ML20147A739
| ML20147A739 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/1997 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9701280266 | |
| Download: ML20147A739 (140) | |
Text
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, . i UNITED STATES OF AMERICA i -
NUCLEAR REGULATORY COMMISSION l ,
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Title:
BRIEFING ON CODES AND STANDARDS -
1
. PUBI,IC MEETING [
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! Location: Rockville, Maryland i
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! l i Date: Wednesday, January 22,1997 -
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! i Pages: 1 - 78 1
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l DISCLAIMER This is an unofficial transcript of a meeting of r
the United States Nuclear Regulatory Commission held on
.7,nnary 99. 1997 in the Commission's office at one White Flint North, Rockville, Maryland. The meeting was ,
open to public' attendance and observation. This transcript has not been reviewed, corrected or edited, and it may j contain inaccuracies.
The transcript is intended solely for general informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
4 BRIEFING ON CODES AND STANDARDS 5 ***
6 PUBLIC MEETING 7 ***
8 '\
l 9 Nuclear Regulatory Commission 10 Room 1F-16 11 One White Flint North 4
12 11555 Rockville Pike 13 Rockville, Maryland 14 15 Wednesday, January 22, 1997 16 17 The Commission met in open session, pursuant to 1
18 notice, at 10:00 a.m., the Honorable SHIRLEY A. JACKSON, '
19 Chairman of the Commission, presiding.
20 COMMISSIONERS PRESENT:
21 SHIRLEY A. JACKSON, Chairman of the Commission '
22 KENNETH C. ROGERS, Member of the Commission 23 GRETA J. DICUS, Member of the Commission 24 EDWARD McGAFFIGAN, JR., Member of the Commission 25 ANN RILEY & ASSOCIATES, LTD.
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. . I l 2 l 1 STAFF AND PRESENTERS:
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3 JOHN C. HOYLE, Secretary l 4 WILLIAM J. OLMSTEAD, Associate General Counsel 5 EDWARD JORDAN, Dep. Executive Director for 6 Regulatory Effectiveness, Program Oversight, 7 Investigations, and Enforcement t
8 JOSEPH MURPHY, Special Assistant, RES j 9 DR. CARL PAPERIELLO, Director, NMSS 10 GILBERT MILLMAN, Program Manager, RES l
11 JUNE LING, Associate Executive Director, Codes and l 12 Standards, ASME 13 BRIAN SHERON, Director, Division of Engineering, 14 NRR 15 MARCO MIGLIARO, Past Vice President (Standards),
16 IEEE 17 SATISH AGGARWAL, Senior Program Manager, Office of 18 Nuclear Regulatory Research 19 20 21 '
22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
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3 1 PROCEEDINGS 2 (10:05 a.m.]
3 CHAIRMAN JACKSON: Well, good morning, ladies and 1
4 gentlemen.
5 I am pleased to welcome members of the Staff and 6 June Ling, representing the American Society of Mechanical 7 Engineers; Mr. Marco Migliaro, representing the Institute r
8 of Electrical and Electronic Engineers or the IEEE, to brief 9 the Commission on consensus codes and standards.
10 Codes and standards are an integral part of NRC's 11 regulatory process. NRC endorses codes and standards by 12 reference in our regulations and through regulatory guides.
I 13 The codes and standards rule, 10 CFR 50.55(a) endorses the 14 ASME Code Sections 3 and 11 and the IEEE Standard 279.
15 During today's briefing the Staff will focus on I
16 the NRC's use of consensus codes and standards, and Ms. Ling i 17 will provide an overview of the ASME discussion on codes and 18 standards development and briefly describe some current ASME 19 initiatives, I understand.
20 Mr. Migliaro will discuss the IEEE standards 21 process, NRC's participation in that process, and any other 22 relevant issues that he wished to bring to the attention of 23 the Commission.
24 I understand copies of the viewgraphs are 25 available at the entrances to the room. If none of my ANN RILEY & ASSOCIATES, LTD.
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1 fellow Commissioners have any opening comments, I would like 2 to ask you, Mr. Jordan, to begin.
3 MR. JORDAN: Good morning, Chairman Jackson, and 4 Commissioners.
E This morning the Staff representatives and 6 representatives of two of the engineering societies will 7 brief the Commission on activities related to consensus 8 codes and standards.
9 The Staff presentation will focus on its 10 participation in their development and their use in the 11 regulatory process.
12 You have introduced the two representatives from
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13 industry. I would like to introduce the members from the 14 Staff that are here -- Brian Sheron, Division of 15 Engineering, NRR; Gil Millman, who is Program Manager, 16 Codes and Standards, from the Office of Research; Dr. Joe 17 Murphy, who is acting for Themis Speis today and Themy 18 indicated to me chat he has already participated in his last 19 Commission meeting.
20 [ Laughter.)
21 MR. MURPHY: Maybe so.
22 MR. JORDAN: So he has passed the baton on.
23 Carl Paperiello is here, Director of the Office of 24 Nuclear Materials, and the other parties have been 25 introduced and by introducing the members from the NRC, ANN RILEY & ASSOCIATES, LTD.
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1 identifying that we are going across the offices -- the 2 offices are represented, materials as well as reactors.
3 Codes and standards have been and continue to be ,
4 important tools in NRC's implementation of its regulatory 5 mandate. Such standards as a body contain technology which 6 is kept current through periodic revisions based on 7 experience.
8 These codes and standards are used by the industry 9 and the regulator in the process of ensuring and 10 demonstrating the safety of nuclear power plants and other 11 activities licensed by the NRC.
12 Staff participation in the development and use of ,
4 13 consensus standards and codes is an NRC-wide activity.
14 The Office of Nuclear Reactor Research is making 15 the presentation today because it is the lead office for 16 coordinating the NRC's codes and standards activities.
17 Research has had this function since the NRC Office of i 18 Standards Development was subsumed into the Office of 19 Research in 1981.
20 With increasing economic pressures on both 21 industry and NRC, the use of consensus codes and standards 22 is becoming an even more important element in the regulatory 23 process. In this changing environment and with the move j 1
24 toward risk-informed, performance-based regulations, the 25 Staff expects to work more closely with the technical i I
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1 societies such as the ASME, IEEE, American Nuclear Society, 2 and so on consistent with Commission decisions on the 3 direction-setting issue Number 13, to identify specific 4 areas where there is a need for emphasis on new or updated 5 standards.
6 I'll now turn this presentation over to Dr. Joseph 7 Murphy.
t 8 MR. MURPHY: Thank you, Ed. Good morning. ;;
l 9 The presentation this morning will focus on !
10 consensus national standards with primary examples directed l 11 to engineering standards applied to reactors.
12 We will discuss why the consensus codes and 13 standards are important to the NRC, how they fit into the 14 regulatory framework, Staff participation on the committees, 15 and the current activities that we consider important.
16 Although not part of this presentation, I would I 17 like to point out that the Staff is also involved as 18 official members of international standards writing 19 activities. This includes IAEA Advisory Committees, and with 20 regard to the IAEA, NRC has the official leave for the 21 Adviscry Commission on Safety Standards and is represented 22 on the Nuclear Safety Standards Ad\isory Committee, NUSSAC, 23 and the Radiation Standards Advisory Committee, RISAC.
24 In consultation with others we are also involved 25 in preparing the U.S. position for two other advisory ANN RILEY & ASSOCIATES, LTD.
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1 committees to the IAEA.
2 Making the presentation for the Staff today will 3 be Mr. Gil Millman. Mr. Millman has recently been assigned 4 to the position in Research of Program Manager for Codes and l 5 Standards. He has been involved in a very intensive way 6 with ASME activities on codes and standards for the past 20 7 years.
r 8 As you have already mentioned, we are pleased to 9 have the speakers with us today from the ASME and the IEEE 10 that you have already introduced, and with that I'll turn it !
11 over to Mr. Millman.
12 MR. MILLMAN: Thank you. This morning I'll
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13 explain why consensus codes and standards are important'to 14 the NRC, how we endorse them in the regulatory process, and 15 how the Staff participates in their development.
16 I will also identify some actions the Staff plans 17 to take that would further promote NRC's use of consensus 18 codes and standards.
19 Consensus codes and standards are important to the 20 NRC because they provide the specificity needed to implement 21 NRC's broad, general design criteria. Additionally, they 22 form a basis for NRC requirements and guidance in the many 23 areas noted.
24 I use the term " form a basis" because NRC still 25 has the responsibility to review each of these standards and c
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8 1 make an independent determination that a particular standard 2 suits the purpose it is intended for with regard to the 3 regulatory use.
4 Drawing on the knowledge and experience of 5 thousands of volunteers in the codes and standards process, 6 the codes and standards incorporate many years of accepted 7 good engineering practice and reflect state-of-the-art 8 technology.
9 Additionally, the efforts of these many volunteers 10 provide a tremendous multiplier effect on NRC resources.
11 Next slide, please.
12 The regulatory framework for implementing codes .
13 and standards contains components that apply to both NRC and 14 the licensees. In the context of this talk I am going to 15 use the term licensees to be applicants and licensees.
16 First, the part that applies to the NRC. Public 17 Law 104-113, National Technology Transfer and Advancement 8 18 Act of 1995, requires that federal agencies use consensus 19 national standards -- consensus standards and participate in 20 their development.
21 It also has a provision that says you don't have 22 to use these standards if you can justify why they are not l 23 appropriate for an intended use. In that case the head of 24 the agency is required to provide an explanation to OMB 25 identifying why that standard is not being used.
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1 OMB Circular A-119, Federal Participation in the 2 Development and Use of Voluntary Standards, provides the 3 guidance to implement the law. The circular has been around 4 for a lot longer than the law. The circular was initially 5 issued in 1982 and provided some general guidance as to how 6 agency staff should participate on the various consensus 7 committees, and this was very valuable information and we 8 have used part of that, the text of that original circular, f 9 in a letter which I will talk about in terms of nominating 10 people to committees.
11 In 1993 the circular was revised and it put 12 additional teeth into it.
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13 First, it required within 120 days of the issuance 14 of the circular that an agency standards executive be 15 identified. We did that and the NRC Standards Executive is 16 John Craig, Deputy Director of the Division of Engineering 17 Technology, Office of Nuclear Regulatory Research.
18 In addition, the circular provides that there be 19 an annual report identifying how each agency has used 20 standards in that past fiscal year.
21 The report is fairly simple. You just have to
- 22 identify the standards that you have endorsed and the 23 numbers of people that you have -- that have participated on 24 committees in the process. There are some other importing 25 requirements but they are equally simple.
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i o a 10 1 There is one additional provision in the '93 ;
2 circular that requires some effort. There is a requirement 3 for a five-year review of agency internal standards, 4 " internal standard" meaning like a regulatory guide that 5 provides provisions not endorsing a national standard but 6 contains its own provisions.
7 To review those kinds of standards and make a 8 determination of whether any of those standards, internal 9 standards, could be converted into a national standard that 10 in turn could be endorsed by, say, a regulatory guide I 11 might say that Research is working with NMSS to identify 12 such guides within the NMSS process and working with ANSI to ,
13 identify some standards development organizations that'would 14 work with us to develop those standards.
15 The route for licensees to use codes and standards 16 is, first of'all, the regulations, and then regulatory 17 guides. Now there are other regulatory mechanisms for .
18 identifying and referencing consensus standards. They are 19 generic letters, standard review plans, technical 20 specifications.
21 With regard to the regulations, there aren't a lot 22 of codes and standards that are endorsed through the 23 regulations but those that are are of course requirements.
24 In particular, the most important one is 10 CFR, 50.55(a).
25 The codes and standards rule picks up the boiler and ANN RILEY & ASSOCIATES, LTD.
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11 1 pressure vessel code, which I will refer to a little bit 2 later.
3- Next slidc, please.
4 COMMISSIONER ROGERS: Just before you leave that, 5 was there anything else that came out of Public Law 104.113 6 in addition to what was in the 1993 revised OMB circular ,
7 that affected us?
8 MR. MILLMAN: No, it was just. those three points:
9 use the standards, participate on the committees, and you 10 can take an exemption but you have to report to OMB.
11 I believe those were the only three provisions.
12 Next slide, please. ,
13 As I noted, endorsement of codes and standards be 14 regulation is not a major path in terms of numbers but it is 15 in terms of importance.
16 What I have identified here is a typical I
17 rulemaking path that is outlined in terms of a significant 18 questions of policy, and I say that because it requires the 19 review and approval of the Commission for issuances.
20 Now the EDO does have delegated authority for 21 issuing certain types of rulemakings that are not of a 22 significant question of policy. In such a case the EDO 23 would approve the rulemaking for issuance. The Commission 24 would be notified through a daily Staff note, and the 25 forwarding to the Federal Register would be held fer five s
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i 12 1 days while the Commission reviews that action.
2 Now the Administrative Procedures Act requires 3 that there be a notice of proposed rulemaking and that the 4 opportunity for public comment exists, and we do this on an 5 natural basis.
6 The regulatory process here is a two phase 7 process -- first, proposed rule, separated by a public 8 r comment from the final rule. j 9 Now in the context of this slide, I would like to 10 overlay the concept of a regulatory guide, which is another 11 mechanism for endorsing codes and standards.
12 The regulatory guide takes the same two-step 13 process -- draft regulatory guide, final regulatory guide, '
14 separated by the public comment period. !
15 The one major difference is the level of approval. l 16 The draft regulatory guide is approved, first of all, the 17 Office of Regulatory Research is responsible for issuing all 18 regulatory guides. The draft regulatory guide can be issued 19 for public comment under the signature of the cognizant 20 Reeearch Division Director.
21 The final regulatory guide would be issued under 22 the signature of the Director of the Office of Research, so 23 that is the process of how we endorse codes and standards 24 through a regulation and through a regulatory guide.
25 Next slide, please. .
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1 MR. MILLMAN: Since some of the discussions that 2 follow pertain to the ASME code, I would like to take a 3 moment to briefly overview the code.
4 The ASME Boiler and Pressure Vessel Code has 11 5 sections, two of which are nuclear sections. The nuclear 6 sections are Section III, which deals with construction of 7 nuclear power plant components; and Section 11, which deals 8 with the inservice inspection, ISI, and the inservice fi 9 testing, IST of the Nuclear Power components.
10 Section III and Section XI are mandated for use by 11 10 CFR.50.55(a). This has been accomplished since 1971.
12 Addendas to the Boiler and Pressure Vessel Code i
13 are issued every three years. Addendas are issued every 14 year.
15 The next element of the Boiler and Pressure Vessel 16 Code is a code case. You might have heard of code cases.
17 Sometimes they are confused with interpretations.
18 A code case is an alternative to the Boiler and 19 Pressure Vessel Code. It is generally specifically written 20 as an alternative to a specific paragraph of the Code. In 21 lieu of doing something for paragraph so-and-so, may I do '
22 this -- and they will provide the guidance for doing that.
23 The code cases undergo the exact same approval 24 process within the code as the basic code does itself.
25 The code cases that come out of the Boiler and n
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. . I 14 I 1 Pressure Vessel Code are endorsed in three regulatory 2 guides. One guide addresses construction cases, another 3 guide addresses material cases and another guide addresses 4 inservice inspection, inservice testing issues.
5 Code cases are issued four times a year. Now that 6 is one of the reasons that sometimes code cases are written 7 to implement a new provision to the Code, because they come 8 out four times a year, whereas opposed to the Code being [
9 revised only once a year. Code cases come out more 10 frequently.
11 An interpretation now is a clarification to the 12 Boiler and Pressure Vessel Code. It is not part of the
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13 regulations and NRC is not bound by the interpretations.
1 14 The interpretations are issued formally twice a year by the 15 ASME. However, once an interpretation is approved by the 16 Committee, that interpretation, the response to the 17 interpretation is sent to the inquirer and is i- plementable {
18 immediately -- so anyone that's aware of the issuance of 19 that letter to the inquirer can issue the interpretation 20 virtually on the spot within a week or two after the 21 interpretation is approved.
22 CHAIRMAN JACKSON: Let me ask a question about i
23 that.
24 MR. MILLMAN: Yes.
25 CHAIRMAN JACKSON: How do you keep track of them
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ll 15 1 and to what extent are these interpretations relied upon by 2 our licensees as well as by the NRC?
3 MR. MILLMAN: They are relied upon. They are 4 clarifications to the Code.
5 Generally the Staff and the ASME or in agreement 6 with what the interpretations say, there are very few 7 interpretations that are potential differences between the f
8 Staff and the ASME committees. j 9 Every once in awhile one does come out, but they 10 are relied upon very heavily. They are relied upon in the 11 field by the inspectors. The licensee may point to an 12 interpretation that would influence the way the Code would I
13 be implemented at that utility site, so they are relied on 14 very heavily.
15 CHAIRMAN JACKSON: So what is enforceable?
16 MR. MILLMAN: Generally, I believe the staff at 17 the site would go along with the interpretation. If there 18 is a conflict in that interpretation we now have an 19 inspection manual section that says bring that difference to 20 headquarters for resolution -- it's Part 9900.
21 CHAIRMAN JACKSON: Brian, you wanted to say 22 something.
23 MR. SHERON: Yes. I would just like to add that 24 this issue has come up recently.
25 We have taken a position that interpretations that ANN RILEY & ASSOCIATES, LTD.
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16 1 are made subsequent to the Staff endorsing the Code we do 2 not believe are part of what we had approved.
3 In other words, it's after the fact. As Gil said, 4 I think in most cases we go along. We agree with the 5 interpretations that the Code does provide because it's 6 basically a clarification that sometimes is needed.
7 We have written a letter to our regions. I think f
8 I signed it out probably over a year ago in which we told 9 the regions that if in the course of doing an inspection 10 there is a question raised regarding implementation of the 11 Code and an interpretation that it should be referred back 12 to the headquarters office and we would try and resolve it ,
t 13 then.
14 So that is basically the position we have been 15 following since this whole issue came up with regard to 16 interpretations.
17 CHAIRMAN JACKSON: Commissioner McGaffigan?
18 COMMISSIONER McGAFFIGAN: I would like to follow 19 up. This might be the right time to ask a question I was 20 going to ask later and the industry folks should feel free 21 to respond after the Staff, but one of the concerns that we 22 got from ASME in the context of the direction-setting issue 23 paper was that little consideration has been given to the 24 need to streamline and simplify NRC's internal process and 25 regulatory process to be able to endorse nuclear codes and 6
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17 1 standards within a year after they have been issued by the 2 ASME.
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3 It sort of goes to the last couple viewgraphs.
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, 4 Our processes, whether it is a reg guide or a 5 rulemaking, take years. They go on the second page. In 6 their processes you are talking about quarterly updates and
- 7 there's a difference in time constants.
8 Has the Staff given any thought to how to bring 9 these time constants into better alignment or resolve this j 10 concern that ASME has expressed to us in the strategic 1
11 assessment process?
12 MR. MILLMAN: The Staff has given thought to that l
13 very consideration. We haven't come up with a conclusion on 14 how to speed up our process because built into our process 15 is this public comment period and going out for public 16 comment and resolving the comments you are kind of built 17 into a two-year timeframe. I 18 COMMISSIONER McGAFFIGAN: They suggest doing some 19 things concurrently rather than seriatim. The same time the 20 codemaking is being done we would try to get the two 21 processes at least to be parallel.
- 22 MR. MILLMAN: I believe that the Staff would be in 23 agreement to try and speed up the process. How we would do
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24 it is yet to be determined but we agree that the process 25 needs to be speeded up.
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- 18 1 MR. JORDAN: For the Staff, as the author of the 2 DSI-13 --
3 [ Laughter.)
4 MR. JORDAN: -- we certainly do have an interest 5 in developing ways to make those reviews a lot more timely 6 so the implementation phase of that DSI will clecrly address 7 that. I recognize it is a problem and feel that we will fix 8 that problem.
9 CHAIRMAN JACKSON: Ms. Ling, you wanted to make a 10 comment.
' MS. LING: Yes. I appreciate bringing up the ASME 12 request that the endorsement of ASME codes and standards be ,
i 13 expedited.
14 I would like to make a comment on a response to 15 your question, Chairman Jackson, on interpretations. .
16 Recently we did convey ASME's position on k
17 interpretations to your Staff and basically that position is 18 that as Mr. Millman stated, interpretations do not make new 19 rules -- do not establish new requirements.
20 They are intended to purely clarify existing 21 requirements.
22 On that basis ASME is the only official 23 interpreter of the code requirements since we are the 24 developer of the code requirements.
25 But what was also agreed was that should ASME i
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. . I 19 1 issue an interpretation that was contrary to the intent of 2 the regulatory process in adopting that particular set of 3 requirements, then that is purely within the realm of the 4 regulatory process.
5 With that again, as Mr. Sheron mentioned, the 6 number of interpretations -- we issue probably I would say 7 in all of our codes and standards activities about 30,000 8 inquiries to our documents a year. ,f 9 When you narrow that down to the official 10 interpretations issued in writing to the Nuclear Sections of 11 the Boiler Code we are probably talking a few hundred per 12 year, and in all of the years of our interpretations there ,
L 13 were perhaps maybe less than 10 that fell into the area of 14 where ASME might have issued an interpretation which the 15 regulators felt was contrary to their intent when they 16 adopted that particular requirement.
17 CHAIRMAN JACKSON: Thank you.
18 What in fact is the latest edition of the ASME 19 Boiler and Pressure Vessel Code, and what is the latest 20 edition endorsed by reference in our regulations?
21 MR. MILLMAN: The latest edition referenced in our '
22 regulation is the '89 edition for Class I, II and III 23 components. For containment structures, for ISI containment 24 structures it is the '92 edition with the '92 addenda.
25 The latest version out is the '95 edition with the IJUi RILEY & ASSOCIATES, LTD.
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8 20 1 '96 addenda.
2 We are presently in rulemaking, preparing 3 rulemaking to pick up that latest version.
4 CHAIRMAN JACKSON: And when do we erpect that that 5 rulemaking might be completed?
6 MR. SHERON: Right now there's two options in 7 terms of how to proceed with a rule.
8 These are being finalized by the Office of I i
9 Research and I believe it would be presented to the 10 Committee to review generic requirements probably within the 11 next couple months, so hopefully we would get this out by !
12 springtime, something for public comment.
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13 CHAIRMAN JACKSON: Okay.
14 MR. MILLMAN: Next slide, please.
15 CHAIRMAN JACKSON: I have one last question. j
. l 16 Have we made any judgments on the safety aspect of l l
17 changes to the Code since the last endorsement by the NRC in l 18 regulations, since you are talking at least for part of it 19 for components, Class I, II, III. You are going back, going 20 on eight years.
21 Have there been any judgments in terms of safety 22 impact?
23 MR. SHERON: Yes, there's two areas I would point 24 out.
25 One of the things we are doing right now as part I
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21 f 1 of the rulemaking is going through the new, the '95 edition 2 and trying to ascertain which items we think are very ,
3 important to safety.
4 One is Appendix 8, which was the performance 5 demonstration -- initiative on inservice inspection, and 6 that is one which we wor.1d like to see required like 7 immediately -- in other words, not wait for the 10-year ISI 8 update that each plant -- I don't know if you recognize it.
9 Plants have to update their programs every 10 10 years and at that time when they update they would have to 11 adopt the latest version of the Code. We think the :
12 performance demonstration program, Appendix 8, is very ,
i 13 important in terms of finding flaws and so forth and we"have 14 a generic letter out on it right now and we are proposing i
15 that in implementing the rule this would be something that
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16 licensees would have to implement very soon. >
17 An area where we found we had difficulties is the I 18 new pipe and design area. The rule has promulgated new ,
19 piping design criteria for pipes which the Staff has taken i 20 objection to. We just don't agree with them.
21 We had a number of technical concerns. These were 22 ultimately sent to the ASME in a joint letter signed by Mr.
23 Beckjord and Dr. Murley several years ago.
i 24 The ASME is taking this along with other new i 25 information and is reassessing. There is I believe a special ANN RILEY & ASSOCIATES, LTD.
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I, 22 1 working group or task group which the NRC is working with 2 them to try and resolve what these differences are, but 3 these are two examples where we have gone through.
4 One we think is very important and we are I
5 endorsing it for early implementation. The other is where 6 we have disagreements and we are not endorsing it.
7 CHAIRMAN JACKSON: Well, referencing Commissioner 8 McGaffigan's earlier question and given what you just said, f'
9 do you, you know, in a systematic way parse the additions or 10 addenda relative to their safety and risk significance and 11 give attention to them on that basis in terms of expediting 12 perhaps portions of them?
l 13 MR. MILLMAN: Well, up to the '89 edition we were 14 mandating use of the total edition and addenda and even in 15 that '89 edition we did perform a regulatory analysis that 16 distinguished between administrative and editorial type 17 items of a medium cost benefit and items of a very [
18 significant cost benefit, which in that particular case 19 happened to be a reactor vessel exam.
20 We did do a regulatory analysis, a full regulatory 21 analysis on the reactor vessel examinations. We are still 22 working on this very next edition and very next amendment 23 and the concept of the backfit rule has come into 24 consideration.
25 Prior -- the '89 edition we didn't worry about the ANN RILEY & ASSOCIATES, LTD.
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. . i j 23 I backfit rule. It was an automatic backfit from years 1971 i 2 on. Now we are considering the impact of that and the Staff 3 is puzzling through how to handle it.
4 CHAIRMAN JACKSON: Doesn't that again suggest that 5 a parsing based on risk significance is all the more 6 relevant?
7 MR. MILLMAN: Well, there's another thought that 8 you have to put into this and that is this is not like a f
9 requirement that's being written by the staff.
10 CHAIRMAN JACKSON: Right.
11 MR. MILLMAN: It's written through an engineering 12 society, industries participating, and regulatory ,
i 13 authorities are participating, so it's another concept and 14 we have to figure out how that works into the process.
15 MR. MURPHY: I think it's important to point out 16 that there are two options that we're studying right now. l 17 In the one case, we're taking the various portions of the 1 18 Code that are changing and we're looking at each one of them 19 and we're doing a regulatory analysis on it to do just what 20 you said, to assess the safety significance of it.
21 The other option, and one option would be to 4
22 approve only those we feel have a high safety significance.
23 The other option is more geared to what we have done in the 24 past in approving the Code, changes in their entirety.
25 Whichever option we choose, and they have ANN RILEY & ASSOCIATES, LTD.
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. . i 24 1 strengths and weaknesses both ways which we're still 2 analyzing, we will have the benefit of that regulatory j 3 analysis that's been done on each portion of the Code, so 4 we'll know what's important and what's not. I think more 5 importantly, we know what's critical to do in a reasonable 6 time frame.
l l
7 Many of the Code changes are relaxations, but 8 some, as Dr. Sheron has indicated, are very important and we f
9 need to proceed. So we will have that background. No 10 matter which option we select, we will have the results of 11 that regulatory analysis and that is essentially complete i 12 now, so we're moving ahead at a reasonably fast rate. ,
t 13 CHAIRMAN JACKSON: I get the impression that' 14 Commissioner McGaffigan has a follow-on question. ,
1 15 COMMISSIONER McGAFFIGAN: Well, again, one of the ;
l 16 comments we got from NEI, which is slightly different, has i 17 to do with increasing margins of safety through selectively 18 picking which Codes we're going to endorse and which not.
19 I'll just read it, you guys probably are familiar with it, ,
20 "Under such circumstances, it should be expected that l 21 codification of practices that go beyond assuring adequate 22 safety, that go instead to achieving operational excellence, 23 will not occur. Industry cannot be expected to contribute 24 through codes and standards activities to the growth of the 25 margin of safety which will be required by the regulator."
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i 25 1 I'd just be interested in your comment on that 2 because I think it's pertinent to these two options probably 3 that you're thinking about in this Code and in general. Is 4 there an industry perception that our approach to Code 5 development is constantly one where we're increasing margins 6 of safety that get no relief from anywhere else?
7 MR. SHERON: I would say no. I don't think there i
8 is a uniform feeling from the industry. What we were [
9 concerned about in these two approaches, is one is where you 10 go through let's say the latest edition of the Code and you 11 look at each item and determine if there is a substantial 12 improvement to safety that meets the backfit rule.
[
13 We find that there is a lot of improvements that 14 may be more administrative in nature. They may enhance the 15 ISI Program administratively, but may not contribute 16 directly to increased safety.
17 What we have heard from some utilities is that by 18 imposing the entire new version of a Code, you are imposing 19 all of these administrative requirements which they may say 20 for us, it is not beneficial to adopt them and you're 21 costing us money because we have to change procedures, we '
22 have to retrain our technicians, et cetera, et cetera. This 23 is a burden to us and it's not cost justified.
24 The other side of the coin is that when you start 25 going through these editions of the Code, like the 1995 ANN RILEY & ASSOCIATES, LTD.
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- 26 1 edition, and you start categorizing each one and it's 2 somewhat important, administrative, or you shouldn't do it, 3 what the concern is that then you've created a menu in which 4 a utility can go in now and say, well, I'll adopt this, this 5 and this, but I won't adopt that, and what they wind up with 6 is an ISI program that nobody can trace back to anything.
7 That's a concern on a lot of the staff that you 8 have now this program in which they've picked some parts of 9 the 1989 version, some of the 1995, something in between, 10 and to have that traceability so an inspector goes out and 1 11- can say, are you following the Code and what is your Code of 12 record. Now there is no Code of record; it's several Codes.
i 13 That's the other side of the coin and we're trying to deal )
l 14 with that. We're still struggling a little bit.
15 CHAIRMAN JACKSON: So that's what you mean when 16 you say that you haven't totally worked out how the kind of 17 cost benefit analyses that what, 10 CFR 50.109, require, 18 apply in this context and how you go about parsing, but 19 nonetheless, you are looking at the parsing issue and how it 20 relates to the safety?
21 MR. SHERON: Yes.
- 22 CHAIRMAN JACKSON: Because that's important. !
23 l Okay, thank you. '
24 MR. MILLMAN: Next slide, please.
25 CHAIRMAN JACKSON: Are we still talking about --
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27 1 one last one -- this ASME Section 3 that relates to l j 2 construction. This is one of those hidden bomb questions. .
' I 3 Are all currently operating nuclear plants constructed to ;
1 i
4 that standard? l l
5 MR. MILLMAN: To Section 3? l l
i 6 CHAIRMAN JACKSON: Right. ;
7 __. MR. MILLMAN:- .No.
8 CHAIRMAN JACKSON: So what then applies, what 9 regulations govern plants that are not? j 10 MR. MILLMAN: I don't know what the regulation --
] 1 l
11 CHAIRMAN JACKSON: I told you what it was.
12 MR. SHERON: I believe there are a number of .
13 different standards that were applied prior to plants that 14 adopted Section 3. We could get you a list. I don't know l j 15 whether anyone on the staff --
16 MR. MILLMAN: In terms of the standards, it's 17 B31.1, ASME B.31.1. '
18 CHAIRMAN JACKSON: You don't have to give the
}
19 litany here, but the real question I have is -- you've 20 answered the first part of the question, so given that 21 answer, the issue is how broad-based it is and I'm going to 22 come to you in a second and do a we clear. You mentioned a 23 kind of a problem for our inspectors relative to another i
24 question, but if now we have this ASME standard and you have 25 plants not built to it, what clarity is there as to what l
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28 1 governs their situation. Dr. Shao?
l 2 DR. SHAO: My name is Larry Shao, Director of 3 Division of Engineering Technology. ,
1 4 Depending when the plant was built and 5 constructed, Secticn 3 was issued in 1963. Before Section 6 3, ASME Code Section 3, there were two codes. One is 7 B.31.1, Power Piping Code. There's another one called 31.7, 8 Nuclear Piping. So if the plant is built before that, it [
9 was built to B.31.1 or B.31.7 and when the ASME Code Section .
l 10 3 came out, then all the plants were built to ASME Code 11 Section 3.
12 CHAIRMAN JACKSON: How were they different from
{
13 ASME Code --
14 DR. SHAO: Actually, B.31.1 was a little bit more 15 conservative than the ASME Code. For instance, the 16 allowable stretch is one-quarter of the ultimate and for 17 Section 3, the allowable stretch is one-third of the 18 ultimate.
19 CHAIRMAN JACKSON: What about B.31.7?
20 DR. SHAO: B.31.7 is essentially the same as ASME 21 Code Section 3. .
22 CHAIRMAN JACKSON: Okay. So maybe you could just 23 send the information to the Commission relative to how these 24 things fall out across that line. Okay, thank you.
25 MR. MILLMAN: Slide 9, please. We've addressed ANN RILEY & ASSOCIATES, LTD.
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. , i 29 1 much of what's on here. I'll just go to the third bullet.
2 There is this 120-month update that we've talked about. One 3 thing that we haven't mentioned is the fact that 10 CFR 4 55(a) endorses or actually references three regulatory 5 guides, the three regulatory guides that I mentioned 6 previously that endorse the Code cases.
- 7 In addition, 55(a) incorporates by reference the 8 IEEE Standard 279 which is Criteria for Protection Systems. f 9 Other IEEE standards are normally endorsed through the 1 10 regulatory guide process. l l
11 Next slide, please.
12 CHAIRMAN JACKSON: Not so fast. Commissioner I
{'
13 Rogers?
14 COMMISSIONER ROGERS: I wandered if you'd give us, l
15 just very quickly, some examples of limitations and l 16 modifications that we've imposed.
17 MR. MILLMAN: The last one we had imposed -- first 1 i
18 of all, let me say that we've imposed like eight in 25 19 years, so it's not a whole bunch. The one that comes to my 20 mind off the top is the last one was on containment 21 isolation valves, the method that was being treated in the 22 particular version of the Code, we didn't feel properly 23 addressed the evaluation of leakage data. We required that 24 a specific version of the Code be used rather than the one 25 that it was contained in.
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- - - . - - ~ . . _ . -. .
. . I 30 1 Others addressed the examination categories for 2 piping. None of them I would put into a major category.
3 Offhand, I can't think of others.
4 CHAIRMAN JACKSON: Let me ask you a question about 5 your view graph 9, the one on the scope of 10 CFR 50.55(a).
6 You mentioned that it incorporates by reference the IEEE 7 Standard 279 and that other IEEE standards are endorsed by 8 reg guides.
f 9 Does this mean that -- first of all, has that i l 4
10 standard ever been updated or superseded? '
11 MR. MILLMAN: It will be. There is action being
- 12 taken to use IEEE Standard 603 in lieu of 279. That !
[
13 rulemaking is being initiated.
14 CHAIRMAN JACKSON: That's Criteria for Safety
]
1 3
15 Systems?
16 MR. MILLMAN: Right.
17 CHAIRMAN JACKSON: Okay. How old is that l j 18 standard?
19 MR. MILLMAN: Which one?
, 20 CHAIRMAN JACKSON: 279?
21 MR. MIGLIARO: Actually, if I can answer that, '
22 IEEE 279, the last edition was 1971, but it has been 23 withdrawn for a number of years by the IEEE, so it is no 24 longer an official IEEE standard.
25 CHAIRMAN JACKSON: Okay, but at the moment that's ANN RILEY & ASSOCIATES, LTD.
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i-31 1 still --
2 MR. MILLMAN: That's the one in effect.
' CHAIRMAN JACKSON: And you're saying there's a 4 rulemaking to replace 279 by 603. I see there's someone 5 here who wiehes to speak.
6 MR. AGGARWAL: Satish Aggarwal from Research.
7 Madam Chairman, I'd like to point out that we have already r
8 endorsed IEEE Standard 603 by issuance of effective guide !
9 1.1.53. As far as the staff is concerned, this is already 10 replaced but we are now proceeding in the rulemaking to 11 change that particular paragraph to IEEE Standard 603.
12 CHAIRMAN JACKSON: Okay. So 279 is the only
[
13 electrical standard that is in actual regulatory 14 performance?
15 MR. AGGARWAL: That is correct. That is the only 16 standard.
17 COMMISSIONER McGAFFIGAN: Could I ask a question?
18 On something as simple as that, when did we send that letter 19 saying the staff endorsed the 603 or whatever? When was 20 that action taken?
21 MR. AGGARWAL: That regulatory guide was issued in 22 June 1996.
23 COMMISSIONER McGAFFIGAN: In June of last year?
24 MR. AGGARWAL: Right.
25 COMMISSIONER McGAFFIGAN: I'd urge that we get on ,
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i 32 1 with something like that. I doesn't sound like a big 2 package that has to come to the Commission.
3- CHAIRMAN JACKSON: It's more complicated than it B 4 seems but it still begs the question in terms of the 5 timeliness with which the changes are made because the 6 question I had was you have these standards that have been 7 endorsed in reg guides and then you have this overall 8 electrical standard, I really don't know because obviously f 9 the Commission is not into the details of it, but I note 10 that you have a standard relating to digital computers and 11 one related to criteria for safety systems.
12 We know that a number of licensees are making
[
13 digital upgrades to various systems in their plants, 14 presumably they have interactions that cross these 15 boundaries of these various standards. So I think there's 4
16 some lack of clarity, at least that I have, in terms of how 1*/ the replacement of one standard in our regulation plays off 18 of the various standards that may be endorsed in the reg 19 guides and how they all interact with each other. To me, I 20 don't know what it all means, so maybe you can provide some 21 more clarity to the Commission.
22 MR. OLMSTEAD: Or some more complexity.
23 CHAIRMAN JACKSON: Well, sometimes clarity 24 involves complexity.
25 MR. OLMSTEAD: Right. I think one of the things ANN RILEY & ASSOCIATES, LTD.
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i 33 1 that complicates this is that the Federal Register abhors 2 incorporation by reference.
3 CHAIRMAN JACKSON: Yes.
l 4 MR. OLMSTEAD: So we have to play a lot of little I l
5 procedural devices in order to get these codes into the l 6 regulations and that takes time. So the endorsing process 7 through the reg guides is quicker, but our change in the i
fI 8 regulations lags that because we can't just incorporate the ;4 9 reg guide by reference and then change the reg guide because 10 the Federal Register won't approve that.
11 I think a lot of the problem you're having is the 12 kind of procedural devices we have to go through in order to I
13 get it actually in the Code of Federal Regulations which is ;
t 14 saying something different than that's what the staff is ,
15 enforcing because what they're enforcing is what they've 16 approved.
17 CHAIRMAN JACKSON: What's in the regulation.
18 MR. OLMSTEAD: And in the reg guides.
19 CHAIRMAN JACKSON: The reg guides don't have 20 enforceability.
21 MR. OLMSTEAD: That's right but they do have 22 interpretive force. We have to treat those, particularly 23 under this new rulemaking process, we have to send that down 24 to OMB and to the Congress, and do all these other things 25 just as we do the regulations. .
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I 34 1 We have to be real careful with this incorporation 2 by reference problem because the Federal Register wants the 3 public to be able to read this and know what the current 4 edition is. They don't want us using in the reg guide 5 process to endorse a standard that's not here.
6 CHAIRMAN JACKSON: Let me ask a question to you 7 and put it this way. Does our method of endorsement matter 8 in regulatory space and how does it matter?
[
9 MR. OLMSTEAD: It matters because we have to be 10 careful to comply with the Office of Federal Register 11 requirements for our regulations.
12 CHAIRMAN JACKSON: No. I'm talking about from the
[
13 point of view of how we carry out our regulatory program.
14 MR. OLMSTEAD: No. That is an ultimate safety 15 decision, I think. We will find a way to get it in the 16 regulations, depending on what the safety decision is. I'm 17 just telling you, historically it's been a problem to get it 1 18 into the Code of Federal Regulations because of the 19 incorporation by reference problem, but I don't think it's a 20 safety problem.
21 COMMISSIONER McGAFFIGAN: Could I ask, is this a '
.-l 22 problem that other regulatory agencies face as well that try )
23 to use codes?
24 MR. OLMSTEAD: Absolutely.
25 COMMISSIONER McGAFFIGAN: And has anybody ever ,j 1
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l il 35 l 1 gone to the Congress and said, do you really mean it here?
! 2 MR. OLMSTEAD: Yes.
! 3 COMMISSIONER McGAFFIGAN: Or can we step back.
4 MR. OLMSTEAD: I think the whole purpose of 'll 5 passing this Act was referenced a little bit earlier, that 6 says agencies will incorporate the industrial codes and 7 standards, was an effort by Congress to address this problem l
ri 8 and we're hopeful that in working with OMB, we'll get some l 9 relief on that, but we're in the process -- l 10 COMMISSIONER McGAFFIGAN: So it isn't a statutory 11 problem any longer; it's a problem with OMB and what they - l 12 -
[i 13 MR. OLMSTEAD: And working out with the Offic'e of 14 Federal Register how we're going to incorporate industrial ,
15 codes and standards when they change as rapidly as they do 16 because the Federal Register process is a slow process. I'm 17 not trying to make it more complex.
18 CHAIRMAN JACKSON: No, you're just trying to 19 explain it the way it is and as far as we all understand. I 20 guess my issue really has to do with given the speed of 21 changes and our method of endorsement, what operational --
22 operational in the sense of our carrying out our program --
23 what happens in enforcement space, how we interact with our 24 licensees, et cetera, what impact does this have? Reg 25 guides are that, are they not, they're guides)
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i 36 1 MR. SHERON: They're an acceptable way to 2 implement a regulation.
3 CHAIRMAN JACKSON: So if there is an issue or some ..
4 disagreement with a licensee, then we fall back on the 5 safety argument. Is that the whole point to come around the 6 fact that something may or may not be codified in the 7 regulation?
r 8 MR. SHERON: Ultimately, we have to make a l 9 decision whether there is a violation the regulations or 10 not, if there is a different way of doing something. That's ,
11 why we issue the reg guides, to provide guidance on an 12 acceptable way for the utility to meet the regulation.
[
13 I don't think, though, that this causes a big 14 problem. The utilities are not, I don't think, anxious to 15 go changing their in-service inspection and testing programs 16 very rapidly because it is very expensive to do it.
17 CHAIRMAN JACKSON: Right.
18 MR. SHERON: I think they would like to see some 19 quantum step changes made and then they would go and 20 implement a whole new program.
21 CHAIRMAN JACKSON: I see. Commissioner Rogers?
22 COMMISSIONER ROGERS: Yes. Is there a problem 23 with cur holding up really finalizing everything with ,
l 24 respect to a rule that would incorporate by reference a 25 standard because we can't get it published in the Federal
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i 37 1 Register with just a reference to that? In other words, is 2 there a disconnect there that we have everything in place, 1
3 we know what we want, it's a reference to that standard, the !
,1 4 rule would so state, but it can't be published in the ;
5 Federal Register because of this other problem?
6 Knowing that, does that hold us back from making 7 it clear what our rule actually is?
r 8 MR. OLMSTEAD: Not for the simple changes. For l 9 the ones the staff comes in and says, all we want to do is 10 update the standard here, we don't see any problem, we have 11 a mechanism to do those rule changes very fast. As a matter 12 of fact, those don't even come to the commission; they're
(
13 approved by the EDO and the rulemaking process can be done 14 in 90 days.
15 But for those where there is some disagreement 16 within the staff about what sections of the Code to apply, 17 you're going to have commentors coming in with disagreements 18 with the staff and that's going to have to be resolved.
19 Those are the cases I thought we were focused on which is 20 why we're not taking the whole Code and just updating the 21 reference, we're actually picking and choosing what portions '
22 of the Code we want to incorporate. Those are the more 23 difficult cases.
24 CHAIRMAN JACKSON: Well, with us having slowed you 25 down, we're going to ask you to speed up.
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. . i 38 1 MR. MILLMAN: We've covered page 10, Endorsement >
2 of IEEE Standards. The consensus process, I'll cover very 3 rapidly.
4 The consensus process, slide 11, is something we 5 live with when we're writing these consensus standards.
6 It's administered by ANSI, it's implemented by the 7 particular SDO and the consensus process, taken as a whole, 8 is intended to provide the majority view but it protects the f
9 individual vote.
10 I have to say that vigilance is required on the 11 part of all participants to ensure that the process is 12 implemented squeaky clean. One of the items, balance of I
13 categories of interest, what we talk about there is within 14 the Consensus Committee, there are designers, constructors, 15 regulatory inspectors, insurance. Within that regulatory 16 block, there's only one or two people. Within the utility 17 owner block, that's usually up to the max of one-third of 18 the committee.
19 So although you're talking about balance of 20 interest, in terms of the number of votes in any one of 21 these blocks, the NRC is a single vote in the process and 22 that needs to be clear.
23 CHAIRMAN JACKSON: That's interesting. So what 24 then does substantial agreement mean?
25 MR. MILLMAN: Substantial agreement means two-ANN RILEY & ASSOCIATES, LTD.
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39 1 thirds vote within the Consensus Committee, but understand 2 that the balance of interest plays a part in this.
3 CHAIRMAN JACKSON: That's why I asked the 4 question. :
5 MR. MILLMAN: Yes, I understand. Next slide, 6 please.
7 Nomination process for staff committee members, t
8 generally speaking, a letter comes in asking for staff jl i
9 participation or we initiate the letter. The important 10 thing about this letter is, which is signed out by the 11 Director of the Office of Research, the letter nominates an 12 agency representative and in that letter, it uses the words I
13 from the OMB circular which states, " Staff participation 14 does not connote agency agreement with committee decisions."
15 So although the individual is there doing his best 16 to put forth the agency view, the agency is not necessarily 17 committed to what comes out of the decision process. The '
18 letter that goes out from Research is a nomination letter.
19 The SDO votes on all nominations for acceptance. Next 20 slide, please.
21 Staff, committee member responsibilities, these, '
22 again, are defined by OMB Circular A-119, "Be An Active 23 Participant." Participate on the basis of equality. That 24 means don't let the agency's influence dominate the process.
25 That's something we cannot permit to happen for this to be a ANN RILEY & ASSOCIATES, LTD.
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i 40 1 fair process.
2 Views expressed should not be inconsistent or in 3 conflict with established agency views. To do this, it 4 means a lot of homework on the part of the committee 5 representatives, that they're able to understand what the l 6 views are and to express them.
7 Now, down at the level of developing the 8 standards, there may not be a specific agency position. For 9 example, on the Code cases on risk informed, we know that 10 the agency is moving forward to risk informed, but we 11 certainly don't know every step of the Code case what the 12 agency position would be, so the staff makes best judgments ,
t 13 along the way.
14 Page 14, I'll pass. That's just an organizational 15 chart showing where the consensus committees are. The 16 committee items that are identified as committee are the 17 consensus committees where the balance of interests actually i 18 takes place. Slide 15, please.
19 This is just an example of the ASME Section 11 20 committees. It's a very intense four days of meetings which 21 is where all these committees meet. The process starts out
- 22 at the working groups on Mondays and works up to the i i
23 subcommittees on Thursdays. There has to be a lot of 24 coordination on the part of the committee members to j 25 understand what's happening at the lower committee so we can !
i 1
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. . i 41 1 establish some valid actions as the process moves forward.
2 Next slide, please.
3 The IEEE board and committees are similar to the l
l 4 ASME structure. The regulatory guides that endorse the IEEE I 5 standards that went final during this last year, those IEEE 6 standards came out of The Power Engineering Society. All 7 the standards that are in draft right now -- not the 8 standards, rather, but the regulatory guides that are in !
i 9 draft endorsing the IEEE standards on computer software came 10 out of The Computer Society. Next view graph, please.
11 This next view graph will provide a summary of 12 staff participation on the various SDos. As you can see,
[
13 the ASME has the most people, the most staff on the various 14 committees. I should indicate what "other" is. There is 12 15 other societies in there -- excuse me, seven other societies 16 -- The Association for Advancement of Medical 17 Instrumentation, The National Council on Radiation k 18 Protection and Measurements, The Instrument Society of 19 America, plus others. We have one or two people on each of 20' these committees.
21 Now, this totals 166, but it doesn't represent 166 j 22 individual people. For example, I'm on an ANSI committee as l l
23 well as an ASME committee, so I'm counted twice. Next 24 slide, please.
25 2his next slide shows the distribution of staff ANN RILEY & ASSOCIATES, LTD.
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. . I 42 1 participation from the various offices. This totals 142.
2 You can see from this chart that there's broad agency 3 participation. We estimate that this 142 staff represents a 4 little under 10 FTEs. Next slide, please.
5 Section XI and other documents within the ASME 6 process are living documents. The committee meets four 7 times a year and changes are made on a regular basic based 8 upon improvements in knowledge, improvements in technology, f 9 and this list provides an example of some of these revisions 10 that are important to the NRC. I'll just go through a 11 couple.
12 The very first one, the Section XI code case for
(
13 thermal annealing reactor vessels is an important Code case 14 and was developed to assist a utility request for thermal 15 annealing.
16 What the Code case does is provide the stress 17 allowables that must be met during the thermal anneal to k 18 ensure the continued integrity of the reactor vessel. This 19 particular Code case was developed on an expedited basis 20 within the Code with considerable help from the NRC and 21 utilities.
22 Look down at the very last one, the operation and 23 maintenance of the O&M Code for pumps, valves and snubbers, 24 the O&M Code was originally put forth in 1990. It's been 25 modified since. We've got a lot of dedicated people from ANN RILEY & ASSOCIATES, LTD.
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43 1 the staff and from industry working on this process and they 1
2 haven't seen their document endorsed in the process yet. ;
i 3 The next amendment to 55(a) will incorporate the 4 O&M Code. The version that will be incorporated is a 1995 5 edition with the 1996 addenda. This Code would replace the 6 rules for IST that are presently in Section 11 and are 7 presently what is enforced. Next slide, please.
8 Current activities that are ongoing, as Dr. Sheron 9 previously mentioned, the Section III revision that we have 10 a problem with, dealing with the seismic design of piping, 11 is being revisited by the ASME, looking at new information 12 to determine whether those rules should be modified. ,
i 13 Both section XI and O&M have active code cases 14 being developed or code cases being developed actively for 15 risk-informed ISI and IST.
16 As.you know, the Staff is working with pilots to 17 implement risk-informed ISI and IST programs. These code 18 cases will come out, I presume. At some point they will be 19 evaluated for endorsement relative to the results of the IST 20 programs.
21 CHAIRMAN JACKSON: Of the pilots? '
22 MR. MILLMAN: Of the pilots, that is correct.
23 IEEE is just initiating a program to look at risk-24 informed criteria for design and application but that is 25 just a start and that's just being considered at this point.
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.e- .
44 1 Digital upgrades, electromagnetic and radio
-2 . frequency and interference and software reliability are all
'3 being considered in the context of criteria for replacements 4 :and upgrades and new applications.
, 5 Next slide, please.
6 Finally -- to the summary.
7 The first bullet really reflects the state of 8 activities. The NRC continues to rely heavily on the use of~
4
. 9 consensus codes and standards and the Staff continues to I,
10 participate actively with SDOs on current issues.
j 11 The second bullet is supportive of direction i
l- 12 setting issues -- 12 on risk-informed ~ performance-based
(
) 13 regulations and 13 on the role of industry.
! 14 The Staff plans to increase interactions with SDOs j
15 regarding the development of new codes, standards and j 16 guides, especially those which_will facilitate the
- 17 . transition to risk-informed, performance based regulations. >I 18 Finally, to address implementation of the Public 19 ' Law and the circular, RES will prepare an action plan to 20 . ensure NRC compliance with Federal law and policy guidelines i
j 21 for participation in the development and use of codes and
! 22 standards. The action plan will be submitted to the 23 commission for approval for implementation.
1
! 24 COMMISSIONER ROGERS: When?
I 25 MR. MILLMAN: The action plan would have to be t
i i 1
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II 45 i i coordinated with all other offices and this is an agency-2 wide program. I would think that between six to nine months 3 we would have some sort of a program that could move forward ,
4 to the Commission that would have been considered by the l l
5 other offices.
6 CHAIRMAN JACKSON: Why don't you come back with a 7 date that you think makes sense?
8 MR. MILLMAN- That's fine. [
9 CHAIRMAN JACKSON: Yes?
10 COMMISSIONER McGAFFIGAN: And could I ask Mr.
11 Jordan a question on his paper on DSI-13? The financial 12 resource requirements involved that have been guesstimated
[
13 as to what would be involved in carrying out the preliminary 14 review of the Commission were pretty substantial. I am 15 trying to understand, given that you have 142 people, 16 approximately 10 FTEs, why in order to do what you want to 17 do in terms of additional code work, why are -- I think the k 18 estimates were 20-25 additional FTEs -- that that would be a 19 two or threefold expansion on what we are doing now. Am I 20 misreading the resource estimates for DSI-13?
21 MR. MILLMAN: No , and it is front-end loaded. If 22 we were to implement that fully we would change the way we 23 do business and so it would be in the manner of developing a 24 process to speed up our interactions and intensify the 25 interactions, identify the codes and standards and guides ANN RILEY & ASSOCIATES, LTD.
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46 1 that we believe need updating because the updating process i 2 for the codes committees is extensive and time-consuming as 3
well, so it becomes an industry burden if there is a focus P f
4 that the NRC puts on code areas that don't presently have a focus that would need care and feeding. l 5
6 COMMISSIONER McGAFFIGAN: So it would be the 7 same -- under 42 people but a much larger percentage of 8 their time would be devoted -- f 9 MR. MILLMAN: The first year or two there would 10 have to be more time dedicated in order to get this moving 11 in the direction and speed we are looking for.
12 CHAIRMAN JACKSON: Dr. Paperiello, I am assuming I
13 they don't just have you sitting at the table for t 14 appearances sake. Therefore, the question I have for you is 15 where do these issues most impact the programs you are e
16 responsible for? ,
I have people that are on these i 17 DR. PAPERIELLO:
18 various committees, some of which we really haven't focused 19 on today such as the ANS and the Health Physics Society, the 20 Institute of Nuclear Materials Management.
21 We use a number of codes and one of the things 22 that hasn't been discussed is I would say codes we use but 23 from my knowledge we never endorse. We just see them being 24 used.
25 For example, almost all the procedures that are .
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r 47 1 used for measuring radiation by our licensees are found l
l 2 somewhere in a standard somewhere -- in an ASTM procedure 3 for water and waste-water, there are standards for doing l
4 alpha, you know, various types of spectroscopy and the like.
t 5 We do not really have people on any of those 6 committees. We use them. It's sort of almost that's the way 7 you do business.
l 8 If we get involved -- to the extent to which we l t 9 get involved with regulation of DOE many of our standards ,
10 are going to have to be updated -- almost all of the 11 Division III regulatory guides -- and I would say about half 12 of the Division VIII regulatory guides are out of date. They ,
4 13 were written in the '70s and not really changed and our j 14 dosimetry has changed.
15 If we change over instead of revising them l .
l 16 ourselves, the fact of the matter is they haven't been 17- revised for lack of resources, if we have this done through '
l 18 a consensus standard it's going to involve a considerable l 19 amount of work.
l 20 It ought to be done that way because there is far 21 less expertise relative to the industry today than there was 22 when those guys were written 20 years ago.
23 There are other organizations where we don't l 24 interact with very much which we probably should -- for 25 example, the American Association of Physicists in Medicine ANN RILEY & ASSOCIATES, LTD.
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48 l 1 have probably on the order of 40 to 45 standards, not all of ,
2 which affect what we do but a number of which do. l l
3 In some cases we use standards but don't really l
4 acknowledge it. It's just as a practical matter. In other
! 5 cases we just don't use standards which are out there that 6 we probably ought to use. We do things on our own.
7 CHAIRMAN JACKSON: Should we be using standards or i
8 are there particularly critical areas where we use standards ;
l 9 that we haven't endorsed that we need to take a look at? !
l ,
f 10 DR. PAPERIELLO: Oh, I would say anything
- l 11 involving the use of -- where a guide was issued prior to l
12 1980 we need to take a look at the area addressed.
{
13 CHAIRMAN JACKSON: Now has this then been i
l 14 systematically assessed and have the resource estimates for 15 beginning to address some of this been folded into the 16 resource estimates of the Commission?
17 DR. PAPERIELLO: Yes. We have been interacting 18 with the people in Research who put together all these 19 estimates. Yes. ,
20 CHAIRMAN JACKSON: Okay.
21 MR. MILLMAN: And part of my answer really should 22 have been to broaden the codes effort further into the 23 materials area.
l 24 CHAIRMAN JACKSON: Okay. I think we should move l
l 25 along to the ASME presentation. i i
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1 I,
49 I 1 MS. LING: Madam Chairman, Commissioners, and 1
2 fellow attendees, I am honored to be here and to have this l
)
3 opportunity tt represent the American Society of Mechanical 4 Engineers. )
5 I would like to introduce two other people who are 6 here with me today.
7 The first is an elected officer of ASME, Mr. James 8 Perry. Jim is Chairman of the ASME Board of Nuclear Codes f 9 and Standards and holds the title of Vice President, Nuclear 10 Codes and Standards.
I 11 Also, an ASME staff person is here, Mr. Jerry 12 Eisenberg. Jerry is the Director of Nuclear Codes and ,
t 13 Standards at ASME. "
14 Next slide, please.
15 MS. LING: A brief overview of ASME. We were 16 founded in 1880. We are a 501(C) (3) nonprofit organization 17 and we are chartered in the state of New York.
18 Currently ASME has about 125,000 members. Most 19 reside in the United States but we do have members in 130 I 20 countries around the world.
21 We only have individual members. ASME does not i
22 have company nor corporate membership.
23 In addition to codes and standards, some of the 1 24 activities of ASME include education. We are heavily 25 involved in the accreditation of engineering curricula at ANN RILEY & ASSOCIATES, LTD.
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50 <
1 universities, and we also provide continuing education 2 courses in professional development.
3 In addition to that, our Washington, D.C. office 4 is active in government relations and basically their role 5 is to promote the positions and views of the engineering 6 profession to Congress and to state and local governments.
t 7 Another major activity of the society are 8 technical divisions. We have about 35 technical divisions 9 in different areas of discipline and a major activity in ,
10 that arena is technical papers on the emerging technology, I 11 international conferences, and regional conferences.
12 All in all, ASME has about 400 staff employees. ,
i 13 We have 10 offices around the United States and we are 14 headquartered in New York City.
15 Next slide, please.
16 This is a quick snapshot of codes and standards 17 development within the society. The ASME Council on Codes i 18 and Standards is the governing body for all codes and 19 standards and related accreditation programs.
20 We have about 600 published codes, standards, and 21 guides within ASME. The are administered and developed by 22 about 100 consensus bodies. There are about 4,000 23 volunteers who serve on these consensus committees 24 developing codes and standards.
25 We have about 43 engineer serving codes and ANN RILEY & ASSOCIATES, LTD.
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a 51 1 standards and I would note that many of our documents are 2 used and recognized in other countries and we accredit 3 manufacturers in 57 countries about the world.
4 Next overhead, please.
5 MS. LING: This overhead lists examples.of the 6 relationship between USNRC and ASME and I must say it has ;
7 been a very long and solid relationship since 1963, when the 8 first ASME code on vessels was published.
9 I won't spend-time on each of these bullets. I 10 would like to highlight the third one, and that is key to ,
l 11 our relationship, and from the questioning this morning it 12 is gratifying to hear that many of the questions and , ;
. I 13 discussions this morning have centered on the timely 1 14 endorsement of codes and standards, and truly ASME believes 15 this is essential for the entira process and to continue 16 credibility of our program.
17 Next slide, please.
18 CHAIRMAN JACKSON: Tell us -- will you be telling 19 us a little about your own process for establishing new 20 codes and standards and then how long does that process 21 typically take?
22 MS. LING: Okay. The process we have currently 23 for establishing codes and standards is that we would 24 receive a request from any source, whether it be industry, 25 whether it be government or whether it be an individual.
4 i
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1 That request would be evaluated by the Board on 2 Nuclear Codes and Standards and if it met certain criteria 3 such as, one, that there was a true need for such a
') 1 4 standard; two, that codification or standardization was the l
5 proper action -- perhaps it might be a singular case or case l
6 in which there is not an established response to the i 7 problem, in which case standardization would not be the 8 appropriate action; the third key is that there be available f
9 expertise out there in the industry and elsewhere to 10 establish the balance of interest that Mr. Millman has 11 stated was so essential to consensus, that there be 12 individuals from the manufacturing arena, the design area, i
13 the owner-operator area, the NRC, and Research, and public 14 interest, that we could form a committee that would 15 represent a balance of interests for the particular topic.
16 If those criteria are met, then ASME would engage 17 the project, establish a committee, and work would begin. k<
18 In the past and currently consensus is a long 19 process. To assure that all views are adequately 20 represented, to assure that the process is open to anyone, 21 and to provide for due process of any agreements the process
.l 22 can take a long time. l 23 Right now I would say our quickest time might be, 24 on a code case might be a few months. On revision to the 25 code it might be one year. On the long end we are talking ANN RILEY & ASSOCIATES, LTD.
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i 53 1 many, many, many years in ensuring that consensus has been 2 reached.
3 We are engaged right now in the process to 4 redesign the codes and standards development process What ;
5 we hope to achieve is the ability to develop new major 6 revisions within a one-year period of time.
7 What we hope to do is to streamline the process, r'
8 but once again adhere to the basic criteria of consensus ,
9 that the process be open, that there is due process engaged, 10 and that there is a balance of interests and representation 11 of consensus.
12 So with that we have engaged in an effort on
{
13 redesign recently. We hope to complete that process by the 14 end of this calendar year and we hope to have some pilot 15 programs going on next year under the new development 16 process. -
17 CHAIRMAN JACKSON: Okay.
18 MS. LING: Next slide, please.
19 Mr. Millman had spent some time speaking about 20 Public Law 104 and 113. There is also a proposed revision 21 of OMB A-119, which is currently out for public review and 22 comment.
23 I would note that in the revised OMB under the 24 definition of voluntary consensus standards bodies they have 25 incorporated the input of ASME that says again openness, ANN RILEY & ASSOCIATES, LTD. ,
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54 1 balance of interests, and due process are the essential 2 criteria in developing voluntary consensus standards. j 1
3 I think that is what sets us apart from other '
4 standards that might be developed by industry or industry
( 5 consortia. I I
6 Next slide, please. i l
7 This is a list of some current ASME initiatives '
8 and the first one I have just mentioned, our effort to 9 redesign the code development process.
1 10 Under the globalization of codes and standards I 11 would note that within the last 18 months I and many other :
12 representatives of ASME have met with other regulatory ,
, \
13 agencies and industries about the world.
14 I would note that one effort was with Korea and I
15 under a royalty agreement with the Korean Electric
~
16 Association they have taken Section III,Section XI, Section 17 V,Section IX of the ASME Code, have modified it to some i l
18 extent, and have adopted it as the Korean Electric Power 19 Industry Code.
20 We received word a few months ago that the 21 government has issued an ordinance that as of some time this 22 year all domestic suppliers will need to comply with the 23 KEPI Code, which is based on the ASME code.
24 Additionally, we have met with the Electric Power 25 Generation Division, EMITI, in Japan, and I received word a ANN RILEY & ASSOCIATES, LTD.
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i 55 1 month ago that as part of that deregulation effort and their 2 reliance on standards for safety in a deregulated world that 3- they will be adopting the ASME Code as well into their 4 regulations for power generation in Japan.
5 In addition to those countries, we have also met 6 with the China NNSA- tue Czech Republic, Hungary, Romania, 7 and the Slovak Republic, and as a result of that one of the 8 actions ASME has engaged in is to add a session to our 9 international conference on nuclear engineering, a session 10 that would be based on use of Section XI for VVER reactors.
11 In Eastern Europe there was a high interest in 12 that activity and where they seemed to have a reluctance to ,
a 13 gather among themselves they felt an international 14 conference would be a good forum to share experiences and 15 questions.
16 The risk informed nuclear code development Mr.
17 Millman had covered the Section XI code cases that are b 18 moving forward within ASME.
19 CHAIRMAN JACKSON: And are you actually 20 coordinating your work with our Staff's --
21 MS. LING: Yes. '
22 CHAIRMAN JACKSON: -- efforts in these areas?
23 MS. LING: To the best of our ability, yes.
24 CHAIRMAN JACKSON: And what does that mean?
25 MS. LING: That means that the NRC Staff have been ANN RILEY & ASSOCIATES, LTD.
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d 8 56 1 very active in the Section XI working group, subgroup and 2 subcommittees that have developed these code cases and to my 3 knowledge as of this date we would expect those code cases ,
4 to move forward through our own consensus committee and 5 hopefully through the regulatory adoption -- guide adoption 6 process.
7 CHAIRMAN JACKSON: Okay.
t 8 MS. LING: The strategic assessment of regulatory l 9 activities, Mr. Jim Perry has submitted the ASME comments on 10 that and as far as harmonization of conforming assessment 11 activities we are again working with China, Japan, Korea and 12 assuring that the accreditation of manufacturers on a world
(
13 about basis is consistent and harmonized.
14 Next slide, please.
15 In conclusion we definitely look forward to the 16 continuous solid and good working relationship that ASME has 17 enjoyed with the NRC Staff for many, many decades. I 18 I think there's been a healthy recognition between 19 the two organizations of the respective roles and 20 responsibilities of the two organization -- that, yes, they 21 are different but they both meet the common goal of public 22 safety.
23 The third bullet once again I appreciate much of 24 the discussion this morning regarding how we can work better 25 together to improve the overall effectiveness of the ANN RILEY & ASSOCIATES, LTD.
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57
. 1 process.
2 I think there are things that ASME can do as well l
3 that will improve that.
4 Lastly, I would like to state that there are many 5 people in this room who have put in a lot of blood, sweat
! 6 and tears into development of consensus within ASME, and I 7 would like to take this opportunity to publicly thank them.
8 Thank you.
9 CHAIRMAN JACKSON: Thank you.
10 Let me just ask two follow-up questions. How does 11 ASME view its interpretations? Do you view them as being 12 part of the codes?
13 MS. LING: Yes, yes.
14 CHAIRMAN JACKSON: And if I go back to the Boiler 15 and Pressure Vessel Code, how would you characterize the 1 16 major changes made in that code since _989? would you view 17 them as primarily relaxations?
18 MS. LING: No, I would not. I would view them as 19 reflections of a changing technology and lets us learn and 20 from experience. I think there are some that are relaxation 21 of the Code. In cases where by consensus and that includes ;
22 the views of all interested parties where they felt that 23 based on experience there could be some relaxation in 24 certain area, and in the same breath based on consensus I 25 would think there might be come tightening up of ANN RILEY & ASSOCIATES, LTD.
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58 1
1 requirements, again based on experience.
I 2 CHAIRMAN JACKSON: Since I have you, let me go l
3 back to a comment you were making, some comments you were !
4 making on one of your slides having to do with this balance 5 of interests or balance of categories of interests.
6 Is it your feeling that it works well or it 7 doesn't -- and I am going to ask you the same question.
8 MR. MILLMAN: It works well most of the time.
9 There are times when clearly there is an item that 10 is of interest to the utility and they -- the utility 11 members would vote in unison and at the same time the NRC 12 has an objection to it, and votes contrary to that item. ,
13 The NRC vote in that balance of interests is a 14 single vote in that block.
15 CHAIRMAN JACKSON: What's your comment?
16 MS. LING: I think it works well. I think it's 17 probably the best process we have in place to achieve 18 collective engineering judgment on establishing technical 19 requirements.
20 I think that in all cases what happens is that 21 there will be those areas of disagreement. I think that by 22 assuring that you have active participation and by assuring 23 that no one single interest category can dominate a 24 committee, which we do achieve through procedures, that the 25 balance of interests is key, is important. It works well ANN RILEY & ASSOCIATES, LTD.
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59 '
1 and it is better than anything else we have.
1 2 CHAIRMAN JACKSON: I agree, but how do address his 3 issue of the weighting in terms of just sheer numbers and .
4 how voting might get done?
5 MS. LING: The criteria that we impose on the 6 consensus level is that no more than one-third of the total 7 membership can come from one single interest category.
r 8 Mr. Millman may be referring to the lower T {
9 levels, which are the technical expertise and I would think 10 on a working group level in Section XI you might have a good 11 representation from the utility industry because that is 12 where the technical expertise is, but again you have to look
[
13 at the entire process, so any revision or any action would 14 go through the consensus committee, on which there is a 15 strict adherence to the balance of interests.
16 It goes through public review and there is also 17 the avenue of due process, so it's a good system. It's a 18 solid system. It's not a perfect system but once again it's 19 the best thing we have.
20 CHAIRMAN JACKSON: Do you agree?
21 MR. MILLMAN: I agree it's the best we have and
}
22 it's the best I could conceive, and it does work most of the 23 time but like anything it's not perfect.
24 CHAIRMAN JACKSON: On that note, let's hear from 25 Mr. Migliaro.
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a e a 60 1 MR. MIGLIARO: Thank you -- also, thank you for 2 inviting me here today.
3 My name is Marco Migliaro and I am the Chief 4 Electrical Engineer in the Nuclear Division at Florida Power 5 & Light.
6 I am here today though to speak about the 7 Institute of Electrical and Electronic Engineers, better 8 known as the I -- Triple E, the IEEE Standards Program and f 9 the NRC interfaces with that program.
10 Let me say that I have participated in the IEEE 11 standards development program for approximately 28 years, 12 most of which has been in the area of nuclear power ,
1 13 standards.
14 I am a past Vice President of the Institute in the 15 Area Standards. I am a past member of the Board of 16 Directors and I am a past Chair of the Standards Board.
17 I am also a fellow member of the Institute.
18 Next slide, please.
19 If we look at the IEEE, it is the world's largest 20 professional society with 315,000 members in 150 countries, 21 and although we see the words " Electrical and Electronics 22 Engineers" there are many members of the Institute that have 23 degrees in physics, mathematics, medicine, and computer 24 science. In fact, the IEEE is home to some 120,000 members !
I 25 whose interests lie in the fields of computer science and I
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. o 61 1 information technology.
2 I would like to point out that Commissioner Rogers 3 is a Senior Member of IEEE. 4 The IEEE has 37 technical societies including 5 aerospace and electronic systems, communication, computers, 6 engineering and medicine biology and power engineering.
7 I have attached a list of those societies with a i 8 brief statement about each as an attachment to your handout. 1 9 If we now look at the institute on a regional 10 basis -- next slide, please -- we see that the IEEE is 11 divided into 10 regions around the world. By far the 12 largest population of members are in regions one through six 13 or within the borders of the United States.
14 However, today 30 percent of our .nembership 15 resides outside the borders of the U.S. -- that is in 16 regions seven, eight, nine, and ten.
17 Those also happen to be the fastest growing 18 membership areas and we project that by the year 2000 or l 1
19 shortly thereafter a full 50 percent of our membership will 20 be from outside the borders of the U.S.
21 Next slide, please.
22 Looking at the IEEE organization, we are the 23 members, the board of directors, the executive committees 24 and six major boards, each headed by a vice president of 25 which Standards is one.
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I 62 1 Next slide, please.
2 However, when we talk about Standards, we need to !
\
l l 3 look at two major boards of the institute, the first being ,l l
4 the Standards Board. The Standards Board has a number of 5 committees and it's responsible for the Standards program in 6 the IEEE. It is responsible for the interfaces both within 7 and without the IEEE in the area of Standards and it speaks 8 for the IEEE in the area of Standards.
f l
9 One committee, the new Standards Committee, is 10 responsible for approving new Standards projects or 11 revisions if standards exist. Once the work has been done 12 and drafts are available that are submitted to the Standards
(
13 Board for approval, the Standards Review Committee makes the 14 recommendations for approval. I would like to point out 15 that there is NRC participation in that committee. '
16 There are nine other committees of the Standards t
17 Board and then the Standards Board has Standards I 18 Coordinating Committees and Accredited Standards Committees 23 which actually write standards. However, when we look at 20 standards writing activities, the bulk of that activity 21 falls underneath the Technical Activities Board within the '
22 37 societies of IEEE. Today, 24 of those societies actively 23 participate in the Standards program and that is where you 24 will find the Standards Writing Group and those are the 25 people that provide the technical expertise to the IEEE i
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I 63 1 standards.
2 Next slide, please.
3 Very briefly, the IEEE Standards Board has 26 4 members and a number of liaisons, one of which is the NRC.
5 The board meets four times a year and, given the changing 6 membership of the IEEE, one to two meetings a year outside 7 the borders of the U.S. with one of those meetings typically 8 outside the borders of North America. [
9 Participation by the NRC dates back to the early 10 1970s. It's extremely beneficial from IEEE's point of view.
11 The NRC liaison is looked to as an expert on the Board in 12 nuclear-related standards issues and, since issues may arise
[
13 at any meeting, it is imperative that everybody, members and 14 liaisons, attend all the meetings.
15 IEEE has expressed appreciation, most recently in 16 1994, in a letter from Dr. Nagle who was then President of 17 IEEE to Dr. Sellin, who was then Chair of the NRC. The 18 Commission should continue to support this activity.
19 There are approximately 700 active IEEE standards 20 and, at any one time, there are approximately the same 21 number of new and revisions in progress.
22 CHAIRMAN JACKSON: Let me just ask a quick 23 question. How many of the standards are endorsed by NRC 24 regulations and reg guides out of the 700?
25 MR. MIGLIARO: Well, 700 is all standards within ANN RILEY & ASSOCIATES, LTD. ;
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i 64 1 IEEE. 2 CHAIRMAN JACKSON: I know that. I am asking you 3 how many are --
4 MR. MIGLIARO: I don't have an exact number but ;
l 5 there are about 75 nuclear standards and, out of that, say 6 about half.
7 MR. AGGARWAL: There are approximately 30 l r
8 standards that have been endorsed in the regulatory guides. ,
9 CHAIRMAN JACKSON: In the reg guides and 10 regulations, or just reg guides?
11 MR. AGGARWAL: No, as I pointed out, the only 12 single standard is 279.
I 13 CHAIRMAN JACKSON: The 279, right.
14 Thank you.
15 COMMISSIONER McGAFFIGAN: What about the other 45?
If You said there's about 75?
17 MR. MIGLIARO: If you give me a minute, I'll get 18 to it in another slide, please.
19 Of the approximately 700 active standards that 20 have broken down, about 45 percent power, 30 percent 21 computer, 10 percent industry application and then 15 22 percent encompassed the balance of all IEEE standards.
23 IEEE standards are recognized world wide and many 24 of them become the base documents for international 25 standardization. There is a number of ways in which these i
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i 65 1 things are done. One, given the example of the LAN or the 2 Local Area Network Standards which, although developed 3 within IEEE, were simultaneously adopted as international 4 IEEE standards.
5 There are also some standards in the nuclear power 6 industry that are used directly by other countries in their 7 nuclear power programs. Examples of those are IEEE 323 on 9
8 qualification and IEEE 344 on seismic. j 9 The IEEE also has a policy to allow cross-adoption 10 of standards and IEEE standards have been adopted by 11 Standards Australia and Standards Council of Canada.
12 Next slide, please.
I 13 We have heard these words many times before but 14 the five guiding principles of IEEE are the same, due 15 process, consensus, openness, balance and right of appeal.
16 The only thing I would like to point out is that 17 consensus within IEEE is a little bit different in that when I 18 we send out a ballot, we ask for 75 percent return to have a 19 successful ballot and, of that 75 percent return, 75 percent 20 must be affirmative in order for the standard to have 21 achieved consensus.
22 Next slide, please.
23 The IEEE standards are voluntary standards. They 24 are developed by volunteers and, in fact, today we have over 25 30,000 persons involved in the development of IEEE i
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66 1 standards.
2 Because of our policy of openness and balance, you 3 don't need to be a member of IEEE to participate in 4 standards writing activities. For example, a number of 5 years ago, when IEEE was asked to develop or look into 6 standards on electromagnetic fields, we put out invitations 7 to epidemiologists and biologists to join our committees.
8 So that the input for our standards comes from designers, [
9 operators, industry experts, regulators, manufacturers and 10 other interested parties and, in general, IEEE standards 7 11 reflect state of the art.
12 CHAIRMAN JACKSON: Let me ask Mr. Millman, what is 1
13 your assessment of the consensus process relative to hd'w the 14 standards developed in IEEE?
15 MR. MILLMAN: The ballot structure is a little 16 different than it is at ASME but there are some other 17 parameters that get into the ASME balloting that haven't 18 been discussed and that is, first consideration ballot, one 19 negative ballot stops the item. So a single voice is heard.
20 Frequently that is the NRC voice.
21 CHAIRMAN JACKSON: In the ASME process.
22 MR. MILLMAN: In the ASME process. In the IEEE 23 process, the 75 percent, I think, would make a significant 24 difference if that's the way it were implemented at ASME.
25 CHAIRMAN JACKSON: Okay.
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, . I 67 1 MR. MIGLIARO: Next slide, please. That's slide 2 number 10.
3 Where are all these standards used? They are used 4 for electrical and instrumentation control equipment. I 5 look at these or view these as the brain and the nervous 6 system of the plant. There are field sensors that 7 continuously monitor parameters and conditions in the plant 8 which are relayed and based on what the sensors see, actions f 9 are taken, sometimes automatic, to stop, start or shut down 10 plant systems.
11 There is also information fed to the operators 12 either to alert them that a condition is present or to I
13 prompt them to take corrective action. This equipment plays 14 a vital role in maintaining safety of plants and they are 15 relied on for safe and economic operation of the plants.
16 Looking at nuclear standards development, let me 17 first say that the IEEE began standards development in the 18 1800s on one of its two founding societies, the AIEE began 19 to write standards. By that comparison, the nuclear power 20 standards are a relative newcomer to the IEEE beginning 21 about 25 to 30 years ago. But over that time, more than 22 100,000 persons have participated in the development of 23 those nuclear standards. Today, we have more than 75 active 24 standards. The scope, equipment areas of those standards 25 are included as an attachment to your handout.
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68 1 We have a number of other documents that are 2 offered from IEEE and I will just go through them briefly.
3 The nuclear power collection -- I have some of these by my 4 side here -- is a compilation bound under one cover of all 5 current issues of nuclear power standards within the IEEE. I 6 The Nuclear Power Archives, as the name implies, is a bound 7 edition of all the past revisions of all the nuclear power 8 standards. The Nuclear Science Collection is available.
9 The Nuclear Equipment Qualification Sourcebook, 10 that is a somewhat unique product in that all the documents 11 required for equipment qualification, both the IEEE and the 12 NRC, are bound under one cover. .
i 13 IEEE 500, which was last published in 1984, is 14 reliability data for nuclear power plants. This is a very 15 important standard; however, at this point in time, there 16 really have been no takers on the revision of this document 17 and I think -- I present to you an issue -- I think this is i 18 one area where the NRC can take a look at it and maybe take 1
19 a leadership role in making sure that IEEE 500 does get 20 updated.
21 Next slide, please, number 12.
22 Interfaces with the NRC. I have already stated 23 that we have an interface at the Standards Board level. We 24 have an interface at the society level and you have seen 25 slides of that. Three major societies that the NRC deals
'I .
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n 69 1 with are Power Engineering, Computer and Nuclear and Plasma 2 Sciences.
l 3 Typically, the votes of the NRC here on working 4 groups, subcommittees and committees. Then there is also 5 NRC representation on the Standards Coordinating Committees.
6 If we look at the regulations -- next slide 7 please -- we have already stated IEEE 279 which has been 8 withdrawn by IEEE is the only standard reference in the f 9 regulations. The remainder of .TJ7.E standards are endorsed )
10 by regulatory guides. These are very valuable to users i l
11 because they present the NRC position on a particular 12 standard.
I 13 Although the NRC actively participates in the 14 working group and the working group members themselves may 15 have information as to how the NRC feels, many of the users 4
16 in the industry don't have the benefit of attending working 17 group meetings so the regulatory guide is used to convey all 18 those issues to the licensees and they are extremely 19 valuable. However, the shortcomings here are that many are 1
20 for old revisions and very few cover recent editions of the 21 standards.
22 CHAIRMAN JACKSON: How old are we talking?
23 MR. MIGLIARO: Some go back to the 1970s.
24 CHAIRMAN JACKSON: And --
25 MR. MIGLIARO: The 1970 edition.
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. a 70 1 CHAIRMAN JACKSON: And what is the most recent?
2 MR. MIGLIARO: The most recent additions, without 3 picking a particular one, I would say the most recent 4 addition, because the IEEE policy is to revise or reaffirm 5 their standards every five years, then they could be as much 6 as 20 years behind.
7 COMMISSIONER McGAFFIGAN: So I might ask whoever 8 spoke earlier, of the 30 that we have endorsed, how many [
9 are -- you said you had 75 total, 30 we've endorsed 10 approximately through reg guides. Of that 30, how many do 11 you think we are endorsing old standards or old revisions?
12 MR. MIGLIARO: I would say the bulk, probably 80
[
13 percent would be endorsing old revisions.
14 CHAIRMAN JACKSON: Going back to the '70s in 15 general?
16 MR. MIGLIARO: No, they would be in the '70s and 17 '80s. k 18 COMMISSIONER McGAFFIGAN: What about the other 45 19 that sort of hang out there and is it important, if we ever 20 got around to it, to having those also considered in our reg 21 guides?
- 22 MR. MIGLIARO: Sure. My next slide, actually.
23 COMMISSIONER McGAFFIGAN: Okay, sorry.
24 MR. MIGLIARO: No, it's a good lead-in. Thank you 25 very much.
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1 71 1 CHAIRMAN JACKSON: Before you get to that, let me 2 just ask you this question. Do you -- do'you actively seek 3 NRC endorsement of IEEE standards in these areas?
4 MR. MIGLIARO: The IEEE personally, no. The IEEE 5 does not actively seek the endorsement.
6 CHAIRMAN JACKSON: Okay, and how are your 7 standards development initiatives supported financially?
8 MR. MIGLIARO: Our initiatives are all voluntary.
9 The members on the working groups are usually supported 10 either by themselves or their organizations or their 11 companies.
12 CHAIRMAN JACKSON: So it doesn't come out of your 13 budget, per se?
14 MR. MIGLIARO: It doesn't come out of our budget, 15 no. The only activity that comes out of the IEEE budget is I
16 the support of the IEEE staff members, paid staff members 17 that attend these meetings and the support of the editorial 18 staff and the publishing of the documents.
19 CHAIRMAN JACKSON: And what about your code 20 development?
21 MS. LING: It is the same, volunteers. They 22 receive their support elsewhere but the administrative 23 support for the codes and standards framework is through 24 sales of the codes and standards.
25 CHAIRMAN JACKSON: It's through sales? ;
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6 72 1 MS. LING: Sales of the codes and standards.
2 MR. MIGLIARO: I would like to add one thing on 3 that. There have been a couple of initiatives where we have 4 'done some fundraising to support a particular standard. An 5 example of that was the current impassity or carrying 6 capability of electric conductors. That is a large, 7 voluminous document and years ago, when it was first f
8 initiated, all the computer time on that document was 9 supported by a cable company.
10 With companies downsizing, a lot of that is not 11 possible today so some of that work was done through 12 fundraising activities to support the standard. ,
t 13 CHAIRMAN JACKSON: So you could have standards 14 developed that are supported by a given company?
15 MR. MIGLIARO: No, they are not cupported. In 16 general, they are not supported by a given company. But we 17 had had a fundraising effort that allowed the computer 18 work -- paid for the computer time necessary to generate the 19 final document in the case of the impassity. That is one 20 single case that I can point out to.
21 CHAIRMAN JACKSON: But you don't sell anything?
22 MR. MIGLIARO: Yes, we do sell standards.
23 CHAIRMAN JACKSON: So you sell standards, too?
24 MK. MIGLIARO: Yes.
25 CHAIRMAN JACKSON: So that is part of your ANN RILEY & ASSOCIATES, LTD.
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73 l '
l 1 financial support base.
2 MR. MIGLIARO: It is part of the financial support l l l' l 3 for the staff but it is not -- we do not financially support 4 any of the volunteers.
l 5 CHAIRMAN JACKSON: I understood that.
6 Thank you.
7 MR. MIGLIARO: Thank you.
r 8 Slide number 14.
[
9 There had been some recent activity within the NRC 10 in the area of regulatory guides. Three reg guides, as we 11 have seen before, were endorsed, endorsed the latest 12 standards and there have been some draft guides for
[
13 computer-related standards. This is particularly important 14 as digital systems and digital upgrades begin to go into the 15 nuclear plants. However, that effort is probably below what 16 we would like to see as far as endorsing all of our 17 standards.
18 There is much more that can be done. The issues 19 here, number one, develop regulatory guides for all the 20 nuclear-related standards and the other is then to train 21 your inspectors on the use of these guides so that there is '
22 a uniform approach across all tne regions.
23 CRAIRMAN JACKSON: What opportunities do you think l
24 are available to keep inspectors current on new technologies 25 and the implications that are reflected in standards?
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e 74 o
MR. MIGLIARO: Well, there can be a number of 1
2 issues. There can be short seminars, short courses 3 presented to the instructors to give them an idea of the 4 standards development. 1 5 CHAIRMAN JACKSON: Do you present such courses? !
6 MR. MIGLIARO: Yes, we do present those courses.
7 They have been limited recently but they are available and they are available for presentation anywhere. There is f, 8
9 normally a fee associated with that to cover the time, of 10 course, of the instructors.
11 CHAIRMAN JACKSON: Industrial rates.
I 12 MR. MIGLIARO: I won't speak for the rates. ,
13 CHAIRMAN JACKSON: Okay.
14 MR. MIGLIARO: Finally, active participation by ,
15 the NRC staff at committee and working group levels must
- {
16 continue. As you have seen, you have about 26 people active However, there are 15 that actively I 17 on IEEE activities.
18 work on sponsor committees and actively ballot the documents 19 and we understand that although we see 15 or 26 names, there 20 are actually many, many more people that work and provide 21 input to those persons in the development of comments to . . ,
22 particular standards.
23 In summary, I would like to say that the issues 24 are the continued support of the staff by the NRC, IEEE 500 25 update, the issuance of reg guides and training for the ,
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75 1 inspectors.
2 One brief statement, as we approach the twenty-3 first century, IEEE has taken a lot of initiatives to 4 restructure itself to its new membership base or its 5 changing membership base and the Standards Group will not be 6 immune from such changes. There are plans not to change the 7 process but there are plans to develop a separate standards 8 association within IEEE. The enabling bylaws have been 9 approved and steps will be taken over the next few years to 10 implement that program.
11 Thank you very much for your time.
12 CHAIRMAN JACKSON: Okay, Commissioner Rogers?
13 COMMISSIONER ROGERS: Well, it seems to me that it 14 is quite apparent that there is really quite a difference in 15 approach here between the two professional societies in many 16 ways and that NRC's use of these is somewhat different in 17 the very large difference in the number of standards, ASME 18 standards or codes that have been -- that are reflected in 19 our regulations. Whereas, with the IEEE, it is more in reg 20 guides.
21 I wonder if you have any comments with respect to 22 that difference, particularly as we see more and more use of 23 digital systems and control systems and so on and so forth 24 as replacements in nuclear power plants and whether, 25 perhaps, there should be a little elevation of the use of ANN RILEY & ASSOCIATES, LTD.
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. < 1 76 1 IEEE standards in regulations in your view?
2 MR. MIGLIARO: I guess having grown up in the IEEE 3 world, I would like to say that I am pretty comfortable with 4 the way IEEE standards have been issued and reg guides have 5 been issued to endorse those. So I wouldn't see -- I l 6 wouldn't recommend any change in that area in particular.
7 CHAIRMAN JACKSON: Commissioner Dicus.
t 8 COMMISSIONER DICUS: No questions, thank you. [
9 CHAIRMAN JACKSON: Commissioner McGaffigan.
10 COMMISSIONER McGAFFIGAN: Just one question for Ed 11 Jordan.
12 The suggestion on the IEEE 500 update and NRC
[
13 taking a leadership role. Where in the scheme of things, 14 given DSI 13 preliminary views, would you place that? Or 15 have you had a chance to think about it?
16 CHAIRMAN JACKSON: Don't do like they do in court, 17 now. If you need to think about it, you should think about 18 it, because we're going to hold you to what you say here. j 19 [ Laughter.)
20 MR. JORDAN: I'll be careful not to make any 21 promises.
- 22 Clearly, the object of the DSI 13 is to look 23 across all of the codes and standards activities and target 24 those for which there can be the greatest safety benefit 25 gained based on the staff expenditure and the two good ANN RILEY & ASSOCIATES, LTD.
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1 organizations that are represented here certainly represent J
2 a fairly large effort that the NRC has been involved in and 3 has some tradition.
4 We do, as Dr. Paperiello said, use a lot of other 5 codes and standards that we don't formally endorse and so I 6 think it's looking across all of those and then coming up i 7 with a strategy, coming back to the Commission with ;
8 recommendations based on the needs and the materials in the [
9 reactor area. :
10 COMMISSIONER McGAFFIGAN: That was a good, safe
- 11. answer.
12 MR. JORDAN: So we promise to study it and bring I
13 you back an organized approach with those 25 FTE that wh 14 suggested would be required.
15 CHAIRMAN JACKSON: Okay. I 16 I would like to thank the staff, everyone, 17 Ms. Ling and Mr. Migliaro for an informative briefing.
18 As noted during the briefing, new federal 19 requirements do place increased emphasis on government staff 20 participation in the development of as well as the use of 21 standards and codes developed through the kinds of processes 22 we have mentioned and have been discussing. ASME and IEEE 23 standards can promote the safe operation of nuclear plants.
24 I think the evidence is there. Therefore, they are and have 25 become an integral part of our regulatory processes and ANN RILEY & ASSOCIATES, LTD. l Court Reporters )
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__ .-. - _ _ - _ _ _ _- _-.m_ . _ _ - _ _ _
78 1 structure.
2 To that end, then, on behalf of the Commission, I ,
3 want to encourage the staff, the ASME and the IEEE to 4 maintain their good working relationships and to strive to 5 improve the timeliness as well as the effectiveness of the 6 overall process. I think there are, at least from what I 7 have heard, opportunities on all sides.
8 The Commission's overall views on these issues are 9 being expressed through its action on the strategic 10 assessment and rebaselining DSI, the preliminary views of ,
11 which you have already expressed, Mr. Jordan. And they will 12 provide a framework for going forward.
13 However, as you have just promised in as soft a 14 way as you thought you could get away with, we do need a 15 real framework document and that's true of any of the 16 actions, follow-on actions on the DSIs, that really look at i 17 what the resource implications are and a prioritization 18 scheme for working our way through that. Then I would 19 assume that the IEEE 500 would be explicitly treated within 20 that context.
21 So unless there are any further comments, we are 22 adjourned. But I would remind the Commissioners that we do 23 have an affirmation session.
24 [Whereupon, at 11:54 a.m., the briefing was 25 adjourned.)
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8 CERTIFICATE l
% l This is to certify that the attached description of a meeting of the U.S. Nuclear Regulatory Commission entitled:
TITLE OF MEETING: BRIEFING ON CODES AND STANDARDS -
PUBLIC MEETING f, i
PLACE OF MEETING: Rockville, Maryland DATE OF MEETING: Wednesday, January 22, 1997 I
was held as herein appears, is a true and accurate record of the meeting, and that this is the original transcript thereof taken stenographically by me, thereafter reduced to typewriting by me or under the direction of the court k' reporting company ;
Transcriber: Y a on R t i je m i m t
Reporter: Jon Hundley i
e-L
i i
ASME INTERNATIONAL PRESENTATION TO THE .
U.S. NUCLEAR REGULATORY COMMISSION June Ling Associate Executive Director, Codes and Standards i
January 22,1997 i
i
. - - r, m -, , !
ASME OVERVIEW i
o Founded 1880 o Nonprofit Organization o 125,000 Members in 130 Countries o Wide Variety of Programs Codes and Standards
- Education: Engineering, Professional Development
- Government Relations
- Technical Divisions-Conferences, Exhibits o 400 Staff Employees in 10 Offices 2
- - . . - . = . - _ . - . . . . . - - - - . - - . - . . . - _ _ - - - . - - - - - .
1 ASME CODES AND STANDARDS DEVELOPMENT '
o Council on Codes and Standards o 600 Published Codes, Standards, and Guides o 100 Main Committees (Consensus Bodies) o 4000 Volunteers o ASME Engineering Staff Support 3
.l
USNRC-ASME RELATIONSHIP l o 1963: First ASME Code for Nuclear Vessels l
o Codes and Standards Development-Broad NRC Participation l
o Timely Endorsement of Codes and Standards Essential o ASME/USNRC/NBBl: Triparty Meetings o NRC/ASME Pump & Valve Symposium: Technology Transfer o Periodic NRC/ASME Meetings: NC&S Related .
i 4
~
USE OF VOLUNTARY CONSENSUS STANDARDS o Public Law 104-113 o Proposed Revision of OMB A-119 Openness Balance of Interest Due Process I
i 5
-. . .. -. ,, . - . , ., ,i
~
ASME CURRENT INITIATIVES o Reengineering the Code Development Process o Globalization of Codes and Standards: Worldwide Safety o Risk-informed Nuclear Code Development ,
o Feedback on NRC Strategic Assessment of Regulatory Activities o Harmonization of Conformity Assessment Activities Worldwide I I i
6 t
i i
CONCLUSIONS o Maintain Good Working Relationship: NRC Staff /ASME Reps.
o Recognize Respective NRC/ASME Roles and Responsibilities: Protect Public Health and Safety o Jointly improve Timeliness / Effectiveness of Overall Process:
Endorsement, Prioritization, Feedback-NC&S Issues important to Continue Level of NRC Staff Support in NC&S o
Activity h
l 7
pn ne au,% '
e 8 8 5 E
%**+
/
NRC USE OF
! CONSENSUS CODES AND STANDARDS January 22,1997
~
Gilbert C. Millman, Program Manager i Office of Nuclear Regulatory Research e
6 AGENDA Time Sub_iect SDeaker . 2 10:05 am introduction and Themis P. Speis, -
Background Deputy Director, RES '
10:15 am Staff Presentation Gilbert C. Millman, Program Manager, RES 11:00 am Presentation by June Ling, ASME American Society of ,
Assoc. Executive Director Mechanical Engineers Codes and Standards 11:15 am Presentation by Marco W. Migliaro Institute of Electrical Florida Power & Light and Electronic Past Vice President Engineers (Standards), IEEE 2
_l
TABLE OF CONTENTS Subiect Pages introduction 4 Why Consensus Codes and Standards are 5 Important to the NRC Regulatory Framework 6 Endorsement by Regulation 7 The ASME Boiler and Pressure Vessel Code 8 Scope of 10 CFR 9 50.55a 9 Endorsement of IEEE Standards 10 The Consensus Process 11 Staff Participation on Committees 12-18 Examples of Recent ASME Products 19 Current Activities 20 ;
Summary 21 Backup slides 22-29 3 i
~
~~ '
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INTRODUCTION
- Consensus codes and standards have been an integral part of the regulatory process for almost three decades.
- New Federal requirements place increased emphasis on government staff participation and use of standards.
e This briefing discusses the way in which codes and standards effectively and efficiently promote the safe operation of nuclear power plants, and overviews the staff's participation in the development and endorsement process
- National / international standards 6
4 6
,. .. .. -. - -g - , ,
WHY CONSENSUS CODES AND STANDARDS ARE IMPORTANT TO THE NRC
- Complement NRC's broad General Design Criteria
- Form a basis for NRC requirements and guidance in many areas of the design, construction, inspection, testing, and repairs of mechanical and electrical components, and large civil structures
- Incorporate many years of accepted good engineering practice and reflect state-of-the-art technology
- Provide for efficient use of NRC resources 5 ,
l REGULATORY FRAMEWORK l
FOR IMPLEMENTATION OF
! CODES AND STANDARDS l
e Public Law 104-113, " National Technology Transfer and Advancement Act of 1995" e OMB Circular A-119, " Federal Participation in the Development and Use of Voluntary Standards" e Regulations, primarily 10 CFR 9 50.55a, " Codes and standards"
- Regulatory Guides and other regulatory documents 6
ENDORSEMENT BY REGULATION i
- Establish NRC position through office reviews and concurrences
- Review and approval by EDO
- Review and approval by Commission
- Issue for and resolve public comments
- Second review, concurrence, and approval cycle
- lssue final regulation 4
7 l
S
- L ~'_.
l'_ _ _ _ _ _ _
~i
THE ASME BOILER AND PRESSURE VESSEL (B&PV) CODE ,
- Eleven sections, two of which are " nuclear" sections
- Nuclear sections
- Section lli(construction)
- Section XI (inservice inspection (ISI) and testing (IST))
- Mandated in 10 9 CFR 50.55a !
l
, i
- Code cases are alternatives to B&PV Code !
- Endorsed in three regulatory guides
- Interpretations clarify B&PV Code
- Not part of regulations !
- NRC is not bound by interpretations .
i e f i
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I l
SCOPE OF 10 CFR 9 50.55A e incorporates by reference and mandates use of ASME B&PV Code Section ill and Section XI e May impose NRC limitations and modifications e Requires 120-month update of ISI and IST programs e Endorses use of selected ASME code cases via three referenced regulatory guides e incorporates by reference IEEE Std. 279; other IEEE standards are endorsed by regulatory guides 9
l
ENDORSEMENT OF IEEE STANDARDS e Recently endorsed in final regulatory guides
- IEEE Std. 338 periodic testing
- IEEE Std. 7-4.3.2 digital computers
- IEEE Std. 603 criteria for safety systems e Eight standards recently endorsed in six draft regulatory guides, include:
- IEEE Stds.1012 and 1028 - validation and verification, reviews, and audits for digital computer software
- IEEE Stds. 828 and 1042 - configuration management 10
THE CONSENSUS PROCESS
- Administered by American National Standards
- institute (ANSI)
- Implemented by Standards Developing Organization (SDO), such as ASME or IEEE
<
- Consensus: Due process + " substantial" agreement
- Due process
- Openness
- Balance of Categories of Interest
- Fair consideration of views
- Written record
- Right of appeal 11 Se e F
- F M4 9 M m' q g
-l STAFF COMMil i EE MEMBER NOMINATION PROCESS
- Standards Developing Organization (SDO) or NRC requests participation
- In consultation with other program offices, letter to committee chairman (signed by Director, Office of Nuclear Regulatory Research) nominates agency representative ,
- Letter specifies that staff participation does not connote agency agreement with committee decisions
- SDO votes on all nominees for acceptance 12 i
STAFF COMMITTEE MEMBER RESPONSIBILITIES ,
- Defined in OMB Circular A-119 .
- Be active participant
- Participate on basis of equality with other representatives i i
- Views expressed should not be inconsistent or in conflict with established agency views
- May serve as chairperson, or in other official capacity 13 1 I
ASME COMMis IEE STRUCTURE Council '
Codes and Stenderde (SM Matthews)NRR I I I Bcara Board Board Prosauro Technology Accreditation Nuclear Codes and Stenderde Codes & Stenderde (SM Matthews) NRR (GC Millmen) RES t ;
Nonnuclear Nuclear I I I
Committee Committee Commitee Boller & Pressure Vessel Operation and Nuclear Air &
Melntononce Gee Treatment (GC MMmen) RES (RR Bellamy) RON I (RH Weesmen) HRR Committee Nuclear Quel. W Mechedel C or uclear Nonnuclear
" " NRR Opemh (RH W i
1,II,lV,V, lit VI. Vil, VM, XI Committee IX, X Nuclear Ousilty l
+ w w 9 M w += q e y
ASME SECTION XI -
- WG: Plant LNo Extenelon WG:GeneralRequiremente _ Nuclear heerviceinspection _
(DA Jackson)RES (CM Regen) M (GC Millmen)RES r
I I subpoup Subyoup Sutgoup Water-Cooled Systems Evolustion Standerde Repelr and Replacement (D Tereo) NRR (KR Wichmen) NRR (RA Hermann) NRR l
_ WG:Insp. Sye. & Comp.
(TM McLellen) NRR subgroup Subyoup NondestrucIlve Examinston Intemels and Core Supporte >
(MC Modes) RGN I (CE Carpenter) NRR
_ wg.ProcoureTW (D TWoo) NRR f
WG: Proc. Quel &
_ WG: Riek-Besed Exam.
-- M Exam _
WG: Oper. Plant Critorie _
WG: Welding, Spec. Rep.
(SA AN) NRR (MC Modos)RGNI (EM Hochett) RES (RA Hermann) NRR i
_ WG: Metal Contelnmente
" I
_ WG: Flow Evolustion _ WG: Design ReconcMedon (WE Norris) RES (N Economos)RGNI N )NRR (EV Imbro) NRR WG: concrete Contein. WG: Redp. & Prog. Req.
- WG: Pipe Flow Evel. p )g (HG Asher) NRR 15 y W& M M% _
IEEE BOARD AND COMMii IEES Review Committee (REVCOM)
Standards Board (SK Aggerwel) RES (SK Aggerwal) RES
=
Multiple Committees e
I =
I I 1
industry Appilcations C6 18 More Societies Power Engineering SW W W _
h Engineering Committee Multiple NPEC Committees (SK Aggerwel)RES _
16 M
m g
STAFF PARTICIPATION ON SDOS Standards Developing Organization Staff American Society of Mechanical Engineers 47 American Nuclear Society 39 Institute of Electrical and Electronics Engineers 26 Health Physics Society 12 American Society of Testing and Materials 11 Institute of Nuclear Materials Management 6 American National Standards Institute 5 American Concrete Institute 4 American Society of Civil Engineers 4 Other 12 17
- F 4
- M S M p a*=q -g y
T STAFF PARTICIPATION ON SDOS BY OFFICE i
Office NRR NMSS RES AEOD Regions OC Staff 71 21 34 6 9 1 1
i 18 i
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EXAMPLES OF RECENT ASME PRODUCTS e Section XI Code case for thermal annealing reactor vessels e Section XI Code case for examination of longitudinal welds in piping
- Updates to Section XI performance demonstration criteria for ultrasonic inspections
- Section XI Code case for steam generator tube repairs by electrochemical deposition
~
-J
CURRENT ACTIVITIES
- Section 111 revision to seismic. design of piping
- Section 111 rules for nuclear waste transport packaging
- Section XI Code case for evaluation of through wall flaws in Class 3 moderate energy piping i
- Section XI Code cases for risk-informed ISI
- OM Code case for risk-informed IST
- IEEE
- Risk-informed criteria for design and application
- Digital upgrades, EMI/RFI, and software reliability
- On-line maintenance; human factors in maintenance
- Quality and reliability of off-site power
~ ~ ' ~
_ _ - _ _ _ _ _ _ : ____L-____-________ _ .- _L_.
l i
i
SUMMARY
- The NRC continues to rely heavily on the use of consensus codes and standards, and the staff continues to participate actively with SDOs on current issues e Staff plans to increase interactions with SDOs regarding l the development of new codes, standards, and guides, especially those which will facilitate the transition to risk-informed, performance-based regulations
- RES will prepare an Action Plan to ensure NRC compliance with federal law and policy guidelines for participation in the development and use of consensus codes and standards The Action Plan will be submitted to the Commission for approval for implementation 21 i
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i -
I BACKUP SLIDES .
Title Page International Standards, IAEA 23 Public Law 104-113 24 OMB Circular A-119 25-27
, Endorsement by Regulatory Guide 28 IEEE Committee and Subcommittee Structure 29 22 ,
~ ' ~ ~' ~ '
"I
INTERNATIONAL STANDARDS lAEA ACSS AdvisoryCommiselon on Safety Standeres (NRC 1.eed)
I I l- I NUSSAC RASSAC WASSAC TRANSSAC RadiaWon sew Stendeds '
Nuclear sew Standards Weste Safety Standards Dansport Safety Stended Advisory Committee Advisory Committee Advisory Committee Advloory Committee ;
(BM Morrte) RES (DA Cool) NMSS ,
a, ort aperi noe., apert croupe Gmupe Groupe Groupe 23 :
l
PUBLIC LAW 104-113 i NATIONALTECHNOLOGYTRANSFER AND ADVANCEMENT ACT OF 1995
- Federal agencies shall use technical standards that are developed or adopted by voluntary consensus standards
- Agencies shall participate on consensus standards bodies when such participation is in the public interest, and is compatible with agency missions and budget resources
- An agency may use technical standards not developed by voluntary consensus standards bodies if the head of that
- agency transmits to the Office of Management and Budget an explanation of the reason for using such standards 24 t
OMB CIRCULAR A-119 FEDERAL PARTICIPATION IN THE DEVELOPMENT AND USE OF VOLUNTARY STANDARDS Policy of Federal Government e Rely, when feasible, on voluntary standards
- Participate on voluntary standards bodies .
- Coordinate agency participation to ensure:
- effective use of agency resources
- views expressed by agency representatives do not conflict with interests and established views of the agency 25
4 OMB CIRCULAR A-119 (CONT.)
FEDERAL PARTICIPATION IN THE DEVELOPMENT AND USE OF VOLUNTARY STANDARDS l
Policy Guidelines T
e Adopt voluntary standards that serve agencies purposes and are consistent with applicable laws and regulations
- Give preference to performance based standards
- Agency is not committed to use a voluntary standard i which, in its opinion, does not meet statutory criteria, or l is otherwise inappropriate !
e Establish Agency Standards Executive i
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OMB CIRCULAR A-119 (CONT.)
FEDERAL PARTICIPATION IN THE DEVELOPMENT AND USE OF VOLUNTARY STANDARDS Responsibilities of Standards Executive
- Ensure coordination of agency views among agency representatives on standards groups
- Ensure review of existing agency standards every five years, and replacement of those for which an appropriate voluntary standard can be substituted
- Prepare an annual report on the status of agency interaction with voluntary standards bodies 27 i
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l ENDORSEMENT BY l REGULATORY GUIDE
- Prepare draft regulatory guide and regulatory l
analysis
- Review and approval by cognizant RES and user office Division Directors
- Issue for and resolve public comments
- Second review, concurrence, and approval cycle
- Issue regulatory guide final under signature of Director, RES 28 i
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- Meets 4 times a year one to two meetings outside the US o Participation by USNRC dates back to 1970s is extremely beneficial expert to Board on nuclear related issues 4 -
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e Recognized Worldwide many become the base document for international standard'ization
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Principles of the IEEE Standards Process -
- Due Process e Consensus
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- e Voluntary Standards Developed by volunteers Over 30,000 persons involved Input from designers, operators, industry experts, regulators, manufacturers and other interested parties Reflect State-of-the-Art F 9 F W 9 N# M D*7 * '9 W '
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- Play a vital role in maintaining safety
- Are relied on for safe and economic '
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IEEE Nuclear Standards Development .
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- Began more than 25 years ago
- More than 100,000 persons have participated over this time
- More than 75 Active Standards Nuclear Power Collection Nuclear Power Archives Collection l -
Nuclear Science Collection l
l Nuclear Equipment Qualification Sourcebook l -
IEEE 500 l
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IEEE Standards and the USNRC .
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- IEEE Standard 279-1971 is in the regulations e Regulatory. Guides (RGs) are used for other l
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are valuable to users many are for old revisions few cover recent standards
-i IEEE Standards and the USNRC .l e Recent activity by the NRC is encouraging three RGs endorse the latest standards draft guides for computer related standards e There is much more that should be done RGs for all nuclear standards
- Active participation by USNRC Staff at committee and working group levels must continue
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) Scope: The scope of IEEE standards may cover some or all of the following: design i 1 installation design, specification, qualification, installation, maintenance, inspection i monitoring, calibration and testing.
1 i Equipment: Specific equipment covered by these standards includes, but is not limited to:
- Batteries Battery Chargers Inverters
{ Switchgear Digital Equipment Motor Operated Valves 1
Computers Motors Engine-Generators j Cables Relays Motor Control Centers Control Panels Heat Tracing Electric Penetrations Instruments Raceways t
Areas: '
Standards are also available, that are not associated with specific equipment, but do provide recommendations and guidance in the areas of:
Human Factors Safety Systems Security Systems Preferred Power Supply Single Failure Criteria Independence Periodic Testing Equipment Qualification ,
Probabilistic Risk Assessment Reliability Analysis i Preoperational Testing Seismic Qualification Post Accident Monitoring Cable Fire Stops Calibration - ,
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,.1 IKEE SOC 1ETY .
h DFORMATION ~
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The following pages contain a description of the Societies members can join.
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AEROSPACE & ELECTRONIC SYSTEMS The Society covers the organizadon, design development, and operauon of funcuonal systems for space, air, ocean, and ground environments. These systems include navigation, avionies, mobile electnc power and electronics, radar, aonar, military and law-enforcement systems, =damasive test sunulators and command-and control.
ANTENNAS & PROPAGATION l
'Ihe Society covers all areas relating to antenna theory, design, appiscauons, and nuesurements;
- propagation, both theory and effects; basic and applied - ';- "= aamamaientiaan, cosapate*Iaa=1 and numerical techniques, personal - , amtsanag and ddfraction, radar and radar cross earviana, interactson of fields with matenals, antennas and r , ;"= as related to systems, and EM vie ==Iwaiian BROADCAST TECHNOLOGY ,
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'the Society aa==p== virtually the entire spectrum of eachaalag== needed for the various braademariar services. It a. Ngonates cleanents of antan===, elecssonics, power, namar.aintiana, signal processing, information timory, computers and audio into a braadcastias perspecanve that focuses on devices, ['
equipment, :=% and systems for the pradarvian distribuuon, tr======aa and papagation of radio and television signals.
CIRCUITS & SYSTEMS ,
Tbc Society focuses on the theory, analysis, design, and the pracsscal i=plame=*=*iaa of circuits, and the application of circuit theoretic techniques to systems and signal pecessing ranging front basic scienufic .
'( theory to industnal apphcatson.
I COMMUNICATIONS The Society embraces all aspects of the advaarnamme of the science, engineenng, technology and applications for transferring infor==esan between tar =*iaae by the use of signals. " Ibis includes: sources and destination involving all types of tenninals, computers and informauon pmcessors; all pertinent systems and operauons to bring about this transfer, guided and ungsded tran==*==aa snedia; switched and unswitched networks; and network layouts, protocols, architectures and implamene=*iane COMPONENTS, PACKAGING, & MANUFACTURING 'IECHNOLOGY ,
The Society's concerns are the scientific, engineering and pmducason aspects of matenals, component ,
parts, modules including hybrids and electronic systems including selection, applicauon, menembly, packagin{ reliability, tesung, and control.
COMPUTER .
The scope of the Society encompasses all aspects of theory, design, pracuce, and applications relating to
- computer and information processtag science and technology. It covers -- ; 1- hardware such as architectuit, design, and test technology, computer software such as languages and operating systems, and computer related functions and interactions in larger systems such as com, o communications and distributed systems. It also embraces such emerging 'daalagies as multimedia, visualization, and intelligent systems.
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CONSUMER ELECTRONICS The Society has grown to embrace muleinwha entertainment, digital high definition, tv, digital radio, advanced games, recreational apparatus, hand held productivity tools, and home ci5cc predacts in addition to the traditional areas of audio, radio, tv, ver, camcorder, and other home electronics. l CONTROL SYSTEMS sl i
The Society covers the theory, design, and implenwientian of control systems encompassing components and their integration in the construction of such systems. The interests of the Society range fresa contal theory to control nachantogy to control applications.
DIELECTRICS & ELECTRICAL INSULATION The Society covers inantasian materials, insulahan systems, shelectric phanamaan and discharges in i l
vacuum, gaseous, liquid and solid electrical lamilating insserials, and the =riti=rian of these dielectric matenals in electrical and electronic circuits and systems under all envira==aae=1 conditions. [
EDUCATION The Society is concerned with antaratianal. =**M technology, and prata==aani development programs ,
within the electrical engineenng disciphaes.
ELECTROMAGNETIC COMPATIBILITY The Society is concerned with the design, iaea- =% testsag, and analysis of electrotechnology products {
and systems to contml radated and ea=Awart interferena, and strives for the anhan,wanae of EMC through the generation of engineenng penantards messemane eachairpses, study of ='--: - 1 +
ambient and manmade environments, and educasian ELECTRON DEVICES The Society's interest spans all aspects of the physics and phenomena of electmn and ion devices -
elemental and compound semiconductor devias, quantum effect and optical devices, displays and imaging devices, photovoltaics, solid state sensors and scenaears, power and high fi%,.i.i.cy devices, and tubes and other vacuum electronic devices.
ENGINEERING MANAGEMENT
- Ihe Society's interest spans research, application, and antaration relating to management sciences and technologid for individuals and organineions engaged in engineering and eachaalogical issues.
ENGINEERING IN MEDICINE AND BIOLOGY
'Ibe Society is interested in the application of the concepts and methods of the physical and engineering sciences to biology and to medicine.
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a GEOSCIENCE AND REMOTE SENSING The Society is concerned with the theory, aaa~aar and techmques o(science and engineering as they
- apply to the sensing of the earth, oceans, etmosphere, and space; and the processing, interpretation, and disanminneina of this informanian INDUSTRIAL ELECTRONICS The Society encompasses the apphcation of electronics and electrical sciences related to industrial Processes.
INDUSTRY APPLICATIONS
'Ibe Society is concerned with the global development and spplication of electncal systems, apparatus, devices and controls to the processes and equipment afindustry and conumerce. k promotes the design, manufacture and manage = eat ofsafe, reliable, and --I 3a=*=Itsena== It encouragesindustry leadership in enerD conservatson and c .k - -- ^ { health, and safety issues; the creation of voluntary engineering standards and m=aadad practices; and the professional development afits members.
INFORMATION THEORY The Society is concerned with the processing, trap ==iemian, storage, and use afinfor==tian,. and the foundation of the r=aamaicania== process. It specifically ear ==r===ar theoretaal and certain applied aspects of coding, -a==ae=*ian and communications networks.
INSTRUMENTATION AND MEASUREMENT
'Ihe Society is dedicated to the developenent and use of analog and digital electncal and ciectronic instruments, systems, and standards to measure, analytacally process, monitor and record physical phenomena in time and f.wi omains. d Included are equipment with maa==ric control and stimulus ;
functions and transducers to access other dimensional quantities. l LASERS AND ELECTRO-OPTICS I
The Society's' scope encompasses lasers, optical devices, opucal abers, associated lightwave technology, and applications in systems with quantum electronic <~aaaaaa'e Topics span research, t . 4..;.;.t. ,
design, manufacture, apphcations of matenais, devices and system, and science and techaalagy activities '
that enhance the field of quantum electronics.
1 MAGNETICS
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l The Society encompasses all matters involved in the funda-*=1 i ; ; design, and apphcation of !
magnetic devues including magnetic materials and p!== - = i MICROWAVE THEORY AND TECHNIQUES
'Ihc Society covers microwave theory, techniqueis and apphentia=* as they relate to components, devices, circuits, integrated circuits, multi circuit assemblies, sub-systems and systems involving the generation, l amplification, modulation, control, transmission, reception, detection and demodulation of nuerowave l
signals in scientific, technict.l and industrial activities. '
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l NUCLEAR AND PLASMA SCIENCES
' The Society encompasses all phases of nuclear and plas'u arwarms and engineering including instrumentation including instrumentauon for renearch; desemion and measurane=# of rndinhan; nuclear biomedical applications; radiation monitoring; particle acceleratorr, reamor systems; effects of radation on materials and components; applicauons of radmuon and nuclear energr, plasma dynamics and plasma sources OCEANIC ENGINEERING f 1
The Society provides a forum to exchange eachaie=1 information related to engineenng expertise in an ocean environment; e.g., underwater =<= aria =mana-n= underwater vehicles, remote sonstag, neural networks, current measurements, aonar signal processing, marine - - - . . . and navigation, oceanographic instrumentation, polar instr ==an=*iaa, non aaa==sie image processing and modeling/ simulation.
POWER ELECTRONICS
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The mission of the Society is the development and pradial appbcation ofpower elecuonics eachnalagy, which encorapenee the use ofelectrome awaranears the apphcation ofcircuit theory and design techniques, and the development of analytical tools towant h electronic conversion, control and conditioning of electric power. .
POWER ENGINEERING '
The scope of the Society embrams planning, research. -i. " , ^ design, ,," ^*=, construccon, installation, and operation of facilities systerns for generanon, traa==- and distribution of electnc I energy. It includes development of engineenng standants involving the field ofinterest, and technical scientific, literary, edar=% !. and other ammues that cominbute to this field.
PROFESSIONAL COMMUNICATION The Society embraces the study, Ed.,, at, improvement and promobon of effective techniques for preparing, organizing, processing, editing, collecting, g,.w -/,r,i;, tenclung and disseminating any form of technical information by and to individuals and groups by any methad of conununication. It also includes communication tools and processes that contnbute to collaborauve engineenng, as well as 'Wa*'.
- scientific, industrial, and other activities that contribute to the ^4 and products usedin the field. l RELIABILITY I
The Society is concerned with the inolA.w involved in attaining reliability, maintaining it through the life of the system or device, and measuring it. Availability, mamtainability, product liability, quality and system safety are significant concerns of the Society.
ROBOTICS AND AUTOMATION '
The Society is concerned with all aspects of intelligent and interactive connection of perception to action through cognition and planning using kina==*ie, dynamics, control and simulation of robots and i automatic machines.
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SIGNAL PROCESSING The Society addresses the theory and application of filtering, codang, tr=namenting aseemating datarsing, analyzins, romsnizins, sy='*=f remrdms, and reproducing signals by disital or analog devices or techniques. Sisaal incandes audio, video, speech, image, coni-inic.ei , geophysical, sonar, radar, l medical, musical, and other sisnels. l l
SOCIALIMPLICATIONS OF TECHNOLOGY r
The Society strives for the appbcahon of electrotechnology for han*Eirial uses by busnankind, and the 1 applicationofhigh ' and ethacal armadards among IEEE mesters; and pursues interest in the impact of electrotechnology on society, the impact of society on the engmeenng prafa==naa the history of electmtechnology's societal aspeas, as well as emnonde, socal, and professional .- - " , in the l Practice ofengineering.
SYSTEMS, MAN, AND CYBERNETICS The Society is involved in the intershon of the theones on --==ic=*ian control, s/- A and j system structure and the _ ,," ' - of these to a vast vanety of systems including biological, technological and societal systems.
ULTRASONICS, FERROELECTRICS, AND FREQUENCY CONTROL The Society enmmg=- the theory, sa*aalagy, e A and appbcahons related to the generation, transmission, and d**ar*iaa of pr are==ical waves and vibration and their interacson with light and electric fieldr, fermelectric materials and I.w wy control. ,
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lt VEHICULAR TECHNOLOGY t
The Society concerns itself with land, airborne, and maritime mobde services; portable commarcial and ;
citizen's communications services; vehicular electrotechnology, equipment and systems of the automotive industry; traction power, signals, --sascariant and contml systems for mass transit and railroads.
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i BIOGRAPHICAL SKETCH Maren W MigHarD was born in Brooklyn, NY, USA in 1948. He received a BEE from Pratt Institute in 1%9. l
- Mr Migliaro has been employed in the electric utility industry, primarily in generating station engineering and design, for more than 25 years and has worked for both utilities and consultants j on pmjects throughout the world. He is currently the Chief Electrical and I&C Engineer for the !
1 Nuclear Division at Florida Power & Light. Mr Migliaro is an expert in the area of de power !
' systems, batteries and unintermptible power supply (UPS) systems. He has provided consulting ,
i services, primarily in the field of stored energy emergency power systems, to a variety of industries. Mr Migliaro has authored more than 35 technical papers and is a contributor to five li l
) books. ('Ihe majority of the papers and contributions are in his field of expertise.) Mr Migliaro
! is the editor for the IEEE (Institute, of Electrical and Electronics Engineers) Sourcebook on Lead-
- Acid Batteries. He has also developed a number of training programs on stationary battery selection, sizing, installation design, installation and maintenance and has presented these programs throughout the world. Mr Migliaro was a member of the group that developed the IEEE i
Standards on stationary batteries. These standards, used throughout the world, have recently been {
} endorsed by the Battery Council International. Mr Migliaro was also selected as one of tb:
experts used to develop IEEE Standard 500-1977, Guide to the Collection and Presentation of Reliability Datafor Nuclear Power Generating Stations. Mr Migliato was the co-author of the IEEE Statement on Inproving US Panicipation in Intemational Standards and presented testimony ;
q on the subject at the hearings conducted by the US Department of Commerce, National Institute .
l for Standards and Technology. l Mr Migliaro was elected a Fellow of the IEEE in 1988, for " contributions to the application and standardization of battery technology for industrial and utility power systems." He is a member of the IEEE Power Engineering and Industry Applications Societies. Mr Migliaro is currently a i
member of the IEEE Standards Board, the IEEE Standards Coordinating Committee on Stationary
- Batteries and is a Chapter Chairman for two standards in the IEEE Color Book series. He has served IEEE in the past in many capacities including, VP-Standards Activities, Member of the l Executive Committee, Member of the Board of Directors, Chairman of the Energy Development l and Power Generation Committee and Chairman of the PES Standards Coordinating Committee.
He is also a past member of the ANSI (American National Standards Institute) Electrical and
- Electronics Standards Board.
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Mr Migliaro is the recipient of the 1996 IEEE Charles Proteus Steinmetz Award, the IEEE l Standards Medallion, the 1994 ANSI Meritorious Service Award, the 1993 IEEE Standards Board Award and two Power Engineering Society Distinguished Service Awards. He is a Registered Professional Engineer in the states of New York, New Jersey, Massachusetts, Pennsylvania and Florida. He is listed in a number of biographical references including American Men and Women '
of Science, and Who's Who in America.
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