ML20202C958
| ML20202C958 | |
| Person / Time | |
|---|---|
| Issue date: | 02/23/1996 |
| From: | Cherny F NRC |
| To: | Serpan C NRC |
| Shared Package | |
| ML20202C086 | List:
|
| References | |
| FRN-62FR63892, RULE-PR-50 AE26-1-031, AE26-1-31, NUDOCS 9802130085 | |
| Download: ML20202C958 (3) | |
Text
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- ~ ~l ABat-I From: Charles Serpan 9 til To: FCC1 Date: 2/23/96c h.s cm{ , F.c_.
3:19pf
Subject:
50.55A UPDATE -CONTINUED l
I would appreciate your review of the enclosed summary sheet, !
that describes the current approach we think we are taking for '
the 50.55a update. Frank Cherny and I would be happy to meet with you yet this afternoon or Monday to discuss, if you wish.
I know that we in RES would prefer to continue the present system of truly updating to' endorsed addenda on a 120-month cycle, with cppropriate backfitting of safety-significant items for immediate
, imposition We would even prefer your lowered hurdles for
" Regulatory Anslyses" for code addenda as suggested in the revised CRGR charter. Alternatively, if OGC would reiterate their acceptance of waived backfit for code endorsement, that would be very helpful as well. (Noting that we still would formally backfit anything considered Safey Significant.)
Lastly, at this point, we intend to keep Appendix VIII in the rulemaking package with a backfit analysis for immediate imposition. However, the writeup will be detatchable for reconsideration as a GL or Bulletin if it cannot pass muster as a backfit.
We await your response with interest.
9802130085 980206 PDR PR 4 , 50 62] 63892 PDR y
1 l / 9E M -l '
EMSENT REC 0dMEJDATION, RES AliR_l!M CONTINUE CONCEPT' OF 120-MONTH UPDATE OF NRC-ENDORSED CODE ADDENDA REJECT INDUSTRY-REQUESTED "BASELINING" OF CODE AT 1989-XI AND 1990-O&M SAFETY SIGNIFICANT (SS) ISSUES WHICH ARE DERIVED FROM CODE ADDENDA MANDATED BY NRC; IMPOSED IMMEDI ATELY* THROUGH REGULATORY ANALYSIS PROCESS CONSISTENT WITH 50.109 BACKFIT PROCEDURES (l E. APPENDIX Vill)
ALL OTHER NON-SAFETY-SIGNIFICANT CHANGES
" VOLUNTARY" BY LICENSEES ESTABLISH REGULATORY ANALYSIS REQUIREMENTS FOR CODE ADDENDA AND SS ITEMS IN ADDENDA:
EITHER CRGR CHARTER OR REVISED 50.109 IMPLICATIONS RESULTS IN "DE FACTO" BASELINING AT 1989-XI AND 1990-O&M SINCE REQUIREMENTS ARE ALREADY APPROVED / ENDORSED IN 50.55a WILL RESULT IN NO FUTURE UPDATES AT 120-MONTH INTERVALS BECAUSE ALL NON-SAFETY-SIGNIFICANT CHANGES W;LL BE VOLUNTARY.
WILL DESTROY ANY INCENTIVE FOR CODE IMPROVEMENTS IN TECHNOLOGY SINCE ADOPTION, EVEN OF ASME-DESIGNATED " MANDATORY" PARTS WILL NOT BE REQUIRED BY NRC TO BE IMPOSED AT 120-MONTH INTERVALS Imposition of so-called SS (Safety-Significant) requirements, containerf in code addenda, at 120-month update intervais is not consistent v>!!h 50.109, since such delayed imposition would be considered non-safety-significant by the backfit rule. Thus, the backfit rule would have to be revised to specifically accept delayed imposition of
p5;iv j%
. SS requirements in Code Addenda for continued use 90 of the-120-month update provision.
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