ML20202C988
| ML20202C988 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/1996 |
| From: | Serpan C NRC |
| To: | Cherny F NRC |
| Shared Package | |
| ML20202C086 | List:
|
| References | |
| FRN-62FR63892, RULE-PR-50 AE26-1-035, AE26-1-35, NUDOCS 9802130094 | |
| Download: ML20202C988 (3) | |
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From: Charles Serpan To:: FCC1-Date: '2/5/96 8:24am C heVettV , $, C- ,
Subject:
- agreement.on 5055a I
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Meeting on 50.55a 2 February, 1996 Serpan, Cherny, Strosnider, Wessman, Campbell Proposed approach for rulemaking on 50.55a Delete " baseline" concept using 1989 ASME-XI/ISI and 1990 ASME/IST Retain ongoing procedure for 120-month update of NRC-approved code.
Results in de facto "baselining" to 1989-XI and 1990 O&M as they are already accepted.
Any new 120-month update will have to pick up to that level anyway.
Allow voluntary use of 1995 addenda to Code.
Only issue beyond the 1989/1990 editions not considered voluntary is Appendix VIII; we intend to impose that now through backfit.
RES must be sure that such voluntary use does not result in an unacceptable decrease in sa'ety. ,
Industry 120-month updates beyond those based on 1989/1990, would therefore not have to modify plans just to accommodate administrat te changes.
Assume that Appendix VIII can proceed as a backfit with the present justification Get the package to CRGR with the present backfit analysis, under assumption they will agree and force the issue versus OGC with Taylor. j Await (hope for) decision on compliance /backfit issue for IWE/IWL, then perhars use that as precedent for the Appendix VIII issue.
Redefine " adequate protection" per Gery Mizuno, and proceed with imposition of Appendix VIII on that basis. I proceed with new, revised package including all other elements.
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j)g 7k-l g% F propose subsequent, new rulemaking to reviss backfit rule ~to allow for a lower hurdle to be met for codes s and standards. adoptions, which are believed to represent a " substantial increase" in safety; this concept is suggested in NUREG/BR-0058, Rev. 2, footnote 5, page 3.
Once-the revised 50.55a rulemaking and the_ subsequent backfit rule change on the codes and Standard- hurdle is resolved, - (?i999/2000?) initiate another lemaking to update code to the then, code addendum a voluntary basis, with appropriate backfits .or items 1 considered safety issues.
Use the Jordan-Sheron procedure for backfitting safety-significant issues both as part of the normal update process, and on an urgent no-waiting-time imposition basis. Da not codify this process per se, but self-impose on ourselves.
Urge the: code to separate safety-significant and administrative issues in updates so that NRC can clearly identify those .tt wants to be backfitted as saf ety-significant iter.is ,
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