ML20202C163
| ML20202C163 | |
| Person / Time | |
|---|---|
| Issue date: | 12/18/1995 |
| From: | Serpan C NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Morrison D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20202C086 | List:
|
| References | |
| FRN-62FR63892, RULE-PR-50 AE26-1-007, AE26-1-7, NUDOCS 9802120181 | |
| Download: ML20202C163 (9) | |
Text
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.pa t UNITED STATES j 'jt NUCLEAR REGULATORY COMMISSION WASHINGTON D.C. 3c66H001 {T) @'
4, . . . . . ,8 December 18, 1995 NOTE T0: David L. Morrison, Director Office of Nuclear Regulatory Re arch FROM: C. Z. Serpan, Jr., Ch Generic Safety Issues Br ch, , IS
SUBJECT:
BRIEFING NOTES ON 50.55a RULE UPDATE Enclosed are a summary set of briefing notes on the 50.55a rule update, for your meeting with EDO and other office directors on the 20th. The essential elements we recommend are the following:
- Retain the 120 month update and drop the " baseline" concept. Thus, we do not support the first two items of the slide: Proposed 50.55a Revisions,
- Agree with Jordan that staff and CRGR have not applied the 50.109 backfit tests on 50.55a updates as rigorously in the past as we should have.
If we commit to such rigorous updates in the future, it will go a long way to meet the arguments in Entergy's CBLA request.
- Recommend that senior management urge the Code to make only "significant" changes rather than a myriad of administrative ones. Updates then are '
small in number but large in safety.
- Recommend no other changes in the package. Thus, don't move yet to performance or risk based.
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PROPOSED AMENDMENT TO 10 CFR 50.55a CHANGES IN THE USE OF THE ASME CODE l
Presentation For:-
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Executive Director For Operations Date: December 20,1995 4
! Cifice of Nuclear Regulatory Research e
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$ CHANGES IN THE USE OF THE ASME CODE BACKGROUND e ASME Boiler & Pressure Vessel (B&PV) Code forms basis for many plant design, inspection, and testing requirements e NRC endorses use of ASME Code in 10 CFR 50.55a requires ISI and IST programs programs must conform to Section XI of B&PV Code l
spe.gifies 120-month update interval for iSI and IST programs
- requires program updates to most recent endorsed edition each interval l e Periodic updates include both technical and administrative changes occasional technical changes result in large safety improvement, i.e.,
ASME Section XI, Appendix Vill " Performance Demonstration For Ultrasonic Examination Systems" many technical changes result in. small incremental safety improvements
- some administrative changes impose significant burden many changes have littic or nol impact on safety G
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m BACKGROUND (continuedl '
R e Entergy Operations, Inc. (EOl), submitted a CBLA request to nat update their current 10-year interval programs for ISI and IST:
argued acceptable level of quality and safety. maintained by continued use of earlier edition of the ASME Code 10-year update produces hardship without a compensating level of quality and safety ,
e NRR Staff reviewed EOl proposal and agreed with general concept e RES and NRR have proposed rulernaking to implement the most significant aspect of EOl request in addition.to several other proposed revisions to 10 L 'CFR 50.55a
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m PROPOSED 50.55A REVISIONS c <
e Eliminate 120-month update requirement for ISI and.lST e Establish baseline requirements: 1989 Section XI for ISI and 1990 OM Code for IST e Delete Modification Related To Containment isolation Valves e Clarify Scope of 10 CFR 50.55a e impose safety significant code changes l
Implement Section XI, Appendix Vill through 1995 Edition -- ISI performance demonstration requirements-L e- Endorse alternatives to the baseline ASME Code rules Temporary Corrective Measures for Service Induced . Degradation for-ASME Code Class 3 Piping e
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- 4 PROPOSED 50.55a REVISIONS (continued)
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! e Endorse Editions and Addenda of the OM and BPV Codes through 1995 for
- voluntary implementation l- -
Must implement full edition and addenda to exercise voluntary update l provision without submittal for NRC review L
Will give licensees freedom to select use of code / addenda later than i
baseline editions as endorsed in the regulations i
l e Use regulatory guides to endorse Code cases RG's 1.84,1.85, and 1.147 for B&PV Code Cases l
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CURRENT PROPOSED RESPONSE TO ENTERGY REQUEST e Proposed Elimination of 120 Month Update Requirement -
10 CFR 50.55ai:gH:4:n:ii? and 50.55aChX4:u:ii) e Impact Of Proposed Elimination Is Reduction in Regulatory Burden For Licensees And Probably Some increase For NRC, But There Is Concern Both Among Some NRC Staff and Within Industry: Elimination of the Update Requirement Probably Has Negative Impact On Code Development' Process -
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?k ALTERNATIVE POSITIVE RESPONSE TO ENTERGY 4
% e Retain 120 Month Mandatory Update Requirernent In 10 CFR 50.55a - Sends Message That NRC Continues To Support Development. Of Industry Codes and Standards e Rigorously Subject Each Code Requirement Endorsed For Mandatory Update To The Provisions Of 10 CFR 50.109 and the CRGR Charter which should result in mandatory updating of only Safety Significant Code revisions l e NRC Staff Participating On ASME Code Committees l Should Emphasize To ASME To Make Primarily Safety Significant Code Revisions, Not Continue The Current Process Of Making Many Editorial Revisions That Do Not Contribute To Safety
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R RES COMMENTS AND RECOMMENDATION tg
- e Elimination Of The Mandatory 120 Month Update is The Most Controversial Aspect Of The Current Rulemaking Among NRC Staff e RES IS Supportive Of The E. Jordan Recommendation To Retain The 120 Month Update Provision Currently in The Regulation Combined With The Additional Disciplines Noted On Slide Entitled " ALTERNATIVE POSITIVE RESPONSE TO ENTERGY" And Thus Believe it Would Result in The Same Reduction in Regulatory Burden As Eliminating The 120 Month Update Provision Without Negative Effects On The Codes and Standards Process e*
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