaction based rather than safety based.

In an effort to continuously improve the NQA-1 standard, the NQA-1 Standards Committee reviews and revises the standard as necessary, but at least every two years provides the most up-to-date nuclear quality assurance standard to be used across the globe that provides cost-effective quality assurance practices that focus on safety and results.

With the focus on safety and results, the standard has established rigorous qualification requirements for planning and performance of nuclear quality assurance audits, and for personnel participat-ing and, in particular, leading these audits.

Organizations implementing the standard must ensure that the lead auditor and auditor(s) requirements established in requirement 2, and audit process requirements (planning, performing, reporting, and follow-up) in requirement 18, are rigorously adhered to.

The 2015 and 2017 editions of NQA-1 made some changes from the 2008 edition and the 2009 addenda. This paper addresses the changes made between the NQA-1-2008 and 2009 addenda and the NQA-1-2015 and 2017 editions regarding qualification or audit personnel and changes in the audit requirements.


The following paragraphs provide a summary of the changes between the NQA-1 standard editions captured in the table on p. 18. Although changes were made to the newer NQA-1 editions, the changes made do not have a significant impact on those implement-ing the standard because the changes were wording clarifications or movement of require-ments from one section to another or creating a new section from requirements deleted from an existing section. Therefore, there are basically no changes between the editions, merely word changes for clarification, movement of information from one location to another for clarification, or creating new sections with information deleted from a previous section for clarification purposes.

Requirement 2, Quality Assurance Program, 100 GeneralThe title of requirement 2, section 100 was changed from “Basic” to “General” in the NQA-1-2009 addenda, and this change continued through the 2015 and 2017 editions. In part, this change was made to align with the NQA-1 Interpretation QA12-007 (issued March 22, 2012). Individuals and entities were misinterpreting the NQA-1 standard to mean that they could use only the 100 sections (i.e., basic) of NQA-1 Part I and/or Part II and they would have a compliant NQA-1 program. The QA12-007 interpretation response clarified that this was not correct. The response stated: “The application of only section 100 by an implementing organization is insufficient to claim credit for implementing Part I or Part II of an NQA-1 based quality assurance program. It is also insufficient for an invoking organization to invoke only section 100 of Part I or Part II and expect results equivalent to specifying all of Parts I or II.” The section 100s represent the general material, which follows in the requirement of guidance.

A sentence specifying, “on-the-job training shall be used if direct hands-on applications or experience is needed to achieve and maintain proficiency” was added to requirement 2, section 202 in the 2008 edition. This sentence continued through the 2017 edition.

Therefore, there are no net impacts to imple-menters due to the changes to requirement 2, section 100.

Requirement 2, 301 Nondestructive Examination (NDE)A paragraph clarifying the American Society of Nondestructive Testing (ASNT) Recom-mended Practices or Standards provided acceptable qualification requirements for NDE personnel and that applicable codes and standards or design criteria controlling the qualification of NDE personnel were to be utilized to establish the applicable ASNT qualification requirements were added in the 2008 edition. This paragraph was worded to broaden the use of ASNT standards in general, rather than specifying only the use of SNT-TC-1A. This change allows for more national and international use of the NQA-1 standard.

This paragraph continued through the 2017 edition. Therefore, there are no changes to requirement 2, section 301 other than the word “section” was changed to “paragraph,” and therefore there are no net impacts to implementers.

Requirement 2, 303 Lead AuditorThe second sentence in the paragraph was changed to address sections 303.1 through 303.4 of requirement 2 only and eliminated reference to sections 303.5 and 303.6. A new sentence to the paragraph was added

Ron Schrotke is the owner and principal of Ron Schrotke, LLC. He has over 30 years of experience in quality and project management, engineer-ing, and organizational administration—with particular involvement in the National Laboratory and Department of Energy (DoE) area. Schrotke has been a member of the American Society of Mechanical Engineers (ASME) since 2000 and since 1987 has been an active participant on the ASME NQA-1 Committee on Nuclear Quality Assurance. He served as chair of the NQA-1 Main Committee from 2008–2014, and is currently the chair of the NQA-1 Main Committee, since July 2017. Schrotke is also a member of the ASME Board of Nuclear Codes and Standards (BNCS).



to clarify that lead auditors were to maintain their proficiency in accordance with requirement 2, section 303.5 and were to requalify in accordance with requirement 2, section 303.6.

A new paragraph was added in 2008 to allow for participation in assessments through review and acceptance by the certifying authority. The wording from the 2008 edition continued through the 2017 edition. Therefore, there are no net impacts to imple-menters due to the changes to requirement 2, 303.

Requirement 2, 305, Technical SpecialistA new paragraph was added in the 2008 edition for technical specialist qualification requirements. The wording from the 2008 edition continued through the 2017 edition. Therefore, there are no net impacts to implementers due to the changes to requirement 2, 305.

Requirement 2, 400 Records of QualificationNQA-1-2008 requirement 2, 400 (a) 1-3 remained unchanged in all editions. Requirement 2, 400 (a) 4 (including 4a, 4b, 4c), 5, 6, and 8 (including 8b) were eliminated from this section and are now addressed in NQA-1-2015 and NQA-1-2017 in new sections 401 Inspection and Test Personnel and 402 Lead Auditor Personnel. Requirement 2, 400 (a) 7 remains in requirement 2, 400 in NQA-1-2005 and NQA-1-2017 editions, but is now requirement 2, 400 (a) 4 and the words “who is responsible for such certification” were eliminated from the sentence because it is unnecessary for clarification, as it is clear that the designated person is the person who is responsible for the certifications.

Section 400 of requirement 2 was revised in NQA-1-2015 and NQA-1-2017 editions to clarify that in addition to the requirements specified in requirement 2, 400, the specific requirements for each qualification/certification that are to be certified in writing are now specified in the new paragraphs 401 and 402 of requirement 400.

NQA-1-2015 and NQA-1-2017 requirement 2, 401 and 402 now contain basically the same requirements that were previously in NQA-1-2008 requirement 2, 400 (a) 4 (including 4a, 4b, 4c), 5, 6, and 8 (including 8b). These requirements were moved to these two new paragraphs and the words or the requirements were revised slightly to make the requirements more clear to the user for what is required for inspection and test personnel and lead auditor

personnel. For requirement 402, audit participation and annual assessment or proficiency of maintenance of the qualification was also added as a requirement.

Implementers will need to review their NQA-1-2008/2009 addenda programs against the changes in the NQA-1-2015 and NQA-1-2017 editions to update their programs to reflect these clarifying changes made in requirement 2.

Requirement 18, 200 SchedulingA new paragraph was added to requirement 18, 200, regarding grace periods. Grace periods may now be applied to scheduled audits and annual evaluations of supplier performance. There is also a new requirement for scheduling the next activity if a grace period is used.

Within requirement 18, 200, two new sub-requirements were added to clarify audit requirements for Internal Audits (201) and External Audits (202). Requirement 201 internal audits now contains three sub-requirements that specify requirements for auditing intervals for (1) Nuclear Facilities Prior to Placing the Facility in Operation (201.1), (2) Nuclear Facilities After Placing the Facility into Operation (201.2.) and (3) Suppliers and Other Nuclear Support Organizations (201.3). Requirement 201 External Audits now specifies specific intervals for performing external audits (e.g., supplier audits).

The only other change in requirement 18 between the NQA-1-2008 and the NQA-1-2015/2017 editions is in requirement 600. The word “adverse” was removed from the paragraph wording regarding investigating audit findings. The word was removed to recognize the need for an audit to identify all findings, which includes positive findings (or results) as well as negative (or adverse) findings. Additionally, it is important for management to investigate all audit findings.

Implementers will need to review their NQA-1-2008/2009 addenda programs against the changes in the NQA-1-2015 and NQA-1-2017 editions to update their programs to reflect these clarifying changes made in requirement 18.

The table on p. 18 provides a more succinct picture of the changes to the requirements. For a copy of the table, contact Daren Jensen at [email protected] or Ron Schrotke at [email protected].





NQA-1-2008 NQA-1a-2009 NQA-1-2015 NQA-1-2017

300 QUALIFICATION REQUIREMENTS

300 QUALIFICATION REQUIREMENTSNo change



301 Nondestructive Examination (NDE)This section specifies requirements for the qualification of personnel who perform radiographic (RT), magnetic particle (MP), ultrasonic (UT), liquid penetrant (PT), electromag-netic (ET), neutron radio-graphic (NR), leak testing (LT), acoustic emission (AE), and visual testing (VT) to verify conformance to the specified requirements.

301 Nondestructive Examination (NDE) No change

301 Nondestructive Examination (NDE)No change other than the word “section” was changed to the word “paragraph”

301 Nondestructive Examination (NDE)No change other than the word “section” was changed to the word “paragraph”

302 Inspection and Test 302 Inspection and Test 302 Inspection and Test 302 Inspection and Test

No change No change No change

303 Lead Auditor 303 Lead Auditor 303 Lead Auditor 303 Lead Auditor

The lead auditor organizes and directs audits, reports audit findings, and evaluates corrective action.

No change No change No change

An individual shall meet the requirements of paras. 303.1 through 303.6 of this requirement prior to being designated a lead auditor.

No change An individual shall meet the requirements of paras. 303.1 through 303.4 of this requirement prior to being designated a lead auditor.

An individual shall meet the requirements of paras. 303.1 through 303.4 of this requirement prior to being designated a lead auditor.

Lead auditors shall maintain proficiency in accordance with the requirements of para. 303.5 or requalify in accordance with the requirements of para. 303.6, as applicable.

Lead auditors shall maintain proficiency in accordance with the requirements of para. 303.5 or requalify in accordance with the requirements of para. 303.6, as applicable.

303.1 Communication Skills 303.1 Communication SkillsNo change

303.1 Communication SkillsNo change

303.1 Communication SkillsNo change

303.2 Training 303.2 TrainingNo change

303.2 TrainingNo change

303.2 TrainingNo change

303.3 Audit Participation Prospective

303.3 Audit Participation No change

303.3 Audit ParticipationNo change

303.3 Audit ParticipationNo change

303.4 Examination 303.4 ExaminationNo change

303.4 ExaminationNo change

303.4 ExaminationNo change

303.5 Maintenance of Proficiency

303.5 Maintenance of ProficiencyNo change



303.6 Requalification 303.6 Requalification No change

303.6 RequalificationNo change

303.6 RequalificationNo change

304 Auditors 304 AuditorsNo change

304 AuditorsNo change

304 AuditorsNo change



305 Technical Specialists 305 Technical SpecialistsNo change

305 Technical SpecialistsNo change

305 Technical SpecialistsNo change

400 RECORDS OF QUALIFICATION

400 RECORDS OF QUALIFICATIONNo change



(4) basis of qualification No change (4) signature of employer’s designated representative

(4) signature of employer’s designated representative

In addition to the requirements above, specific requirements for each qualifica-tion/certification that are to be certified in writing are specified in paras. 401 and 402 of this requirement.

In addition to the requirements above, specific requirements for each qualifica-tion/certification that are to be certified in writing are specified in paras. 401 and 402 of this requirement.

401 Inspection and Test PersonnelAdditional requirements to those listed in para. 400 shall include the following:

401 Inspection and Test PersonnelAdditional requirements to those listed in para. 400 shall include the following:

(a) education (a) education

(b) work experience (b) work experience

(c) training (c) training

(d) demonstration of capabilities (d) demonstration of capabilities

(e) date of certification/recertification (e) date of certification/recertification

(f) any special physical requirements needed in the performance of each activity, including the need for initial and subse-quent physical examination

(f) any special physical requirements needed in the performance of each activity, including the need for initial and subse-quent physical examination

(g) certification expiration (g) certification expiration

402 Lead Auditor PersonnelAdditional requirements to those listed in para. 400 shall include the following:

402 Lead Auditor PersonnelAdditional requirements to those listed in para. 400 shall include the following:

(a) education (a) education

(b) work experience (b) work experience

(c) training (c) training

(d) audit participation (d) audit participation

(e) examination results (e) examination results

(f) date of certification/recertification (f) date of certification/recertification

(g) annual assessment of proficiency maintenance

(g) annual assessment of proficiency maintenance

500 RECORDS 500 RECORDSNo Change

500 RECORDS 500 RECORDS



REQUIREMENT 18Audits100 BASIC

REQUIREMENT 18Audits100 GENERAL



200 SCHEDULING 200 SCHEDULINGNo Change

200 SCHEDULING 200 SCHEDULING

A grace period of 90 days may be applied to scheduled audits and annual evaluations of supplier performance.

A grace period of 90 days may be applied to scheduled audits and annual evaluations of supplier performance.

When the grace period is used, the next scheduled date for the activity shall be based on the activity schedule date and not on the date the activity was actually performed.

When the grace period is used, the next scheduled date for the activity shall be based on the activity schedule date and not on the date the activity was actually performed.

If the activity is performed early, the next schedule date shall be based on the date the activity was actually performed.

If the activity is performed early, the next schedule date shall be based on the date the activity was actually performed.

201 Internal AuditsExcept where specific regulatory guidance exists or code restrictions apply, organi-zations shall audit internal activities at the following intervals.

201 Internal AuditsExcept where specific regulatory guidance exists or code restrictions apply, organi-zations shall audit internal activities at the following intervals.

201.1 Nuclear Facilities Prior to Placing the Facility Into OperationAll applicable quality assurance program elements shall be audited at least once each year or at least once during the life of the activity, whichever is shorter.

201.2 Nuclear Facilities After Placing the Facility Into OperationAll applicable quality assurance program elements for each functional area 1 shall be audited within a period of two years.

201.2 Nuclear Facilities After Placing the Facility Into OperationAll applicable quality assurance program elements for each functional area 1 shall be audited within a period of two years.

For well-established activities, the period may be extended one year at a time beyond the two-year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished.

For well-established activities, the period may be extended one year at a time beyond the two-year interval based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished.

However, the internal audit interval shall not exceed a maximum of four years.

However, the internal audit interval shall not exceed a maximum of four years.

201.3 Suppliers and Other Nuclear Support OrganizationsAll applicable quality assurance program elements shall be audited at least once each year or at least once during the life of the activity, whichever is shorter.

201.3 Suppliers and Other Nuclear Support OrganizationsAll applicable quality assurance program elements shall be audited at least once each year or at least once during the life of the activity, whichever is shorter.

This interval may be extended up to two years based on the results of an annual evaluation and objective evidence that the activities are being satisfactorily accom-plished in accordance with the applicable quality assurance program elements.

This interval may be extended up to two years based on the results of an annual evaluation and objective evidence that the activities are being satisfactorily accom-plished in accordance with the applicable quality assurance program elements.



202 External AuditsExternal audits (e.g., supplier audits) shall be performed on a triennial basis and supplemented by annual evaluations of the supplier’s performance to determine if the regular schedule audit frequency shall be maintained or decreased or if other corrective action is required.

202 External AuditsExternal audits (e.g., supplier audits) shall be performed on a triennial basis and supplemented by annual evaluations of the supplier’s performance to determine if the regular schedule audit frequency shall be maintained or decreased or if other corrective action is required.

A continuous or ongoing evaluation of the supplier’s performance may be conducted in lieu of the annual evaluations, provided that the results are reviewed in order to determine if corrective action is required.

A continuous or ongoing evaluation of the supplier’s performance may be conducted in lieu of the annual evaluations, provided that the results are reviewed in order to determine if corrective action is required.

300 PREPARATION 300 PREPARATION 300 PREPARATION 300 PREPARATION

301 Audit Plan 301 Audit PlanNo change

301 Audit PlanNo change

301 Audit PlanNo change

302 Personnel 302 PersonnelNo change

302 PersonnelNo change

302 PersonnelNo change

303 Selection of Audit Team 303 Selection of Audit TeamNo change

303 Selection of Audit TeamNo change

303 Selection of Audit TeamNo change

400 PERFORMANCE 400 PERFORMANCENo change

400 PERFORMANCENo change

400 PERFORMANCENo change

500 REPORTING 500 REPORTINGNo change

500 REPORTINGNo change

500 REPORTINGNo change

600 RESPONSEManagement of the audited organization or activity shall investigate adverse audit findings, schedule corrective action, including measures to prevent recurrence of sig-nificant conditions adverse to quality, and notify the appropriate organization in writing of action taken or planned.

600 RESPONSENo change

600 RESPONSENo change other than the word “adverse” was removed in 2015 and 2017.

600 RESPONSENo change other than the word “adverse” was removed in 2015 and 2017.

700 FOLLOW-UP ACTION 700 FOLLOW-UP ACTIONNo change

700 FOLLOW-UP ACTIONNo change

700 FOLLOW-UP ACTIONNo change

800 RECORDS 800 RECORDSNo change

800 RECORDSNo change

800 RECORDSNo change


Reducing Energy Through Behavior Change Requires Multi-Pronged Approach

Author

Brion Hurley is a Lean Six Sigma Master Black Belt at Business Performance Improvement in Portland, OR. He has been an ASQ member since 1998. He teaches lean and Six Sigma classes, facilitates workshops and events, performs statistical analyses, and mentors employees through improve-ment efforts. He is the author of Lean Six Sigma for Good: How improvement experts can help people in need, and help improve the environment.

When evaluating energy reduction ideas within your organiza-tion, employee behavior changes are usually the most cost- effective solutions. These require less approval from manage-ment, very little up-front investment, and can engage employees

in ongoing improvements.

However, getting actual behavior change to take effect can be difficult and frustrating to those leading the change, as many of us have experienced. Even though I’ve spent many years learning and implementing advanced statistical analysis and flow methodology into organizations, it’s the indi-vidual behavior change that has been some of the most challenging.

One approach I have found to make behavior changes more successful is the Six Sources of Influence model developed by VitalSmarts (Influencer Training, 2018). It’s a simple approach I’ve used to help get employees to follow the kanban system at work, as well as encourage local coffee drinkers to use reusable cups.

Instead of picking one or two solutions for a behavior change, the Influencer model suggests implementing at least four sources to greatly increase the chance that the behavior change will last in the long term.



The six sources of influence are:

1. Personal motivation

2. Personal ability

3. Social motivation

4. Social ability

5. Structural motivation

6. Structural ability

A simple matrix can be constructed, with each square representing the key theme of each source. Within each source, I’ve included the key question to answer for the person making the change.

Six Sources of Influence

Motivation Ability

Personal 1. Personal motivation – Do you want to make the change?

2. Personal ability – Do you know how to make the change?

Social 3. Social motivation – Do others encourage the change?

4. Social ability – Do others help you make the change?

Structural 5. Structural motivation – Does the environment encourage the change?

6. Structural ability – Does the environment support the change?

Let’s look at an example you might encounter at your facility, getting employees to shut off lights when they leave.

What Other Ideas Do You Have for Each Source of Influence?

There is no limit to the number of ideas you can generate. This is a great opportunity to utilize brainstorming with your teams to determine simple and cost-effective ways to change behavior.

Let’s assume the improvement teams review the brainstormed list under each source, and decide to implement the following ideas from sources 1, 2, 4, and 6:

• Source 1: Employee training on the cost and environmental impact of leaving the lights on, along with how electricity usage impacts the goals and finances of the company.

• Source 2: Employee training on how and where to turn off the lights.

• Source 4: Post the cell phone for security and facilities in case there are questions or the employee needs assistance.

• Source 6: Color-coded labels on electrical panel show each zone tied to each area of the building.

• Source 6: Sign added to exit door reminds employees to shut off lights before they leave.

By implementing at least one solution within four or more of these sources, the team will see a much bigger change in improvement than only implementing one or two of these ideas.

If you think back to past behavior changes you’ve tried to implement, you can probably think of more sources of influence that can be added to make the change more effective and longer lasting.

This approach is not only useful for reducing electricity, but can be used to help individuals:

• Visit the gym more frequently

• Eat healthier foods

• Floss more frequently

• Bike to work more often

• Wash their hands (watch the video at https://www.youtube.com/watch?v=osUwukXSd0k)

In summary, when you are making behavior changes, don’t be content with just one or two solutions. Evaluate the change against the six sources, and make sure you have at least one idea implemented in four or more sources to maximize the effectiveness of the change.

Reference: https://www.vitalsmarts.com/influencer-training

BEHAVIOR CHANGE: Make sure employees turn off the lights when they leave for the day.

Six Sources of Influence

Motivation Ability

Personal 1. Personal motivation– Employee training on the cost and environmental impact of leaving the lights on, along with how electricity usage impacts the goals and finances of the company.

2. Personal ability– Employee training on how and where to turn off the lights.

– Training is added to new hire training program.

Social 3. Social motivation– Employees remind each other to turn off the lights when they leave.

– Teams review the electricity metrics each week, discuss who was work-ing during the late shift, and provide feedback to those employees.

4. Social ability– Facilities engineer has regular meeting with late-shift employees to remind them and answer questions.

– Post the cell phone for security and facilities in case there are questions or the employee needs assistance.

Structural 5. Structural motivation– Electricity reports posted each week show light usage by hour.

– Electricity reduction goal of 5 percent across the facility, tied to employee bonus program.

6. Structural ability– Color-coded labels on electrical panel show each zone tied to each area of the building.

– Sign added to exit door reminds employees to shut off lights before they leave.

https://www.youtube.com/watch?v=osUwukXSd0k

https://www.vitalsmarts.com/influencer-training/


Natural Gas Quality Standards Adjust to New Supply and Demand

Author

James L. Gooding is managing director of Geoclime, LLC, providing quality and risk man-agement consulting for energy, water, science, and engineering. During multiple careers in government and industry, he worked as a research scientist, industry analyst, and a director of commercial services in electric power and natural gas businesses. He is an ASQ Senior member and Certified Manager of Quality/Organizational Excellence (CMQ/OE).

Multiple Quality Standards Are Still the Rule in Natural Gas

The issue of gas quality and interchangeability was last formally addressed in the United States in 2005.1 But since 2007, U.S. domestic production of natural gas from unconventional resources has created an extraordinary gas supply that has inspired new

sources of demand. The new supply sources, new demand sinks, and the pipeline network used to transport the gas have together entered a new cycle for reassessment of quality requirements for the natural gas commodity.

Although ISO 136862 and ASTM 19453 both

address how natural gas quality is measured, neither is used as the benchmark for defining acceptance criteria as stipulated by end users. Instead, each end user—gas utilities, manufacturing, electric power generation, or liquefied natural gas (LNG) pro-duction—specifies gas quality relative to the end user’s process and equipment requirements. As a consequence, multiple quality control points exist along the supply, transportation, and demand segments of the value chain (Figure 1).

Supply Transportation Demand

Coalbedmethane

well

Coalbedmethane

well

Land�ll/farm

biogas

Land�ll/farm

biogas

Oil wellOil well

Transmissionpipelines

Transmissionpipelines

Gas utilitiesGas utilities

ManufacturingManufacturing

Electric powergeneration

Electric powergeneration

Lique�ed naturalgas (LNG)production

Lique�ed naturalgas (LNG)production

Shalegas wellShale

gas well

Centralizedgas

processing

Local gasprocessing

Natural gasliquids(NGLs)

Local gasprocessing

Oil

Water

Water

Dry gas(high Btu)

Dry gas(low Btu)

Dry gas(low Btu)Rich gas

Rich gas

Figure 1. Quality Zones for Supply, Transporta-tion, and Demand in the Natural Gas Value Chain



Changes in U.S. Gas Supply, Demand, and Quality Guidelines

Data from the Energy Information Administration (EIA) show that in 2007, U.S. domestic gross production of natural gas—before processing to end-use quality requirements—was approximately 24.7 trillion cubic feet (Tcf), whereas end-use demand for gas (after processing) was 23.1 Tcf. In 2016 (the most recent year with complete data), gross production increased to 32.6 Tcf (32 percent growth from 2007) and end-user demand rose to 27.5 Tcf (18 percent growth).

From 2007 to 2016, shale gas wells became the dominant source of new gas, comprising 51 percent of all production. At the same time, residential and commercial gas demand declined and the dominant end users became electric power generation (40 percent of total demand) and industrial enter-prises (31 percent), including revitalized chemical manufactur-ing and production of LNG for export.

Many shale gas fields produce “rich gas” comprising methane with substantial amounts of heavier hydrocarbons (ethane, propane, butane, etc.) known as natural gas liquids (NGLs); ethane enrichment (commonly 10 to 20 percent or more by volume) is a notable change from pre-2007 gas streams (typically less than 5 percent). Although ethane is an ideal feedstock for ethylene manufacturing, processing to remove ethane from rich gas can be relatively costly and inefficient. As a result, ethane that is uneconomical as a stand-alone commodity usually is “rejected” by gas processing into the “dry gas” gas stream sent to transmission pipelines; however, high levels of ethane may not be acceptable to some end users.

Metrics for Baseline Gas Quality

Dry gas quality (suitable for end users after NGL removal) can include dozens of different specifications. But beyond rudimentary requirements that prohibit gross particulate contaminants or other physical debris, the core baseline parameters are as follows:

• Higher Heating Value (HHV) and Lower Heating Value (LHV) HHV is the gross thermochemical energy recoverable through complete combustion under standard conditions (60°F, 14.7 PSIA), including the condensation of any water vapor to

yield latent heat of condensation; LHV is the net combustion energy with water products remaining as vapor. Both HHV and LHV are conventionally expressed as British thermal units (Btu) per standard cubic foot of gas (Btu/scf). The HHV and LHV values for a hydrocarbon compound increase with the number of carbon atoms in the molecule; e.g., HHV/LHV values are 1,010/909 for methane, 1,770/1,619 for ethane, 2,516/2,315 for propane, and so forth.4 The aggregate HHV/LHV in a natural gas stream is a proportional composite of values for individual compounds. HHV/LHV specifications for dry gas are driven by capabilities/limitations of end-user processes or equipment and, also, in the case of LNG production, by limitations imposed by LNG buyers.

• Wobbe Index (WI) and Modified Wobbe Index (MWI) WI = HHV/(gs)0.5 where gs is the specific gravity of the gas relative to air at standard temperature and pressure. But in some applications, including gas turbines and manufactur-ing, fuel or feedstock gas may be preheated to a process temperature so that MWI = LHV/(gs · Tf)0.5 where Tf is the gas temperature (Rankine scale). Reliance on either WI or MWI in gas quality specifications depends on the end user.

• Limits on Minor Inorganic Components Inorganic gases of concern are nitrogen, carbon dioxide, hydrogen sulfide and sulfur dioxide. Nitrogen is a diluent that decreases HHV/LHV whereas carbon dioxide and the sulfur gases are agents of corrosion in the end-user process equipment. Accordingly, end-user quality specifications place strict upper limits on all of the aforementioned minor components.

Rethinking “Pipeline Quality” Gas and Customer Specifications

Transmission pipeline operators have historically served as the foundational gatekeepers of dry gas quality through tariffs—which include gas quality specification sheets—administered to all transportation customers who inject gas into a pipeline or withdraw gas from a pipeline.

The long-standing definition of “pipeline quality” gas has been:

“Raw natural gas from which impurities have been removed so that the natural gas meets the quality specifications of the pipeline transmission facility that will receive it for transportation to market.”5



Because shale gas now dominates supply and ethane-rich gas is common, gas suppliers have argued that pipelines should substantially raise their allowable upper limits for HHV/LHV and WI/MWI values of injected gas. But most gas pipeline operators have resisted large increases, citing concerns about NGL dropouts inside pipelines and adverse effects on system integrity.

Transmission pipeline operators can accept high HHV/LLV gas (also known as high-Btu gas) if they can effectively blend it with low HHV/LHV (low-Btu) gas—such as from coalbed methane or landfill/farm biogas. But coalbed methane and biogas can contain high concentrations of carbon dioxide—and biogas can contain sulfur gases—that are unacceptable to most end users. Accordingly, “pipeline quality” gas specifications remain a balancing act between what can be operationally managed after injection and what is acceptable to end users. The range of indicative end-user specifications is illustrated as follows:

• Gas Utilities. Individual companies set quality specifications that are driven largely by residential and commercial appliances. Although regional variations can occur, typical requirements are: HHV = 950-1,150 Btu/scf; WI = 1,279-1,400; carbon dioxide and nitrogen (combined), ≤ 4% vol.; hydrogen sulfide ≤4-16 ppmv.

• Manufacturing. Gas quality specifications depend on how the gas is used as a feedstock—such as for plastic, fertilizer, anti-freeze, fabrics, or other products. Some chemical manufac-turing can accommodate elevated HHV/LHV and WI/MWI values. In contrast, nitrogen fertilizer manufacturing prefers a nearly pure methane feedstock so that typical requirements are: LHV ≈ 910-930 Btu/scf (HHV ≈ 1,010-1,030); MWI ≈ 32-37; hydrogen sulfide ≤ 10 ppmv.

• Electric Power Generation. Gas-fired power generation utilizes high-speed turbines with fuel specifications made by the turbine manufacturers to validate warranties and working lifetimes. Typical gas requirements are: LHV ≈ 850-950 Btu/scf (HHV ≈ 950-1,050); MWI ≈ 40-50. Gas turbines are vulnerable to certain contaminants that might be tolerable by different end users; a notable example is siloxanes that

are common in landfill biogas6 but not always specified in pipeline tariffs.

• LNG Production. LNG production facilities are designed to make use of regionally available gas supplies; processes applied to high-Btu feedstock can be very different from those applied to leaner feedstock. For most U.S. LNG feedstock, the desire is for HHV ≈1,010-1,100 Btu/scf and WI ≈1,350-1,400 to achieve economical energy density while avoiding additional costs for NGL removal. Also, minimizing boil-off of the LNG product means that carbon dioxide and nitrogen concentrations must be low —ideally ≤ 1% vol. for each gas.

The large majority of end users favor performance-based guidance rather than prescriptive regulation of gas quality. Therefore, the establishment of a single, harmonized quality standard for U.S. natural gas is not expected anytime soon. Instead, it is likely that transmission pipelines will continue the challenge of moderating gas quality issues between suppliers and end users.

References1. “White Paper on Natural Gas Interchangeability and Non-Combus-tion End Use,” NGC+ Interchangeability Work Group, Federal Energy Regulatory Commission (FERC), February 28, 2005, p. 34.

2. ISO 13686:2013. Natural Gas—Quality designation, International Organization for Standardization (ISO), June 2013, p. 48.

3. ASTM D1945-14, Standard Test Method for Analysis of Natural Gas by Gas Chromatography, ASTM International, West Conshohocken, PA, 2014.

4. Table of Physical Constants for Hydrocarbons and Other Compounds of Interest to the Natural Gas Industry, GPA Standard 2145-03, Rev. 2 (07/07), Gas Processors Association (GPA), July 2007, p. 16.

5. “America’s Natural Gas Pipeline Network,” Interstate Natural Gas Association of America (INGAA), July 2009, p. 146.

6. Igoe, B. M. and Welch, M. J. (2015) “Impact of Fuel Contaminants on Gas Turbine Operation,” 15-IAGT-303, 21st Symposium of the Industrial Application of Gas Turbines Committee, Banff, Alberta, Canada, October 2015, p. 12.


Commercial Grade Dedication for Items in Nuclear Safety Applications

Authors

Karen Douglas* and Dr. Abhijit Sengupta**

*This report is provided for informational and educational purposes. The views expressed are those of Karen Douglas and not necessarily those of National Nuclear Safety Administration (NNSA) or U.S. government.

**This report is provided for informational and educational purposes. The views expressed are those of Dr. Abhijit Sengupta and not necessarily those of U.S. government.

Components essential to continued safe operation of commercial nuclear reactors may no longer be available from the initial supplier. Addressing this ongoing need when sources change is commercial grade dedication of items (CGID) in the domestic

commercial nuclear industry, which has been practiced since 1979, with commercial nuclear power plant guidance published in the late 1980s. The basis of CGID lies in the compli-ance of the CGI to the same criteria as the basic component according to the

Atomic Energy Act of 1954, and/or to the implementation of section 206 of the Energy Reorganization Act of 1974. CGID is applied to ensure that items for 10CFR50 commercial power (regulated by the U.S. Nuclear Regulatory Commission) or 10CFR830 defense (regulated by the U.S. Department of Energy) nuclear applications perform their intended function as expected, replacing or substituting for basic components (safety structures, systems, or components [definitions for selected regulatory terms appear at the end of this article]), which were both designed and fabricated under an approved 10CFR50/10CFR830 quality assurance program with adequate controls and documentation. In order to comply with 10CFR21, Reporting of Defects and



Noncompliance, all commercial-grade items shall be dedicated prior to their use in safety-related applications. Safety structures, systems, and components procured as CGID for installation are also controlled internationally with standards established and controlled by the International Atomic Energy Agency (IAEA) with accompanying safety guides. A new ISO standard on nuclear ISO 19443 have discussed CGID among other items.

Both domestic commercial and defense nuclear industries apply ASME NQA-1 Quality Assurance Requirements for Nuclear Applications as the acceptable standard for CGID. ASME NQA-1 (2008 revision with 2009 addenda) citations regulating CGID include:

• Part I, Requirement 7, Section 700, Commercial Grade Items and Services

• Part II, Subpart 2.14, Quality Assurance Requirements for Commercial Grade Items and Services

Adherence to criteria in ASME NQA-1 for procurement of basic components or CGID also precludes acceptance and installation of suspect/counterfeit items (S/CI) for safety systems. Identification and isolation of S/CI is also a concern for many non-nuclear safety applications to achieve desired system performance and lifetime. Numerous resources are available and routinely applied internationally by multiple industries, permitting prevention of procured S/CI from inadvertent installation or use.

Basic components—regulated by 10CFR50 for commercial nuclear power applications or 10CFR830 for defense nuclear applications for safety structures, systems, or com-ponents—employ rigorous design criteria including testing and qualification methods with acceptance criteria. Tests of basic components are performed in the most extreme credible conditions to ensure item performance during operations will maintain safety to workers, the public, and the environment. Test results are then translated by technically qualified professionals to specifications detailing material composition and processing with relevant standards, item dimensions with tolerance/accep-tance band, inspection methods and criteria for acceptance (which are usually more restrictive than manufacturing specifica-tions), inspection instrument calibration methods and frequency, personnel qualification for design, fabrication, inspection, and testing, and documentation and records retained that are required to establish item pedigree.

A technical evaluation of basic components selected for replacement with CGD methods is first performed to identify the critical characteristics that will ensure the replacement item will perform the desired safety function in the most severe environment, thereby offering the same level of protection as the basic component. Critical characteristics—including material composition and processing, and inspection methods with acceptance criteria to verify conformance—will be measured to determine whether the replacement item is suitable to perform its intended safety function.

Acceptance of CGI from suppliers will verify their acceptability by utilizing method one supplemented by the other three methods as needed to determine supplier capability to provide CGI, adhering to the standards specified in the dedication plan, which includes inspection of the critical characteristics. The four approved methods for CGID acceptance include:

1. Inspection and Test (ASME NQA-1 Part II, Subpart 2.14, 601) requires supplier data regarding material pedigree (e.g., drawings/specifications, material composition and processing history).

2. Commercial Grade Survey (ASME NQA-1 Part I, 602; Part II, Subpart 2.14, 601) ensures the supplier quality system is adequate through more extensive evaluation with a certificate of conformance submitted for each subsequent delivery to verify that the system approved earlier remained unchanged and adheres to procurement contract.

3. Source Verification (ASME NQA-1, Part I, 704.2) establishes that critical characteristics for acceptance (CCFA) are verified using appropriate methods and test/inspection instrumentation is adequate, with current calibration records ensuring measurements are valid. Objective evidence of information examined during the dedication process and activities observed must be retained, including verification method for CCFA.

4. Supplier/Item Performance Record (ASME NQA-1 Part I, 704.3; Part II, 2.14 604.3) may supplement the previous three acceptance methods but does not alone suffice for CGD approval. Performance records sufficient to comply with this verification method are stipulated in ASME NQA-1 2009.



Technical specialists may be assigned for commercial-grade item design evaluation to determine critical characteristics and also for the supplier qualification and item acceptance functions to ensure suitability of CGI to perform its intended function. A more extensive discussion of CGD methods with example figures and completed case studies with solutions will be included in the ASQ EED Nuclear Quality Assurance Auditor Training Handbook (anticipated publication by ASQ Quality Press early 2019).

Definitions Terms With Specific Nuclear Industry Applications

Basic Component (10CFR50): Basic component means, for the purposes of §50.55(e) of this chapter:

(1) When applied to nuclear power reactors, any plant structure, system, component, or part thereof necessary to ensure:

(i) The integrity of the reactor coolant pressure boundary;

(ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or

(iii) The capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to those referred to in §50.34(a)(1), §50.67(b)(2), or §100.11 of this chapter, as applicable.

(2) When applied to other types of facilities or portions of such facilities for which construction permits are issued under §50.23, a component, structure, system, or part thereof that is directly procured by the construction permit holder for the facility subject to the regulations of this part and in which a defect or failure to comply with any applicable regulation in this

chapter, order, or license issued by the commission could create a substantial safety hazard.

(3) In all cases, basic component includes safety-related design, analysis, inspection, testing, fabrication, replacement parts, or consulting services that are associated with the component hardware, whether these services are performed by the component supplier or other supplier.

Critical Characteristics (ASME NQA-1): Important design, material, and performance characteristics of a commer-cial-grade item or service, that once verified, will provide reasonable assurance that the item or service will perform its intended safety function.

Safety Structures, Systems, Components (10CFR50): Those struc-tures, systems, and components that are relied upon to remain functional during and following design basis events to ensure:

(1) The integrity of the reactor coolant pressure boundary;

(2) The capability to shut down the reactor and maintain it in a safe shutdown condition; or

(3) The capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to the applicable guideline exposures set forth in §50.34(a)(1) or §100.11 of this chapter, as applicable.

CGID is an expanding practice with NRC license renewal, extending the lifetime of commercial nuclear power plants while maintaining assurance of continued safe operation. Consid-eration of CGID practice and frequency should be included during evaluation of nuclear workforce skills to ensure that technical expertise sufficient to operate existing nuclear power plants will be maintained.


Working Toward Securing the Nuclear Advanced Manufacturing Supply Chain

Authors

Scott Zimmerman has 27 years of IT and cybersecurity experience and is the chief information security officer, principal advisor at Concur-rent Technologies Corpora-tion (CTC) in Johnstown, PA. He is a published author and is frequently asked to speak on topics related to cybersecurity. He has spe-cialized expertise in cyber-security, cloud computing, compliance, and systems engineering. Zimmerman currently leads several cybersecurity research and development projects for the CTC operated Center for Advanced Nuclear Manu-facturing (CANM).

Zimmerman’s education includes a bachelor of science degree in manage-ment information systems and associate of science degree in electronic/computer technology. He is a Certified Information Systems Security Professional (CISSP) and Information Systems Security Engineering Professional (ISSEP).

(continued on next page)

Introduction

For the U.S. nuclear industry to compete in today’s market, it must rely on a healthy and secure supply chain to provide components that 20 to 40 years ago would have been created bespoke from

hard copy. The drive for digitization of the industry has created the need to be able to digitally communi-cate, securely, items such as engineering and test data. This technological modernization has opened up the industry to new threats that in the past were not a part of the threat profile.

Organizations that support the advanced manufacturing nuclear supply chain are not immune to cybersecurity risks. In fact, in an October 2017 alert published by the U.S. Computer Emergency Readiness Team (US-CERT) warned of an advanced persistent threat activity targeting sectors including nuclear and advanced manufacturing markets. The alert followed investigations by the Department of Homeland Security (DHS) and the Federal Bureau of Investigation (FBI). “Since at least May 2017, threat actors have targeted government entities and the energy, water, aviation, nuclear, and critical manufacturing sectors, and, in some cases, have leveraged their capabilities to compromise victims’ networks.”1 Further, nuclear power facilities themselves have become increasingly targeted and have seen breaches on


business (although not OT) networks. The evidence from the field is clear—the cyberse-curity problem is a growing issue facing the nuclear industry.

The task of securing the supply chain is a daunting one. Organizations everywhere, including the nuclear supply chain, are hard-pressed to combat current cyber threats facing their own information technology (IT) and operational technology (OT) networks. Yet the supply chain introduces an additional level of increased attack surface. The business-to-busi-ness interaction required to produce nuclear technology is both broad and nuanced. From raw material suppliers mining iron ore and nickel, to sub-component distributors providing heat transfer tubes, to systems integrators who bring these components together—the required business relationships for production can number in the hundreds.6 Each interaction between these external systems presents an additional introduction of risk to the organiza-tion due to a larger exposed attack surface. Smaller, less resourced organizations in the supply chain present less hardened targets for hackers to attack. Once you combine the number of relationships and significant differ-ences in security maturity per organization, you can start to understand the magnitude of the problem. In October 2015, in conference materials published by the National Institute of Standards and Technology (NIST)2, the partic-ipants stressed that the problem alone is not just an IT one. They asserted that supply chain risks touch sourcing, vendor management, supply chain continuity and quality, transporta-tion security, and many other functions across the enterprise and require a coordinated effort to address. The materials also point out that “Cybersecurity is never just a technology problem, it’s a people, processes, and knowledge problem.” In general, their findings suggest that breaches are not about IT failure, but about human error. It is impossible to

secure critical information and intellectual property with just IT cybersecurity systems unless employees throughout the supply chain employ secure cybersecurity practices.

Supply Chain Cyber Attack Vectors

The most important differences between the traditional and supply chain attack surfaces is that the attack surface of a supply chain is the cumulative exposure of each organi-zation within the chain. The realization is a frightening one, given the state of security in organizations. It is imperative, however, to understand how many of an organization’s third-party relationships can cause negative impacts through access to sensitive and confidential data. Without confirming the existence of adequate safeguards and security policies in third parties and reviewing third-party management policies and programs to ensure risks are addressed, the nuclear industrial manufacturer is establishing its own security status as that of its least secure partner. A serious barrier to identifying those supply chain security liabilities is the lack of adequate resources to manage third-party risk, according to 60 percent of participants in research conducted by the Ponemon Institute4. Without rigorous evaluation and validation of the security risk presented by partners, your attack surface grows with each relationship.

In one of the more publicized breaches in recent history, Equifax attributed its massive loss of customer information to a flaw in outside software it was using. It then attributed a malicious download link on its website to yet another vendor. It’s not just Equifax. According to the previously cited research conducted this fall by the Ponemon Institute,4 56 percent of organizations have had a breach that was caused by one of their vendors. In addition,

Lucas Truax is a security engineer at Concurrent Technologies Corporation. He began in IT as a developer and has worked in IT security for most of the last decade, both securing and attacking a variety of information systems. Truax holds a master of science degree in software engineer-ing. Additionally, he holds the GIAC Response and Industrial Defense (GRID) and Certified Information Systems Security Profes-sional (CISSP) certifications.



the trend in breaches coincides with an increased level of access by third parties to sensitive information. Over two years, the average number of third parties with access to sensitive information at each organization has increased from 378 to 471. The authors of the study indicated confidence that the number may be even higher. Surprisingly, only 35 percent of companies had a list of all the third parties with which they were sharing sensitive information.4

Approach to Understanding the Level of Your Supply Chain Security Posture

To effectively reduce their exposure, companies must have a strategy in place to actively address cybersecurity in and along the entire supply chain, not just for their internal cyber posture. To establish the organizational strategy and combat these threats, organizations should take a two-prong approach to secure their supply chain. First, on the internal level, by imple-menting security practices from both the NIST Cybersecurity Framework for Critical Infrastructure, and the DHS sector-spe-cific guidance of “Critical Manufacturing Sector Cybersecurity Framework Implementation Guidance” released in 2015.3 Through implementing these best practices, organizations will greatly enhance their own cybersecurity posture. In addition, we recommend organizations begin to implement a supply chain cyber management system that will provide dynamic and near real-time risk level insight into the other entities in their supply chain.

The NIST released voluntary Framework for Improving Critical Infrastructure Cybersecurity in February 2014 to provide a common language that critical infrastructure organizations can use to assess and manage their cybersecurity risk. The framework provides a tool and methodology for organizations to use to help prioritize their cybersecurity decisions based on risk and individual business needs and not a prescriptive approach such as federal regulations. As more entities implement the framework, its approach will serve as a recog-nized baseline for cybersecurity controls and practices. In order for an organization to participate within your supply chain, it should be strongly encouraged that organizations implement to provide a means to quantify their security posture as it relates to predefined standards such as NIST SP800-82. This security

posture measurement can then be communicated as part of the cybersecurity dynamic approach outlined below.

Organizations within the supply chain should be able to rapidly verify that a supplier has implemented either the NIST Framework or other cybersecurity frameworks of cybersecurity controls and that the consumer on an ongoing basis can remotely monitor them. The problem quickly becomes an issue of assessing the risk of these external organizations without performing an assessment of each organization. When evaluating the security of business relationships, there are several early indicators of supplier security awareness including the following7:

• A documented cybersecurity plan, including policies and procedures for patch management and updating their environments as well as how the supplier protects their environments from third-party suppliers

• An engineering and software development environment that is isolated from the business networks

• A physical security plan that provides assurance that assets are protected while in the supplier’s possession

• Audit process to ensure the supplier’s policies are being implemented

• A documented process and framework for conducting code reviews

The interconnectivity between partners within the supply chain makes all firms in the chain inherently susceptible to their partner’s weaknesses. It would serve the prime or consumer well to develop effective portable cyber controls throughout the supply chain to protect organizations that can’t afford the staff or tools, and lack the cyber sophistication. In addition to these controls, the consumer must be able to make a determination of the cyber risk associated with each supplier within the chain on an ongoing and dynamic basis. A significant factor in defining risk is the level of interaction between a supplier and organiza-tion. The level of interaction can indicate a level of dependence on the supplier. For example, an organization may have a heavy reliance on a raw materials provider, but the interaction between the organization’s network and the supplier’s may be non-existent. In another case, an organization may have low dependence on a supplier, but the supplier organization



may require remote access to the network, resulting in a high interaction score.

Concurrent Technologies Corporation (CTC) has been develop-ing a risk-based supply chain cyber management methodology and application to measure the security of the data, interaction with suppliers, and systems and processes that make up the nuclear advanced manufacturing (AM) supply chain communi-cation network. The early results indicate that this methodology and application would provide a flexible and scalable risk-based cybersecurity assessment and audit framework that needs to focus on the supply chain.

The methodology, application, and data produced provide a risk score that organizations can use to assess security risk of current and potential suppliers and take risk-based mitigation steps in their interactions with the organizations. This risk score will have four components:

• Geographic location: The internet knows no borders, but according to most reports, cybercrime has specific “geo-graphical features”8

• Security Posture: An external assessment of a supplier’s security practices

• Readiness: A supplier’s internal assessment of their com-pliance with commonly accepted standards such as NIST 800-171 and ISO/IEC 27001 and 27002

• Interaction: Determining the level of interaction with a supplier and defining a level of dependence on the supplier

The system takes into account each of the score components shown above and through the use of a proprietary algorithm produces the score for each supplier. Organizations can then make risk-based decisions and implement appropriate cyber mitigation controls to ensure a secure communication channel.

Summary

The software- and information-driven approach provided in this article will provide an organization an approach to enable a more dynamic view into their supply chain’s cybersecurity posture. Deploying a software-driven solution such as this along with ensuring security best practices are followed, such as including security requirements in every RFP and contract, on-site review of supplier cybersecurity implementation, and defenses including addressing vulnerabilities and security gaps should help to improve security and reduce cyber risks.

References 1. https://www.us-cert.gov/ncas/alerts/TA17-293A, accessed June 2018.

2. https://csrc.nist.gov/CSRC/media/Projects/Supply-Chain-Risk-Management/documents/briefings/Workshop-Brief-on-Cyber-Supply-Chain-Best-Practices.pdf, accessed June 2018.

3. https://www.dhs.gov/sites/default/files/publications/critical-manufacturing-cybersecurity-framework-implementation-guide- 2015-508.pdf, accessed June 2018.

4. https://www.opus.com/ponemon/, Data Risk in the Third-Party Ecosystem, Second Annual Study, September 2017, accessed June 2018.

5. http://www.businessinsider.com/nuclear-power-plant-breached-cyberattack-2017-6, Hackers breached a US nuclear power plant’s network, and it could be a ‘big danger,’ June 2017, accessed May 2018.

6. https://www.oecd-nea.org/ndd/workshops/pmnnb/presentations/docs/2.1.pdf, The World Nuclear Supply Chain – An Overview, March 2014, accessed June 2018.

7. https://nupic.com/nupic/GetFile.aspx?ID=61&tbl=HOME_HOT...DOCS..., Overview of Nuclear Cyber Security Program on Suppliers, Barbara Weber, accessed June 2018.

8. https://securelist.com/the-geography-of-cybercrime-western-europe-and-north-america/36671/, The geography of cybercrime: Western Europe and North America, YuryNamestnikov, accessed June 2018.

https://www.us-cert.gov/ncas/alerts/TA17-293A

https://csrc.nist.gov/CSRC/media/Projects/Supply-Chain-Risk-Management/documents/briefings/Workshop-Brief-on-Cyber-Supply-Chain-Best-Practices.pdf



https://www.dhs.gov/sites/default/files/publications/critical-manufacturing-cybersecurity-framework-implementation-guide-2015-508.pdf



https://www.opus.com/ponemon/

http://www.businessinsider.com/nuclear-power-plant-breached-cyberattack-2017-6

http://www.businessinsider.com/nuclear-power-plant-breached-cyberattack-2017-6

https://www.oecd-nea.org/ndd/workshops/pmnnb/presentations/docs/2.1.pdf

https://www.oecd-nea.org/ndd/workshops/pmnnb/presentations/docs/2.1.pdf

https://nupic.com/nupic/GetFile.aspx?ID=61&tbl=HOME_HOT...DOCS...

https://nupic.com/nupic/GetFile.aspx?ID=61&tbl=HOME_HOT...DOCS...

https://securelist.com/the-geography-of-cybercrime-western-europe-and-north-america/36671/

https://securelist.com/the-geography-of-cybercrime-western-europe-and-north-america/36671/


Quality Management 4.0 for Both Physical and Digital Nuclear Power PlantPart 1.Intelligent Digital Design Platform

Authors

Dr. Zheng Mingguang, IAQ Academician, Chief Designer of CAP1400, President of Shanghai Nuclear Engineering Research & Design Institute Co., Ltd. (SNERDI), Senior Vice President of SNPTC-China

Liu Haibin, Deputy Director of QA Department of SNERDI, Vice Chair of ASME NQA CIWG

Dr. Gu Danying, Senior Engineer, Department of Electric Instrumentation and Control

Bai Xiaoling, Engineer, QA Department of SNERDI

Nuclear energy is one of the greatest discoveries by mankind in the 20th century. The utilization of nuclear power has made important contributions to societal and economic development.

About 450 global units contribute about 11 percent of the world’s electric power. In general, modern nuclear power is safe, efficient, economic, clean, and environmentally friendly. Currently, 39 units are running with 39 GW in mainland China, and 18 units with 20 GW are under construction.

Nuclear energy is one of the core energy sources

for sustainable development. Large-size reactors for electric power generation and small modular reactors (SMRs) for multiple applications—including a combination of electric, process heat, and district heating—are needed for economic reasons and convenience. Major problems focus on safety, security, and safeguards; ecosystems and environment; economy and efficiency; and sustainability.

But how can nuclear energy ensure its sustainable development, eliminate the possibility of the risks such as Fukushima accidents, improve safety and security, and promote the coordinated and economic development of the global industrial supply chain?

A nuclear power plant designed by SNERDI. Copyright SNERDI.



What should be the role of quality management in nuclear power plants (NPPs)?

The fourth industrial revolution, characterized by digital intelligence, results in transformations in manufacturing, improved efficiencies, and increased quality in supply chains and product innovation. The digital revolution is also emerging into the full life cycle of NPPs, including research, design, verification and validation (V&V), manufacturing, construction, and operation and mainte-nance (O&M) (Figure 1).

Broadly speaking, the first three items (i.e., research, design, V&V) can be defined as the development and design phase, and the last three items (i.e., manufac-ture, construction, operation and maintenance) can be defined as the O&M phase. Quality management has progressed from quality control (QC), to total quality control (TQC) to quality assurance (QA), and now has entered the era of quality 4.0. Quality management 4.0 in nuclear power closely aligns quality management with industry 4.0 to enable the full life cycle of NPP efficiencies, performances, and innovation.

This paper consists of two parts. Part 1 will focus on quality management 4.0 during the digital design phase, and will show how intelligent digital design with effective quality improves the efficiency of nuclear energy development. Part 2 will focus on quality management 4.0 during the digital O&M phase, and will show how the cyber physical systems (CPS) concept is connected with intelligent O&M to maximize the safety, economy, and efficiency of NPPs, and promote the coordinated development of upstream and downstream industry chains.

An intelligent design platform should include:

• Design tool system

• Design management

• Design justification

• Operation supporting tools

• Big data system

The digital quality management system will be incorporated in all design processes such as the digital and visual quality management system.

To build up the intelligent design platform, the following questions shall be answered:

• How do we build up the intelligent digital design system with future vision?

• How do we incorporate and integrate the philosophy of quality assurance in the intelligent digital design?

• How do we change and shape all the requirements of design such as RGs and criteria, design process flows, design management, and both tacit and implicit knowledge into digitalized information and cultivate continuously?

Figure 2 shows the answers to the above three questions. SNERDI is pushing forward and perfecting the intelligent digital design system applied to nuclear power design. The entire life cycle is based on the data center, using all kinds of digital tools such as big data, cloud platform, internet of things, virtual reality, simulation platform, expert judgment diagnosis systems, etc. It integrates all aspects of the quality management system and changes the original design process in depth. The design method improves the design efficiency, improves design quality, and promotes quality improvement of the whole industry chain.

The integrated data center (Figure 3) ensures data quality with accuracy, associative, and uniqueness in data collection, vali-dation, translation, interface, management, use, and change.

Part 1: Design phase Part 2: O&M phase

V&V

Research

Design

Construction

O&M

Manufacture

Digital twins

V&V = veri�cation and validationO&M = operation and monitoring

Figure 1. Full life cycle of NPP



The basis of digital design is to establish a comprehensive data center, including a two-dimensional design data center, 3-D design data center, analysis and calculation data center, simulation verification data center, etc. The structured and unstructured data of the entire life of the nuclear power plant are structured, centralized, and controlled. Including data collection, validation, transmission, interaction, association, manage-ment, use, and change, ensure that all the data used by the process have a unique source, and there is an association between data, and the full relationship between data and items, models, processes, resources, documents, rules, analysis, and decision-making. In a simple example, if the result of the thermal hydraulic calculation improves the flow demand, it will automatically reflect the pipe size design and the valve design of the fluid system, and then trigger a series of require-ments of the mechanical calculation confirmation. Centralized storage of data also lays a very good foundation for knowledge management, facilitates the inheritance of knowledge, and implements a variety of data display forms according to the different needs of the terminal, and provides strong basic data for the expert support system.

The integrated design platform ensures the implementation and coordi-nation of rules including multidiscipline and specialty integrated design, expert knowledge, digital design rules, and intelligent design process. The most important step is digitalization of the design rules; tacit, implicit, and explicit knowledge; and criteria for design justifications. On the basis of the comprehensive data center, the integrated digital design platform of the whole professional collaboration is set up.

Expert decisionsupport

Internet ofthings (IoT)

Effectivenessmonitoring

Conditionmonitoring

Intelligentdiagnosis

Virtualconstruction

Intelligentconstruction

Intelligentmanufacturing

Integratedequipment

Performancecalculationvirtual V&V

Constructionorg.

Construction

Manufacture

Veri�cationand validation

Operation andmaintainence Design

Research

Data center

Scheme fastcomparison

Auto-designintelligent design

Big data

Cloud

Virtual reality

Simulation

Figure 2. Digital revolution during the full life cycle of NPP

Figure 3. Integrated data center

Item

Model

Process

Recourse

DocumentRule

Analysis

Demonstration

Decision

Data

With cloud platform technology, the engineer and designer can work together globally with just a computer and a network. The design platform integrates the digital expert’s knowledge and the design rules, realizes the design process iteratively by the expert system to complete the intelligent automatic diagnosis and completes the automatic iteration, transforms the original upstream and downstream files into the data direct transmission, and lays the foundation for the realization of the one-key design prospect.

Visual design facilitates the process and reduces the cost of design. The digital design realizes the visualization of the system and equipment design process and design results, integration of mechanics and layout, and the design drawings can be transferred directly to the manufacturing plant for processing and manufacturing, which brings great



convenience to the design, manufacturing, and layout and greatly improves the efficiency of design and manufacture. This will improve the capability of the entire nuclear power manufacturing industry chain.

Digital verification improves economics and inherent knowledge. Digital simulation provides a very convenient and economical way for design and verification. Powerful virtual reality technology saves costs and time, and prevents environmental damage with a large number of experiments. Machine interface and safety are greatly optimized by human engineering research and severe accident simulation during the design stage. For example, a shielding building made up of high-strength concrete, through strict digital simulation to verify the vibration effect, combustion effect, explosion effect, etc., ensures the impact of large commercial aircraft, and guarantees the safe operation of the nuclear power plant.

Safety is the foundation of the development of nuclear energy. Quality is the foundation of nuclear energy safety. To ensure the safety of nuclear energy, the requirements of the IAEA, the national nuclear safety administration, ASME, and ISO on quality assurance should be taken into account. A strict and integrated quality assurance management system should be implemented because a quality design is the base of NPPs.

In conclusion, the intelligent digital design platform will improve efficiency, economy, and safety as well as enhance the knowledge management of NPPs. Great attention shall be paid to top-level design such as functions for future, quality, shielding building data associations, and reliability of the digital design platform.

Part 2 “Intelligent Digital O&M Platform” will be continued on the next newsletter.

▼ WCQI 2018. EED team meets Shanghai Nuclear Engineering Research and Design Institute (SNERDI). From left: Kevin Fahey, Mike Gilman, Karen Douglas, Dr. M. Zheng (president, SNERDI), Dr. Abhijit Sengupta, Jarrod Suire (chair, ASQ EED) and Michelle Dudley (chair-elect, ASQ EED).

▲ Dr. Abhijit Sengupta of ASQ EED was awarded as 2018 ASQ Fellow, along with two others.



ASQ Energy and Environmental Division 2018 – 2019 Proposed Organizational Chart

Vice ChairEnergy

M. Gilman

Vice ChairEnvironmental

Secretary

T. Koepp

Vice ChairAdministration

Dr. A. Richard

Immediate PastChair

Dr. G. Allen

LeAnna AyerTreasurer

K. Aleckson

ChairJ. Suire

Chair-ElectM. Dudley

NuclearK. Douglas

SustainabilityA. Masoudi

AuditingT. Kartachak

MembershipArthur Richard

Voice of theCustomer

S. Prevette

At-Large MembersDr. J. DewG. Johnson

T. HorneG. Merkel

J. WorthingtonEED StandardsC. Moseley

Communicationsand Newsletter

Dr. A. Sengupta

Body of KnowledgeM. Dudley

A. Masoudi

T. Koepp

Oil and Gas EnvironmentalRemediation andDecommissioning

B. Marguglio

RenewablesM. Dudley

Conventional andAlternative

EnvironmentalManagement

G. Lilly

EnergyManagement

Narahari Rao

Programsand Learning

Dr. William Good

08/27/2018

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