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Public Workshop on NRC 10CFR50.55a Improvement Initiative
	ML20042D231
Person / Time
Site:	Nuclear Energy Institute
Issue date:	02/11/2020
From:	; Nuclear Energy Institute
To:	O'Banion M; Plant Licensing Branch IV
	O'Banion M
References
	Download: ML20042D231 (16)
	v • d • e

Public Workshop on NRC 10CFR50.55a Improvement Initiative NEI Codes and Standards Task Force February 11, 2020

NEI Task Force Discussion Items Review Approach Relative Ranking and Review of Ideas Background information on 10CFR50.55a Simplification from 12-3-19 NRC-NEI Public Meeting

Review Approach Collegial review with NEI Codes and Standards Task Force Identified various Benefits and Challenges of Each Idea Developed Comments and Suggestions Relative Ranking of High, Medium and Low based on potential impact and likelihood of implementation

Vision for Simplification of 50.55a NRC endorses ASME Section XI, III, and OM with very few if any conditions.

Streamlined process for deviations to Code and use of Code Cases w/o prior separate NRC approval.

No compulsory requirement to update to latest editions.

Ideas Ranked High Change to Requirement on Updating ISI Programs Documenting NRC Approved Votes and Code Cases for Incorporation in Rule Direct Final Rule for Unconditionally Approved Code Cases Revisiting the Need to Mandate Codes and Standards by Removing Section III, XI and OM Codes from 50.55a Entirely

Ideas Ranked Medium Relocate the Text of 10 CFR 50.55a into a Regulatory Guide(s) and Incorporate the RG(s) into 50.55a Add a 50.59-Like Change Control Process to Allow Licensees to Make Minor Deviations from the Code without NRC Approval Rewrite of 50.55a

Ideas Ranked Low Create a Users Guide for 10CFR50.55a Performance-Based Approach to ASME Standards

Questions and Discussion Background Information from 12-3-19 NRC Public Meeting

10CFR50.55a Simplification Industry Suggestions on Simplifying Rule and Proposed Changes

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Background===

10CFR50.55a has become complicated with many details beyond the level of applicable regulation 10CFR50.55a is difficult and cumbersome to follow with various elements and conditions associated with any specific code/standard spread throughout the rule 10CFR50.55a references code editions that licensed stations no longer implement

Suggested Simplification Simplify the identification of approved versions of the Code editions versus listing all of them Align approved code editions, conditions and code cases by applicable codes rather than scattered throughout the rule Maintain Regulatory Guide provision for implementing code cases Maintain relief request / impracticality provision Possibly create an Option B that provides these simplified requirements

Proposed Changes as Part of Simplification Eliminate or significantly extend the requirement for the 10-year Code update as required by the Licensee Containment Program, ISI Program, and IST Program (e.g. extend to 24 years)

Establish 3 - four year inspection/test periods over twelve year intervals, versus the current 3/4/3 year periods over 10 year intervals Permanent approval of Relief Requests until code incorporation Perform back-fit/forward-fit review for all existing conditions that are proposed to remain to ensure requisite safety benefit

Reason for Simplification and Proposed Changes Format the Rule in a manner that is easier to understand Minimize conflicts with code requirements and reduce the need for licensees to seek relief Reduce or eliminate the cost of an ISI or IST ASME Code update for dual unit or single unit site

Costs for each update has risen to approximately $1M per station 4-year inspection/test periods allow two outages per period to align with skip outages and divisional outages and not require inspections or tests to be done earlier than required Updating the Code program to a later edition each 10 years is no longer necessary to achieve an acceptable level of quality and safety

Reason for Simplification and Proposed Changes (cont.)

From initial licensing of a plant,120-month update was a way to review code inspection requirements and their impact, and in some cases add or remove requirements based on newer code versions Licensees can adopt later NRC approved ASME Code editions, but should not be mandated to do so since they are following NRC approved ASME Code editions As plants have matured, the need for a living ASME Code has been reduced Licensees can implement other mechanisms to quickly react to emerging issues through industry groups to address safety or regulatory concerns as compared to a 120-month update Changes necessary for safety purposes can be specifically stated or conditioned in 10 CFR 50.55a

NEI Going Forward Recommendations Facilitate NEI member feedback on any 10CFR50.55a proposed simplifications and changes Develop a relief request to extend code updates to 24 years, with 12 year inspection intervals having three 4 year periods per interval Consider petitioning for rule making for the proposed changes and others changes that encompass previous industry wide reliefs or hardships that can be shown to not have commensurate safety benefit

ML20042D231

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