ML23158A087
| ML23158A087 | |
| Person / Time | |
|---|---|
| Issue date: | 06/07/2023 |
| From: | Yamir Diaz-Castillo NRC/NRR/DRO/IQVB |
| To: | |
| References | |
| Download: ML23158A087 (11) | |
Text
1 31st Annual NUPIC Vendor Conference Regulatory Process for Code Cases and ASME Code Case N-883 Yamir Diaz-Castillo NRR/DRO/IQVB June 14 - 15, 2023
Agenda
- Background
- Regulatory Process for Code Cases
- Next Steps
- Questions and Contact Information
=
Background===
- What is the purpose of a Code Case?
- To clarify the intent of existing requirements.
- To allow early implementation of an approved Code revision.
- To provide, when there is an urgent need, rules for materials or construction not covered by existing Code rules.
Regulatory Process
- 10 CFR 50.55a, Codes and Standards, incorporates by reference the ASME B&PV Code.
- Lists the Editions and Addenda, Regulatory Guides (RG), and Code Cases that have been approved by incorporation by reference in the regulation.
Regulatory Process
- RG 1.84, Design, Fabrication, and Materials Code Case Acceptability, ASME Section III, Revision 39, December 2021
- RG 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 20, dated December 2021
- RG 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 4, December 2021
Regulatory Process
- RG 1.84 identifies Code Cases the NRC has determined to be acceptable alternatives to applicable parts of Section III of the ASME B&PV Code.
- 10 CFR 50.55a(z) allows the use of alternatives to Code requirements in 10 CFR 50.55a provided that the alternatives:
- Provide an acceptable level of quality and safety, and
- Compliance will result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Regulatory Process
- NRC-approved Code Cases provide an acceptable voluntary alternative to the mandatory ASME B&PV Code provisions.
- Users of Code Cases are responsible for ensuring it does not conflict with the licensees commitments or regulatory requirements.
- Code Case N-883 - Construction of Items Prior to the Establishment of a Section III, Division 1 Owner
- Approved in RG 1.84 with the following condition:
- This Code Case may only be used for the construction of items by a holder of a construction permit, operating license, or combined license under 10 CFR Part 50 or Part 52. This Code Case may not be used by a holder of a manufacturing license or standard design approval or by a design certification applicant.
- Code Case N-883 would allow Certificate Holders to construct components prior to the establishment of an Owner.
- NRC concerned with not being able to provide regulatory oversight of the ASME Certificate Holders manufacturing the components:
- Not consistent with the requirements in Appendix B to 10 CFR Part 50 and in 10 CFR 50.55a for a basic component.
Next Steps
- Feedback provided to ASME B&PV Code committees to enhance Code Case N-883.
- NRC working on developing different regulatory approaches to consider incorporation of the premise of Code Case N-883 into the regulatory framework.
Questions and Contact Information Contact Information:
Yamir Diaz-Castillo Phone: 1-301-415-2228 Email: yamir.diaz-castillo@nrc.gov