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10 CFR 50.55a –Time for Change

10 CFR 50.55a –Time for Change. Alex Marion Vice President, Nuclear Operations Nuclear Energy Institute NRC Regulatory Information Conference March 11, 2009. 10 CFR 50.55a, Codes and Standards. Background Issues/Concerns Proposed Solution(s) Conclusion. Background.

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10 CFR 50.55a –Time for Change

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  1. 10 CFR 50.55a –Time for Change Alex Marion Vice President, Nuclear Operations Nuclear Energy Institute NRC Regulatory Information Conference March 11, 2009

  2. 10 CFR 50.55a, Codes and Standards • Background • Issues/Concerns • Proposed Solution(s) • Conclusion

  3. Background • Proposed rule November 25, 1969 • Final Rule issued June 12, 1971 • AEC concern that industry standards were not being implemented in plant design and construction in a timely manner • 38 revisions (1972-2008)

  4. Background • Have the original objectives been achieved? • Are plants safe when compliant with specific Addenda/Edition of the ASME Code? • Section III, XI, O&M, CONAGT, NQA, QME, Cranes, PRA Technical Adequacy,… • Editions issued approx. every 3 years • Addenda issued annually • Code Cases • Public Law 104-113 • OMB Circular A-119 • NRC Management Directive 6.5 • SECY 00-0100 and 08-0140

  5. Issues/Concerns • Rulemaking every 2-3 years • Regulatory Guides incorporated into the regulation • Processes • Proposed alternatives 50.55a (a)(3) • Relief requests • Exemptions • 10 year ISI updates • Code Cases • Resources • NRC, licensees and vendors

  6. Issues/Concerns • Enhancements in plant safety • SDO consensus process • Cost/benefit • Imposition of new regulatory positions • Limitations and exceptions • Regulatory stability and uncertainty

  7. Proposed Solution – Back to Basics • Reduce the volume • Plain English • Eliminate unnecessary content • The what? • The when? • The why? • The how?

  8. Proposed Solution – Back to Basics • Principles of Good Regulation • Independence • Openness • Efficiency • Clarity • Reliability

  9. Proposed Solution(s) • Straight up endorsement • Approx. 60 NRC Staff actively involved in ASME committees • Exceptions/limitations only if conflict with existing regulations • Apply 10 CFR 50.59 and 50.71(e) • Control plant licensing and design bases • Detailed information of plant Code of Record to be incorporated into licensee controlled document

  10. Proposed Solution(s) • Both allow NRC to maintain oversight • Inspection • Enforcement • Both will ensure ASME Code remains central to design, operation and maintenance

  11. Conclusion • Now is the time • Unnecessary regulatory burden • Marginal safety benefit • Plant safety has been demonstrated • Is it serving the purpose for which it was originally intended? • Improve the process once and for all

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