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Home > Electronic Reading Room > Document Collections > Commission Documents > Commission Meetings, Slides, Transcripts, Meeting SRMs, and Full Written Explanation for Closed Meetings > 1997
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01/22/1997
1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
***
BRIEFING ON CODES AND STANDARDS
***
PUBLIC MEETING
***
Nuclear Regulatory Commission
Room 1F-16
One White Flint North
11555 Rockville Pike
Rockville, Maryland
Wednesday, January 22, 1997
The Commission met in open session, pursuant to
notice, at 10:00 a.m., the Honorable SHIRLEY A. JACKSON,
Chairman of the Commission, presiding.
COMMISSIONERS PRESENT:
SHIRLEY A. JACKSON, Chairman of the Commission
KENNETH C. ROGERS, Member of the Commission
GRETA J. DICUS, Member of the Commission
EDWARD McGAFFIGAN, JR., Member of the Commission
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STAFF AND PRESENTERS:
JOHN C. HOYLE, Secretary
WILLIAM J. OLMSTEAD, Associate General Counsel
EDWARD JORDAN, Dep. Executive Director for
Regulatory Effectiveness, Program Oversight,
Investigations, and Enforcement
JOSEPH MURPHY, Special Assistant, RES
DR. CARL PAPERIELLO, Director, NMSS
GILBERT MILLMAN, Program Manager, RES
JUNE LING, Associate Executive Director, Codes and
Standards, ASME
BRIAN SHERON, Director, Division of Engineering,
NRR
MARCO MIGLIARO, Past Vice President (Standards),
IEEE
SATISH AGGARWAL, Senior Program Manager, Office of
Nuclear Regulatory Research
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P R O C E E D I N G S
[10:05 a.m.]
CHAIRMAN JACKSON: Well, good morning, ladies and
gentlemen.
I am pleased to welcome members of the Staff and
June Ling, representing the American Society of Mechanical
Engineers; Mr. Marco Migliaro, representing the Institute
of Electrical and Electronic Engineers or the IEEE, to brief
the Commission on consensus codes and standards.
Codes and standards are an integral part of NRC's
regulatory process. NRC endorses codes and standards by
reference in our regulations and through regulatory guides.
The codes and standards rule, 10 CFR 50.55(a) endorses the
ASME Code Sections 3 and 11 and the IEEE Standard 279.
During today's briefing the Staff will focus on
the NRC's use of consensus codes and standards, and Ms. Ling
will provide an overview of the ASME discussion on codes and
standards development and briefly describe some current ASME
initiatives, I understand.
Mr. Migliaro will discuss the IEEE standards
process, NRC's participation in that process, and any other
relevant issues that he wished to bring to the attention of
the Commission.
I understand copies of the viewgraphs are
available at the entrances to the room. If none of my
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fellow Commissioners have any opening comments, I would like
to ask you, Mr. Jordan, to begin.
MR. JORDAN: Good morning, Chairman Jackson, and
Commissioners.
This morning the Staff representatives and
representatives of two of the engineering societies will
brief the Commission on activities related to consensus
codes and standards.
The Staff presentation will focus on its
participation in their development and their use in the
regulatory process.
You have introduced the two representatives from
industry. I would like to introduce the members from the
Staff that are here -- Brian Sheron, Division of
Engineering, NRR; Gil Millman, who is Program Manager,
Codes and Standards, from the Office of Research; Dr. Joe
Murphy, who is acting for Themis Speis today and Themy
indicated to me that he has already participated in his last
Commission meeting.
[Laughter.]
MR. MURPHY: Maybe so.
MR. JORDAN: So he has passed the baton on.
Carl Paperiello is here, Director of the Office of
Nuclear Materials, and the other parties have been
introduced and by introducing the members from the NRC,
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identifying that we are going across the offices -- the
offices are represented, materials as well as reactors.
Codes and standards have been and continue to be
important tools in NRC's implementation of its regulatory
mandate. Such standards as a body contain technology which
is kept current through periodic revisions based on
experience.
These codes and standards are used by the industry
and the regulator in the process of ensuring and
demonstrating the safety of nuclear power plants and other
activities licensed by the NRC.
Staff participation in the development and use of
consensus standards and codes is an NRC-wide activity.
The Office of Nuclear Reactor Research is making
the presentation today because it is the lead office for
coordinating the NRC's codes and standards activities.
Research has had this function since the NRC Office of
Standards Development was subsumed into the Office of
Research in 1981.
With increasing economic pressures on both
industry and NRC, the use of consensus codes and standards
is becoming an even more important element in the regulatory
process. In this changing environment and with the move
toward risk-informed, performance-based regulations, the
Staff expects to work more closely with the technical
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societies such as the ASME, IEEE, American Nuclear Society,
and so on consistent with Commission decisions on the
direction-setting issue Number 13, to identify specific
areas where there is a need for emphasis on new or updated
standards.
I'll now turn this presentation over to Dr. Joseph
Murphy.
MR. MURPHY: Thank you, Ed. Good morning.
The presentation this morning will focus on
consensus national standards with primary examples directed
to engineering standards applied to reactors.
We will discuss why the consensus codes and
standards are important to the NRC, how they fit into the
regulatory framework, Staff participation on the committees,
and the current activities that we consider important.
Although not part of this presentation, I would
like to point out that the Staff is also involved as
official members of international standards writing
activities. This includes IAEA Advisory Committees, and with
regard to the IAEA, NRC has the official leave for the
Advisory Commission on Safety Standards and is represented
on the Nuclear Safety Standards Advisory Committee, NUSSAC,
and the Radiation Standards Advisory Committee, RISAC.
In consultation with others we are also involved
in preparing the U.S. position for two other advisory
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committees to the IAEA.
Making the presentation for the Staff today will
be Mr. Gil Millman. Mr. Millman has recently been assigned
to the position in Research of Program Manager for Codes and
Standards. He has been involved in a very intensive way
with ASME activities on codes and standards for the past 20
years.
As you have already mentioned, we are pleased to
have the speakers with us today from the ASME and the IEEE
that you have already introduced, and with that I'll turn it
over to Mr. Millman.
MR. MILLMAN: Thank you. This morning I'll
explain why consensus codes and standards are important to
the NRC, how we endorse them in the regulatory process, and
how the Staff participates in their development.
I will also identify some actions the Staff plans
to take that would further promote NRC's use of consensus
codes and standards.
Consensus codes and standards are important to the
NRC because they provide the specificity needed to implement
NRC's broad, general design criteria. Additionally, they
form a basis for NRC requirements and guidance in the many
areas noted.
I use the term "form a basis" because NRC still
has the responsibility to review each of these standards and
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make an independent determination that a particular standard
suits the purpose it is intended for with regard to the
regulatory use.
Drawing on the knowledge and experience of
thousands of volunteers in the codes and standards process,
the codes and standards incorporate many years of accepted
good engineering practice and reflect state-of-the-art
technology.
Additionally, the efforts of these many volunteers
provide a tremendous multiplier effect on NRC resources.
Next slide, please.
The regulatory framework for implementing codes
and standards contains components that apply to both NRC and
the licensees. In the context of this talk I am going to
use the term licensees to be applicants and licensees.
First, the part that applies to the NRC. Public
Law 104-113, National Technology Transfer and Advancement
Act of 1995, requires that federal agencies use consensus
national standards -- consensus standards and participate in
their development.
It also has a provision that says you don't have
to use these standards if you can justify why they are not
appropriate for an intended use. In that case the head of
the agency is required to provide an explanation to OMB
identifying why that standard is not being used.
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OMB Circular A-119, Federal Participation in the
Development and Use of Voluntary Standards, provides the
guidance to implement the law. The circular has been around
for a lot longer than the law. The circular was initially
issued in 1982 and provided some general guidance as to how
agency staff should participate on the various consensus
committees, and this was very valuable information and we
have used part of that, the text of that original circular,
in a letter which I will talk about in terms of nominating
people to committees.
In 1993 the circular was revised and it put
additional teeth into it.
First, it required within 120 days of the issuance
of the circular that an agency standards executive be
identified. We did that and the NRC Standards Executive is
John Craig, Deputy Director of the Division of Engineering
Technology, Office of Nuclear Regulatory Research.
In addition, the circular provides that there be
an annual report identifying how each agency has used
standards in that past fiscal year.
The report is fairly simple. You just have to
identify the standards that you have endorsed and the
numbers of people that you have -- that have participated on
committees in the process. There are some other reporting
requirements but they are equally simple.
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There is one additional provision in the '93
circular that requires some effort. There is a requirement
for a five-year review of agency internal standards,
"internal standard" meaning like a regulatory guide that
provides provisions not endorsing a national standard but
contains its own provisions.
To review those kinds of standards and make a
determination of whether any of those standards, internal
standards, could be converted into a national standard that
in turn could be endorsed by, say, a regulatory guide I
might say that Research is working with NMSS to identify
such guides within the NMSS process and working with ANSI to
identify some standards development organizations that would
work with us to develop those standards.
The route for licensees to use codes and standards
is, first of all, the regulations, and then regulatory
guides. Now there are other regulatory mechanisms for
identifying and referencing consensus standards. They are
generic letters, standard review plans, technical
specifications.
With regard to the regulations, there aren't a lot
of codes and standards that are endorsed through the
regulations but those that are are of course requirements.
In particular, the most important one is 10 CFR, 50.55(a).
The codes and standards rule picks up the boiler and
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pressure vessel code, which I will refer to a little bit
later.
Next slide, please.
COMMISSIONER ROGERS: Just before you leave that,
was there anything else that came out of Public Law 104.113
in addition to what was in the 1993 revised OMB circular
that affected us?
MR. MILLMAN: No, it was just those three points:
use the standards, participate on the committees, and you
can take an exemption but you have to report to OMB.
I believe those were the only three provisions.
Next slide, please.
As I noted, endorsement of codes and standards be
regulation is not a major path in terms of numbers but it is
in terms of importance.
What I have identified here is a typical
rulemaking path that is outlined in terms of a significant
questions of policy, and I say that because it requires the
review and approval of the Commission for issuances.
Now the EDO does have delegated authority for
issuing certain types of rulemakings that are not of a
significant question of policy. In such a case the EDO
would approve the rulemaking for issuance. The Commission
would be notified through a daily Staff note, and the
forwarding to the Federal Register would be held for five
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days while the Commission reviews that action.
Now the Administrative Procedures Act requires
that there be a notice of proposed rulemaking and that the
opportunity for public comment exists, and we do this on an
natural basis.
The regulatory process here is a two phase
process -- first, proposed rule, separated by a public
comment from the final rule.
Now in the context of this slide, I would like to
overlay the concept of a regulatory guide, which is another
mechanism for endorsing codes and standards.
The regulatory guide takes the same two-step
process -- draft regulatory guide, final regulatory guide,
separated by the public comment period.
The one major difference is the level of approval.
The draft regulatory guide is approved, first of all, the
Office of Regulatory Research is responsible for issuing all
regulatory guides. The draft regulatory guide can be issued
for public comment under the signature of the cognizant
Research Division Director.
The final regulatory guide would be issued under
the signature of the Director of the Office of Research, so
that is the process of how we endorse codes and standards
through a regulation and through a regulatory guide.
Next slide, please.
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MR. MILLMAN: Since some of the discussions that
follow pertain to the ASME code, I would like to take a
moment to briefly overview the code.
The ASME Boiler and Pressure Vessel Code has 11
sections, two of which are nuclear sections. The nuclear
sections are Section III, which deals with construction of
nuclear power plant components; and Section 11, which deals
with the inservice inspection, ISI, and the inservice
testing, IST of the Nuclear Power components.
Section III and Section XI are mandated for use by
10 CFR.50.55(a). This has been accomplished since 1971.
Addendas to the Boiler and Pressure Vessel Code
are issued every three years. Addendas are issued every
year.
The next element of the Boiler and Pressure Vessel
Code is a code case. You might have heard of code cases.
Sometimes they are confused with interpretations.
A code case is an alternative to the Boiler and
Pressure Vessel Code. It is generally specifically written
as an alternative to a specific paragraph of the Code. In
lieu of doing something for paragraph so-and-so, may I do
this -- and they will provide the guidance for doing that.
The code cases undergo the exact same approval
process within the code as the basic code does itself.
The code cases that come out of the Boiler and
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Pressure Vessel Code are endorsed in three regulatory
guides. One guide addresses construction cases, another
guide addresses material cases and another guide addresses
inservice inspection, inservice testing issues.
Code cases are issued four times a year. Now that
is one of the reasons that sometimes code cases are written
to implement a new provision to the Code, because they come
out four times a year, whereas opposed to the Code being
revised only once a year. Code cases come out more
frequently.
An interpretation now is a clarification to the
Boiler and Pressure Vessel Code. It is not part of the
regulations and NRC is not bound by the interpretations.
The interpretations are issued formally twice a year by the
ASME. However, once an interpretation is approved by the
Committee, that interpretation, the response to the
interpretation is sent to the inquirer and is implementable
immediately -- so anyone that's aware of the issuance of
that letter to the inquirer can issue the interpretation
virtually on the spot within a week or two after the
interpretation is approved.
CHAIRMAN JACKSON: Let me ask a question about
that.
MR. MILLMAN: Yes.
CHAIRMAN JACKSON: How do you keep track of them
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and to what extent are these interpretations relied upon by
our licensees as well as by the NRC?
MR. MILLMAN: They are relied upon. They are
clarifications to the Code.
Generally the Staff and the ASME or in agreement
with what the interpretations say, there are very few
interpretations that are potential differences between the
Staff and the ASME committees.
Every once in awhile one does come out, but they
are relied upon very heavily. They are relied upon in the
field by the inspectors. The licensee may point to an
interpretation that would influence the way the Code would
be implemented at that utility site, so they are relied on
very heavily.
CHAIRMAN JACKSON: So what is enforceable?
MR. MILLMAN: Generally, I believe the staff at
the site would go along with the interpretation. If there
is a conflict in that interpretation we now have an
inspection manual section that says bring that difference to
headquarters for resolution -- it's Part 9900.
CHAIRMAN JACKSON: Brian, you wanted to say
something.
MR. SHERON: Yes. I would just like to add that
this issue has come up recently.
We have taken a position that interpretations that
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are made subsequent to the Staff endorsing the Code we do
not believe are part of what we had approved.
In other words, it's after the fact. As Gil said,
I think in most cases we go along. We agree with the
interpretations that the Code does provide because it's
basically a clarification that sometimes is needed.
We have written a letter to our regions. I think
I signed it out probably over a year ago in which we told
the regions that if in the course of doing an inspection
there is a question raised regarding implementation of the
Code and an interpretation that it should be referred back
to the headquarters office and we would try and resolve it
then.
So that is basically the position we have been
following since this whole issue came up with regard to
interpretations.
CHAIRMAN JACKSON: Commissioner McGaffigan?
COMMISSIONER McGAFFIGAN: I would like to follow
up. This might be the right time to ask a question I was
going to ask later and the industry folks should feel free
to respond after the Staff, but one of the concerns that we
got from ASME in the context of the direction-setting issue
paper was that little consideration has been given to the
need to streamline and simplify NRC's internal process and
regulatory process to be able to endorse nuclear codes and
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standards within a year after they have been issued by the
ASME.
It sort of goes to the last couple viewgraphs.
Our processes, whether it is a reg guide or a
rulemaking, take years. They go on the second page. In
their processes you are talking about quarterly updates and
there's a difference in time constants.
Has the Staff given any thought to how to bring
these time constants into better alignment or resolve this
concern that ASME has expressed to us in the strategic
assessment process?
MR. MILLMAN: The Staff has given thought to that
very consideration. We haven't come up with a conclusion on
how to speed up our process because built into our process
is this public comment period and going out for public
comment and resolving the comments you are kind of built
into a two-year timeframe.
COMMISSIONER McGAFFIGAN: They suggest doing some
things concurrently rather than seriatim. The same time the
codemaking is being done we would try to get the two
processes at least to be parallel.
MR. MILLMAN: I believe that the Staff would be in
agreement to try and speed up the process. How we would do
it is yet to be determined but we agree that the process
needs to be speeded up.
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MR. JORDAN: For the Staff, as the author of the
DSI-13 --
[Laughter.]
MR. JORDAN: -- we certainly do have an interest
in developing ways to make those reviews a lot more timely
so the implementation phase of that DSI will clearly address
that. I recognize it is a problem and feel that we will fix
that problem.
CHAIRMAN JACKSON: Ms. Ling, you wanted to make a
comment.
MS. LING: Yes. I appreciate bringing up the ASME
request that the endorsement of ASME codes and standards be
expedited.
I would like to make a comment on a response to
your question, Chairman Jackson, on interpretations.
Recently we did convey ASME's position on
interpretations to your Staff and basically that position is
that as Mr. Millman stated, interpretations do not make new
rules -- do not establish new requirements.
They are intended to purely clarify existing
requirements.
On that basis ASME is the only official
interpreter of the code requirements since we are the
developer of the code requirements.
But what was also agreed was that should ASME
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issue an interpretation that was contrary to the intent of
the regulatory process in adopting that particular set of
requirements, then that is purely within the realm of the
regulatory process.
With that again, as Mr. Sheron mentioned, the
number of interpretations -- we issue probably I would say
in all of our codes and standards activities about 30,000
inquiries to our documents a year.
When you narrow that down to the official
interpretations issued in writing to the Nuclear Sections of
the Boiler Code we are probably talking a few hundred per
year, and in all of the years of our interpretations there
were perhaps maybe less than 10 that fell into the area of
where ASME might have issued an interpretation which the
regulators felt was contrary to their intent when they
adopted that particular requirement.
CHAIRMAN JACKSON: Thank you.
What in fact is the latest edition of the ASME
Boiler and Pressure Vessel Code, and what is the latest
edition endorsed by reference in our regulations?
MR. MILLMAN: The latest edition referenced in our
regulation is the '89 edition for Class I, II and III
components. For containment structures, for ISI containment
structures it is the '92 edition with the '92 addenda.
The latest version out is the '95 edition with the
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'96 addenda.
We are presently in rulemaking, preparing
rulemaking to pick up that latest version.
CHAIRMAN JACKSON: And when do we expect that that
rulemaking might be completed?
MR. SHERON: Right now there's two options in
terms of how to proceed with a rule.
These are being finalized by the Office of
Research and I believe it would be presented to the
Committee to review generic requirements probably within the
next couple months, so hopefully we would get this out by
springtime, something for public comment.
CHAIRMAN JACKSON: Okay.
MR. MILLMAN: Next slide, please.
CHAIRMAN JACKSON: I have one last question.
Have we made any judgments on the safety aspect of
changes to the Code since the last endorsement by the NRC in
regulations, since you are talking at least for part of it
for components, Class I, II, III. You are going back, going
on eight years.
Have there been any judgments in terms of safety
impact?
MR. SHERON: Yes, there's two areas I would point
out.
One of the things we are doing right now as part
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of the rulemaking is going through the new, the '95 edition
and trying to ascertain which items we think are very
important to safety.
One is Appendix 8, which was the performance
demonstration -- initiative on inservice inspection, and
that is one which we would like to see required like
immediately -- in other words, not wait for the 10-year ISI
update that each plant -- I don't know if you recognize it.
Plants have to update their programs every 10
years and at that time when they update they would have to
adopt the latest version of the Code. We think the
performance demonstration program, Appendix 8, is very
important in terms of finding flaws and so forth and we have
a generic letter out on it right now and we are proposing
that in implementing the rule this would be something that
licensees would have to implement very soon.
An area where we found we had difficulties is the
new pipe and design area. The rule has promulgated new
piping design criteria for pipes which the Staff has taken
objection to. We just don't agree with them.
We had a number of technical concerns. These were
ultimately sent to the ASME in a joint letter signed by Mr.
Beckjord and Dr. Murley several years ago.
The ASME is taking this along with other new
information and is reassessing. There is I believe a special
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working group or task group which the NRC is working with
them to try and resolve what these differences are, but
these are two examples where we have gone through.
One we think is very important and we are
endorsing it for early implementation. The other is where
we have disagreements and we are not endorsing it.
CHAIRMAN JACKSON: Well, referencing Commissioner
McGaffigan's earlier question and given what you just said,
do you, you know, in a systematic way parse the additions or
addenda relative to their safety and risk significance and
give attention to them on that basis in terms of expediting
perhaps portions of them?
MR. MILLMAN: Well, up to the '89 edition we were
mandating use of the total edition and addenda and even in
that '89 edition we did perform a regulatory analysis that
distinguished between administrative and editorial type
items of a medium cost benefit and items of a very
significant cost benefit, which in that particular case
happened to be a reactor vessel exam.
We did do a regulatory analysis, a full regulatory
analysis on the reactor vessel examinations. We are still
working on this very next edition and very next amendment
and the concept of the backfit rule has come into
consideration.
Prior -- the '89 edition we didn't worry about the
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backfit rule. It was an automatic backfit from years 1971
on. Now we are considering the impact of that and the Staff
is puzzling through how to handle it.
CHAIRMAN JACKSON: Doesn't that again suggest that
a parsing based on risk significance is all the more
relevant?
MR. MILLMAN: Well, there's another thought that
you have to put into this and that is this is not like a
requirement that's being written by the staff.
CHAIRMAN JACKSON: Right.
MR. MILLMAN: It's written through an engineering
society, industries participating, and regulatory
authorities are participating, so it's another concept and
we have to figure out how that works into the process.
MR. MURPHY: I think it's important to point out
that there are two options that we're studying right now.
In the one case, we're taking the various portions of the
Code that are changing and we're looking at each one of them
and we're doing a regulatory analysis on it to do just what
you said, to assess the safety significance of it.
The other option, and one option would be to
approve only those we feel have a high safety significance.
The other option is more geared to what we have done in the
past in approving the Code, changes in their entirety.
Whichever option we choose, and they have
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strengths and weaknesses both ways which we're still
analyzing, we will have the benefit of that regulatory
analysis that's been done on each portion of the Code, so
we'll know what's important and what's not. I think more
importantly, we know what's critical to do in a reasonable
time frame.
Many of the Code changes are relaxations, but
some, as Dr. Sheron has indicated, are very important and we
need to proceed. So we will have that background. No
matter which option we select, we will have the results of
that regulatory analysis and that is essentially complete
now, so we're moving ahead at a reasonably fast rate.
CHAIRMAN JACKSON: I get the impression that
Commissioner McGaffigan has a follow-on question.
COMMISSIONER McGAFFIGAN: Well, again, one of the
comments we got from NEI, which is slightly different, has
to do with increasing margins of safety through selectively
picking which Codes we're going to endorse and which not.
I'll just read it, you guys probably are familiar with it,
"Under such circumstances, it should be expected that
codification of practices that go beyond assuring adequate
safety, that go instead to achieving operational excellence,
will not occur. Industry cannot be expected to contribute
through codes and standards activities to the growth of the
margin of safety which will be required by the regulator."
. 25
I'd just be interested in your comment on that
because I think it's pertinent to these two options probably
that you're thinking about in this Code and in general. Is
there an industry perception that our approach to Code
development is constantly one where we're increasing margins
of safety that get no relief from anywhere else?
MR. SHERON: I would say no. I don't think there
is a uniform feeling from the industry. What we were
concerned about in these two approaches, is one is where you
go through let's say the latest edition of the Code and you
look at each item and determine if there is a substantial
improvement to safety that meets the backfit rule.
We find that there is a lot of improvements that
may be more administrative in nature. They may enhance the
ISI Program administratively, but may not contribute
directly to increased safety.
What we have heard from some utilities is that by
imposing the entire new version of a Code, you are imposing
all of these administrative requirements which they may say
for us, it is not beneficial to adopt them and you're
costing us money because we have to change procedures, we
have to retrain our technicians, et cetera, et cetera. This
is a burden to us and it's not cost justified.
The other side of the coin is that when you start
going through these editions of the Code, like the 1995
. 26
edition, and you start categorizing each one and it's
somewhat important, administrative, or you shouldn't do it,
what the concern is that then you've created a menu in which
a utility can go in now and say, well, I'll adopt this, this
and this, but I won't adopt that, and what they wind up with
is an ISI program that nobody can trace back to anything.
That's a concern on a lot of the staff that you
have now this program in which they've picked some parts of
the 1989 version, some of the 1995, something in between,
and to have that traceability so an inspector goes out and
can say, are you following the Code and what is your Code of
record. Now there is no Code of record; it's several Codes.
That's the other side of the coin and we're trying to deal
with that. We're still struggling a little bit.
CHAIRMAN JACKSON: So that's what you mean when
you say that you haven't totally worked out how the kind of
cost benefit analyses that what, 10 CFR 50.109, require,
apply in this context and how you go about parsing, but
nonetheless, you are looking at the parsing issue and how it
relates to the safety?
MR. SHERON: Yes.
CHAIRMAN JACKSON: Because that's important.
Okay, thank you.
MR. MILLMAN: Next slide, please.
CHAIRMAN JACKSON: Are we still talking about --
. 27
one last one -- this ASME Section 3 that relates to
construction. This is one of those hidden bomb questions.
Are all currently operating nuclear plants constructed to
that standard?
MR. MILLMAN: To Section 3?
CHAIRMAN JACKSON: Right.
MR. MILLMAN: No.
CHAIRMAN JACKSON: So what then applies, what
regulations govern plants that are not?
MR. MILLMAN: I don't know what the regulation --
CHAIRMAN JACKSON: I told you what it was.
MR. SHERON: I believe there are a number of
different standards that were applied prior to plants that
adopted Section 3. We could get you a list. I don't know
whether anyone on the staff --
MR. MILLMAN: In terms of the standards, it's
B31.1, ASME B.31.1.
CHAIRMAN JACKSON: You don't have to give the
litany here, but the real question I have is -- you've
answered the first part of the question, so given that
answer, the issue is how broad-based it is and I'm going to
come to you in a second and do a we clear. You mentioned a
kind of a problem for our inspectors relative to another
question, but if now we have this ASME standard and you have
plants not built to it, what clarity is there as to what
. 28
governs their situation. Dr. Shao?
DR. SHAO: My name is Larry Shao, Director of
Division of Engineering Technology.
Depending when the plant was built and
constructed, Section 3 was issued in 1963. Before Section
3, ASME Code Section 3, there were two codes. One is
B.31.1, Power Piping Code. There's another one called 31.7,
Nuclear Piping. So if the plant is built before that, it
was built to B.31.1 or B.31.7 and when the ASME Code Section
3 came out, then all the plants were built to ASME Code
Section 3.
CHAIRMAN JACKSON: How were they different from
ASME Code --
DR. SHAO: Actually, B.31.1 was a little bit more
conservative than the ASME Code. For instance, the
allowable stretch is one-quarter of the ultimate and for
Section 3, the allowable stretch is one-third of the
ultimate.
CHAIRMAN JACKSON: What about B.31.7?
DR. SHAO: B.31.7 is essentially the same as ASME
Code Section 3.
CHAIRMAN JACKSON: Okay. So maybe you could just
send the information to the Commission relative to how these
things fall out across that line. Okay, thank you.
MR. MILLMAN: Slide 9, please. We've addressed
. 29
much of what's on here. I'll just go to the third bullet.
There is this 120-month update that we've talked about. One
thing that we haven't mentioned is the fact that 10 CFR
55(a) endorses or actually references three regulatory
guides, the three regulatory guides that I mentioned
previously that endorse the Code cases.
In addition, 55(a) incorporates by reference the
IEEE Standard 279 which is Criteria for Protection Systems.
Other IEEE standards are normally endorsed through the
regulatory guide process.
Next slide, please.
CHAIRMAN JACKSON: Not so fast. Commissioner
Rogers?
COMMISSIONER ROGERS: I wandered if you'd give us,
just very quickly, some examples of limitations and
modifications that we've imposed.
MR. MILLMAN: The last one we had imposed -- first
of all, let me say that we've imposed like eight in 25
years, so it's not a whole bunch. The one that comes to my
mind off the top is the last one was on containment
isolation valves, the method that was being treated in the
particular version of the Code, we didn't feel properly
addressed the evaluation of leakage data. We required that
a specific version of the Code be used rather than the one
that it was contained in.
. 30
Others addressed the examination categories for
piping. None of them I would put into a major category.
Offhand, I can't think of others.
CHAIRMAN JACKSON: Let me ask you a question about
your view graph 9, the one on the scope of 10 CFR 50.55(a).
You mentioned that it incorporates by reference the IEEE
Standard 279 and that other IEEE standards are endorsed by
reg guides.
Does this mean that -- first of all, has that
standard ever been updated or superseded?
MR. MILLMAN: It will be. There is action being
taken to use IEEE Standard 603 in lieu of 279. That
rulemaking is being initiated.
CHAIRMAN JACKSON: That's Criteria for Safety
Systems?
MR. MILLMAN: Right.
CHAIRMAN JACKSON: Okay. How old is that
standard?
MR. MILLMAN: Which one?
CHAIRMAN JACKSON: 279?
MR. MIGLIARO: Actually, if I can answer that,
IEEE 279, the last edition was 1971, but it has been
withdrawn for a number of years by the IEEE, so it is no
longer an official IEEE standard.
CHAIRMAN JACKSON: Okay, but at the moment that's
. 31
still --
MR. MILLMAN: That's the one in effect.
CHAIRMAN JACKSON: And you're saying there's a
rulemaking to replace 279 by 603. I see there's someone
here who wishes to speak.
MR. AGGARWAL: Satish Aggarwal from Research.
Madam Chairman, I'd like to point out that we have already
endorsed IEEE Standard 603 by issuance of effective guide
1.1.53. As far as the staff is concerned, this is already
replaced but we are now proceeding in the rulemaking to
change that particular paragraph to IEEE Standard 603.
CHAIRMAN JACKSON: Okay. So 279 is the only
electrical standard that is in actual regulatory
performance?
MR. AGGARWAL: That is correct. That is the only
standard.
COMMISSIONER McGAFFIGAN: Could I ask a question?
On something as simple as that, when did we send that letter
saying the staff endorsed the 603 or whatever? When was
that action taken?
MR. AGGARWAL: That regulatory guide was issued in
June 1996.
COMMISSIONER McGAFFIGAN: In June of last year?
MR. AGGARWAL: Right.
COMMISSIONER McGAFFIGAN: I'd urge that we get on
. 32
with something like that. I doesn't sound like a big
package that has to come to the Commission.
CHAIRMAN JACKSON: It's more complicated than it
seems but it still begs the question in terms of the
timeliness with which the changes are made because the
question I had was you have these standards that have been
endorsed in reg guides and then you have this overall
electrical standard, I really don't know because obviously
the Commission is not into the details of it, but I note
that you have a standard relating to digital computers and
one related to criteria for safety systems.
We know that a number of licensees are making
digital upgrades to various systems in their plants,
presumably they have interactions that cross these
boundaries of these various standards. So I think there's
some lack of clarity, at least that I have, in terms of how
the replacement of one standard in our regulation plays off
of the various standards that may be endorsed in the reg
guides and how they all interact with each other. To me, I
don't know what it all means, so maybe you can provide some
more clarity to the Commission.
MR. OLMSTEAD: Or some more complexity.
CHAIRMAN JACKSON: Well, sometimes clarity
involves complexity.
MR. OLMSTEAD: Right. I think one of the things
. 33
that complicates this is that the Federal Register abhors
incorporation by reference.
CHAIRMAN JACKSON: Yes.
MR. OLMSTEAD: So we have to play a lot of little
procedural devices in order to get these codes into the
regulations and that takes time. So the endorsing process
through the reg guides is quicker, but our change in the
regulations lags that because we can't just incorporate the
reg guide by reference and then change the reg guide because
the Federal Register won't approve that.
I think a lot of the problem you're having is the
kind of procedural devices we have to go through in order to
get it actually in the Code of Federal Regulations which is
saying something different than that's what the staff is
enforcing because what they're enforcing is what they've
approved.
CHAIRMAN JACKSON: What's in the regulation.
MR. OLMSTEAD: And in the reg guides.
CHAIRMAN JACKSON: The reg guides don't have
enforceability.
MR. OLMSTEAD: That's right but they do have
interpretive force. We have to treat those, particularly
under this new rulemaking process, we have to send that down
to OMB and to the Congress, and do all these other things
just as we do the regulations.
. 34
We have to be real careful with this incorporation
by reference problem because the Federal Register wants the
public to be able to read this and know what the current
edition is. They don't want us using in the reg guide
process to endorse a standard that's not here.
CHAIRMAN JACKSON: Let me ask a question to you
and put it this way. Does our method of endorsement matter
in regulatory space and how does it matter?
MR. OLMSTEAD: It matters because we have to be
careful to comply with the Office of Federal Register
requirements for our regulations.
CHAIRMAN JACKSON: No. I'm talking about from the
point of view of how we carry out our regulatory program.
MR. OLMSTEAD: No. That is an ultimate safety
decision, I think. We will find a way to get it in the
regulations, depending on what the safety decision is. I'm
just telling you, historically it's been a problem to get it
into the Code of Federal Regulations because of the
incorporation by reference problem, but I don't think it's a
safety problem.
COMMISSIONER McGAFFIGAN: Could I ask, is this a
problem that other regulatory agencies face as well that try
to use codes?
MR. OLMSTEAD: Absolutely.
COMMISSIONER McGAFFIGAN: And has anybody ever
. 35
gone to the Congress and said, do you really mean it here?
MR. OLMSTEAD: Yes.
COMMISSIONER McGAFFIGAN: Or can we step back.
MR. OLMSTEAD: I think the whole purpose of
passing this Act was referenced a little bit earlier, that
says agencies will incorporate the industrial codes and
standards, was an effort by Congress to address this problem
and we're hopeful that in working with OMB, we'll get some
relief on that, but we're in the process --
COMMISSIONER McGAFFIGAN: So it isn't a statutory
problem any longer; it's a problem with OMB and what they -
-
MR. OLMSTEAD: And working out with the Office of
Federal Register how we're going to incorporate industrial
codes and standards when they change as rapidly as they do
because the Federal Register process is a slow process. I'm
not trying to make it more complex.
CHAIRMAN JACKSON: No, you're just trying to
explain it the way it is and as far as we all understand. I
guess my issue really has to do with given the speed of
changes and our method of endorsement, what operational --
operational in the sense of our carrying out our program --
what happens in enforcement space, how we interact with our
licensees, et cetera, what impact does this have? Reg
guides are that, are they not, they're guides?
. 36
MR. SHERON: They're an acceptable way to
implement a regulation.
CHAIRMAN JACKSON: So if there is an issue or some
disagreement with a licensee, then we fall back on the
safety argument. Is that the whole point to come around the
fact that something may or may not be codified in the
regulation?
MR. SHERON: Ultimately, we have to make a
decision whether there is a violation the regulations or
not, if there is a different way of doing something. That's
why we issue the reg guides, to provide guidance on an
acceptable way for the utility to meet the regulation.
I don't think, though, that this causes a big
problem. The utilities are not, I don't think, anxious to
go changing their in-service inspection and testing programs
very rapidly because it is very expensive to do it.
CHAIRMAN JACKSON: Right.
MR. SHERON: I think they would like to see some
quantum step changes made and then they would go and
implement a whole new program.
CHAIRMAN JACKSON: I see. Commissioner Rogers?
COMMISSIONER ROGERS: Yes. Is there a problem
with our holding up really finalizing everything with
respect to a rule that would incorporate by reference a
standard because we can't get it published in the Federal
. 37
Register with just a reference to that? In other words, is
there a disconnect there that we have everything in place,
we know what we want, it's a reference to that standard, the
rule would so state, but it can't be published in the
Federal Register because of this other problem?
Knowing that, does that hold us back from making
it clear what our rule actually is?
MR. OLMSTEAD: Not for the simple changes. For
the ones the staff comes in and says, all we want to do is
update the standard here, we don't see any problem, we have
a mechanism to do those rule changes very fast. As a matter
of fact, those don't even come to the Commission; they're
approved by the EDO and the rulemaking process can be done
in 90 days.
But for those where there is some disagreement
within the staff about what sections of the Code to apply,
you're going to have commentors coming in with disagreements
with the staff and that's going to have to be resolved.
Those are the cases I thought we were focused on which is
why we're not taking the whole Code and just updating the
reference, we're actually picking and choosing what portions
of the Code we want to incorporate. Those are the more
difficult cases.
CHAIRMAN JACKSON: Well, with us having slowed you
down, we're going to ask you to speed up.
. 38
MR. MILLMAN: We've covered page 10, Endorsement
of IEEE Standards. The consensus process, I'll cover very
rapidly.
The consensus process, Slide 11, is something we
live with when we're writing these consensus standards.
It's administered by ANSI, it's implemented by the
particular SDO and the consensus process, taken as a whole,
is intended to provide the majority view but it protects the
individual vote.
I have to say that vigilance is required on the
part of all participants to ensure that the process is
implemented squeaky clean. One of the items, balance of
categories of interest, what we talk about there is within
the Consensus Committee, there are designers, constructors,
regulatory inspectors, insurance. Within that regulatory
block, there's only one or two people. Within the utility
owner block, that's usually up to the max of one-third of
the committee.
So although you're talking about balance of
interest, in terms of the number of votes in any one of
these blocks, the NRC is a single vote in the process and
that needs to be clear.
CHAIRMAN JACKSON: That's interesting. So what
then does substantial agreement mean?
MR. MILLMAN: Substantial agreement means two-
. 39
thirds vote within the Consensus Committee, but understand
that the balance of interest plays a part in this.
CHAIRMAN JACKSON: That's why I asked the
question.
MR. MILLMAN: Yes, I understand. Next slide,
please.
Nomination process for staff committee members,
generally speaking, a letter comes in asking for staff
participation or we initiate the letter. The important
thing about this letter is, which is signed out by the
Director of the Office of Research, the letter nominates an
agency representative and in that letter, it uses the words
from the OMB circular which states, "Staff participation
does not connote agency agreement with committee decisions."
So although the individual is there doing his best
to put forth the agency view, the agency is not necessarily
committed to what comes out of the decision process. The
letter that goes out from Research is a nomination letter.
The SDO votes on all nominations for acceptance. Next
slide, please.
Staff, committee member responsibilities, these,
again, are defined by OMB Circular A-119, "Be An Active
Participant." Participate on the basis of equality. That
means don't let the agency's influence dominate the process.
That's something we cannot permit to happen for this to be a
. 40
fair process.
Views expressed should not be inconsistent or in
conflict with established agency views. To do this, it
means a lot of homework on the part of the committee
representatives, that they're able to understand what the
views are and to express them.
Now, down at the level of developing the
standards, there may not be a specific agency position. For
example, on the Code cases on risk informed, we know that
the agency is moving forward to risk informed, but we
certainly don't know every step of the Code case what the
agency position would be, so the staff makes best judgments
along the way.
Page 14, I'll pass. That's just an organizational
chart showing where the consensus committees are. The
committee items that are identified as committee are the
consensus committees where the balance of interests actually
takes place. Slide 15, please.
This is just an example of the ASME Section 11
committees. It's a very intense four days of meetings which
is where all these committees meet. The process starts out
at the working groups on Mondays and works up to the
subcommittees on Thursdays. There has to be a lot of
coordination on the part of the committee members to
understand what's happening at the lower committee so we can
. 41
establish some valid actions as the process moves forward.
Next slide, please.
The IEEE board and committees are similar to the
ASME structure. The regulatory guides that endorse the IEEE
standards that went final during this last year, those IEEE
standards came out of The Power Engineering Society. All
the standards that are in draft right now -- not the
standards, rather, but the regulatory guides that are in
draft endorsing the IEEE standards on computer software came
out of The Computer Society. Next view graph, please.
This next view graph will provide a summary of
staff participation on the various SDOs. As you can see,
the ASME has the most people, the most staff on the various
committees. I should indicate what "other" is. There is 12
other societies in there -- excuse me, seven other societies
-- The Association for Advancement of Medical
Instrumentation, The National Council on Radiation
Protection and Measurements, The Instrument Society of
America, plus others. We have one or two people on each of
these committees.
Now, this totals 166, but it doesn't represent 166
individual people. For example, I'm on an ANSI committee as
well as an ASME committee, so I'm counted twice. Next
slide, please.
This next slide shows the distribution of staff
. 42
participation from the various offices. This totals 142.
You can see from this chart that there's broad agency
participation. We estimate that this 142 staff represents a
little under 10 FTEs. Next slide, please.
Section XI and other documents within the ASME
process are living documents. The committee meets four
times a year and changes are made on a regular basis based
upon improvements in knowledge, improvements in technology,
and this list provides an example of some of these revisions
that are important to the NRC. I'll just go through a
couple.
The very first one, the Section XI Code case for
thermal annealing reactor vessels is an important Code case
and was developed to assist a utility request for thermal
annealing.
What the Code case does is provide the stress
allowables that must be met during the thermal anneal to
ensure the continued integrity of the reactor vessel. This
particular Code case was developed on an expedited basis
within the Code with considerable help from the NRC and
utilities.
Look down at the very last one, the operation and
maintenance of the O&M Code for pumps, valves and snubbers,
the O&M Code was originally put forth in 1990. It's been
modified since. We've got a lot of dedicated people from
. 43
the staff and from industry working on this process and they
haven't seen their document endorsed in the process yet.
The next amendment to 55(a) will incorporate the
O&M Code. The version that will be incorporated is a 1995
edition with the 1996 addenda. This Code would replace the
rules for IST that are presently in Section 11 and are
presently what is enforced. Next slide, please.
Current activities that are ongoing, as Dr. Sheron
previously mentioned, the Section III revision that we have
a problem with, dealing with the seismic design of piping,
is being revisited by the ASME, looking at new information
to determine whether those rules should be modified.
Both Section XI and O&M have active code cases
being developed or code cases being developed actively for
risk-informed ISI and IST.
As you know, the Staff is working with pilots to
implement risk-informed ISI and IST programs. These code
cases will come out, I presume. At some point they will be
evaluated for endorsement relative to the results of the IST
programs.
CHAIRMAN JACKSON: Of the pilots?
MR. MILLMAN: Of the pilots, that is correct.
IEEE is just initiating a program to look at risk-
informed criteria for design and application but that is
just a start and that's just being considered at this point.
. 44
Digital upgrades, electromagnetic and radio
frequency and interference and software reliability are all
being considered in the context of criteria for replacements
and upgrades and new applications.
Next slide, please.
Finally -- to the summary.
The first bullet really reflects the state of
activities. The NRC continues to rely heavily on the use of
consensus codes and standards and the Staff continues to
participate actively with SDOs on current issues.
The second bullet is supportive of direction
setting issues -- 12 on risk-informed performance-based
regulations and 13 on the role of industry.
The Staff plans to increase interactions with SDOs
regarding the development of new codes, standards and
guides, especially those which will facilitate the
transition to risk-informed, performance based regulations.
Finally, to address implementation of the Public
Law and the circular, RES will prepare an action plan to
ensure NRC compliance with Federal law and policy guidelines
for participation in the development and use of codes and
standards. The action plan will be submitted to the
commission for approval for implementation.
COMMISSIONER ROGERS: When?
MR. MILLMAN: The action plan would have to be
. 45
coordinated with all other offices and this is an agency-
wide program. I would think that between six to nine months
we would have some sort of a program that could move forward
to the Commission that would have been considered by the
other offices.
CHAIRMAN JACKSON: Why don't you come back with a
date that you think makes sense?
MR. MILLMAN: That's fine.
CHAIRMAN JACKSON: Yes?
COMMISSIONER McGAFFIGAN: And could I ask Mr.
Jordan a question on his paper on DSI-13? The financial
resource requirements involved that have been guesstimated
as to what would be involved in carrying out the preliminary
review of the Commission were pretty substantial. I am
trying to understand, given that you have 142 people,
approximately 10 FTEs, why in order to do what you want to
do in terms of additional code work, why are -- I think the
estimates were 20-25 additional FTEs -- that that would be a
two or threefold expansion on what we are doing now. Am I
misreading the resource estimates for DSI-13?
MR. MILLMAN: No, and it is front-end loaded. If
we were to implement that fully we would change the way we
do business and so it would be in the manner of developing a
process to speed up our interactions and intensify the
interactions, identify the codes and standards and guides
. 46
that we believe need updating because the updating process
for the codes committees is extensive and time-consuming as
well, so it becomes an industry burden if there is a focus
that the NRC puts on code areas that don't presently have a
focus that would need care and feeding.
COMMISSIONER McGAFFIGAN: So it would be the
same -- under 42 people but a much larger percentage of
their time would be devoted --
MR. MILLMAN: The first year or two there would
have to be more time dedicated in order to get this moving
in the direction and speed we are looking for.
CHAIRMAN JACKSON: Dr. Paperiello, I am assuming
they don't just have you sitting at the table for
appearances sake. Therefore, the question I have for you is
where do these issues most impact the programs you are
responsible for?
DR. PAPERIELLO: I have people that are on these
various committees, some of which we really haven't focused
on today such as the ANS and the Health Physics Society, the
Institute of Nuclear Materials Management.
We use a number of codes and one of the things
that hasn't been discussed is I would say codes we use but
from my knowledge we never endorse. We just see them being
used.
For example, almost all the procedures that are
. 47
used for measuring radiation by our licensees are found
somewhere in a standard somewhere -- in an ASTM procedure
for water and waste-water, there are standards for doing
alpha, you know, various types of spectroscopy and the like.
We do not really have people on any of those
committees. We use them. It's sort of almost that's the way
you do business.
If we get involved -- to the extent to which we
get involved with regulation of DOE many of our standards
are going to have to be updated -- almost all of the
Division III regulatory guides -- and I would say about half
of the Division VIII regulatory guides are out of date. They
were written in the '70s and not really changed and our
dosimetry has changed.
If we change over instead of revising them
ourselves, the fact of the matter is they haven't been
revised for lack of resources, if we have this done through
a consensus standard it's going to involve a considerable
amount of work.
It ought to be done that way because there is far
less expertise relative to the industry today than there was
when those guys were written 20 years ago.
There are other organizations where we don't
interact with very much which we probably should -- for
example, the American Association of Physicists in Medicine
. 48
have probably on the order of 40 to 45 standards, not all of
which affect what we do but a number of which do.
In some cases we use standards but don't really
acknowledge it. It's just as a practical matter. In other
cases we just don't use standards which are out there that
we probably ought to use. We do things on our own.
CHAIRMAN JACKSON: Should we be using standards or
are there particularly critical areas where we use standards
that we haven't endorsed that we need to take a look at?
DR. PAPERIELLO: Oh, I would say anything
involving the use of -- where a guide was issued prior to
1980 we need to take a look at the area addressed.
CHAIRMAN JACKSON: Now has this then been
systematically assessed and have the resource estimates for
beginning to address some of this been folded into the
resource estimates of the Commission?
DR. PAPERIELLO: Yes. We have been interacting
with the people in Research who put together all these
estimates. Yes.
CHAIRMAN JACKSON: Okay.
MR. MILLMAN: And part of my answer really should
have been to broaden the codes effort further into the
materials area.
CHAIRMAN JACKSON: Okay. I think we should move
along to the ASME presentation.
. 49
MS. LING: Madam Chairman, Commissioners, and
fellow attendees, I am honored to be here and to have this
opportunity to represent the American Society of Mechanical
Engineers.
I would like to introduce two other people who are
here with me today.
The first is an elected officer of ASME, Mr. James
Perry. Jim is Chairman of the ASME Board of Nuclear Codes
and Standards and holds the title of Vice President, Nuclear
Codes and Standards.
Also, an ASME staff person is here, Mr. Jerry
Eisenberg. Jerry is the Director of Nuclear Codes and
Standards at ASME.
Next slide, please.
MS. LING: A brief overview of ASME. We were
founded in 1880. We are a 501(C)(3) nonprofit organization
and we are chartered in the state of New York.
Currently ASME has about 125,000 members. Most
reside in the United States but we do have members in 130
countries around the world.
We only have individual members. ASME does not
have company nor corporate membership.
In addition to codes and standards, some of the
activities of ASME include education. We are heavily
involved in the accreditation of engineering curricula at
. 50
universities, and we also provide continuing education
courses in professional development.
In addition to that, our Washington, D.C. office
is active in government relations and basically their role
is to promote the positions and views of the engineering
profession to Congress and to state and local governments.
Another major activity of the society are
technical divisions. We have about 35 technical divisions
in different areas of discipline and a major activity in
that arena is technical papers on the emerging technology,
international conferences, and regional conferences.
All in all, ASME has about 400 staff employees.
We have 10 offices around the United States and we are
headquartered in New York City.
Next slide, please.
This is a quick snapshot of codes and standards
development within the society. The ASME Council on Codes
and Standards is the governing body for all codes and
standards and related accreditation programs.
We have about 600 published codes, standards, and
guides within ASME. The are administered and developed by
about 100 consensus bodies. There are about 4,000
volunteers who serve on these consensus committees
developing codes and standards.
We have about 43 engineer serving codes and
. 51
standards and I would note that many of our documents are
used and recognized in other countries and we accredit
manufacturers in 57 countries about the world.
Next overhead, please.
MS. LING: This overhead lists examples of the
relationship between USNRC and ASME and I must say it has
been a very long and solid relationship since 1963, when the
first ASME code on vessels was published.
I won't spend time on each of these bullets. I
would like to highlight the third one, and that is key to
our relationship, and from the questioning this morning it
is gratifying to hear that many of the questions and
discussions this morning have centered on the timely
endorsement of codes and standards, and truly ASME believes
this is essential for the entire process and to continue
credibility of our program.
Next slide, please.
CHAIRMAN JACKSON: Tell us -- will you be telling
us a little about your own process for establishing new
codes and standards and then how long does that process
typically take?
MS. LING: Okay. The process we have currently
for establishing codes and standards is that we would
receive a request from any source, whether it be industry,
whether it be government or whether it be an individual.
. 52
That request would be evaluated by the Board on
Nuclear Codes and Standards and if it met certain criteria
such as, one, that there was a true need for such a
standard; two, that codification or standardization was the
proper action -- perhaps it might be a singular case or case
in which there is not an established response to the
problem, in which case standardization would not be the
appropriate action; the third key is that there be available
expertise out there in the industry and elsewhere to
establish the balance of interest that Mr. Millman has
stated was so essential to consensus, that there be
individuals from the manufacturing arena, the design area,
the owner-operator area, the NRC, and Research, and public
interest, that we could form a committee that would
represent a balance of interests for the particular topic.
If those criteria are met, then ASME would engage
the project, establish a committee, and work would begin.
In the past and currently consensus is a long
process. To assure that all views are adequately
represented, to assure that the process is open to anyone,
and to provide for due process of any agreements the process
can take a long time.
Right now I would say our quickest time might be,
on a code case might be a few months. On revision to the
code it might be one year. On the long end we are talking
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many, many, many years in ensuring that consensus has been
reached.
We are engaged right now in the process to
redesign the codes and standards development process. What
we hope to achieve is the ability to develop new major
revisions within a one-year period of time.
What we hope to do is to streamline the process,
but once again adhere to the basic criteria of consensus
that the process be open, that there is due process engaged,
and that there is a balance of interests and representation
of consensus.
So with that we have engaged in an effort on
redesign recently. We hope to complete that process by the
end of this calendar year and we hope to have some pilot
programs going on next year under the new development
process.
CHAIRMAN JACKSON: Okay.
MS. LING: Next slide, please.
Mr. Millman had spent some time speaking about
Public Law 104 and 113. There is also a proposed revision
of OMB A-119, which is currently out for public review and
comment.
I would note that in the revised OMB under the
definition of voluntary consensus standards bodies they have
incorporated the input of ASME that says again openness,
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balance of interests, and due process are the essential
criteria in developing voluntary consensus standards.
I think that is what sets us apart from other
standards that might be developed by industry or industry
consortia.
Next slide, please.
This is a list of some current ASME initiatives
and the first one I have just mentioned, our effort to
redesign the code development process.
Under the globalization of codes and standards I
would note that within the last 18 months I and many other
representatives of ASME have met with other regulatory
agencies and industries about the world.
I would note that one effort was with Korea and
under a royalty agreement with the Korean Electric
Association they have taken Section III, Section XI, Section
V, Section IX of the ASME Code, have modified it to some
extent, and have adopted it as the Korean Electric Power
Industry Code.
We received word a few months ago that the
government has issued an ordinance that as of some time this
year all domestic suppliers will need to comply with the
KEPI Code, which is based on the ASME code.
Additionally, we have met with the Electric Power
Generation Division, EMITI, in Japan, and I received word a
. 55
month ago that as part of that deregulation effort and their
reliance on standards for safety in a deregulated world that
they will be adopting the ASME Code as well into their
regulations for power generation in Japan.
In addition to those countries, we have also met
with the China NNSA, the Czech Republic, Hungary, Romania,
and the Slovak Republic, and as a result of that one of the
actions ASME has engaged in is to add a session to our
international conference on nuclear engineering, a session
that would be based on use of Section XI for VVER reactors.
In Eastern Europe there was a high interest in
that activity and where they seemed to have a reluctance to
gather among themselves they felt an international
conference would be a good forum to share experiences and
questions.
The risk informed nuclear code development Mr.
Millman had covered the Section XI code cases that are
moving forward within ASME.
CHAIRMAN JACKSON: And are you actually
coordinating your work with our Staff's --
MS. LING: Yes.
CHAIRMAN JACKSON: -- efforts in these areas?
MS. LING: To the best of our ability, yes.
CHAIRMAN JACKSON: And what does that mean?
MS. LING: That means that the NRC Staff have been
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very active in the Section XI working group, subgroup and
subcommittees that have developed these code cases and to my
knowledge as of this date we would expect those code cases
to move forward through our own consensus committee and
hopefully through the regulatory adoption -- guide adoption
process.
CHAIRMAN JACKSON: Okay.
MS. LING: The strategic assessment of regulatory
activities, Mr. Jim Perry has submitted the ASME comments on
that and as far as harmonization of conforming assessment
activities we are again working with China, Japan, Korea and
assuring that the accreditation of manufacturers on a world
about basis is consistent and harmonized.
Next slide, please.
In conclusion we definitely look forward to the
continuous solid and good working relationship that ASME has
enjoyed with the NRC Staff for many, many decades.
I think there's been a healthy recognition between
the two organizations of the respective roles and
responsibilities of the two organization -- that, yes, they
are different but they both meet the common goal of public
safety.
The third bullet once again I appreciate much of
the discussion this morning regarding how we can work better
together to improve the overall effectiveness of the
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process.
I think there are things that ASME can do as well
that will improve that.
Lastly, I would like to state that there are many
people in this room who have put in a lot of blood, sweat
and tears into development of consensus within ASME, and I
would like to take this opportunity to publicly thank them.
Thank you.
CHAIRMAN JACKSON: Thank you.
Let me just ask two follow-up questions. How does
ASME view its interpretations? Do you view them as being
part of the codes?
MS. LING: Yes, yes.
CHAIRMAN JACKSON: And if I go back to the Boiler
and Pressure Vessel Code, how would you characterize the
major changes made in that code since 1989? would you view
them as primarily relaxations?
MS. LING: No, I would not. I would view them as
reflections of a changing technology and lets us learn and
from experience. I think there are some that are relaxation
of the Code. In cases where by consensus and that includes
the views of all interested parties where they felt that
based on experience there could be some relaxation in
certain area, and in the same breath based on consensus I
would think there might be some tightening up of
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requirements, again based on experience.
CHAIRMAN JACKSON: Since I have you, let me go
back to a comment you were making, some comments you were
making on one of your slides having to do with this balance
of interests or balance of categories of interests.
Is it your feeling that it works well or it
doesn't -- and I am going to ask you the same question.
MR. MILLMAN: It works well most of the time.
There are times when clearly there is an item that
is of interest to the utility and they -- the utility
members would vote in unison and at the same time the NRC
has an objection to it, and votes contrary to that item.
The NRC vote in that balance of interests is a
single vote in that block.
CHAIRMAN JACKSON: What's your comment?
MS. LING: I think it works well. I think it's
probably the best process we have in place to achieve
collective engineering judgment on establishing technical
requirements.
I think that in all cases what happens is that
there will be those areas of disagreement. I think that by
assuring that you have active participation and by assuring
that no one single interest category can dominate a
committee, which we do achieve through procedures, that the
balance of interests is key, is important. It works well
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and it is better than anything else we have.
CHAIRMAN JACKSON: I agree, but how do address his
issue of the weighting in terms of just sheer numbers and
how voting might get done?
MS. LING: The criteria that we impose on the
consensus level is that no more than one-third of the total
membership can come from one single interest category.
Mr. Millman may be referring to the lower T
levels, which are the technical expertise and I would think
on a working group level in Section XI you might have a good
representation from the utility industry because that is
where the technical expertise is, but again you have to look
at the entire process, so any revision or any action would
go through the consensus committee, on which there is a
strict adherence to the balance of interests.
It goes through public review and there is also
the avenue of due process, so it's a good system. It's a
solid system. It's not a perfect system but once again it's
the best thing we have.
CHAIRMAN JACKSON: Do you agree?
MR. MILLMAN: I agree it's the best we have and
it's the best I could conceive, and it does work most of the
time but like anything it's not perfect.
CHAIRMAN JACKSON: On that note, let's hear from
Mr. Migliaro.
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MR. MIGLIARO: Thank you -- also, thank you for
inviting me here today.
My name is Marco Migliaro and I am the Chief
Electrical Engineer in the Nuclear Division at Florida Power
& Light.
I am here today though to speak about the
Institute of Electrical and Electronic Engineers, better
known as the I -- Triple E, the IEEE Standards Program and
the NRC interfaces with that program.
Let me say that I have participated in the IEEE
standards development program for approximately 28 years,
most of which has been in the area of nuclear power
standards.
I am a past Vice President of the Institute in the
Area Standards. I am a past member of the Board of
Directors and I am a past Chair of the Standards Board.
I am also a fellow member of the Institute.
Next slide, please.
If we look at the IEEE, it is the world's largest
professional society with 315,000 members in 150 countries,
and although we see the words "Electrical and Electronics
Engineers" there are many members of the Institute that have
degrees in physics, mathematics, medicine, and computer
science. In fact, the IEEE is home to some 120,000 members
whose interests lie in the fields of computer science and
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information technology.
I would like to point out that Commissioner Rogers
is a Senior Member of IEEE.
The IEEE has 37 technical societies including
aerospace and electronic systems, communication, computers,
engineering and medicine biology and power engineering.
I have attached a list of those societies with a
brief statement about each as an attachment to your handout.
If we now look at the institute on a regional
basis -- next slide, please -- we see that the IEEE is
divided into 10 regions around the world. By far the
largest population of members are in regions one through six
or within the borders of the United States.
However, today 30 percent of our membership
resides outside the borders of the U.S. -- that is in
regions seven, eight, nine, and ten.
Those also happen to be the fastest growing
membership areas and we project that by the year 2000 or
shortly thereafter a full 50 percent of our membership will
be from outside the borders of the U.S.
Next slide, please.
Looking at the IEEE organization, we are the
members, the board of directors, the executive committees
and six major boards, each headed by a vice president of
which Standards is one.
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Next slide, please.
However, when we talk about Standards, we need to
look at two major boards of the institute, the first being
the Standards Board. The Standards Board has a number of
committees and it's responsible for the Standards program in
the IEEE. It is responsible for the interfaces both within
and without the IEEE in the area of Standards and it speaks
for the IEEE in the area of Standards.
One committee, the new Standards Committee, is
responsible for approving new Standards projects or
revisions if standards exist. Once the work has been done
and drafts are available that are submitted to the Standards
Board for approval, the Standards Review Committee makes the
recommendations for approval. I would like to point out
that there is NRC participation in that committee.
There are nine other committees of the Standards
Board and then the Standards Board has Standards
Coordinating Committees and Accredited Standards Committees
which actually write standards. However, when we look at
standards writing activities, the bulk of that activity
falls underneath the Technical Activities Board within the
37 societies of IEEE. Today, 24 of those societies actively
participate in the Standards program and that is where you
will find the Standards Writing Group and those are the
people that provide the technical expertise to the IEEE
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standards.
Next slide, please.
Very briefly, the IEEE Standards Board has 26
members and a number of liaisons, one of which is the NRC.
The board meets four times a year and, given the changing
membership of the IEEE, one to two meetings a year outside
the borders of the U.S. with one of those meetings typically
outside the borders of North America.
Participation by the NRC dates back to the early
1970s. It's extremely beneficial from IEEE's point of view.
The NRC liaison is looked to as an expert on the Board in
nuclear-related standards issues and, since issues may arise
at any meeting, it is imperative that everybody, members and
liaisons, attend all the meetings.
IEEE has expressed appreciation, most recently in
1994, in a letter from Dr. Nagle who was then President of
IEEE to Dr. Sellin, who was then Chair of the NRC. The
Commission should continue to support this activity.
There are approximately 700 active IEEE standards
and, at any one time, there are approximately the same
number of new and revisions in progress.
CHAIRMAN JACKSON: Let me just ask a quick
question. How many of the standards are endorsed by NRC
regulations and reg guides out of the 700?
MR. MIGLIARO: Well, 700 is all standards within
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IEEE.
CHAIRMAN JACKSON: I know that. I am asking you
how many are --
MR. MIGLIARO: I don't have an exact number but
there are about 75 nuclear standards and, out of that, say
about half.
MR. AGGARWAL: There are approximately 30
standards that have been endorsed in the regulatory guides.
CHAIRMAN JACKSON: In the reg guides and
regulations, or just reg guides?
MR. AGGARWAL: No, as I pointed out, the only
single standard is 279.
CHAIRMAN JACKSON: The 279, right.
Thank you.
COMMISSIONER McGAFFIGAN: What about the other 45?
You said there's about 75?
MR. MIGLIARO: If you give me a minute, I'll get
to it in another slide, please.
Of the approximately 700 active standards that
have broken down, about 45 percent power, 30 percent
computer, 10 percent industry application and then 15
percent encompassed the balance of all IEEE standards.
IEEE standards are recognized world wide and many
of them become the base documents for international
standardization. There is a number of ways in which these
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things are done. One, given the example of the LAN or the
Local Area Network Standards which, although developed
within IEEE, were simultaneously adopted as international
IEEE standards.
There are also some standards in the nuclear power
industry that are used directly by other countries in their
nuclear power programs. Examples of those are IEEE 323 on
qualification and IEEE 344 on seismic.
The IEEE also has a policy to allow cross-adoption
of standards and IEEE standards have been adopted by
Standards Australia and Standards Council of Canada.
Next slide, please.
We have heard these words many times before but
the five guiding principles of IEEE are the same, due
process, consensus, openness, balance and right of appeal.
The only thing I would like to point out is that
consensus within IEEE is a little bit different in that when
we send out a ballot, we ask for 75 percent return to have a
successful ballot and, of that 75 percent return, 75 percent
must be affirmative in order for the standard to have
achieved consensus.
Next slide, please.
The IEEE standards are voluntary standards. They
are developed by volunteers and, in fact, today we have over
30,000 persons involved in the development of IEEE
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standards.
Because of our policy of openness and balance, you
don't need to be a member of IEEE to participate in
standards writing activities. For example, a number of
years ago, when IEEE was asked to develop or look into
standards on electromagnetic fields, we put out invitations
to epidemiologists and biologists to join our committees.
So that the input for our standards comes from designers,
operators, industry experts, regulators, manufacturers and
other interested parties and, in general, IEEE standards
reflect state of the art.
CHAIRMAN JACKSON: Let me ask Mr. Millman, what is
your assessment of the consensus process relative to how the
standards developed in IEEE?
MR. MILLMAN: The ballot structure is a little
different than it is at ASME but there are some other
parameters that get into the ASME balloting that haven't
been discussed and that is, first consideration ballot, one
negative ballot stops the item. So a single voice is heard.
Frequently that is the NRC voice.
CHAIRMAN JACKSON: In the ASME process.
MR. MILLMAN: In the ASME process. In the IEEE
process, the 75 percent, I think, would make a significant
difference if that's the way it were implemented at ASME.
CHAIRMAN JACKSON: Okay.
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MR. MIGLIARO: Next slide, please. That's slide
number 10.
Where are all these standards used? They are used
for electrical and instrumentation control equipment. I
look at these or view these as the brain and the nervous
system of the plant. There are field sensors that
continuously monitor parameters and conditions in the plant
which are relayed and based on what the sensors see, actions
are taken, sometimes automatic, to stop, start or shut down
plant systems.
There is also information fed to the operators
either to alert them that a condition is present or to
prompt them to take corrective action. This equipment plays
a vital role in maintaining safety of plants and they are
relied on for safe and economic operation of the plants.
Looking at nuclear standards development, let me
first say that the IEEE began standards development in the
1800s on one of its two founding societies, the AIEE began
to write standards. By that comparison, the nuclear power
standards are a relative newcomer to the IEEE beginning
about 25 to 30 years ago. But over that time, more than
100,000 persons have participated in the development of
those nuclear standards. Today, we have more than 75 active
standards. The scope, equipment areas of those standards
are included as an attachment to your handout.
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We have a number of other documents that are
offered from IEEE and I will just go through them briefly.
The nuclear power collection -- I have some of these by my
side here -- is a compilation bound under one cover of all
current issues of nuclear power standards within the IEEE.
The Nuclear Power Archives, as the name implies, is a bound
edition of all the past revisions of all the nuclear power
standards. The Nuclear Science Collection is available.
The Nuclear Equipment Qualification Sourcebook,
that is a somewhat unique product in that all the documents
required for equipment qualification, both the IEEE and the
NRC, are bound under one cover.
IEEE 500, which was last published in 1984, is
reliability data for nuclear power plants. This is a very
important standard; however, at this point in time, there
really have been no takers on the revision of this document
and I think -- I present to you an issue -- I think this is
one area where the NRC can take a look at it and maybe take
a leadership role in making sure that IEEE 500 does get
updated.
Next slide, please, number 12.
Interfaces with the NRC. I have already stated
that we have an interface at the Standards Board level. We
have an interface at the society level and you have seen
slides of that. Three major societies that the NRC deals
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with are Power Engineering, Computer and Nuclear and Plasma
Sciences.
Typically, the votes of the NRC here on working
groups, subcommittees and committees. Then there is also
NRC representation on the Standards Coordinating Committees.
If we look at the regulations -- next slide
please -- we have already stated IEEE 279 which has been
withdrawn by IEEE is the only standard reference in the
regulations. The remainder of IEEE standards are endorsed
by regulatory guides. These are very valuable to users
because they present the NRC position on a particular
standard.
Although the NRC actively participates in the
working group and the working group members themselves may
have information as to how the NRC feels, many of the users
in the industry don't have the benefit of attending working
group meetings so the regulatory guide is used to convey all
those issues to the licensees and they are extremely
valuable. However, the shortcomings here are that many are
for old revisions and very few cover recent editions of the
standards.
CHAIRMAN JACKSON: How old are we talking?
MR. MIGLIARO: Some go back to the 1970s.
CHAIRMAN JACKSON: And --
MR. MIGLIARO: The 1970 edition.
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CHAIRMAN JACKSON: And what is the most recent?
MR. MIGLIARO: The most recent additions, without
picking a particular one, I would say the most recent
addition, because the IEEE policy is to revise or reaffirm
their standards every five years, then they could be as much
as 20 years behind.
COMMISSIONER McGAFFIGAN: So I might ask whoever
spoke earlier, of the 30 that we have endorsed, how many
are -- you said you had 75 total, 30 we've endorsed
approximately through reg guides. Of that 30, how many do
you think we are endorsing old standards or old revisions?
MR. MIGLIARO: I would say the bulk, probably 80
percent would be endorsing old revisions.
CHAIRMAN JACKSON: Going back to the '70s in
general?
MR. MIGLIARO: No, they would be in the '70s and
'80s.
COMMISSIONER McGAFFIGAN: What about the other 45
that sort of hang out there and is it important, if we ever
got around to it, to having those also considered in our reg
guides?
MR. MIGLIARO: Sure. My next slide, actually.
COMMISSIONER McGAFFIGAN: Okay, sorry.
MR. MIGLIARO: No, it's a good lead-in. Thank you
very much.
. 71
CHAIRMAN JACKSON: Before you get to that, let me
just ask you this question. Do you -- do you actively seek
NRC endorsement of IEEE standards in these areas?
MR. MIGLIARO: The IEEE personally, no. The IEEE
does not actively seek the endorsement.
CHAIRMAN JACKSON: Okay, and how are your
standards development initiatives supported financially?
MR. MIGLIARO: Our initiatives are all voluntary.
The members on the working groups are usually supported
either by themselves or their organizations or their
companies.
CHAIRMAN JACKSON: So it doesn't come out of your
budget, per se?
MR. MIGLIARO: It doesn't come out of our budget,
no. The only activity that comes out of the IEEE budget is
the support of the IEEE staff members, paid staff members
that attend these meetings and the support of the editorial
staff and the publishing of the documents.
CHAIRMAN JACKSON: And what about your code
development?
MS. LING: It is the same, volunteers. They
receive their support elsewhere but the administrative
support for the codes and standards framework is through
sales of the codes and standards.
CHAIRMAN JACKSON: It's through sales?
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MS. LING: Sales of the codes and standards.
MR. MIGLIARO: I would like to add one thing on
that. There have been a couple of initiatives where we have
done some fundraising to support a particular standard. An
example of that was the current impassity or carrying
capability of electric conductors. That is a large,
voluminous document and years ago, when it was first
initiated, all the computer time on that document was
supported by a cable company.
With companies downsizing, a lot of that is not
possible today so some of that work was done through
fundraising activities to support the standard.
CHAIRMAN JACKSON: So you could have standards
developed that are supported by a given company?
MR. MIGLIARO: No, they are not supported. In
general, they are not supported by a given company. But we
had had a fundraising effort that allowed the computer
work -- paid for the computer time necessary to generate the
final document in the case of the impassity. That is one
single case that I can point out to.
CHAIRMAN JACKSON: But you don't sell anything?
MR. MIGLIARO: Yes, we do sell standards.
CHAIRMAN JACKSON: So you sell standards, too?
MR. MIGLIARO: Yes.
CHAIRMAN JACKSON: So that is part of your
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financial support base.
MR. MIGLIARO: It is part of the financial support
for the staff but it is not -- we do not financially support
any of the volunteers.
CHAIRMAN JACKSON: I understood that.
Thank you.
MR. MIGLIARO: Thank you.
Slide number 14.
There had been some recent activity within the NRC
in the area of regulatory guides. Three reg guides, as we
have seen before, were endorsed, endorsed the latest
standards and there have been some draft guides for
computer-related standards. This is particularly important
as digital systems and digital upgrades begin to go into the
nuclear plants. However, that effort is probably below what
we would like to see as far as endorsing all of our
standards.
There is much more that can be done. The issues
here, number one, develop regulatory guides for all the
nuclear-related standards and the other is then to train
your inspectors on the use of these guides so that there is
a uniform approach across all the regions.
CHAIRMAN JACKSON: What opportunities do you think
are available to keep inspectors current on new technologies
and the implications that are reflected in standards?
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MR. MIGLIARO: Well, there can be a number of
issues. There can be short seminars, short courses
presented to the instructors to give them an idea of the
standards development.
CHAIRMAN JACKSON: Do you present such courses?
MR. MIGLIARO: Yes, we do present those courses.
They have been limited recently but they are available and
they are available for presentation anywhere. There is
normally a fee associated with that to cover the time, of
course, of the instructors.
CHAIRMAN JACKSON: Industrial rates.
MR. MIGLIARO: I won't speak for the rates.
CHAIRMAN JACKSON: Okay.
MR. MIGLIARO: Finally, active participation by
the NRC staff at committee and working group levels must
continue. As you have seen, you have about 26 people active
on IEEE activities. However, there are 15 that actively
work on sponsor committees and actively ballot the documents
and we understand that although we see 15 or 26 names, there
are actually many, many more people that work and provide
input to those persons in the development of comments to
particular standards.
In summary, I would like to say that the issues
are the continued support of the staff by the NRC, IEEE 500
update, the issuance of reg guides and training for the
. 75
inspectors.
One brief statement, as we approach the twenty-
first century, IEEE has taken a lot of initiatives to
restructure itself to its new membership base or its
changing membership base and the Standards Group will not be
immune from such changes. There are plans not to change the
process but there are plans to develop a separate standards
association within IEEE. The enabling bylaws have been
approved and steps will be taken over the next few years to
implement that program.
Thank you very much for your time.
CHAIRMAN JACKSON: Okay, Commissioner Rogers?
COMMISSIONER ROGERS: Well, it seems to me that it
is quite apparent that there is really quite a difference in
approach here between the two professional societies in many
ways and that NRC's use of these is somewhat different in
the very large difference in the number of standards, ASME
standards or codes that have been -- that are reflected in
our regulations. Whereas, with the IEEE, it is more in reg
guides.
I wonder if you have any comments with respect to
that difference, particularly as we see more and more use of
digital systems and control systems and so on and so forth
as replacements in nuclear power plants and whether,
perhaps, there should be a little elevation of the use of
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IEEE standards in regulations in your view?
MR. MIGLIARO: I guess having grown up in the IEEE
world, I would like to say that I am pretty comfortable with
the way IEEE standards have been issued and reg guides have
been issued to endorse those. So I wouldn't see -- I
wouldn't recommend any change in that area in particular.
CHAIRMAN JACKSON: Commissioner Dicus.
COMMISSIONER DICUS: No questions, thank you.
CHAIRMAN JACKSON: Commissioner McGaffigan.
COMMISSIONER McGAFFIGAN: Just one question for Ed
Jordan.
The suggestion on the IEEE 500 update and NRC
taking a leadership role. Where in the scheme of things,
given DSI 13 preliminary views, would you place that? Or
have you had a chance to think about it?
CHAIRMAN JACKSON: Don't do like they do in court,
now. If you need to think about it, you should think about
it, because we're going to hold you to what you say here.
[Laughter.]
MR. JORDAN: I'll be careful not to make any
promises.
Clearly, the object of the DSI 13 is to look
across all of the codes and standards activities and target
those for which there can be the greatest safety benefit
gained based on the staff expenditure and the two good
. 77
organizations that are represented here certainly represent
a fairly large effort that the NRC has been involved in and
has some tradition.
We do, as Dr. Paperiello said, use a lot of other
codes and standards that we don't formally endorse and so I
think it's looking across all of those and then coming up
with a strategy, coming back to the Commission with
recommendations based on the needs and the materials in the
reactor area.
COMMISSIONER McGAFFIGAN: That was a good, safe
answer.
MR. JORDAN: So we promise to study it and bring
you back an organized approach with those 25 FTE that we
suggested would be required.
CHAIRMAN JACKSON: Okay.
I would like to thank the staff, everyone,
Ms. Ling and Mr. Migliaro for an informative briefing.
As noted during the briefing, new federal
requirements do place increased emphasis on government staff
participation in the development of as well as the use of
standards and codes developed through the kinds of processes
we have mentioned and have been discussing. ASME and IEEE
standards can promote the safe operation of nuclear plants.
I think the evidence is there. Therefore, they are and have
become an integral part of our regulatory processes and
. 78
structure.
To that end, then, on behalf of the Commission, I
want to encourage the staff, the ASME and the IEEE to
maintain their good working relationships and to strive to
improve the timeliness as well as the effectiveness of the
overall process. I think there are, at least from what I
have heard, opportunities on all sides.
The Commission's overall views on these issues are
being expressed through its action on the strategic
assessment and rebaselining DSI, the preliminary views of
which you have already expressed, Mr. Jordan. And they will
provide a framework for going forward.
However, as you have just promised in as soft a
way as you thought you could get away with, we do need a
real framework document and that's true of any of the
actions, follow-on actions on the DSIs, that really look at
what the resource implications are and a prioritization
scheme for working our way through that. Then I would
assume that the IEEE 500 would be explicitly treated within
that context.
So unless there are any further comments, we are
adjourned. But I would remind the Commissioners that we do
have an affirmation session.
[Whereupon, at 11:54 a.m., the briefing was
adjourned.]
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