Inside NIRMA Summer 2021

would set a precedent that other utilities/plants could
take advantage of, or 2) insert electronic records
guidance into a subsequent version of NQA-1 (more on
that later).
Duke Energy Safety Evaluation Report Request
In March 2015, Duke Energy Carolinas submitted a
request to the NRC to approve a change to the Quality
Assurance Topical Report (QATR) for its three nuclear
stations. The request was to revise the QATR to
reference the 2011 versions of the TGs. The NRC
found it acceptable that the requirements of 10 CFR 50
Appendix B would still be satisfied through compliance
with the TGs. Therefore, the Duke SER satisfied one
of the alternatives cited in the PP06 position paper.
Bottomline: If you want to have electronic records management for
your site, the NRC approves the use as long as your electronic
records comply with these 2011 versions of the TGs.
[On the NIRMA website, for these TGs, you will
find a folder called “NRC-SER Endorsed NIRMA TGs
(2011)” under the Technical Guidelines section of the
Reference Documents area.]
Regulatory Guide 1.28, Revision 5
Quality Assurance Program Criteria
(Design and Construction)
In October 2017, the NRC issued Revision 5 of
Regulatory Guide 1.28. Prior to that, in Revision 4, the
NRC stated that, if electronic QA records were being
stored and managed, its position on electronic records
was based on Generic Letter 88-18 and RIS 2000-18
that references the 1998 NIRMA guidelines (TG-11, TG
-15, TG-16, TG-21). In Revision 5, the NRC stated:
“For the management of electronic records,
appropriate controls on quality assurance include the
following:
(a) No deletion or modification of records unless
authorized pursuant to the record retention rule
(b) Redundancy (system backup, dual storage, etc.) is
provided
(c) Legibility is required of each record
(d) Records media are properly maintained
(e) Inspections to ensure no degradation of records
(f) Records are acceptably converted into any new
system before the old system is taken out of
service
The Nuclear Information and Records Management
Association (NIRMA) technical guides (TGs), as
listed…, provide guidance to establish the
appropriate quality controls that incorporates the
implementation of enterprise content management
systems, web-based technologies, and higher capacity
LAN/WAN networks. The NRC approves for use
the 2011 versions of the NIRMA TGs.”
Bottomline: The NRC, in Revision 5, essentially leveraged its
position stated in the Duke SER and approves the use of the
2011 NIRMA TGs.
American Society of Mechanical Engineers:
Quality Assurance Requirements for
Nuclear Facility Applications
NIRMA members, in 2015, began to participate in
the Programs Management Process (PMP)
Subcommittee of NQA-1. It was surmised that the
NIRMA TG content is very extensive, but wordy, so
NIRMA TG (2011) requirements were reduced or
summarized to fit the ASME NQA-1 format and scope.
The advantages for the industry are that the
manufacturers can use these changes very quickly; NSSS
vendors and new build facilities can adjust, as needed.
ASME NQA-1 is the “go-forward” strategy for industry
and NRC review. It will not be tied to any specific TG
version, so the standard can adjust as technology
changes. From a NIRMA perspective, there will be
many ASME interpretations, of which answers can then
be sought in the full NIRMA TGs.
Bottomline: The electronic records requirements are published as
part of ASME NQA-1-2017. (Caution: You have to be
committed to/and use this standard/year to take advantage of
this.)
Whew! Thanks for hanging in there with me. It’s
been quite a ride in guidance space for over 30+ years,
and NIRMA has been in the thick of it! In future
columns, I intend to continue with addressing the other
aspects of nuclear electronic records, such as
authentication, sustainability, disaster planning and
recovery, and more! Stay tuned!
Eugene has been a member of NIRMA for over
34 years. At the time he joined, NIRMA had
only been in existence for 11 years. He would love
to hear about stories and anecdotes from others, so
please email him at eugene.yang@kismetconsulting.com.
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