ML20202C229

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Discusses Results of AEOD Review of Proposed Amend to 10CFR50.55a Codes & Stds, Transmitted in
ML20202C229
Person / Time
Issue date: 01/10/1997
From: Ross D
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 AE26-1-011, AE26-1-11, NUDOCS 9802120198
Download: ML20202C229 (8)
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[ UNITED STATES 8 s* P; NUCLEAR REGULATORY COMMISSION f WASHINGTON, D.c. 30eeH001

%,,,,,, January 10, 1997 MEMORANDUM TO: David L. Morrison, Director Office of Nuclear Regulatory Research FROM: Denwood F. Ross, Jr., Acting Dir Office for Analysis and Evaluation of Operational Data .[

SUBJECT:

PROPOSED AMENDMENT TO 10 CFR 50.55a ' CODES AND STANDARDS" AEOD staff have reviewed the proposed amendment to 10 CFR 50755a (Codes And Standards) transmitted in your November 5,1996, letter. We understand there is some urgency in proceeding with issuance because of delays encountered in redirecting the rule.

However, we bolleye the current proposal does not adequately address long term implementation. We agree in principal with the current proposal as a temporary approach, l but believe the Rule should be fundamentally restructured.

We have developed several options and a list of deelslon criteria as a means to eSaluate . .,

the options and establish a balanced process. Attachment fprovfdes aTrfef' description of the codes and standards process. Attachment 2 is a list of propossd options together

, , with PRO and CON statements for the option. The options considered are: 1) stay with the current rule (no new rule); 21 adopt the proposed RES/NRR code rule (Morrison -

,memoranduro dated 11/5/96); 3) Radical ASME Code change to include shall and should; ,

, 4) performance based rble; and 5) Endorse tho' ASME Cod,e through the 1995 Edition and .

96 Addenda (upciate 'he historical' process ,of Option'1) ',4.ttachment 3 is a list of det:Islon criteria'. * *

  • Each option has strengths and weaknesses. We believe it is clear that staying with the

" status quo" of Option 1 has very limited appeal. Similarly, Options 3 and 4 involve changes in approach that are not easily achievable in the near future and possibly not even long term. Thus, Options 2 (the RES draft proposal) and 5 (the historical update previously l used) are the most viable approaches. We believe that Option 5 offerr a CONTACT: Earl J. Brown,AEOD/SPD/RAB 301/415 7572 9802120198 900206 PDR PR 50 62FR992 PDR T&> u e u m .

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D. Morrison - 2-i i

stronger oystall package relative to enforceability, uniformity, constructive use of the 4

consensus process, and 6ptimum use of NRC resources in the long term. Additionally, we i

believe the approach is supportable via the qualitative process discussed in Attachment 3 .

' to the Revised Charter For the Committee To Review Generic Requirements (CRGR) dated .

April 19,1996,  !

In the statement of considerations of the current proposed rule change, we believe that 1 .

you could sifd a discussion of Option 5, endorsement of the code through the latest edition

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and addenda. The discussion would state that this option is being considered as well as  ;
the proposed rule changes. This will provide industry an opportunity to comment on both  !

options. Alternately, the proposed rule could be delayed and rewritten to endorse the code  :

j through the latest edition.

  • l Attachments: As stated 1

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l- F. Miraglia, NRR 1 W. Olmsteed, OGC P, Norry, OA

  • i- G. Cranford, IRM e
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l CODES AND STANDARDS RULE CODE PROCESS  !

De existing 10 CFR $0.55a Codes and Standards Rule endorses the ASME Code Sections 111  :

and XI including addenda through the 1988 Addenda and edtions through the 1989 Edition subject to certain limitations and modifications, nis rule was last sevised in 1992. The Code issues addenda annually and editions every 3 years. Bus, the Code has issued 1992 and 1995 l r Editions and addenda through the 1996 Addenda since NRC last revised the Rule. Each new 1 Edition incer reintes the addenda issued after the previous Edition (for example, the 1995 Edition would be composed of the 1992. Edition as changed by the 1992,1991 and 1994 Addenda). ,

CURRENT PROPOSAL  ;

I The cunent proposal attempts to follow the previous NRC approach for endorsing the ASME Code by reference in the Regulation. This process involved requiring some version of the Code, an update provision to use newer Code editions on a 10 year basis, and specific

, limitations and modifications are cited. However, the proposal is a significant deviation from i past practice in that only limited portions of recent Code editions are endorsed as requirements, his dilemma arises from the 50.109 constraint that new requirements meet cost / benefit criteria.  ;

OPTIONS AND ATTRIBUTES ,

Five rule options were reviewed as candidate,appeaches for NRC to address use'of the. ,

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ASME Code.' These options cover a wide range of possibilities within the' context 'of ,,

,- historical NRC rules up to a performance based approach! A list of PRO and CON items was developed for each option. This list considers the affect of each approach on attributes such ,

as enforceability; clarity relative to provisions which are required, permissible, or p ohibited;

! program consistency among plants; and flexibility.

Review of these options indicates staff would have to prepare a detailed description of code ,

items that are either required, permissible,' or prohibited for most options. - This would have to continue for the foreseeable future, his detail would be more enforceable in a regulation than hi a regulatory guide. Both the RES/NRR proposal and these other options may not adequately address either new construction (which Code edition should be used) and plants that obtain plant life extension (a plant could continue ISI and IST to the same rules for 40 years).

Attachment 1 i

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OPTIONS .

Opties 1 Stay with current 50.55a. (Do not issue any new rule now or later.)  !

This establishes the 89 Edition as a ? base" Code. By the year 2000, approximately 60 plants will be up to the 3rd inspection interval (only one more i update) and approximately 83 plants will be up to the 29 Edition.  !

P.RQ . -

  • Staff effort miniml-t .

Many changes aAer the 89 edition are-nlaxations of requirements (presumably with no ,

. reduction of safety). . .

. CQN - .. .

  • We currently rely bn Generic Letters and ensuing licensee commitments (which are subject to change by the licensee using 10 CFR 50.59) to impose new technology such as MOV eNorts,151 qualification. Changing the regulation itself p' laces requirements on a firmer more enforceable footing.
  • Continuing to endorse the 89 edition does not promote new technologp.
  • Code Addenda and Editions i.ssued aAer '88" and "89" are not enforceable. .
  • New OAM Code and standards
  • are improvements and need to be endorsed. . ..

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  • 1 ,, i
  • Licensee,s wahting to adopt newer code dould have to, submit's relief reqtiest. .
  • Tends to reject consensus process.

Opties 2 - Accept proposed RES/NRR Rule (This also establishes the 89 Edition as a " base" Code and voluntary use oflater Editions; this process would continue at regula- .

intervals).

FAQ .

  • Licensees ha.ve choice. The package weds to be improved to more clearly state what is u required, permitted, and prohibited. This eNort la already umlerway.

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+--- Could minimize licerm costs.

1 Attachment 2

Approach can be used within 10 CFR 50.109 quantitative cost / benefit.

- Quickest mic Issonnce.

Those items identified as required and prohibited are enforceable.

cas .

  • Staff must limit new requirements to 50.109 criteria.

l l Rule difficult to. write. .

  • Licensees will find it dimcult to implement program that meets the rule.

Dimini'shed uniformity because licensees may attempt to pick and choose editions or provisions amongst editions. Could increase staff resources to review.

Could encourage relaxation of Code rules rather than new technology.

Would discourage 10 year update (licensees would only need to change ISI and IST programs to incorporate those few items that NRC identified as required). .

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Dimcult for staff to assure consistency of programs at plants.

Dimcult for staff to know what inspection requirement applies to a spxific component ,

at the plant.- -

..* Option,3 Radical restructur'e of. Code and Rule (a more definitive Code with shall and, .

, .l . ' should and h less prescriptive regulation). Emphasizes self regulatioh and is '

.' amenable'to updhling. -

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[ PAQ b .-

Code would have shall and should as necessary.

  • NRC adopts code as it is.
  • - NRC staff regulatory analysis is simple since work has been done by Code committee.

Cost / benefit review straightforward.

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  • Updates readily handled. -

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  • Code may include new technology, i
  • Code is enforceable.

CQM ASME should not be restrained to not require (should) items they judge important. They-should write what they believe necessary independent of cost _ benefit (also, changes

. viewed collectively rnay meet cost / benefit while individual items may not).

-* Code is not written this way, (i.e., shall, 'should, may),

e is it feasible for Code to change? ,

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What are NRC resources to convince ASME to change? *

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  • How long to implement tids change?
  • Code may concentrate on relaxing requirements.

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  • Could significantly delay issuance of Code.

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Option 4 Performance based regulation (Licensee specifies program that assure performance). Withdraw 50.55a as currently written.

EED. . . _

[ ,, Consistent with performarice based regulatory policy -

  • Relatively simple rule for NRC staff to write. *
  • Could permit use of any (or no) Code edition.

CQN Weakens enforcement (licensees would commit to a program which may but not necessarily conform to a regulatory guide rather than mply with a regulation),

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  • Moves away from ASME and diminishes constructive efforts of the cor.sensus process.

Staff would use regulatory guides rather than rule to identify Code areas and potentially

- code editions that are requM and will continue to develop list of must and must not.

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  • Requires subadttal for staff approval.

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  • More variation in ISI and IST programs at plants.
  • Could significantly delay issuance of rule.

Option 5 Endorse 95 Edition through % Addenda (this would continue historical process of endorsing the ASME Code).

This would require a concurrent regulatory analysis in accordance with 50.109.

EILQ

  • Relatively simple rule for NRC staff to write.
  • Maintains process for Code endorsement.
  • Maintains 10 year update.

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  • Encourages new technology development.
  • Consistent with OMB directive to use industry standards.
  • No need for separate staff review. . .

'. Uses output of constructive consensus process. *

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  • Easy to enforce. ,'* . ., ,. -
  • Uniformity and predictable.
  • CON
  • Not consistent with qt:antitative cost benefit 50.109 criteria.
  • Could slightly delay issuance of rule.

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DECISION CRITERIA

  • Enforceability
  • Safety (amenable to update aner a generic letter or bulletin) risk considerations
  • Uniformity / Predictability ,
  • Need for Action .

NRC Staff Resources .

  • Require / Prohibit / Relief Request
  • Comity with Consensus Process
  • Compatibility with 50.109 *
  • Performance Based
  • OMB Circular A.119 .

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s Attachment 3

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