ML20202C153
| ML20202C153 | |
| Person / Time | |
|---|---|
| Issue date: | 11/22/1995 |
| From: | Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Morrison D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20202C086 | List:
|
| References | |
| FRN-62FR63892, RULE-PR-50 AE26-1-006, AE26-1-6, NUDOCS 9802120178 | |
| Download: ML20202C153 (2) | |
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1 i riE NUCLEAR REGULATORY COMMISSION
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- Nose 7ber 22,1995 MEMORANDUM 10: David L. Morrison, Director Office of clear Re,gulatory Research FROM: f /JONa r Office /f r' Analysis and Evaluation ofQperationalData ,
SUBJECT:
REVIEW Of PROPOSED REVISION TO 50.55a (g)(4)(ii)
AE00 opposes the proposed revision on three counts:
- 1. The revision appears to discourage the learning of lessons from experience, which is uually carried forth in current code revisions.
- 2. The revision wil' likely discourage future code revisions and updates.
- 3. The revision appes.s to be responding to a flawed problem statement.
Specifically, as AE00 understands the proposal, industry representatives have stated the 10 year update of ISI/IST to the current codes is a backfit without an analysis which consumes industry resources to revise the ISI program with little safety benefit.- Actually, each code revision referenced in 50.55a is subjected to review, a regulatory analysis and CRGR review before incorporation. The provisions of.50.109 apply to these code revisions. In addition, ACRS review, a public comment period, and Commission approval is required.
There may be a problem with the process that has endorsed by reference changes that are not legitimate improvements. That is, perhaps the 50.109 process, and the provisions of the CRGR charter, were not faithfully followed.
However, that is a different and more easily corrected problem with no obvious negative impact.
I have the view that aside from this proposal, which would result in a diminishment of Codes and Standards, there has already been a natural withdrawal of support for codes and standards by industry simply because of the resources involved.
This response from-shrinking industry resources has arrived at the same time
-NRC and industry are articulating a transition toward a' risk informed and performance-based regulatory approach, in my opinion, this less prescriptive approach is accompanied by the need for industry to improve the appropriate hierarchy of' Codes, standards and guides to support simpler rules. This proposed rule appears to denigrate some of our best Code update and revisions at a time when we most need them. The message conveyed by this action would likely contribute to further demise of many industry code and standards efforts.
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2- P g I have discussed this matter with Mr. Thadani of NRR who supports a meeting at the Office Director level for NRR, RES and AE00 to reexamine the basic issue that this action is attempting to solve.
Dependent upon the outcome of that meeting, there may be a need to meet with utility representatives and code committee representatives to examine the .
overall strategy and impact of changes to 50.55a in association with a less prescriptive risk informed, performance based regulatory process, cc: J. Taylor, EDO J. Milhoan, DEDR K. Cyr, OGC
! W. Russell, NRR A. Thadani, NRR L. Shao, RES J. Craig, RES B. Sheron, NRR 1
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